Policy SS9: North East Derbyshire Green Belt

Showing comments and forms 1 to 26 of 26

Support

Consultation Draft (February 2017)

Representation ID: 4558

Received: 02/03/2017

Respondent: Mrs Sarah Bayliss

Representation Summary:

Dronfield desperately needs new housing especially affordable homes for our young people, currently priced out of the very small market here. We wholeheartedly support the use of these small areas of green belt which will not detract from Dronfield as a whole.

Full text:

Dronfield desperately needs new housing especially affordable homes for our young people, currently priced out of the very small market here. We wholeheartedly support the use of these small areas of green belt which will not detract from Dronfield as a whole.

Object

Consultation Draft (February 2017)

Representation ID: 4582

Received: 06/03/2017

Respondent: Mr Oliver Hewitt

Representation Summary:

I do not think you have justified the 'very special circumstances' required to allow release of greenbelt in the Dronfield area. Taking the "Land off Shakespeare Crescent & Sheffield Road" as an example you are suggesting the removal of agricultural land which is so important that the policy makes special provision for agricultural buildings to be erected if it aids their business, this action will surely have a detrimental effect on local agriculture.

This is not poor-quality unproductive land as it is used for grazing and crops and I do not feel you have fully examined all other reasonable options.

Full text:

I do not think you have justified the 'very special circumstances' required to allow release of greenbelt in the Dronfield area. Taking the "Land off Shakespeare Crescent & Sheffield Road" as an example you are suggesting the removal of agricultural land which is so important that the policy makes special provision for agricultural buildings to be erected if it aids their business, this action will surely have a detrimental effect on local agriculture.

This is not poor-quality unproductive land as it is used for grazing and crops and I do not feel you have fully examined all other reasonable options.

Object

Consultation Draft (February 2017)

Representation ID: 4697

Received: 14/03/2017

Respondent: Mrs Anna Lomas

Representation Summary:

I object to changes of use for the green belt. It should remain as green belt.

Full text:

I object to changes of use for the green belt. It should remain as green belt.

Comment

Consultation Draft (February 2017)

Representation ID: 4983

Received: 27/03/2017

Respondent: PDNPA

Representation Summary:

It would be useful to include a reference to the need not only to protect the green belt but the National park area adjacent to the green belt since the methods for protecting green belt could otherwise inadvertently lead to release of land whose development might harm the setting of the National Park. A text reference might be better than a policy ref

Full text:

It would be useful to include a reference to the need not only to protect the green belt but the National park area adjacent to the green belt since the methods for protecting green belt could otherwise inadvertently lead to release of land whose development might harm the setting of the National Park. A text reference might be better than a policy ref

Object

Consultation Draft (February 2017)

Representation ID: 5080

Received: 30/03/2017

Respondent: Mrs Helena Gayle Boulton

Representation Summary:

The evidence that there are some people that want to release the Green Belt for development is only reflecting those that are set to profit from its development.

Full text:

The evidence that there are some people that want to release the Green Belt for development is only reflecting those that are set to profit from its development.

Object

Consultation Draft (February 2017)

Representation ID: 5161

Received: 02/04/2017

Respondent: Mrs Jenny Towers

Representation Summary:

Dronfield does not have the infrastructure to cope with the additional housing proposed. This increase in people will adversely impact upon the existing residents in Dronfield by putting additional pressure on the existing schools and doctors surgeries. In addition, the additional traffic through the town will cause the roads to be more dangerous than they already are. The plans also reduce the green belt area, I strongly object to this and the plans would appear to conflict with the councils statements around the desire to protect and preserve our green belt land.

Full text:

Dronfield does not have the infrastructure to cope with the additional housing proposed. This increase in people will adversely impact upon the existing residents in Dronfield by putting additional pressure on the existing schools and doctors surgeries. In addition, the additional traffic through the town will cause the roads to be more dangerous than they already are. The plans also reduce the green belt area, I strongly object to this and the plans would appear to conflict with the councils statements around the desire to protect and preserve our green belt land.

Comment

Consultation Draft (February 2017)

Representation ID: 5221

Received: 03/04/2017

Respondent: Mr Eric Singleton

Representation Summary:

Policy SS9 does not implement Local Plan Objective D6 as claimed in regards to Dronfield.

Full text:

Comment Scope As a resident of Unstone, my comments are primarily regarding the plan for the Dronfield area; I have not reviewed sections that deal specifically with other areas.
Overall Summary The plan does not make a case that there are exceptional circumstances to justify the removal of land from the Green Belt around Dronfield. The council concedes it has not considered alternative options in the area. The plan is a developer's charter to maximise profit by building on easy to develop green field sites. It will be especially beneficial to developers who have purchased green belt land at agricultural prices in the expectation that the council would eventually capitulate in the face of their lobbying.

The plan does not cite any evidence of changes in local circumstances to justify the increase from the 285 additional dwellings in the Dronfield settlement in the plan issued for consultation between 12/02/2015 and 26/03/15 and the 860 proposed in this plan. The settlement targets in this plan appear to be a distribution of an overall target based on existing settlement size: that is not planning, it is quota allocation of the crudest form. Whilst the council suggests there is a need for 6,000 additional dwellings in the NE Derbyshire area, developers do not appear to agree. If there was significant unmet demand developments such as the Waterside scheme in Chesterfield would have been nearing completion by now, not still open land.

The council acknowledge the green space, outdoor sports and children's play space in Dronfield falls below current standards, yet proposes to make matters worse by planning to build on a golf course in Dronfield and sports ground in Coal Aston whilst making no commitment to provide further outdoor facilities. This is contrary to one of the requirements of sustainable development: to protect and enhance the environment.

The council acknowledges that there is currently no agreed plan nor any binding commitments or safeguards to ensure improvement of the infrastructure necessary to accommodate the additional demand from the planned 860 additional dwellings in Dronfield. The plan must be as unambiguous in its commitment to implementing infrastructure improvements as it is with respect to the number of dwellings proposed. Anything less than this is a plan to inflict environmental damage and congestion blight on the community.

The plan contains multiple contradictions and inconsistencies and includes statements in breach of the policies contained therein.

The plan contains numerous statements with meaningless verbs e.g. the council will encourage, support (without quantification); seek. The use of this language renders what, at first sight, appears to be council commitments to implement controls and safeguards, completely impotent. The persistent use of this language renders the plan misleading.

Consequently, the plan is unsound.
The whole document The quality of the English and the arguments within the plan fall way below that which should be produced by competent and qualified professionals. In particular, the use of the word 'sustainability' ad-nausea is an example of how the plan is full of bland 'planning speak' with little consideration as to the purpose of the statement or point being made. Significant portions of the plan look suspiciously like a copy and paste of boilerplate text.

The council's planning department should review the plan issued by Chesterfield Borough Council and its own plan issued for consultation two years ago; both are significantly better than the current plan.

1.5 Statement "the Council has produced this document for public consultation"

As a core document for a public consultation it is woefully inappropriate. The text is full of planning jargon; acronyms and references to a significant number of related documents.

For example, section 6 makes repeated references to B1, B2 and B8 usage of employment land. Not until 6 pages into section 6 are these terms defined in policy WC2, below paragraph 6.26. Non-B8 classes (paragraph 6.16) are not elaborated.

At least one referenced document (Derbyshire Infrastructure Plan) is not included on the evidence page on the council's website, nor does a search on its name return a link.

To comment effectively on this document requires critical reading and analytical skills associated with a degree level education.

The FAQ leaflet available at the public consultation is equally challenging to comprehend. Paragraph 2 comprises one 56-word long sentence of 'planning speak' punctuated by one semi-colon and one comma.

Whilst the Local Plan and FAQ leaflet is offered in 5 alternative languages and large print, it is also written without consideration for anyone without higher educational level comprehension skills.

Consequently, the consultation is not an inclusive process. The consultation process is therefore fundamentally flawed.
1.14 Statement "The NPPF states that Local Plans must be prepared with the objective of contributing to the achievement of sustainable development".
There is no such thing as the sustainable use of a non-renewable resource, such as the proposed building on land that is currently Green Belt around the Dronfield settlement. The land at Hallowes in Dronfield particularly is currently used for recreational activity; the land adjacent to Shakespeare Crescent in Dronfield is actively farmed. These resources are irreplaceable; once lost, neither will ever be recovered.

The NPPF paragraph 7 states there are three dimensions to sustainable development: economic, social and environmental. The latter includes a requirement to minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.
The proposal to build 860 more dwellings (an increase in 10%) without a commensurate increase in local employment will drive up commuting, CO2 emissions and pollution; that is not sustainable and is contrary to the above NPPF requirement.
1.16 Duty to Co-operate. The only evidence in the plan of the council discharging this duty is co-operation with Bolsover District Council with respect to the Coalite Regeneration Area (paragraph 4.58). There is no evidence of any co-operation with either Chesterfield or Sheffield Councils. This is a major oversight, particularly with respect to the plan for Dronfield.
2.15 The statement "Just under a quarter of households cannot afford market housing" i.e. just over 75% of households can afford market housing. A recent Shelter report suggests on average 80% of families across England are unable to afford newly built homes in their local area. This statement demonstrates that affordability in North East Derbyshire is dramatically better than the national average.
2.17 Statement "The town centres of Clay Cross, Dronfield, Eckington and Killamarsh are all in need of continued support and investment to build upon their strengths, and to help sustain and regenerate them into the future."
However, the plan contains no commitments on investment. A plan to build 860 additional dwellings in Dronfield without a commitment to invest in the infrastructure will negatively impact the quality of life of existing residents; driving up congestion, pollution and CO2 emissions. This is contrary to the council's stated objective D1 Sustainable Growth; D8 Addressing Climate Change
2.20 The council notes that Dronfield is the only town with a railway station. However, there are no connecting public transport links from the outer reaches of the town. Consequently, train users who live more than a few minutes' walk from the station use their car to reach the station creating a serious problem with on-street parking. A failure to commit to addressing this issue whilst proposing a circa 10% increase in households is contrary to the council's stated objective D12 Sustainable Transport and in breach of policy SS1 clause C.
3.5 Statement "much needed affordable homes". The data provided in paragraph 2.15 indicates affordability is not an issue in NE Derbyshire.
3.5 Statement "and regenerate and renew their [Dronfield, Eckington and Killamarsh] towns' centres". The plan contains no binding commitments or obligations that will ensure the delivery of this vision.
3.5 Statement "In planning for growth new high quality housing will have successfully integrated itself into these settlements minimising its impact upon the strategic functions of the Green Belt, and creating strong defensible boundaries for the future."
The council will be aware that a developer owns Green Belt land adjacent to Shakespeare Crescent that is beyond the proposed development boundaries. Any removal of land from the Green Belt will set a precedent. Strong defensible boundaries will only be established with a clear policy of making no changes to the Green Belt.
3.9 Statement "seeking to narrow the gap between the more deprived areas and the more affluent areas". Why is this an objective of the plan? It smacks of left wing social engineering.
3.9 Objective D7 Settlement Identity
The proposal to remove land from the Green Belt adjacent to Shakespeare Crescent is contradictory to this objective. From significant areas in Apperknowle and Hundall Dronfield and Unstone will appear to merge if this land is developed.
The council's planning policies have historically failed to meet this objective; within this plan Coal Aston is shown as within the Dronfield settlement boundary. The plan does not provide evidence as to how it will meet this objective in the future.
3.9 Objectives D8 Addressing Climate Change, D13 Local Amenity

4.5 Policy SS1, Sustainable Development, clauses c and g

Policy SS3 The plan issued for consultation between 12/02/2015 and 26/03/15 stated there was a need for 285 dwellings in the Dronfield settlement between 2011 and 2031, with a residual requirement for 181 after accounting for those built or planned. This plan now states 860 dwellings are required, but provides no justifiable change in local circumstances (i.e. additional employment in the area).
Policy SS3 states that employment growth will be on four strategic sites to the South and East of Chesterfield. It therefore follows that the plan for 860 additional dwellings in Dronfield is environmentally unsustainable; will increase commuting to Sheffield, Chesterfield, and through Chesterfield to the strategic development sites, resulting in increased congestion, pollution affecting large numbers of North Derbyshire residents and increased CO2 emissions. This is inconsistent with objectives 3.9 D8 and D13, and in breach of policy SS1 clauses c and g.
3.9 Objectives N1 Statement "To ensure the vitality and viability of Dronfield, Eckington and Killamarsh town centres by supporting improvements compatible with their local employment, retail and service functions". Explain what the council will do to ensure these improvements are implemented. The plan contains no binding commitments or obligations that will ensure the delivery of this objective.
3.9 Objectives N3 Statement "To improve the quality of employment land in the north of the District and address infrastructure deficiencies to allow for the expansion of existing sites, such as at Callywhite Lane, Dronfield". Explain what the council will do to ensure these deficiencies are addressed. The plan contains no binding commitments or obligations that will ensure the delivery of this objective. The deficiencies at Callywhite Lane are decades old; the council has demonstrably failed to address them to date.
4.4 Statement "The Local Plan's vision and objectives are centred on .... supporting the health and wellbeing of the District's communities".
The planned addition of 860 dwellings in Dronfield without major investment in infrastructure (e.g. an additional exit and access to the A61 dual carriageway) will blight Unstone which is centred around the major routes from the south into Dronfield. This is contrary to the stated vision and objectives.
4.5 Policy SS1, Sustainable Development, clause a: "key business sectors" is meaningless; define "key".
4.12 The statement "The Local Plan aims to provide new jobs" is both false and misleading. The most this plan can potentially achieve is to ensure the development of an environment sufficiently appealing to attract additional employment. The additional congestion in the Dronfield area is likely to do the opposite.
4.12 Statement "[The Local Plan] acknowledges the 61% of people who commute out of the District to work".
Consequently, the Local Plan also acknowledges that providing an additional 860 dwellings in Dronfield without a commensurate increase in local employment will increase commuting, congestion and CO2 emissions. This is inconsistent with objective 3.9 D8 and in breach of policy SS1 clause (c).
4.18 The Plan notes that all the larger employment development sites are to the East or South of Chesterfield. On what basis does the Council justify a 200% increase in the planned dwellings for Dronfield since the plan issued for consultation between 12/02/2015 and 26/03/15?
4.21 Statement "The Council's Growth Strategy has the intention of raising job densities (jobs/worker) within the District"
The plan to build 860 homes in Dronfield will significantly reduce the job density within the settlement.
4.26 The statement in paragraph 4.26: "the Local Plan aims to direct new growth to the district's most sustainable settlements based on the Settlement Hierarchy" and repeated in paragraph 7.4 conflates settlement size with 'sustainability'. This plan offers no evidence to demonstrate that enlarging an already large settlement by building on land currently designated as Green Belt is more 'sustainable' than other options. As noted in the response to paragraph 1.14, there is no such thing as a sustainable use of a non-renewable resource, such as the proposed building on land that is currently Green Belt.
4.28 Statement "Level 1 Settlements ... are considered to be the most sustainable locations for new development ... because they generate the greatest needs for new housing, jobs, services and facilities."
This statement is misleading: the size of a community does not necessarily correlate to job volume creation. The plan does not provide evidence that Dronfield will generate the number of jobs commensurate with 860 additional dwellings. The chronic underutilisation of the Callywhite Lane employment area in Dronfield is evidence of the councils' past failure to provide an environment attractive to new businesses.
4.59
4.69
Policy SS3
Policy SS9 As noted in 4.59: "The essential characteristics of Green Belts are their openness and their permanence..." and in paragraph 4.62: "National Guidance is clear that Green Belt boundaries should only be altered in exceptional circumstances."
The evidence base referenced in policy SS3 does not fulfil the requirement for "exceptional circumstances" that are necessary to take land out of the Green Belt.
As acknowledged in Policy SS9 "The NPPF tells us that inappropriate development is harmful to the Green Belt and should not be approved except in very special circumstances. LPAs should respect the permanence of the Green Belt."
The proposal to take land out of the Green Belt around Dronfield is in breach of policy SS9 and the exceptional circumstances stated therein.
Policy SS9 does not implement Local Plan Objective D6 as claimed. The proposed removal of land from the Green Belt adjacent to Shakespeare Crescent in Dronfield breaches the permanent nature of the Green Belt, rendering any Green Belt land adjacent to existing settlements at risk to further encroachment. The council will be aware that a developer owns land adjacent to Shakespeare Crescent which extends beyond that being proposed for removal from the Green Belt. Once development is permitted on part of this land, the developer will inevitably seek to develop the remaining land in their ownership in the future. The council's policy is encouraging and rewarding developers who speculatively purchase prime Green Belt land, at agricultural land prices, in the expectation that councils will eventually capitulate to pressure to develop these sites.
4.64 Statement "This evidence led the Council to undertake a review of the Green Belt during 2016 and provides the exceptional circumstances necessary to justify alteration of the Green Belt boundaries."
This statement is nonsense. A review does not "provide exceptional circumstances". Exceptional circumstances either exist or they do not. This statement is overt evidence of the council's flawed logic in proposing land be removed from the Green Belt. This plan does not make the case that there are exceptional circumstances.
4.65 The statement "This means that if we wish to achieve a more sustainable pattern of development and provide a sufficient level of development in the North of the District to meet needs, we must accept that this will have an impact on the Green Belt." is further flawed logic. As argued in the comments above, the planned 860 dwellings in Dronfield is unsustainable. There is no inevitability to the loss of Green Belt land. The Local Plan contains no evidence that alternatives have been explored.
4.66 Contrary to the assertion in this paragraph, the land adjacent to Shakespeare Crescent in Dronfield does perform a valid Green Belt function. From significant areas in Apperknowle and Hundall Dronfield and Unstone will appear to merge if this land is developed. This land is also currently actively farmed; one of the fields proposed to be removed from the Green Belt has recently been ploughed.
4.73
4.74
4.75
Policy SS11 Statement in 4.73 "the Local Plan seeks to protect settlement identity and avoid further settlement coalescence". Definition of Local Settlement Gap functionality in 4.74.
As noted above, the proposed removal of land from the Green Belt adjacent to Shakespeare Crescent in Dronfield will lead to Dronfield and Unstone appearing to merge. It will also provide a separation of no more than circa 200 metres along the B6057 between Dronfield and Unstone.
The council has patently failed to protect historic settlement identities: Coal Aston is shown as within the Dronfield settlement boundary within the plan; paragraph 4.70 acknowledges loss of settlement separation in the south of the District. The plan is repeating this mistake on the southern boundary of Dronfield.
The council acknowledges in 4.75 that it has been incompetent at preserving settlement gaps. Consequently, policy SS11 is worthless.
Given the council's inability to maintain settlement gaps, the land adjacent to Shakespeare Crescent must remain in the Green Belt to protect the settlement gap between Dronfield and Unstone.
4.78 Statement "Outside Settlement Development Limits, countryside and/or Green Belt policies apply and all proposals for development will be considered against these requirements set out [sic] in Policies SS14".
Taking land out of the Green Belt outside the current Dronfield settlement limit is the exact opposite of this statement.
4.79 The plan states "Further land outside Settlement Development Limits is therefore not required to meet this [housing provision] need." Consequently, there is no need to take land out of the Green Belt around Dronfield.
4.80 Statement "The Settlement Development Limits identified on the Policies Map have been carried forward from the 2005 Adopted Local Plan. However, this only applies to settlements that fall within categories 1, 2 and 3 as set out in table 4.1." Dronfield falls into category 1. Consequently, the plan states the council does not intend to change the settlement development limit of Dronfield. Therefore, on what basis does the council justify the proposal to take land out of the Green Belt?
5.6 The council's figures show that windfall developments between 2011 and 2016 account for 5% of the proposed needs, but windfalls have not been factored into the plan. The council also states minor sites have not been relied upon nor have "major sites with planning permission which do not accord with the spatial strategy." This latter statement is clearly a reference to sites such as Callywhite Lane in Dronfield where there is little prospect of attracting new businesses and land has remained undeveloped for 10 years or more despite developers submitting planning applications for housing.
The NPPF states that ""Very special circumstances" will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations." Contrary to this guidance, the council has opted to target Green Belt land for development without a rigorous assessment of other contributions to meeting its targets.
5.7 The plan states "There are also a number of sites across the District that have planning permission where there are deliverability concerns and / or a history of unimplemented permissions." The council offer no evidence of actions to understand and resolve the issues leading to this situation, further evidence of inadequate consideration of other options before targeting Green Belt land.
5.8 There is no sound evidence offered for only considering sites capable of accommodating 10 or more dwellings. This indicates the council has been unable or unwilling to fully assess all options before proposing to take land out of the Green Belt.
5.65 Statement "Many households in North East Derbyshire who lack their own housing or live in unsuitable housing cannot afford to buy or rent housing at market rates." is ambiguous without defining "many". It is misleading and, by any reasonable interpretation, contrary to paragraph 2.15 where the council states that just over 75% of households can afford market housing.
Policy LC3 As the council notes, the NPPF states the construction of new buildings in the Green Belt should be regarded as inappropriate apart from a small number of specific exceptions. The scale of development proposed is way beyond that covered by the "limited infilling in villages" exceptional condition in the NPPF. The proposal to develop Green Belt land around Dronfield does not meet the remaining exceptions and is therefore in breach of the NPPF.
5.85 The statements "The Council will seek to ensure that the housing needs of older people and people with disabilities are met" and "It will encourage developers and other agencies to provide dwellings which will enable more people to remain in their homes" are meaningless.
State exactly how the council will ensure this housing need will be met.

It is notable that Rykneld Homes are building four family-sized market value homes on the former Manor Farm site in Dronfield. The site is in close proximity to shops, a medical centre and public transport links. As such, the site is an ideal location for housing for older people, people with disabilities, or affordable housing; yet the council, through its partner Rykneld Homes, chooses to build larger market value properties. Council leader Graham Baxter has said of this scheme: "The key strategic approach to this project is to create a high quality scheme of housing for open market sale, to provide a significant financial surplus". When presented with an excellent opportunity to provide housing for older people or those with disabilities, the council chooses instead to maximise its income from the site. This is indicative of what can be expected to happen if development is permitted on land which is currently Green Belt.
5.86 Statement "The SHMA indicates that there is a particular shortage of market housing and intermediate housing which is suitable for older people". The council is responsible for contributing to this situation. The council has permitted a significant number of bungalows adjacent to Frith Wood and in other areas of Dronfield to be converted to two storey dwellings; more recently bungalows have been demolished to be replaced by family houses (e.g. Carr lane near Stubley Lane). The plan should incorporate an unambiguous commitment by the council to mandate developers to provide a specified proportion of dwellings suitable for older people of the types listed.
5.86 Statement "Access to high speed broadband will allow access to emerging online healthcare initiatives". State what the council proposes to do to ensure this access is provided. If the council do not intend to implement measures to ensure this access, the statement is irrelevant.
5.87 The statement "the Council encourages all new dwellings to be made accessible and adaptable." is a further example of the meaningless statements peppering this plan. I suspect the council meant to say it will encourage developers; it is impossible to encourage a dwelling to do anything.
Policy LC4 Statements "The Council will support the provision of housing for older people" and "The Council will also support the provision of specialist housing"
Quantify what the council means by "support". In the context used support means "give assistance to", requiring a commitment of resources; outside the voluntary sector resources cost money. Define the budget the council intends to set aside for this support and the governance that will determine how funds are accessed and best value is ensured.
Statement "development proposals of 10 or more dwellings should provide 20% accessible and adaptable dwellings". "Should" means this is an optional requirement and therefore not to be relied upon. This statement is of no value unless "should" is replaced with "shall".
To summarise; within policy LC4 the council has not made any quantifiable commitment to ensure the housing needs of older people or those with special needs will be met.
6.2 & 6.8,
Policy WC2 Statement "Existing employment sites will be protected for employment uses". There is no point in protecting land which has remained unused for extended periods and where there is little or no prospect of it being used for employment. The old Padley and Venables site on Callywhite Lane in Dronfield has not been used for employment purposes for at least 10 years and has been the subject of a planning application for housing development. The council acknowledges the challenges of this site in paragraph 6.8 and notes the need for significant investment.
Within the evidence base for policy WC2 the council acknowledges that the NPPF states planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. It also notes public feedback that "considerations should be made over whether a site should be protected where it is clear that employment uses cannot / will not come forward."
The plan currently states the council's intention to continue protecting Callywhite Lane for employment use but does not include a commitment to the investment it acknowledges is necessary to resolve the issues causing the chronic underutilisation of the site. This is in breach of the NPPF guidance quoted in policy WC2 and completely disregards the public feedback acknowledged in this policy.
The council should therefore release this land for housing to reduce the pressure on prime Green Belt land.
6.5
3.9 Objectives D8 Addressing Climate Change, D13 Local Amenity

4.5 Policy SS1, Sustainable Development, clauses c and g Statement "Furthermore the low job density figure reflects that resident jobs relate strongly to nearby employment centres such as Sheffield, Chesterfield and the M1 corridor." Confirms that building 860 new dwellings in Dronfield is environmentally unsustainable; will increase commuting to Sheffield, Chesterfield, and through Chesterfield to the strategic development sites, resulting in increased congestion, pollution affecting large numbers of North Derbyshire residents and increased CO2 emissions. This is inconsistent with objectives 3.9 D8 and D13, and in breach of policy SS1 clauses c and g.
6.7 & 6.8 Statement "...and principal employment growth locations at:
* Callywhite Lane, Dronfield"
This assertion is false. Callywhite Lane has been underutilised for many years because it is not attractive to new businesses.
The council is clearly aware of the challenges at Callywhite Lane and acknowledges in paragraph 6.8 "the need for significant remediation and investment of these large scale previously developed sites". However, he plan includes no infrastructure investment commitment to resolve this situation. The current underutilisation will therefore continue.
The council will be aware of a proposal to build a new office block on the corner of Wreakes Lane (reference 17/00283/FL). It is notable that this employment development is not on Callywhite Lane.
6.13,
Table 6.1 Statement "Dronfield and Killamarsh are the main focus for employment (B1 & B2) in the North". Therefore the council should state the investment it is planning to make to resolve the difficulties with Callywhite Lane (ref. paragraph 6.8). Without such a commitment, the statement is disingenuous as is including it in table 6.1.
6.20 Statement "the allocation at Callywhite Lane in particular will provide a significant improvement to the quality of the employment land portfolio of the District."
Provide the evidence to support the assertion that Callywhite Lane provides this improvement. This statement contradicts the statement in paragraph 6.8 acknowledging the challenges of the site.
6.22 Statement "Policy WC1 allocates 6 hectares (net) of land for B1, B2 and B8 uses at Callywhite Lane".
To propose storage and distribution development (B8) at Callywhite Lane defies belief. The junction of Green Lane, Callywhite Lane and Chesterfield Road in Dronfield bottom is wholly unsuitable for large vehicle movements. Owing to the narrowness of the road along Dronfield bottom these vehicles also represent a significant hazard to other road users and the large number of pedestrians who frequent the area, in particular the children of Dronfield Henry Fanshaw School. If the proposed link road between the eastern end of Callywhite Lane and Chesterfield Road ever materialises, much of this traffic will then be routed past Unstone Junior School and through the residential area of Unstone Green; an equally unsatisfactory solution.
6.23 The council acknowledges the lack of progress since 2005 on the Callywhite Lane Extension yet the plan contains no infrastructure investment commitment (as it notes is necessary in paragraph 6.8) to resolve these issues.
6.23 Statement "Issues over access in particular need to be resolved but there is a likelihood that with the anticipated electrification of the East Midlands Main Line and (in the longer term) HS2, such issues will be resolved."
How on earth does HS2 have an impact on the access to Callywhite Lane when the planned route is several miles to the East of the site? Provide evidence to justify this implausible assertion. The council will also be aware that the electrification of the East Midland Main Line has been postponed.
7.2 What is the purpose of a historical description of Dronfield which appears to pre-date the development the large areas of housing off Snape Hill Lane and Stonelow Road, and also Gosforth Valley? This reads suspiciously like thoughtless copying and pasting as do other areas of the document.

The Green Belt to the south is to prevent Dronfield from merging with Unstone, a separate settlement dating back to the Domesday Book, not Chesterfield as stated - or do the council's planners now intend Unstone to be absorbed into Dronfield as it has allowed to happen with Coal Aston, now showing this once independent settlement as falling within the Dronfield settlement boundary?

The reference to passing trade on the B6158 (Green Lane) does not make sense; I suspect the author means the B6057, the old Chesterfield to Sheffield Road. Whilst the council may consider this a trivial error to note, it is indicative of the lack of rigour and poor quality of the document.
3.9 D12
7.3, 9.36,
Policy ID6 The council notes the presence of a train station in Dronfield, but it fails to acknowledge that there are no public transport links between the main housing areas and the station and the problems this causes.
Train users who live more than a few minutes' walk from the station drive to the station and park nearby. There is limited parking at the train station. FODS (Friends of Dronfield Station) have advised that the current free of charge car parking area is to return to the control of Northern Rail, who intend to implement charges and stop parking along the middle of the car park, thereby reducing its capacity. Therefore, the streets near to the station are choked with the cars of train users; this is a safety hazard for both pedestrians, including pupils of Dronfield Junior School and their parents, and other road users.
Whilst the station is "highly valued" and provides "excellent links to Sheffield and Chesterfield as well as locations further afield" as stated in paragraph 7.3, its usefulness is limited by the lack of an integrated public transport policy and plan. This plan does not address this issue and, in proposing the development of 860 additional dwellings without doing so will result in further exacerbating current problems and damage to the environment.
The plan does not "provide the framework for more sustainable transport choices" for Dronfield as stated in paragraph 9.36, fails to meet objective D12, and is in breach of policy ID6, paragraphs c and d
7.4 Statement "The tight constraints of the Green Belt have restricted development in recent years leading to rising house prices and unmet housing needs. The lack of available land within the existing settlement means that meaningful levels of housing growth can only be accommodated by looking around the edge of the town within the Green Belt."
The council's proposal to develop on the Green Belt is in breach of the Government's Housing and economic land availability assessment guidance (https://www.gov.uk/guidance/housing-and-economic-land-availability-assessment) which states: "Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the "very special circumstances" justifying inappropriate development on a site within the Green Belt".

The council has not demonstrated it has sufficiently considered all other options before proposing to remove land from the Green Belt. The council concedes in paragraph 5.6 that it has not considered windfall and it has dismissed the contribution of smaller sites as stated in paragraph 5.8. The continued protection of land at Callywhite Lane for employment when there is little or no prospect of it being used for this purpose, particularly when a developer has previously sought permission to build dwellings on part of the site, is in breach of NPPF guidelines.

The council's proposal to develop on the Green Belt is also in breach of the Housing White Paper 2017 which states:
"1.39 Therefore we propose to amend and add to national policy to make clear that:
* Authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements, including:
o making effective use of suitable brownfield sites and the opportunities offered by estate regeneration;
o the potential offered by land which is currently underused, including surplus public sector land where appropriate;
o optimising the proposed density of development; and
o exploring whether other authorities can help to meet some of the identified development requirement.
* and where land is removed from the Green Belt, local policies should require the impact to be offset by compensatory improvements to the environmental quality or accessibility of remaining Green Belt land. We will also explore whether higher contributions can be collected from development as a consequence of land being released from the Green Belt."
7.4 Statement "These [parcels of land selected for removal from the Green Belt] have been selected on the basis that they would cause least harm to the strategic functions of the Green Belt".
The council concedes this plan will harm the Green Belt, yet the plan shows the council has not considered alternative options: see comments against paragraph 7.4.
7.6 Statement "Dronfield is significantly lacking in green space, outdoor sports and children's play space."
The statement indicates the council is fully aware that the Dronfield area is already over-developed. Consequently, any further development is not sustainable as claimed. This plan proposes further environmental and well-being damage with the planned building on sports fields at Coal Aston and a golf course. This is the exact opposite of one of the requirements of sustainable development: "protecting and enhancing the environment".
Moreover, whilst proposing yet more development in Dronfield, the council make no commitment to rectify a situation it notes falls below current standards.
7.7 Statement "Overall, the town centre is performing well."
This statement does not reflect the situation in the civic centre where there are currently three empty units, three charity shops and a betting shop which make up 50% of the units.
7.7 The council acknowledges "the condition of the civic centre needs addressing" and should therefore state what level of funding it will provide to do so or how it will mandate developers, who will profit from building the proposed dwellings, to fund the necessary regeneration. The plan contains no commitment to address this issue. The plan completely fails to address the need to improve the infrastructure to accommodate the additional demand from the planned 860 additional dwellings.
7.8 Statement "but the spread out form of the town ... needs addressing in order to maintain the vitality and viability of the town centre".
Then state the council's plans to address the spread-out form of the town centre. Surely development outside the settlement development limits will increase the spread out form of the town?
Table 7.1 Item 1, first bullet: "review of bus services" without a stated commitment to act on the output does not result in the "Improvement of public transport"

Item 1, second bullet: is the council funding the proposed new link road to Callywhite Lane? If it is not, how will it be funded?

Item 1, fourth bullet: what does "Improved public realm" mean?

Item 1, fifth bullet: Explain how an "audit of vehicle speeds" improves balance between car and pedestrian space.

Item 3, bullet 1: "Improvement of the market offer" - how does the council propose to do this?

Item 4, bullet 1: Explain how "review and consolidation of previous audits" will result in making more of existing heritage assets.

Item 4, bullet 2: and what follow-up action will be implemented to secure new uses of historic buildings and spaces?
Policy SP1 Paragraph e(i) where does the council expect "proposals that maximise the benefits from, and protect and improve access to, the railway station" to come from if they are not included in the plan? This plan should include appropriate proposals, not rely on them coming from other sources. Define how the council will support these proposals. As it stands this statement is meaningless - there is no guarantee any proposals will be put forward and no quantification of the support the council will provide.

Paragraph e(iii): statement "Encourage proposals that facilitate the provision of new green space" is meaningless. The council will be fully aware that developers will seek to maximise profit by building as many dwellings as possible within regulatory constraints; they should be obligated to provide new green spaces.

Paragraph e(iv): State how the council will "Encourage uses within the town centre that enhance the offer of the town as an evening destination, particularly leisure facilities" i.e. what types of business will the council attract and how will this be done?

Paragraph f: How does the council intend to ensure developers that profit from building new accommodation will also "contribute to the successful delivery of the Dronfield Regeneration Framework's key themes and proposals" as stated?
8.11 Statement "National policy states that valued landscapes should be protected and enhanced, and requires Local Plans to include criteria based policies against which proposals for any development on or affecting local landscape areas will be judged."
The Drone valley landscape is highly valued by a large proportion of its residents. The council has not fulfilled this National Policy obligation with respect to the proposed development on Green Belt which will have a significant impact on the visual appearance and perception of the landscape.
Figure 8.1,
8.23 It is difficult to discern the different grey shaded areas, however it appears the area around Dronfield is classified as "Coalfield Village Farmlands". This is a grossly misleading classification of the Drone Valley - all the settlements pre-date the development of the coal fields: both Dronfield and Unstone appear in the Domesday Book. The field boundaries visible on both sides of the valley can be traced back to medieval times. The council's proposal to take land out of the Green Belt around Dronfield will destroy portions of this historic landscape. This is in breach of the National planning guidance referenced in paragraph 8.23: "National planning guidance advises that local planning authorities should set out a positive strategy for the conservation and enjoyment of the historic environment"

Figure 8.2,
8.53,
Policy SDC11 Figure 8.2 shows that 'use less energy' as the largest opportunity to reduce carbon emissions.
Paragraph 8.53 states "The Local Plan can make a major contribution to mitigating and adapting to climate change by shaping new and existing development across North East Derbyshire in ways that reduce carbon emissions". Whilst the local plan can make a major contribution to reducing carbon emissions, the current plan for the Dronfield settlement will do the exact opposite.
The current Green Belt land on which the council proposes housing developments will currently be a net CO2 sink. The council's proposal to build an additional 860 dwellings on the outskirts of the Dronfield settlement without a commensurate increase in local employment and no binding commitments to provide public transport from the outer reaches of the settlement to the railway station and existing bus services to Chesterfield and Sheffield will increase commuting, CO2 emissions and pollution.
Consequently, this proposal is not sustainable development and is in breach of policy SDC11.
8.59,
Policy SDC12 The plan notes there is a flood risk in the Dronfield area, however, paragraph 8.59 appears to be a NE Derbyshire Council statement of abdication on this matter, noting that the County Council and Environment Agencies hold the associated flood risk management responsibilities.
Policy SDC12 paragraph (d) states "There is no net increase in surface water runoff for the lifetime of the development on all new development. Run off rates for development on greenfield sites should not be exceeded, and where possible should be reduced from existing."
The proposed building of 860 dwellings on current Green Belt land will inevitably result in significant areas of hard surfaces replacing absorbent land. Consequently, it seems completely unrealistic that current run off rates will not be exceeded. However, the council appears to be relying on this flawed policy; the plan makes no provision for managing the additional run off that will result.
Policy SDC13 The proposal to build 860 dwellings on Green Belt land around Dronfield is in breach of clause (k) of this policy - a requirement to conserve historic landscapes.
8.65,
9.9,
9.37,
9.45,
9.57
Paragraph 8.65 reference to "A Guide to Sustainable Housing Layout and Design"; paragraph 9.9 reference to "Green Infrastructure Study"; paragraph 9.37 (and others) reference to "Derbyshire Infrastructure Plan"; paragraph 9.45 reference to "Local Transport Plan"; paragraph 9.57 reference to "Local Transport Plan 3".
None of these documents are included on the local plan evidence page of the council's website, nor does a search on their name return a link to the document. How does the council expect the public to comment on a plan referencing multiple documents that cannot be found on the council's web site?
This is further evidence that the consultation process is fundamentally flawed.
Why has the council not included a list of references to external documents, including links to where they can be found on the council's web site? A list of references is basic practice when citing external sources within a document.
8.70 Statement "The existing, and likely future, air quality in an area should be considered through Local Plans".
The council's proposal to build an additional 860 dwellings on the outskirts of the Dronfield settlement without a commensurate increase in local employment and no binding commitments to provide public transport from the outer reaches of the settlement to the railway station and existing bus services to Chesterfield and Sheffield will increase commuting and therefore degrade local air quality. The above statement infers the council's plan will seek to improve air quality, not reduce it as it currently plans to do in the Dronfield area.
8.73 Statement "the NPPF acknowledges that good planning should aim to prevent the adverse effects of noise from being unacceptable".
The increased commuting that the current plan will cause in the Dronfield area will have a significant negative noise impact on the residents in Unstone who live along the B6057. The plan contains no evidence to demonstrate that this has been considered or assessed.
Policy SDC14 Statement "Where adverse effects are identified, development will only be approved where suitable mitigation can be achieved which would bring emissions or impacts within acceptable levels".
This policy can only be fulfilled in relation to the proposed additional dwellings in Dronfield through binding commitments to interventions that prevent a significant increase in road traffic through Unstone.
9.5 Statement "The Council is continuing to work with statutory undertakers, utility companies and other agencies to prepare an Infrastructure Delivery Plan which will support the proposed development identified in the Local Plan."
In other words, there is currently no agreed plan nor any binding commitments to provide the infrastructure necessary to support the proposed expansion in housing. Consequently, the plan presented is incomplete, unsound and should be withdrawn and re-issued for further consultation when appropriate commitments on infrastructure provision have been secured.
9.6 Statement "Potential sources of funding for strategic infrastructure could include Local Enterprise Partnerships and the Regional Growth Fund and Growing Places Fund, central government, ..."
In other words, the council has no idea how strategic infrastructure needs arising from the proposed increase in dwellings will be funded.
Consequently, the plan presented is incomplete, unsound and should be withdrawn and re-issued for further consultation when appropriate commitments on infrastructure provision have been secured.
Policy ID1 Statement "Development proposals that would result in the loss or isolation of
existing green infrastructure will not be permitted unless ... a compensatory amount of green infrastructure of an equivalent or better quality can be provided in the local area"
The council's plan contains no such provision with respect to the green infrastructure it is proposing to destroy on the outskirts of the Dronfield settlement. The proposed development at Dronfield is in breach of this policy.
Policy ID1 Statement: "The NPPF tells us that ... policies should be based on up to date assessments of the need for open space, sports and recreation facilities, and opportunities for new provision. LPAs should protect and enhance public rights of way and access, and should not permit development on existing open space except where it is surplus to requirements, or will be replace [sic] by equivalent of superior facilities"
The plan contains no assessment of the need for open space, sports and recreation facilities; it actually proposes destroying both existing sports and recreation facilities at Coal Aston, Hallowes golf course and Green Belt open spaces, none of which are 'surplus to requirements'.
Consequently, the plan for Dronfield is in breach of this NPPF requirement and fails to meet objectives D6, D9, D13 as claimed in this policy.
Objective D16 referenced in this policy does not appear anywhere in the document!!
9.19 Statement "The Council is committed to the protection and enhancement of open space, sports and recreation facilities".
This statement is blatant hypocrisy when the council plans to destroy existing sports and recreational facilities at Coal Aston and Hallowes golf course.
9.22 Statement "The Council has commissioned a Playing Pitch Strategy and an Indoor Sports Facilities Strategy to assess current levels and quality of provision in relation to demand."
In other words, these 'strategies' have not completed the commissioned assessments
Statement "The Council is also in the process of reviewing open spaces, recreation sites and facilities. The outcome of this work will inform the next iteration of the Local Plan."
Further evidence that the current plan is incomplete, contains no binding commitment to providing these facilities, and is therefore unsound.
Policy ID3 The statement "The Council will seek to protect and enhance existing open spaces" is meaningless. State exactly what is meant by "seek" i.e. binding commitments on the council and mandated obligations on developers.
Policy ID3 The Green Belt open spaces around the Dronfield settlement and the playing fields at Coal Aston which the council proposes to destroy are not 'surplus to requirements' nor does the plan contain any obligations for them to be "replaced by equivalent or better provision in terms of quantity and quality in a suitable location". Consequently, the plans for the Dronfield settlement are in breach of this policy.
9.29 Statement "The Local Plan does not designate Local Green Spaces, but any forthcoming Neighbourhood Plans may do so."
The plan does not contain any commitment to respect these designations. The council must make its position clear on this matter.
9.30 Statement "Where new Green Infrastructure is proposed, clear funding and delivery mechanisms must be in place for its long term management and maintenance".
Then state how the council expects the funding and delivery mechanisms to be provided.
9.36 Statement "The relationship between planning, transport and infrastructure is acknowledged as crucial in creating successful and sustainable places that work for everyone. Whilst the planning system cannot directly change people's travel behaviour, it can provide the framework for more sustainable transport choices.
The plan for 860 additional dwellings on the outskirts of Dronfield without a binding commitment to provide public transport links to the development areas does not provide a framework for more sustainable transport choices.
9.37 Statement "but there is an acknowledgment that this understanding will need to be developed further through Local Plans and also through detailed assessments such as modelling and Transport Assessments".
In other words, the council has inadequate data on how the plan for additional dwellings and therefore there is no basis for planning needed improvements to existing highway and public transport networks, services and facilities.
Consequently, the plan presented is incomplete and therefore unsound.
9.38 Statements "Derbyshire County Council is responsible for transportation, which includes producing the Local Transport Plan." and "the District Council has only limited control over highways or transport matters".
In other words, the council has no obligation to assess transport requirements arising from the planned increase in dwellings.
As a local resident, I have no interest in the division of planning responsibilities between the different council bodies; I expect them to work together to produce a coherent and complete plan. The current local plan is evidence that this is not happening. This paragraph makes a strong case to merge the current bodies into a single council with responsibility for all aspects of planning.
9.39 Statement "Sustainable modes of travel such as walking, cycling, public transport, car sharing, and alternative fuel vehicles can be provided through good planning and design".
However, the current local plan contains no commitment to provide public transport links to the proposed development areas on the outskirts of Dronfield. This is bad planning. The paragraph reveals that a Transport Assessment will only evidence the damage these plans are doing to the environment.
9.40 Travel Plans appear to be equally toothless; there is no commitment in the plan to ensure the infrastructure is upgraded to meet the increased demand arising from the additional dwellings planned, to the detriment of current residents and the environment.
9.41 Statement "Access to sustainable forms of transport must be integrated into the design of new development".
Therefore, the council must commit to providing public transport links from the proposed development areas on the outskirts of Dronfield to the existing transport hubs in the centre. This plan contains no such commitment and is therefore flawed.
9.44 Statements "Where possible, bus routes should penetrate new development sites through permeable routes" and "Where appropriate, developers will be asked for a financial contribution so the Council and bus operators can work together to improve bus provision for a particular site."
The plan should be as unambiguous about these commitments as it is for the number of dwellings proposed. The council has access to national statistics that will enable it to quantify the requirements for public transport and other infrastructure facilities, but it has failed to address these matters in the plan.
9.45 Statement "Where applicable, proximity and access to rail services should also form part of planning applications"
9.51 Statement "The future focus will therefore be on limiting parking supply at destination."
This policy is myopic and, as acknowledged with limiting parking on residential estates, will result in difficulties as is already the case in Dronfield in the proximity of the Railway Station. The focus should be on providing viable alternatives to car use i.e. frequent and affordable public transport services linking the outer reaches of settlements such as Dronfield with existing transport hubs.
Policy ID6 The council has acknowledged it does not have authority of the strategic highway network; it therefore cannot implement clause (f) of this policy. Therefore this clause is misleading and should be removed or re-written.
Policy ID6 Statement "You told us that ... The Plan should aim to reduce the use of the car and encourage walking, cycling the use of public transport."
Yet the plan contains no binding commitments to encourage any of these. The council appears to be relying on encouraging developers and other authorities to achieve this aim.
9.53 Statement "Funding or developers [sic] contributions will be sought, as appropriate, to support the delivery of key transport infrastructure improvements."
This statement lacks substance and shows no binding commitment to deliver infrastructure improvements. The plan must be as unambiguous in its implementation of infrastructure improvements as it is with respect to the number of dwellings required. Anything less than this offers no assurance against the environmental damage and congestion blight that would be result from a significant increase in dwelling numbers with no commensurate improvements to infrastructure. Consequently, the plan is incomplete and unsound.
9.54 Statement "Proposals for improvements to transport infrastructure will be supported where it can be demonstrated to be necessary".
Define 'supported' i.e. the level of funding the council will commit to these improvements.
Define 'demonstrated to be necessary' i.e. what criteria will determine an improvement is necessary.

Statement "recognising that transport issues to not stop at administrative boundaries"
I suspect this should read "do not stop"
9.56 Statement "The legacy of coal mining has left a number of disused rail routes throughout the District, which have the potential to be returned to beneficial use to reduce the number of journeys made by road, increase the movement of freight by rail, or increase opportunities for recreation."
Like so many statements in the plan, the above fails the "so what" test. Does the council intend to implement measures to develop these rail routes for the purposes identified? If so, state what these measures are. If the council has no plans to develop disused routes, the statement is irrelevant.
Policy ID7
This policy merely states the basis on which new transport infrastructure will be permitted. Despite proposing the development of 6,600 additional dwellings 50ha of employment land this plan contains no commitment to implement any new infrastructure or improve existing infrastructure. Consequently, this is a plan to increase pollution and congestion, adversely impacting the quality of life of the region's residents.
9.68 Statement "Where new development necessitates new or improved infrastructure ... the Council will require developers to contribute towards any necessary site specific infrastructure".
This does not address improving local infrastructure outside the proposed development sites to meet the increased demands arising from the planned developments.
9.71 The Infrastructure Delivery Plan must be part of the consultation process, not published after the local plan is adopted. With the IDP, the council is presenting a partial picture to the public and leaving many questions unanswered. Consequently, the current consultation process is flawed.
9.73 Provide details of the Community Infrastructure Levy: who pays this; on what basis are charges calculated?
The paragraph seems to suggest the developers pay the levy and, if it is set too high, it will deter development. However, the details requested can only be inferred; they should be explicit. The author assumes the public have prior knowledge of CILs.

Statement "the Council will therefore also carry out work to assess the viability of the Plan as a whole, and whether there would be enough economic incentive to provide new development with infrastructure requirements in place. This work will help to inform whether a levy will be introduced and what rates would be applied".
The first sentence is difficult to decipher, but the council appear to be suggesting that if developers object sufficiently strongly the council will not pursue infrastructure funding via CILs. The outcome of this policy is entirely predictable; developers will provide the minimum on-site infrastructure necessary to meet any applicable mandatory regulations.
9.76 Statement "Where a scheme is agreed to be unviable or marginal, the Council will review the policy arrangements"
Yet another statement rendering purported safeguards and policies in this plan ineffective. Developers must be required to deliver schemes meeting immutable requirements that ensure the provision of appropriate infrastructure. If these requirements result in schemes being unviable, then there is insufficient demand in the market to justify the schemes. The precedent for this approach is well established in many sectors where minimum standards are enforced through regulation, and products or services that do not meet these standards cannot be offered.
9.77 While paragraph 9.76 is retained, paragraph 9.77 does not provide sufficient protection: "essential" is not defined; paragraph 9.76 renders all the stated infrastructure policies mutable.
The paragraph also states "schemes will not be supported"; that does not mean they will not be permitted, rendering the paragraph ineffective.
Policy ID8 Paragraph (c) of this policy also limits a developer's obligation to on-site infrastructure in accordance with the limitations noted in paragraph 9.68 above.

Object

Consultation Draft (February 2017)

Representation ID: 5247

Received: 03/04/2017

Respondent: JVN Architecture

Agent: Mrs Linda Trollope

Representation Summary:

The general aims of this policy including the allowance for agricultural and forestry buildings are in line with national Green Belt guidance. I do however object to the restriction that such buildings should only be allowed where the majority of the income is derived from the business. In general the quality of agricultural land in the district is classified as "poor" or "good to moderate". There are many small agricultural units that are operated in association with a more profitable occupation. To ban the construction of new agricultural buildings in these circumstances would severely limit agricultural operations.

Full text:

The general aims of this policy including the allowance for agricultural and forestry buildings are in line with national Green Belt guidance. I do however object to the restriction that such buildings should only be allowed where the majority of the income is derived from the business. In general the quality of agricultural land in the district is classified as "poor" or "good to moderate". There are many small agricultural units that are operated in association with a more profitable occupation. To ban the construction of new agricultural buildings in these circumstances would severely limit agricultural operations.

Object

Consultation Draft (February 2017)

Representation ID: 5321

Received: 04/04/2017

Respondent: Mrs Hannah Knowles

Representation Summary:

Objection to removal of green belt land in north east derbyshire

Full text:

I object to the removal of land from the Green Belt surrounding the town of Dronfield, and proposed Housing Allocation sites g, h, i, j and k under proposed policy LC1.

The reasons for my objection are set out below.

National Planning Policy and the NPPF

National planning policy encapsulated in the National Planning Policy Framework sets out the current status of Green Belt designation, and the circumstances and situations in which it might be reviewed.
Paragraph 14 of the NPPF clearly states that:

"Local Plans should meet objectively assessed needs with sufficient flexibility to adapt to rapid change; unless ... specific policies in this Framework indicate development be restricted.9"
Footnote 9 then sets out that one such specific policy is "land designated as Green Belt".

This key paragraph within national planning policy clearly sets out that the requirement to meet objectively assessed housing need does not over rule Green Belt policy, and should not be used as a reason to do so. Furthermore the current Housing White paper "Fixing our broken housing market" seeks to add even greater weight to this point by prioritising it within para 14, and by making footnote 9 a 'definitive' rather than suggested list of restrictive policies.

The NPPF plainly sets out that "Green Belt boundaries should only be altered in exceptional circumstances". Again this position is sought to be strengthened through the new white paper, including amendments to ensure that:

"Authorities should only amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements, including;
* Making effective use of sustainable brownfield sites and the opportunities offered by estate regeneration;
* The potential offered by land which is currently underused, including surplus public sector land where appropriate;
* Optimising the proposed density of development; and
* Exploring whether other authorities can help to meet some of the identified development required"
The currently proposed local plan draft in no way demonstrates that "exceptional circumstances" exist, and certainly does not provide any evidence that the above steps have been undertaken or satisfied.
On the contrary, North East Derbyshire District Council have previously published a draft Local Plan which adequately accommodated their housing need without amending Green Belt boundaries, and have therefore proven themselves that the above steps cannot be met (as they can accommodate their growth without needing to take the 'last resort' of Green Belt infringement).

This point is openly admitted in the Council's recently published 'Frequently Asked Questions for Dronfield" pamphlet, wherein it is stated:

"However through the consultation process and further site based work there emerged a clear mismatch between the strategy and the proposed spatial distribution of housing, land availability and demand; such that the levels of growth being planned for across the District could not be accommodated in a sustainable way or where demand and viability were highest. Detailed site analysis found a high level of potential supply in the south of the District where there are issues around the viability of delivering large numbers of sites in a relatively small area. Whereas in the North and West of the District, areas with particularly high demand, there is a significant undersupply of housing land and affordability issues and increased pressure to develop remaining valuable green spaces and employment land."

Whilst concerns are raised about the location of available land in respect of demand and viability, it is clearly set out that within the District there is sufficient land available to meet housing need without amending Green Belt boundaries, and this is without even needing to consider the additional steps set out above of looking at increased densities, working with neighbouring authorities, looking at under used public sector land etc. National planning policy makes it absolutely clear that resorting to Green Belt is a last resort and so concerns about demand and viability cannot trump this.

Furthermore most if not all of the sites identified will come with their own significant abnormal costs, namely steep gradients and likely former shallow mine workings, which are just as likely to impact viability as the sites in the south of the region. There are also many new developments progressing throughout the south of the region, particularly from certain developers, which are clearly proving successful and so I do not feel that these concerns of viability and demand are even justified.

Finally, the new housing white paper also seeks to add clarity that where a Green Belt review is proven to be required (which as set out above, it categorically is not) "local planning authorities should look first at using any Green Belt land which has been previously developed and/or which surrounds transport hubs.'

With the exception of the golf course (which I will return to shortly) not one of the proposed Green Belt releases in Dronfield comprises previously developed land, and rather serve as functioning agricultural land which has been green open space for time immemorial. In respect of the second point, much has been made of Dronfield train station but frankly the services from this station, along with local bus services, are far from great and provide no better service than other towns within the District. Indeed the Local Plan itself readily identifies that most of the region is reasonably well served by public transport via the hub of Chesterfield.

Other material concerns

Local services

Many valid concerns in respect of this matter will be raised in other representations made to this consultation and so I do not intend to go into great detail generally on this point here. What I would like to point out is that the high quality of local schooling is one of the main draws to Dronfield as an area, and it is undeniable that over 800 additional houses will put some degree of added strain on these facilities.

The act of viability testing by developers is an established and necessary one, but can mean that the money available to offset such strains is limited. I would stress that when it comes to establishing an order of priority for S106 monies should these developments come forward, that education must be at the top of the list, followed by improvements to other local facilities and infrastructure.

Affordable housing

Dronfield is a town which is surrounded by other settlements which provide a high quantity of 'traditional' affordable housing (albeit they may not sit within the boundary of NEDDC) and, whilst it may not be a planning concern, there is no appetite for further such housing locally. Provision of such types of housing is one of the greatest costs to developers and so following the above points it is crucial that this requirement sit at the very bottom of the planning gain 'ask list' i.e. if these developments come forward, and there is any debate over whether the full raft of planning gain items can be afforded, education and local services must come first, with traditional affordable housing coming last. Dronfield would be doing more than its 'fair share' were these developments all to come forward and so, again whilst it might not be a planning concern, morally this would only be fair so as to support the facilities and concerns of the existing residents.

That said, what there undeniably is an appetite for locally is low cost affordable housing for sale. With this I mind, and in light of other changes outlined in the housing white paper which aim to broaden the definition of affordable housing within the NPPF and impose a 10% requirement of 'affordable home ownership' products on every site, I would stress that any requirement for affordable housing over and above this 10% on these sites should also specifically encompass the provision of low cost housing for sale products.

The golf course

Allocation h comprises the Hallowes Golf Course. The Local Plan directly identifies a shortage of usable open space and recreation facilities within Dronfield, and so to propose to allocate one of the few sites that serve this purpose for housing is directly contradictory.

Highway safety

In relation to allocation g I would draw particular concern to the capacity of Hallowes Rise. This road carries a very steep incline, and suffers from a high level of 'double parking' making the road difficult to navigate at busy periods. The road is also particularly hazardous during winter months, and numerous accidents have occurred in recent years.

With that in mind I would suggest that, should site g become allocated, the allocation policy should come with specific design restrictions that access to the site comes solely from Chesterfield Road to the North East.
Similarly in respect of allocation h, access of this site from the Hallowes estate (either via Hallowes Rise, or Hallowes Lane) should be prohibited through design restrictions within any future allocation wording.

Object

Consultation Draft (February 2017)

Representation ID: 5410

Received: 07/04/2017

Respondent: PMW Property

Agent: Cerda Planning

Representation Summary:

See attached

Full text:

See attached

Object

Consultation Draft (February 2017)

Representation ID: 5608

Received: 07/04/2017

Respondent: Mrs Amanda Hockey

Representation Summary:

No exceptional circumstances to justify removing land from greenbelt.
Dronfield infrastructure not adequate for this level of development
Character of town changed detrimentally and irrevocably.
Would merge Dronfield with surrounding towns/ vilages/ city
No attempt made to liaise and cooperate with neighbouring authorities

Full text:

I am writing to object to NEDDC planning proposals which set out to remove green belt land in Dronfield to accommodate housing development. I believe the proposed development will be irreversibly detrimental to the town and for its people. My reasons are set out below:
Green Belt
The green belt around Dronfield serves a valued purpose and provides vital outdoor space for the town's population. The plan recognises that Dronfield is already "significantly lacking in green space, outdoor sports and children's play space", then goes on to totally disregard those findings in its proposals. The green belt is actively used by children to play and stay healthy, is very popular with walkers, joggers, horse riders, nature lovers and bird watchers. Removing this when it has been acknowledged that the town has a severe lack of outdoor facilities moves beyond shortsighted management and straight into incompetence.
The governments National Planning Policy Framework states that the fundamental aim of greenbelt policy is to prevent urban sprawl by keeping land permanently open; green belts are characterised by their openness and their permanence. Greenbelt land fulfils the following important purposes, all of which most definitely apply to Dronfield:
* To check the unrestricted sprawl of large built-up areas
* To prevent neighbouring towns merging into one other. This is particularly relevant to the land between Dronfield and Unstone
* To assist in safeguarding the countryside from encroachment
* To preserve the setting and special character of historic towns. The building of 860 houses with the huge population increase that would result in cannot be classed as limited infilling. Instead it would alter the character of the town entirely
* To assist in urban regeneration, by encouraging recycling of derelict and other urban land
* Any removal of land from the Green Belt will set a precedent for developers and leaves the 'permanence' of remaining
Green belt land should only be built on in exceptional circumstances. Guidance from the Department of Communities and Local Government state that "local councils should be looking to brownfield first and foremost, and be in line with government policy of protecting Green Belt." NEDDC have failed to demonstrate that they have adequately investigated potential brown field sites. Furthermore they have disregarded the 731 unoccupied houses within the NEDDC area. A freedom of Information Request showed that no attempt has been made to bring these dwellings back into use which could largely remove the need for additional housing and eliminate any justification for building on green belt land. The plan also fails to demonstrate that NEDDC have fulfilled their obligation to co-operate with neighbouring authorities in order to meet allocations for unmet housing need.
The proposed new boundaries look like an arbitrary line has been drawn to make development easier. 'Infilling' is a technique used in areas of limited space, but the spaces in question around Dronfield are large expanses, so infilling is an invalid reason to occupy the spaces.
Unmet housing demand does not qualify as an exceptional circumstance. In taking the four largest areas of greenbelt land in Dronfield, which are vitally important and highly valued in their current functions as directed by the National Planning Policy Framework, NEDDC is irresponsibly contravening national planning policy guidelines.
Based on the above it is clear that exceptional circumstances to justify building on green belt land do not exist.
Infrastructure
Government policy states that "The Local Plan should make clear, for at least the first five years, what infrastructure is required, who is going to fund and provide it, and how it relates to the anticipated rate and phasing of development." Nowhere in the plan is this laid out and to suggest leaving this area to later consideration is utterly senseless given its importance. I don't believe the infrastructure of Dronfield can cope with the addition of 860 new homes and the huge increase in population and traffic that would be the result.
Roads
The majority of roads in Dronfield were built for a village not a town. They are narrow, steep and winding and during busy times already struggle to cope with demand. The new development is likely to result in an increase of around 1720 cars on the roads. The roads in south Dronfield (where 655 of the new houses are proposed) are particularly unsuited to this level of growth. Hilltop Road, Hallowes Lane and High Street all have sections where there is no pavement. The roads and pavements are narrow and one parked car results in there being just one lane of traffic leading to long queues. Standing traffic will also create unacceptable levels of pollution to be breathed in by all residents.

There is currently no way to access what would be the new estate behind Hilltop Road. If access is to be via Hilltop Road, the road would have to accommodate vehicles from 420 houses, possibly an additional 840 cars. The road is not built for this level of traffic. It will be heavily congested and extremely dangerous. As previously mentioned, part of the road has no pavement, more still is more track than road and in other parts what pavement there is, is very narrow. Also, Residents have to reverse onto their drives; having to do that across a lane of busy traffic is clearly going to be a problem.

If access is to be via a new road on the north side of hilltop road, it would mean either the Hyde Park pub would lose its car park or have to be knocked down completely. The Hyde Park is a community hub and as the only amenity within easy walking distance is very important and highly valued by the residents of south Dronfield. Without it, the character of the road would be altered, very much, to the detriment of the residents.

Hallowes Lane and High Street also suffer from narrow pavements in places and no pavement at all in others. Crossing is hazardous as visibility is poor on both roads.

Having a train station will not solve these issues, it will exacerbate them. People using the station drive there. Aside from an increase in traffic caused by driving to the station, parking is extremely limited forcing people to park on nearby roads, thus narrowing them to one lane creating even more standing traffic and pollution.

All the roads mentioned above are used by children walking to and from school, old people and parents with prams and it can be dangerous as it is. The potential for an accident involving these groups will increase massively and that is clearly unacceptable.

It should also be mentioned that widening the roads and pavements is not an option due to the proximity of existing housing.


Schools
Schools in Dronfield have little or no room to expand. This is especially true of Dronfield Infants and Juniors which would be the catchment school for the 655 new houses to be built in south Dronfield. They stand on small plots with already limited outdoor space. How on earth are they supposed to take in so many extra children that 655 new houses will certainly result in? The consequences will be children having to travel much further to school and possibly be in different schools to their siblings, plus increased class sizes and less open space to play. All of which will have a highly detrimental effect on both the physical and mental wellbeing of the children. Henry Fanshawe, the only secondary school in Dronfield, is over-subscribed every year. There is no way it can accommodate the increase of children that would be the result of 860 new houses. It will not be able to accept the intake of all the Dronfield schools and children will end up having to go out of catchment and out of county.

The proposed housing does not reach the threshold of 1000 new houses to trigger the building of a new school, but clearly 860 new houses is going to have a massive impact on schools in the area. NEDDC have a responsibility to their constituents to ensure that education is not adversely affected. I have seen no evidence so far that this has been considered by NEDDC.

A further worry is that, should NEDDC decide at some point in the future that extra schools are required, they will need to take either more of the green belt or remove the already inadequate amount of green space available to Dronfield residents. Neither option is acceptable.

Doctors
GP services in Dronfield are already over stretched. Waiting time for a pre-booked appointment can be as much as five weeks. There is nothing in the plan to suggest that this has been taken into account or an increase in medical provision will be forthcoming.


Suitability for Large Scale Development

Housing already constitutes such a high proportion of Dronfield's size, the council's reasoning behind such high housing allocation is invalid. An increase of this number, given the existing lack of green space, will change the character and feel of Dronfield irreversibly and detrimentally and must be viewed as a step too far. It should be acknowledged that Dronfield has taken its fair share of growth. There has been a 179% population increase between 1951 and 2011. In the same time period Derbyshire's population as a whole (including Derby) grew by 23%, and Clay Cross by only 8%. Infrastructure capacity and improvements are already lagging behind the huge population increases in Dronfield.

The Local Plan presents Dronfield as a sustainable community based on being the largest settlement in the north of the district, this is a crude measure of sustainability and it is not a substitute for undertaking proper infrastructure assessments prior to drawing up housing allocations. In fact, as the largest settlement it has the least room for expansion.


No one disputes that some affordable housing would be beneficial to Dronfield. However, from the evidence of the local plan and talking to planners at the consultations (where I didn't see a single council member!), it would appear that this development is being driven by the developers who want to build on Dronfield greenbelt rather than more suitable locations in order to cash in on the reputation Dronfield enjoys as such a lovely place to live. As a result of this, and of Dronfield recently being identified as one of the top ten places to live, it is unlikely that housing will be kept affordable. Ironically, this amount of development will remove all the reasons that saw Dronfield so high on the list in the first place.

I implore NEDDC to put the wishes of the people who voted for them before the profit driven priorities of the developers. I also ask that they listen properly to the concerns of local people and undertake much more rigorous research and analysis to produce a local plan that works for everyone. The local plan now being consulted on does not.

Support

Consultation Draft (February 2017)

Representation ID: 5679

Received: 05/04/2017

Respondent: The Coal Authority

Representation Summary:

Support - The Coal Authority supports this policy which identifies that mineral extraction is an acceptable form of development in the Green Belt.

Reason - The Policy supports the principles set out in National Planning Policy in the NPPF.

Full text:

Comments on Coal Mining Issues in North East Derbyshire Local Plan

Surface Coal Resources and Prior Extraction

As you will be aware, the North East Derbyshire District Council area contains coal resources which are capable of extraction by surface mining operations. These resources cover nearly all of the North East Derbyshire.

The Coal Authority is keen to ensure that coal resources are not unnecessarily sterilised by new development. Where this may be the case, The Coal Authority would be seeking prior extraction of the coal. Prior extraction of coal also has the benefit of removing any potential land instability problems in the process.

As The Coal Authority owns the coal on behalf of the state, if a development is to intersect the ground then specific written permission of The Coal Authority may be required.

Coal Mining Legacy

As you will also be aware, the North East Derbyshire area has been subjected to coal mining which will have left a legacy. Whilst most past mining is generally benign in nature, potential public safety and stability problems can be triggered and uncovered by development activities.

Problems can include collapses of mine entries and shallow coal mine workings, emissions of mine gases, incidents of spontaneous combustion, and the discharge of water from abandoned coal mines. These surface hazards can be found in any coal mining area, particularly where coal exists near to the surface, including existing residential areas.

Within North East Derbyshire there are approximately 2,480 recorded mine entries. Mine entries may be located in built up areas, often under buildings where the owners and occupiers have no knowledge of their presence unless they have received a mining report during the property transaction. Mine entries can also be present in open space and areas of green infrastructure, potentially just under the surface of grassed areas. Mine entries and mining legacy matters should be considered by Planning Authorities to ensure that site allocations and other policies and programmes will not lead to future public safety hazards.

Although mining legacy occurs as a result of mineral workings, it is important that new development recognises the problems and how they can be positively addressed. However, it is important to note that land instability and mining legacy is not a complete constraint on new development; rather it can be argued that because mining legacy matters have been addressed the new development is safe, stable and sustainable.

As The Coal Authority owns the coal and coal mine entries on behalf of the state, if a development is to intersect the ground then specific written permission of The Coal Authority may be required.

Specific Comments on the North East Derbyshire Local Plan - Consultation Draft

The comments and/or changes which The Coal Authority would like to make or see in relation to the above document are:

Representation No.1

Policy - Policy SS1: Sustainable Development

Test of Soundness
Positively Prepared Justified Effective Consistency to NPPF Legal & Procedural Requirements Inc. Duty to Cooperate
Yes Yes Yes Yes Yes

Support - The Coal Authority is pleased to note that criterion i. identifies that proposals should avoid sterilisation of mineral resources.

Reason - The Policy supports the principles set out in National Planning Policy in the NPPF


Representation No.2

Policy - Policy SS9 - North East Derbyshire Green Belt

Test of Soundness
Positively Prepared Justified Effective Consistency to NPPF Legal & Procedural Requirements Inc. Duty to Cooperate
Yes Yes Yes Yes Yes

Support - The Coal Authority supports this policy which identifies that mineral extraction is an acceptable form of development in the Green Belt.

Reason - The Policy supports the principles set out in National Planning Policy in the NPPF.


Representation No.3

Paragraphs 5.11 - 5.62 Housing Allocations Descriptions

Test of Soundness
Positively Prepared Justified Effective Consistency to NPPF Legal & Procedural Requirements Inc. Duty to Cooperate
Yes Yes Yes Yes Yes

Support - The Coal Authority is pleased to see that the descriptive text identifies those allocations which are within the defined Development High Risk Area and where proposals need to be supported by a Coal Mining Risk Assessment.


Representation No.4

Paragraph 8.82 - The Coal Authority supports the reference to North East Derbyshire's past coal mining heritage and the identification that large parts of the district have been subject to past coal mining activities which need to be considered when development proposals come forward.


Representation No.5

Policy - Policy SDC15: Contaminated and Unstable Land

Test of Soundness
Positively Prepared Justified Effective Consistency to NPPF Legal & Procedural Requirements Inc. Duty to Cooperate
Yes Yes Yes Yes Yes

Support - The Coal Authority is pleased to see that this policy requires consideration of unstable land and the undertaking of necessary remedial works to ensure that any issues identified are addressed.

Reason - The Policy supports the principles set out in National Planning Policy in the NPPF.


Representation No.6

Paragraphs 8.89 - 8.93 - Safeguarding of Mineral Resources

Test of Soundness
Positively Prepared Justified Effective Consistency to NPPF Legal & Procedural Requirements Inc. Duty to Cooperate
Yes Yes Yes Yes Yes

Supports - The Coal Authority is pleased to see that there is signposting in this Local Plan to Derbyshire County Council as Minerals Planning Authority and reference made to the policies and plans which will form the policy framework for the decision making process when planning applications are being considered.

Reason - In order to ensure that the policy is clear in respect of the requirements of the NPPF.


Conclusion

The Coal Authority welcomes the opportunity to make these comments. The Coal Authority also wishes to continue to be consulted both informally if required and formally on future stages.

Object

Consultation Draft (February 2017)

Representation ID: 5958

Received: 10/04/2017

Respondent: Panache Lingerie Ltd

Agent: Knight Frank

Representation Summary:

Although the respondent support's the Council protection of the Green Belt Panache Lingerie Ltd strongly objects against the assertion that the level of planned growth for NED cannot be accommodated sustainably within sites which are spatially
distributed in accordance with the settlement hierarchy. It is considered that suitable Brownfield sites exist elsewhere within the district.

Full text:

See attachment

Object

Consultation Draft (February 2017)

Representation ID: 5972

Received: 10/04/2017

Respondent: Green Piling Ltd

Agent: Knight Frank

Representation Summary:

Green Piling supports the Council's protection of Green Belt. However, the respondent strongly objects against the assertion that the planned housing growth in NED cannot be accommodated sustainably within sites which are spatially distributed in accordance with settlement hierarchy. It is considered that suitable Brownfield sites exist elsewhere within the district which are being unnecessarily protected for employment use.

Object

Consultation Draft (February 2017)

Representation ID: 6143

Received: 07/04/2017

Respondent: Sheffield FC

Agent: DLP (Planning Ltd) - East Midlands office

Representation Summary:

R Timms objects to Policy SS9 and wishes that for the Sheffield FC site at Sheffield Road, Dronfield a further category should be added to the policy which states
g) The redevelopment of Sheffield Football Club ground at Sheffield Road, Dronfield where the redevelopment delivers a new provision for the club in their historic home of Sheffield

Support

Consultation Draft (February 2017)

Representation ID: 6160

Received: 06/04/2017

Respondent: The National Trust

Representation Summary:

National Trust supports the long term protection of North East Derbyshire's Green Belt through Policy SS9.

Full text:

Spatial portrait

Description of the area
Section 2.8 - National Trust welcomes the reference to the settings of Bolsover Castle and Hardwick Hall and the need to protect these designated heritage assets.

Key issues
Section 2.17 - National Trust welcomes the recognition within the Economy and Employment section of the value of the Peak District and local heritage assets such as Chatsworth, Bolsover and Hardwick Hall as drivers of economic growth and tourism.
Section 2.22 - National Trust supports the recognition of opportunities to increase the capacity of renewable energy generation in the district to help reduce emissions and climate change.
Section 2.24 - While we acknowledge the recognition of pressure on the natural environment as a result of growth, we suggest that it would be helpful to include a positive statement here about protecting and enhancing these assets.
Section 2.25 - National Trust welcomes the reference to protecting heritage assets and we suggest that archaeological remains along with (built and natural) heritage need to be protected and where possible enhanced.

Vision and objectives
National Trust broadly supports the Local Plan Vision.
We also support objectives D3 Tourism, D6 Green Belt, D8 Addressing Climate Change, D9 Design and Place Making, D10 Heritage Assets, D11 Natural Assets, D12 Sustainable Transport, N2 Countryside Recreation, W2 Countryside Character, E3 Environmental Quality.

Spatial strategy
SS3 Spatial Strategy and the Distribution of Development
The purpose of Green Belts is to keep land permanently open. In order to justify the removal of land from the Green Belt the Council will need to demonstrate that there are exceptional circumstances (NPPF paragraph 83) taking account of the need to promote sustainable patterns of development (NPPF 84).
SS9 North East Derbyshire Green Belt
National Trust supports the long term protection of North East Derbyshire's Green Belt through Policy SS9.
SS10 Safeguarded land
The purpose of Green Belts is to keep land permanently open. In order to justify the removal of land from the Green Belt the Council will need to demonstrate that there are exceptional circumstances (NPPF paragraph 83) taking account of the need to promote sustainable patterns of development (NPPF 84).
SS11 Local Settlement Gaps
National Trust supports the principle of identifying local settlement gaps.
SS14 Development within the Countryside
National Trust supports Policy SS14 which aims to ensure that only small scale and appropriate development is allowed in the countryside.

WC6 Visitor Economy and Tourism
Policy WC6 Visitor Economy and Tourism is supported.

SDC2 Trees, Woodlands and Hedgerows
Policy SDC2 Trees, Woodlands and Hedgerows is supported.
SDC3 Landscape Character
National Trust supports Policy SDC3 Landscape Character.
SDC4 Biodiversity and Geodiversity
Policy SDC4 Biodiversity and Geodiversity is supported.
SDC5 Development within Conservation Areas
National Trust supports Policy SDC5. We request that the text 'views into or out of the area' is expanded slightly to include views 'within/across' the area.
SDC6 Development Affecting Listed Buildings
Policy SDC6 is generally supported but would benefit from minor rewording for clarity:
"Proposals for alterations to or changes of use of listed buildings (including its their settings) will be supported where they protect the significance of the heritage asset including impacts on the character, architectural merit or historic interest of the building.
Proposals should consider factors such as employ materials, layout, architectural features, scale and design that respond to and do not detract from the listed building.
Proposals which allow for viable uses that are compatible with the conservation of the fabric of the building and its setting will generally be supported."
SDC7 Scheduled Ancient Monuments and Archaeology
Policy SDC7 is supported.
SDC8 Registered Parks and Gardens
Policy SDC8 Registered Parks and Gardens is supported.
SDC9 Non-designated heritage assets
National Trust generally supports Policy SDC9. We request minor changes to the final paragraph for clarity:
"Proposals involving full or partial demolition of, or significant harm to a local heritage asset will be resisted unless sufficient justification is provided on the proposed scheme and its and the public benefits of the proposal to outweigh the harm caused by the loss of the asset."

ID1 Green Infrastructure
National Trust supports Policy ID1. In part (g) we suggest that the words 'and where appropriate' are unnecessary and should be removed.
ID4 Local Green Spaces
Policy ID4 Local Green Spaces is supported.
ID6 Sustainable Travel
Policy ID6 Sustainable Travel is supported.

Comment

Consultation Draft (February 2017)

Representation ID: 6183

Received: 06/04/2017

Respondent: John Church Planning Consultancy Limited

Representation Summary:

Questions raised over why the Council's green belt review is related mainly to around the fringe of Sheffield. Statement that opportunity for the minor reviews of the boundary was not taken.

Two sites identified: Land at Belmont Cottage, Holymoor Road, Chesterfield and; Land at Hillside, Barrack Road, Apperknowle.

Requests that these sites are released from the green belt and that the Settlement Development Limits be altered accordingly.

See submission or more.

Full text:

LAND AT BELMONT COTTAGE, HOLYMOOR ROAD, CHESTERFIELD AND AT HILLSIDE, BARRACK ROAD, APPERKNOWLE. (MY FILES N49 & H219)

Whilst the Council has undertaken a review of the North East Derbyshire Green Belt, this relates predominantly to major potential development sites around the fringe of the City of Sheffield. The opportunity has not been taken to carry out justified minor reviews of the boundary either to meet previous inconsistencies or to provide for a better definition of the boundary on a defensible basis.

These representations relate to two such examples:

1. Land at Belmont Cottage, Holymoor Road, Chesterfield and
2. Land at Hillside, Barrack Road, Apperknowle.

In the first case, the existing Green Belt boundary is drawn through a residential property. It should more properly follow the boundary of Belmont Cottage along the eastern side of Holymoor Road and then turn eastwards following the southern boundary of Chatsworth Road (A619) before returning along the ownership's eastern boundary to meet up with the existing northern boundary of the Settlement Development Limits for Holymoorside that are excluded from the Green Belt. The Settlement Development Limits should be extended accordingly so that, to that extent, these representations also constitute representation with regard to the delineation of Settlement Development Limits.

The second case relates to land within the curtilage of Hillside, Barrack Road, Apperknowle. The boundary of the Green Belt along the northern side of Town End provides for a "finger" of Green Belt extending into the built framework of the settlement to the south, south-west of the property that was once the Apperknowle Primary School. There is no justification on the ground for this boundary which should more logically follow the Green Belt boundary that runs to the north north-west of the former Apperknowle Primary School and Cedar Croft to meet with the existing boundary to the north of Town End. To the extent that the current Settlement Development Limits boundary is co-terminus with that of the Green Belt, these representations also represent a representation in respect of Settlement Development Limits.

It has always been held that, in order for Green Belt boundaries to provide permanence, which is a key feature of Green Belt designation, boundaries follow recognisable geographical/physical features on the ground. In both the above cases, the suggested slightly revised Green Belt boundary would follow such features. The objection is submitted on that basis and copies of plans showing the suggested revised boundaries will be forwarded under separate cover by E-Mail.

Comment

Consultation Draft (February 2017)

Representation ID: 6222

Received: 06/04/2017

Respondent: CPRE South Yorkshire & Friends of the Peak District

Representation Summary:

In terms of the rationale for that delineation, CPRE is broadly supportive of the policy. However, there is a very high risk that it will be ineffective, and must therefore be considered unsound. (see submission for more.)

Green Belt policy SS9 should provide for enhancement action plans to allow for the implementation of NPPF para 81.

In addition this commitment to enhancement should be extended to land designated as non-Green Belt countryside, settlement gaps and urban greenspaces, in order to assist in implementing policies SDC1 to SDC14 and ID1 to ID5; and to enable their sustainability functions to carry greater weight in decision-making.
.

Full text:

See attachment.

Object

Consultation Draft (February 2017)

Representation ID: 6299

Received: 07/04/2017

Respondent: Strata Homes Limited

Agent: DLP (Planning) Ltd - Sheffield office

Representation Summary:

Strata Homes Ltd objects to Policy SS9 and the designation of land off Harehill Road to the west of Walton Hospital as Green Belt. The respondent points out that this would be a very sustainable location and would not fulfil any of the functions of the Green Belt. If the site would not be allocated under Policy LC1 then the site should be allocated as safeguarded land.

Full text:

See attachment

Object

Consultation Draft (February 2017)

Representation ID: 6304

Received: 07/04/2017

Respondent: Mount St. Mary's College

Representation Summary:

Objection to the draft Local Plan's Green Belt Policy (Policy SS9) and the plan more widely as it fails, in our opinion, to identify the developed parts of the College as previously developed or Brownfield land in the Green Belt. Neither does it enable positive planning promoted by para.81 of the NPPF.

Statement that Local Plan identifies the College as a major developed site within the Green Belt and we feel that such major developed sites are dealt with by Policy GS3.

Full text:

Local Development Plan Current Consultation - February to April 2017

Mount St Mary's College's Objectives & Priorities
My name is Nicholas Cuddihy and today I write to you in my capacity as the CEO of the Mount Trust; a charitable trust established in 2006 to manage the property, resources and aspirations of Mount St Mary's College, Spinkhill and its prep School at Barlborough Hall.

The story of our schools dates back to 1620 when the Jesuits first became active in this park of the UK. In 1842 the Jesuit Provincial established Mount St Mary's College in Spinkhill. The school at Barlborough Hall first opened in 1939. The Mount Trust as we know it today was set up as a Local Trust in 2006 to manage Mount St Mary's College and Barlborough Hall School as co-educational inclusive day and boarding schools in the Jesuit tradition, providing children and their families with access to a seamless education from the ages of 3 to 18 yrs. We have long been significant members of the community in Spinkhill.

Our lands and facilities are shared openly and are enjoyed by many in the village and others all year round. Locals and visitors walk our lands freely and access the footpaths and bridleways at their leisure. Our Memorial Chapel frequently hosts concerts and special religious and other ceremonies. We have long established and successful partnerships with many sports clubs and other local groups who enjoy our sports fields, our public gym and other facilities. Every day and every week athletes, footballers, walkers and others come and go and enjoy our beautiful site. We see ourselves as residents of Spinkhill village and we take our responsibilities seriously in this regard. You can understand therefore how we were surprised to note that our school is not located within the settlement boundary in the proposed Local Development Plan. I will address this concern in more detail later but for now I wish to highlight this concern as I set out the context within which we wish to comment on elements of the draft Local development Plan.

During this year, 2017, we will celebrate the 175th Anniversary of the foundation of our schools. As we celebrate we are also concentrating our efforts on planning for our future. Our schools and lands are obviously hugely expensive to manage and maintain. Our heritage buildings and more modern facilities require ongoing investment. We have been a major employer in the area for more than a century and a half. We currently employ more than 170 people and as we look to the future we know we have to fight hard to survive and to thrive.

The Trust has ambitious plans for the College focusing on making improvements to its facilities and improve the extent and quality of facilities it provides to the public and local community. We are keenly aware that a significant and extended increase in income will be required to secure the long term stability of the school. As we master plan for the long term future of our schools we know we will need to devote significant funds to the maintenance and development of our buildings and lands. It is in this context that we welcome the opportunity to comment on the Draft Local Plan in this current consultation.

1. Green Belt Policies
Having reviewed the draft Plan's evidence base related to housing and growth we are pleased to see that part of the College's previously developed land has been included within the Housing Sites Assessment Report dated February 2017 (Appendix C), as 'Land off Station Road, Spinkhill'. That acknowledges the site as an 'infill site'

Nevertheless, having reviewed the draft Plan's policies map we also note that the entirety of the College's lands within the Spinkhill area is identified as Green Belt. From our understanding of national planning policy (within the National Planning Policy Framework (NPPF)), local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access, sport and recreation amongst other things (para.81). Brownfield land should be acknowledged within the Green Belt, reflecting the exceptions test within the (paragraph 89). The current Local Plan identifies the College as a major developed site within the Green Belt and we feel that such major developed sites are dealt with by Policy GS3.

We wish to therefore object to the draft Local Plan's Green Belt Policy (Policy SS9) and the plan more widely as it fails, in our opinion, to identify the developed parts of the College as previously developed or Brownfield land in the Green Belt. Neither does it enable positive planning promoted by para.81 of the NPPF.

2. Spinkhill Settlement Boundary
We would also like to take this opportunity as referred to earlier to raise our concerns regarding the Council's proposed settlement boundary for Spinkhill Village. The policies maps show that the College is not included within the settlement. We have reviewed the definition of a 'settlement' included in the glossary of the draft plan glossary and believe that the College should be included as part of the Spinkhill Settlement based on that definition. It has always been part of the village and has never been physically separate. For more than a century and a half we have played an important part in local life with leisure and recreation facilities available to the village. The village school was housed on our lands prior to its recent relocation across the road. The old Spinkhill railway station was also located on our land and accessed freely by all until it closed and the allotments which are enjoyed today by many villagers also lie on our land.

3. Housing
I note that the Council's most recent Annual Monitoring Report (AMR) (2015/16) identifies how between 2011 and 2015 the number of completions in the district has been below the Council's 300 dwellings per annum target each year. Between 2011 and 2016 the AMR notes a net undersupply of -484 dwellings for the period, and when the council includes projected completions for 2016/2017 this position worsens to-583 dwellings.

Policy SS2 states that the draft plan will make sufficient land available to accommodate a minimum of 6,600 dwellings during the Plan period (2011-2033). This figure equates to 300 dwellings per annum over the plan period and we understand that this is informed by the draft plan's 2013 Strategic Housing Market Area (SHMA) Assessment.

We note that the Council acknowledges that its approach to housing is to be reviewed and given that its Green Belt Review has established that land needs to be removed from the Green Belt, we propose that the College, as previously developed land in the Green Belt should be reconsidered to accommodate some housing capacity.

In conclusion and speaking more broadly we want to explore how we may be able to work together to succeed together. We would welcome an opportunity to engage with the Council proactively to see how specific education related policies could be included in the draft plan. This is particularly important to us as we look to the future. As we reach 175 years we are conscious of our need to develop and invest so that we can improve the educational and wider public facilities we own and provide to others. We have been a major employer and an important part of the life in Spinkhill for a long time. We want to preserve and develop that for today and for the future.

Additional Comments:

Policy SS£ & SS13:
Smaller settlements classified as "level 3" settlements in Table 4.1 can and should make a significant contribution to housing provision and this can help sustain community facilities. Limiting development in such villages to "limited infilling of one or two dwellings" is too restrictive.
In Spinkhill the land shown on the attached plan as Allotment area could make a significant contribution to housing need and the funds released by this development could help improve facilities at the Mount St Mary's College.

Policy SS9:
This policy only refers to dwellings for agriculture and forestry It should allow for "other occupational dwellings in the countryside"
The Green Belt is too tightly drawn around Spinkhill (see our comment on Appendix B - Green Belt Maps).

Policy LC3:
The limitations in this policy are too restrictive. Smarter homes and homes to provide employee accommodation, linked to established rural based employers should qualify as "affordable housing."

Policy LC7:
Although this policy is intended to include for "other occupational dwellings in the countryside" there is no such provision in the text. The policy only refers to dwellings for agriculture and forestry. This is a serious omission and requires correction. Mount St Mary's College is a rural based employer which will require employee's dwellings to be allowed for in this policy. In its present form this policy is inconsistent with Policy SS14 (b).

Policy SDC1:
This policy is too restrictive in that it only refers to buildings. It should refer to previously developed land. In its present form it is inconsistent with Policy SS14 (a) which refers to development being allowed on "vacant derelict or previously developed land." and SS9 (f).

Policy WC4:
The requirement that "any proposal (to be determined under this policy) will need to accord with other policies in this Plan is unrealistic and unnecessary as it's purpose is allow for an exception to other restrictive policies.

Policies Maps
We have the following comments on the Policies Maps.

The absence of a Map covering the whole of the District leaves a policy vacuum in regard to some areas as certain areas do not fall within any of the maps. This is the case in regard to Spinkhill only part of which is covered on the Renishaw Policies Map.

We attached a map of Spinkhill and request the following:-

- Area shown as Allotment area (on the attached plan) should be within the settlement limits and removed from the Green Belt. This wold allow for development of the land for housing and provide funding for improvement to the facilities at Mount St Mary's College.

- The area at Spinkhill identified as "GS3" in the existing Local Plan, comprising the building complex at Mount St Mary's College, should be within the settlement limits and removed from the Green Belt. It is clearly part of the settlement. This was previously shown as "major development in the Green Belt" which is illogical.

Comment

Consultation Draft (February 2017)

Representation ID: 6308

Received: 07/04/2017

Respondent: Mount St. Mary's College

Representation Summary:

This policy only refers to dwellings for agriculture and forestry It should allow for "other occupational dwellings in the countryside". Statement that the Green Belt is too tightly drawn around Spinkhill

Full text:

Local Development Plan Current Consultation - February to April 2017

Mount St Mary's College's Objectives & Priorities
My name is Nicholas Cuddihy and today I write to you in my capacity as the CEO of the Mount Trust; a charitable trust established in 2006 to manage the property, resources and aspirations of Mount St Mary's College, Spinkhill and its prep School at Barlborough Hall.

The story of our schools dates back to 1620 when the Jesuits first became active in this park of the UK. In 1842 the Jesuit Provincial established Mount St Mary's College in Spinkhill. The school at Barlborough Hall first opened in 1939. The Mount Trust as we know it today was set up as a Local Trust in 2006 to manage Mount St Mary's College and Barlborough Hall School as co-educational inclusive day and boarding schools in the Jesuit tradition, providing children and their families with access to a seamless education from the ages of 3 to 18 yrs. We have long been significant members of the community in Spinkhill.

Our lands and facilities are shared openly and are enjoyed by many in the village and others all year round. Locals and visitors walk our lands freely and access the footpaths and bridleways at their leisure. Our Memorial Chapel frequently hosts concerts and special religious and other ceremonies. We have long established and successful partnerships with many sports clubs and other local groups who enjoy our sports fields, our public gym and other facilities. Every day and every week athletes, footballers, walkers and others come and go and enjoy our beautiful site. We see ourselves as residents of Spinkhill village and we take our responsibilities seriously in this regard. You can understand therefore how we were surprised to note that our school is not located within the settlement boundary in the proposed Local Development Plan. I will address this concern in more detail later but for now I wish to highlight this concern as I set out the context within which we wish to comment on elements of the draft Local development Plan.

During this year, 2017, we will celebrate the 175th Anniversary of the foundation of our schools. As we celebrate we are also concentrating our efforts on planning for our future. Our schools and lands are obviously hugely expensive to manage and maintain. Our heritage buildings and more modern facilities require ongoing investment. We have been a major employer in the area for more than a century and a half. We currently employ more than 170 people and as we look to the future we know we have to fight hard to survive and to thrive.

The Trust has ambitious plans for the College focusing on making improvements to its facilities and improve the extent and quality of facilities it provides to the public and local community. We are keenly aware that a significant and extended increase in income will be required to secure the long term stability of the school. As we master plan for the long term future of our schools we know we will need to devote significant funds to the maintenance and development of our buildings and lands. It is in this context that we welcome the opportunity to comment on the Draft Local Plan in this current consultation.

1. Green Belt Policies
Having reviewed the draft Plan's evidence base related to housing and growth we are pleased to see that part of the College's previously developed land has been included within the Housing Sites Assessment Report dated February 2017 (Appendix C), as 'Land off Station Road, Spinkhill'. That acknowledges the site as an 'infill site'

Nevertheless, having reviewed the draft Plan's policies map we also note that the entirety of the College's lands within the Spinkhill area is identified as Green Belt. From our understanding of national planning policy (within the National Planning Policy Framework (NPPF)), local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access, sport and recreation amongst other things (para.81). Brownfield land should be acknowledged within the Green Belt, reflecting the exceptions test within the (paragraph 89). The current Local Plan identifies the College as a major developed site within the Green Belt and we feel that such major developed sites are dealt with by Policy GS3.

We wish to therefore object to the draft Local Plan's Green Belt Policy (Policy SS9) and the plan more widely as it fails, in our opinion, to identify the developed parts of the College as previously developed or Brownfield land in the Green Belt. Neither does it enable positive planning promoted by para.81 of the NPPF.

2. Spinkhill Settlement Boundary
We would also like to take this opportunity as referred to earlier to raise our concerns regarding the Council's proposed settlement boundary for Spinkhill Village. The policies maps show that the College is not included within the settlement. We have reviewed the definition of a 'settlement' included in the glossary of the draft plan glossary and believe that the College should be included as part of the Spinkhill Settlement based on that definition. It has always been part of the village and has never been physically separate. For more than a century and a half we have played an important part in local life with leisure and recreation facilities available to the village. The village school was housed on our lands prior to its recent relocation across the road. The old Spinkhill railway station was also located on our land and accessed freely by all until it closed and the allotments which are enjoyed today by many villagers also lie on our land.

3. Housing
I note that the Council's most recent Annual Monitoring Report (AMR) (2015/16) identifies how between 2011 and 2015 the number of completions in the district has been below the Council's 300 dwellings per annum target each year. Between 2011 and 2016 the AMR notes a net undersupply of -484 dwellings for the period, and when the council includes projected completions for 2016/2017 this position worsens to-583 dwellings.

Policy SS2 states that the draft plan will make sufficient land available to accommodate a minimum of 6,600 dwellings during the Plan period (2011-2033). This figure equates to 300 dwellings per annum over the plan period and we understand that this is informed by the draft plan's 2013 Strategic Housing Market Area (SHMA) Assessment.

We note that the Council acknowledges that its approach to housing is to be reviewed and given that its Green Belt Review has established that land needs to be removed from the Green Belt, we propose that the College, as previously developed land in the Green Belt should be reconsidered to accommodate some housing capacity.

In conclusion and speaking more broadly we want to explore how we may be able to work together to succeed together. We would welcome an opportunity to engage with the Council proactively to see how specific education related policies could be included in the draft plan. This is particularly important to us as we look to the future. As we reach 175 years we are conscious of our need to develop and invest so that we can improve the educational and wider public facilities we own and provide to others. We have been a major employer and an important part of the life in Spinkhill for a long time. We want to preserve and develop that for today and for the future.

Additional Comments:

Policy SS£ & SS13:
Smaller settlements classified as "level 3" settlements in Table 4.1 can and should make a significant contribution to housing provision and this can help sustain community facilities. Limiting development in such villages to "limited infilling of one or two dwellings" is too restrictive.
In Spinkhill the land shown on the attached plan as Allotment area could make a significant contribution to housing need and the funds released by this development could help improve facilities at the Mount St Mary's College.

Policy SS9:
This policy only refers to dwellings for agriculture and forestry It should allow for "other occupational dwellings in the countryside"
The Green Belt is too tightly drawn around Spinkhill (see our comment on Appendix B - Green Belt Maps).

Policy LC3:
The limitations in this policy are too restrictive. Smarter homes and homes to provide employee accommodation, linked to established rural based employers should qualify as "affordable housing."

Policy LC7:
Although this policy is intended to include for "other occupational dwellings in the countryside" there is no such provision in the text. The policy only refers to dwellings for agriculture and forestry. This is a serious omission and requires correction. Mount St Mary's College is a rural based employer which will require employee's dwellings to be allowed for in this policy. In its present form this policy is inconsistent with Policy SS14 (b).

Policy SDC1:
This policy is too restrictive in that it only refers to buildings. It should refer to previously developed land. In its present form it is inconsistent with Policy SS14 (a) which refers to development being allowed on "vacant derelict or previously developed land." and SS9 (f).

Policy WC4:
The requirement that "any proposal (to be determined under this policy) will need to accord with other policies in this Plan is unrealistic and unnecessary as it's purpose is allow for an exception to other restrictive policies.

Policies Maps
We have the following comments on the Policies Maps.

The absence of a Map covering the whole of the District leaves a policy vacuum in regard to some areas as certain areas do not fall within any of the maps. This is the case in regard to Spinkhill only part of which is covered on the Renishaw Policies Map.

We attached a map of Spinkhill and request the following:-

- Area shown as Allotment area (on the attached plan) should be within the settlement limits and removed from the Green Belt. This wold allow for development of the land for housing and provide funding for improvement to the facilities at Mount St Mary's College.

- The area at Spinkhill identified as "GS3" in the existing Local Plan, comprising the building complex at Mount St Mary's College, should be within the settlement limits and removed from the Green Belt. It is clearly part of the settlement. This was previously shown as "major development in the Green Belt" which is illogical.

Comment

Consultation Draft (February 2017)

Representation ID: 6382

Received: 07/04/2017

Respondent: Tracey Marsden, Nicola Shepherdson & Mark Woodhead

Agent: Caroline McIntyre

Representation Summary:

Policy SS9 'North East Derbyshire Green Belt': The wording of this policy with regards to the exceptions listed from (a) to (f) should reflect the wording of Paragraph 89 of the National Planning Policy Framework ("NPPF") (2012). At present the policy as drafted does not reflect the NPPF and the wording of some parts of the policy is unclear.

Full text:

SUMMARY
The site covers an area of land of circa 4.09 hectares and is located on the edge of Ridgeway, to the north of High Lane and to the west of Camdale Rise and Camdale View. Access to the site is from Camdale View through an existing gated entrance. The site was included within the Green Belt within the 2005 Local Plan.

The site is well located for both the Housing Market Area of NEDDC and Sheffield, and is available, suitable and achievable.

It is considered, for the reasons set out in the detailed representations below, that the assessment of the site has not had full regard to the site's close proximity to Sheffield and the potential this offers to meet any additional housing requirements through the Duty to Cooperate.

Furthermore the assessment of the site and the role it plays with regards to the purposes of the Green Belt has been based on a substantially larger parcel of land, which falls outside the ownership of our clients, and has not addressed the potential for the partial release of land within our clients' site

In summary it is considered that the site should be released either in full or in part from the Green Belt through the forthcoming review of Level 3 Settlement Boundaries, as noted within the Local Plan.


REPRESENTATIONS TO THE DRAFT NEDDC LOCAL PLAN

The following comments are made specifically with regards to the content of the draft Local Plan.

Duty to Cooperate and Further Housing Growth: The Plan refers at Paragraph 1.16 to the Duty to Cooperate and outlines that a Statement of Compliance with the Duty to Cooperate will be issued at the next stage of the Plan preparation.

Whilst it is acknowledged that the Localism Act 2011 and the Planning Practice Guidance1 require that this is demonstrated before the Plan is submitted for examination, the Committee Report on the NEDDC Local Plan from 5 August 20152 has identified this as a potential issue from the outset. The Committee Report stated with regards to the Duty to Cooperate that:

"Although no formal requests have so far been received which confirm any quantum or timescales, requests could be expected from both Derbyshire Dales District Council and Sheffield City Council. In order to provide a robust basis for assessing available capacity the Council would need to have undertaken a Green Belt review in order to demonstrate that all reasonable alternatives had been assessed."

The Green Belt Review (2017) also makes reference at Paragraph 2.10 to a 'reconciliation process' which will need to take place between NEDDC and Sheffield City Council ("SCC"). However no evidence that this has been undertaken is included within the Review or what the implications of this may be for the Plan.

Given the location of our clients' site on the northern periphery of the District and immediately adjacent to the boundary with SCC it is essential to understand at this early stage of the Plan preparation:
* the extent of discussions with SCC and the requirement for any additional housing to be delivered by NEDDC; and
* whether this could impact upon the spatial strategy as set out within the Plan at Policies SS1 and SS3.

Furthermore as outlined at Paragraph 4.22 of the draft Local Plan "The District Council's economic and Local Plan objectives also provide sufficient flexibility to accommodate changes, as the result of on-going work related to job growth and housing across the Sheffield City Region for example."

The Plan will need to remain flexible in order to respond to any increased housing need and our clients' site is well located to meet any housing growth to serve the needs of SCC should this be an issue which arises as the Plan progresses. At present it is not possible to see how the Plan will be sufficiently flexible to respond to these issues.

Relationship and Reliance upon Sheffield: At Paragraph 2.6 the character of the North Sub Area is noted, in particular the reference to the fact that "...The rural area lies entirely in the Green Belt and the towns and other settlements have generally been developed up to their boundaries, meaning that there is few development sites still available within their existing built up areas..." and that "These towns relate closely to the Sheffield conurbation and just under a quarter of people commute out of the District to work in the city."

This is reflected in the Local Plan Vision at Paragraph 3.4 where again the reference is to the objective to share in the economic benefits of the regeneration and sustainable growth of the wider Sheffield City Region.

District Wide Objective D12 'Sustainable Transport' makes reference to increasing the opportunities for travel using sustainable forms of transport by securing improvements to public transport, walking and cycling infrastructure particularly to maintain and improve connectivity with the main urban areas within the Sheffield City Region and to the south and east of the District.

Spatial Strategy: Within Policy SS3 'Spatial Strategy and Distribution of Development' and Tables 4.1 and 4.2 Ridgeway is defined within Table 4.1 as a Level 3 Settlement. This is one which has limited sustainability and places Ridgeway on a par with other more rural settlements. The Settlement Hierarchy Study (2016) places no weight on the location of Ridgeway on the edge of Sheffield and its proximity to a range of public transport links and facilities a short distance away in locations such as Mosborough, Gleadless, Birley, Frecheville and Hackenthorpe.

In the context of the support and relationship of the District with Sheffield, as outlined above, the approach in Policy SS3 and the Settlement Hierarchy Study (2016) is questioned in that there is little regard to the sustainability of settlements such as Ridgeway which are located closer to Sheffield and the potential for good accessibility to services, jobs and transport outside of the District.

Review of Boundaries to Level 3 Settlements: The Draft Local Plan states at Paragraph 4.80 that the review of smaller settlement boundaries is still to be undertaken.

Although Maps for two settlements - Cutthorpe and Holymoorside - are provided, there is no reference within the Draft Local Plan to the decision to release land within these settlements following the Green Belt Review. This is considered further below.

The decision not to allocate any sites or remove land from the Green Belt within the Level 3 Settlements at this stage of the Plan preparation, particularly where these are well located to the adjacent Authorities, does not provide the flexibility to respond to accommodate changes required through the Duty to Cooperate or the Sheffield City Region work (see Paragraphs 1.16 and 4.22 of the Local Plan).

Consideration should be given to the removal of land from the Green Belt as part of the review of smaller settlement boundaries, which is still to be undertaken. Alternatively, the scope of Policy SS10 'Safeguarded Land' should be extended to allow for greater flexibility for the Plan to respond to any future changes to without the need for a full Green Belt Review to be undertaken.

Housing Figures: The Housing Figures within the Plan appear to be based upon the 2013 Strategic Housing Market Area Assessment ("SHMA") and the sensitivity testing in 2014 and not on an updated assessment. This document is now four years out of date, and an updated Assessment should be completed as soon as possible to determine the more localised need for new housing. This will be an important consideration in the review of the boundaries to the Level 3 Settlements.

Policy SS9 'North East Derbyshire Green Belt': The wording of this policy with regards to the exceptions listed from (a) to (f) should reflect the wording of Paragraph 89 of the National Planning Policy Framework ("NPPF") (2012). At present the policy as drafted does not reflect the NPPF and the wording of some parts of the policy is unclear.

Policy SS14 'Development in the Countryside': As drafted it is considered that there is conflict between this Policy and Policy SS9 'North East Derbyshire Green Belt'. Any proposals on land which fall within both the Green Belt and also the Countryside would be covered by conflicting policy with regards to 'limited infill' development, with there being no support for such development proposals under Policy SS14.

Furthermore, there is more scope for development in Level 4 Settlements under Policy SS13 which would allow for development of 1 to 2 dwellings than there would be for Level 3 Settlements which would be more sustainable locations in terms of access to facilities and public transport.

The wording of Policy SS14 should be amended accordingly to make reference to infill development being acceptable where this meets the other objectives and considerations of Policy SS9.

Policy LC3 'Exception Sites for Affordable Housing': the continuation of an Exception Site policy is welcomed. However the reference to an element of market housing only being allowed on sites outside of the Green Belt is disappointing. The financial impetus from an element of market housing in order to deliver an affordable housing scheme on sites within the Green Belt is no different to the requirement on sites outside of the Green Belt.

Furthermore it is considered that the other policies within the NPPF and elsewhere within the draft Local Plan could be used to constrain the extent of any such proposals on the Green Belt as these would need to meet an identified local need and be assessed in terms of the acceptability of any impact on the Green Belt.

Policy LC3 should also be clarified as to how proposals for specialist housing would be considered within the Green Belt. It is considered that as an exception Green Belt land is often well located to deliver such accommodation, and again any such proposals would be considered against the other policies within the Plan.

Policy SDC5 'Development within Conservation Areas': The terminology used within this Policy does not reflect the approach set out within Section 12 of the NPPF. The wording of this policy should be amended accordingly to reflect the NPPF.

SUSTAINABILITY APPRAISAL (2017)

The Sustainability Appraisal ("SA") also acknowledges at Paragraph 6.4.3 that the SHMA is now somewhat out of date and is being updated, which may affect the housing targets within the Local Plan going forward.

Furthermore within the SA there is no assessment of the approach to focus on the larger settlements and not to provide any site allocation for Level 3 settlements. There are also no discussions regarding the assessment carried out under the Green Belt Review and the conclusions drawn from this process. These issues should be considered within the SA.

GREEN BELT REVIEW (FEB 2017)

Within this document our clients' site is included within the parcel of land assessed under RID/GB/002. This parcel of land included both their land at Camdale Rise (Ref ECK/2201) and a significant area of land to the west between the rear of the Settlement Boundary and the boundary with Sheffield City Council.

The overall conclusion on Parcel RID/GB/002 is that this scores 'Red' in an assessment against the Purposes 1 to 3 of the Green Belt by having a role in checking unrestricted sprawl, preventing neighbouring towns from merging into one another and assists in safeguarding the countryside from encroachment.

The 'Common Approach to Green Belt Review across the Sheffield City Region' (August 2014) was prepared to set out a cohesive approach across the region to the Green Belt review process. This outlines a staged approach which can be summarised as:

* Stage 1 - Identify general areas within the Green Belt
* Stage 2 - Technical site assessment
* Stage 3 - Re-appraisal of resultant land parcels.

The NEDDC Green Belt Review notes at Paragraph 2.10 that "Whilst Officers at Sheffield City Council acknowledged there were some differences between their approach and this Study, they accepted that these are not necessarily inconsistencies and merely reflect a slight difference of approach taken in reaching the same end point and are nevertheless in accordance with the SCR. In order to minimise any potential inconsistency with Sheffield's approach, the Study will undertake a 'reconciliation process' between Green Belt sites/parcels on either side of the Sheffield/NEDDC boundary, ensuring that conclusions are broadly comparable..."

Within the NEDDC Green Belt Review large parcels of land are considered, for example Parcel RID/GB/002 covers an area of 8.702 ha. However there does not appear to be any consideration of smaller elements within each parcel which may score different in terms of the purposes of the Green Belt and therefore may be suitable for removal without impacting on the overall objectives of the Green Belt in that location. The Review process therefore seems to be at odds with the detail of Stage 2 of the 'Common Approach to the Green Belt Review' document.

Furthermore, there is a lack of consistency in the approach to selecting parcels for assessment. Had the same approach been taken to our clients' site (along with land to the west) as that taken for Parcel HOLY/GB/024 within Holymoorside, which covered an area of 0.877ha, the conclusions regarding our clients' site ECK/2201 may have been different and the land closest to the existing built up area of the Settlement Boundary to Ridgeway would be scored differently to the land at the northern most edge of the overall Parcel of land being considered.

A detailed consideration of how the removal of our clients' site at Camdale Rise from the Green Belt would be considered against the five purposes of including land within the Green Belt was set out in the representations made in respect of this site on 23 December 2015. The detail of this has not been repeated as part of this submission, but the key points relating to the entire site are summarised below.

In addition in considering this site as a whole, without the additional land included under RID/GB/002, it may be that parts of the site ECK/2201 closest to the existing Settlement Boundary would have even less of an adverse impact on the purposes of the Green Belt in this location and removal from the Green Belt of these alone would be considered acceptable.

In summary site ECK/2201 can be considered as follows:

* Purpose 1 'To check the unrestricted sprawl of large built-up areas': The site is adjacent to the urban area of both land within Ridgeway falling in NEDDC and SCC. It is bounded by clear and strong change in the topography to the east, residential properties on Camdale View, Camdale Rise, Ribblesdale Drive and other residential properties to the south and south east. The site is adjacent to agricultural land to the north and west, but existing hedgerows and additional strong landscaped boundaries can be formed to further enhance the existing physical edge of the site, minimising any impact on the openness of the Green Belt. To the north beyond the furthest extents of the site is The Birley Wood Golf Club which forms a strategic gap to settlements on the edge of Sheffield, limiting the urban sprawl in this direction.

The existing boundary in this location is defined only by the extent of built development and there are no topographical or landscape features which reinforce this boundary.

It is therefore considered that new strong boundaries, and ones which are stronger than those currently in place could be established through the release of all or part of the site from the Green Belt. For these reasons it is considered that the application of a Red score for our clients' site on this point is incorrect.

* Purpose 2 'To prevent neighbouring towns merging into one another': The assessment has been carried out on the basis of the entire parcel of land at RID/GB/002, rather than any consideration of smaller elements within this. Furthermore, the existing residential area to the east, which falls within SCC, has a relationship with adjacent settlements of below the distances outlined as the criteria within the Review.

The removal of the ECK/2201 site from the Green Belt and its new boundaries would still prevent neighbouring towns merging into one another. The urban area of High Lane already merges with Quarry Hill and no physical gap currently exists between these settlements, with residential development forming a continuous line of development alongside the northern urban edge of the B6388.

It is not considered that the release of this site, in whole or part, will lead to the coalescence of settlements in this location given that a large gap will still exist between the northern edge of the site and the nearest settlement. The Birley Wood Golf Course is also located beyond White Lane which ensures the gap between settlements is maintained and will prevent any coalescence of settlements in this location.

* Purpose 3 'To assist in safeguarding the countryside from encroachment': Part of the overall site is already contained by the existing development to the south and east. The release of site ECK/2201 from the Green Belt may have minor impact on safeguarding the countryside from encroachment, but this needs to be considered in the context of the Council's need for Green Belt release to meet their housing requirement over the plan period and any need for additional housing which arises from the Duty to Cooperate.

Furthermore, the Housing Site assessment makes reference to the north western part of the site encroaching into the countryside. It is considered that should this be a barrier to the entire site being taken out of the Green Belt then the areas of the site closest to the Settlement Boundary should be considered without this peripheral part of the site.

* Purpose 4 'To preserve the setting and special character of historic towns': The conclusion within the Review is supported in that the release of the site from the Green Belt is unlikely to have any significant impact on the historical part of Ridgeway village.

* Purpose 5 'To assist in urban regeneration, by encouraging the recycling of derelict and other urban land': No comment is provided on this given the approach taken within the Review with regards to this purpose.

In summary it is requested that the Green Belt Review of Parcel RID/GB/002 be reconsidered with regards to the potential for the removal of smaller elements of the Parcel, forming all or part of Site ECK/2201, from the Green Belt. This would be on the grounds that the elements of Site ECK/2201 closer to the existing Settlement Boundary could be removed without having the same impact on the purposes of the Green Belt as those for the wider RID/GB/002 site.

Furthermore, the release of land within the location would help NEDDC have the flexibility to meet any housing which may come out of the updated SHMA and the Duty to Cooperate process.

Housing Sites Assessment Report (Feb 2017)

Within this document our clients' site is assessed under Ref ECK/2201 - Land at Camdale Rise. The whole of the site put forward has been assessed as a single proposal in its entirety and we maintain that the entire site remains available, suitable and achievable. However it is requested that the also Council review the option for the partial removal of the site from the Green Belt should it be that this would reduce the concerns outlined in the Assessment with regards to the Green Belt and countryside.

The assessment of the site is considered incorrect for the following reasons:

* Green Belt: The site is assessed in its entirety within the Green Belt Review under RID/GB/002. For the reasons set out above it is considered that this assessment does not consider the differences across the parcel and the assessment should be revisited, with regards to the potential to remove all or part of site ECK/2201 from the Green Belt.

* Access: The assessment states that 'No satisfactory access can be achieved, because the site has no frontage to an adopted highway. Third party land would be required.' This is incorrect. Access to the site can be obtained from the highway via the existing gated access from Camdale View which is in the control of our clients. This existing gate provides access to a made track across part of the site, already accessed by public utility authorities.

* Services: No acknowledgement is made of the proximity of Ridgeway and the site to Sheffield and the range of public transport and services within the wider area within Sheffield.

* Nature Conservation: Whilst the site boundary included as part of the original Call for Sites submission does include an area of woodland, this forms part of the boundary to the site. This area could be excluded from any area removed from the Green Belt.

* Achievability: The site does not require third party land for access. This should be amended.

In summary, for the reasons outlined above it is considered that the conclusion not to consider Site ECK/2201 further as a Housing site is based on an incorrect assessment of the site and should be revisited.

SETTLEMENT HIERARCHY STUDY (2016)

As outlined above, our client is concerned that the assessment carried out under this document does not given any weight to the location of Ridgeway, and in particular High Lane, on the edge of Sheffield and its proximity to a range of public transport links and facilities a short distance away in Mosborough, Gleadless, Birley, Frecheville and Hackenthorpe.

The draft Local Plan notes the heavy reliance on Sheffield for employment and outlines objectives within the Plan to maximise on the relationship with Sheffield and the Sheffield City Region as a whole.

It is therefore considered that greater weight should be afforded to Ridgeway as a sustainable location that could deliver housing which is well located to Sheffield.

SUMMARY

In summary it is considered that the site remains available, suitable and achievable and should be released from the Green Belt to meet the district's housing needs over the plan period.

We would therefore urge the Council to review the draft Local Plan and Evidence Base documents in the light of the above submission and consider the removal of all or part of our clients' site from the Green Belt as part of the review of Level 3 Settlement Boundaries which is still to be undertaken at the next stage of the Local Plan process.

Support

Consultation Draft (February 2017)

Representation ID: 6407

Received: 07/04/2017

Respondent: Mr Paul Stock

Representation Summary:

In response to and for the reasons set out in our previous representations to the Draft Local Plan (Part 1) we welcome and fully support the fact that the Council has now undertaken a review of the Green Belt in the District since the last iteration of the Local Plan. In this regard we endorse the Council's thinking on this matter as set out in paragraphs 4.63 to 4.66 in the consultation draft Local Plan.

Full text:

Response and Representations to the Consultation Draft Local Plan (2011-33) for North East Derbyshire District Council

INTRODUCTION
1. The National Planning Policy context has evolved greatly since the adoption of the North East Derbyshire Local Plan. The North East Derbyshire Development Plan must now be found to be in compliance with the policies of the National Planning Policy Framework (the Framework) to be considered sound at Examination. Should policies in the North East Derbyshire Development Plan be found to be in conflict with the Framework then a presumption in favour sustainable development will apply when considering site allocations and applications for planning permission. The Council must ensure that both the emerging Development Plan documents are consistent with national policy.

CONSULTATION DRAFT LOCAL PLAN
2. This section deals with our responses to the consultation draft Local Plan for North East Derbyshire and sets out our detailed representations on specific local plan policies and proposed allocations.

Policy SS2 - Scale of Development.
3. The consultation draft Local Plan confirms the Council's view that the Plan should provide for a local housing target of 6,600 dwellings between 2011 and 2033 (300dpa).
4. We believe that the decision taken by the Council not to review the housing requirement has been made without sufficient regard to the requirements and guidance provided by national policy and practice guidance as cited above. It is not reasonable to conclude that housing needs are no higher than adopted by referencing household projections alone. The Council must also consider wider issues such as market signals, affordable and economic needs. The Gallagher Judgement highlights the importance of undertaking the exercise of undertaking a full assessment of housing needs, outlining that the balancing exercise cannot be performed without being informed by the actual full housing need.
5. The importance of ensuring housing needs data that informs the housing requirement is kept up-to-date is demonstrated by the examination of the Harrogate Allocations DPD. Following the hearings the Inspector wrote to the Council and outlined that the lack of an assessment of how up-to-date housing needs could be met within the Borough meant that it was not possible to determine whether the footnote 9 of S14 of the Framework had been met. The Plan was ultimately withdrawn.
6. The balancing of housing and employment strategies is critical in securing economic development and sustainable growth. Delivering an insufficient level of housing in an Authority in support of identified economic needs may lead to an increase in unsustainable commuting patterns or stifle growth prospects due to the lack of a sufficient local labour resource. The balancing of the supply of housing in consideration of economic needs is clearly set out as a key consideration in Plan making by S21 and S158 of the Framework.
7. We consider it is also material that the Council has thus far failed to deliver the planned requirement. This would suggest that North East Derbyshire as an authority is a persistent under deliverer and therefore should apply a 20% buffer to the five year housing requirement (as required by S49 of the Framework).
8. In context of the above findings it is clear the Council must undertake a thorough review with the aim of accommodating identified up-to-date housing needs in order to secure the full delivery of the Plan.

Policy SS9 - Green Belt.
9. In response to and for the reasons set out in our previous representations to the Draft Local Plan (Part 1) we welcome and fully support the fact that the Council has now undertaken a review of the Green Belt in the District since the last iteration of the Local Plan. In this regard we endorse the Council's thinking on this matter as set out in paragraphs 4.63 to 4.66 in the consultation draft Local Plan.

Appendix B: Areas to be Removed from Green Belt - Renishaw.
10. We fully support the proposal by the Council to remove the land hatched in green from the Green Belt as shown on the Renishaw Green Belt Plan, a copy of which is set out below:
11. The National Planning Policy Framework is clear in S85 that with regards to the Green Belt local authorities should:
a. Ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development;
b. Not include land which is unnecessary to keep permanently open;
c. Define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
12. We believe the proposal by the consultation draft Local Plan to release land from the Green Belt and allocate it for housing development helps in removing a serious question on the ability of the Local Plan to provide the increased need for new housing especially in places where it is most needed in market terms such as Renishaw. In the absence of such a new policy it would have brought into doubt the soundness of the Plan when examined.
13. We contend the release of the land described as to the north east of Hague Lane, Renishaw from the Green Belt is consistent with the Framework. The proposed site is already enclosed on three sides by existing development.
14. The proposed site does not play a role in preventing coalescence. The site is bounded by clear, defensible features preventing coalescence and urban sprawl.
15. The proposed site represents a release of Green Belt land that is entirely consistent with S85 of the National Planning Policy Framework.

Policy SS3: Spatial Strategy & the Distribution of Development.
16. We fully support the proposal set out in the Table 4.2 accompanying Policy SS3 (Housing Provision 2011-2033) to allocate 270 dwellings at Renishaw which is classified as a Level 2 Settlement (Large Village).

Policy LC1: Housing Allocations.
17. We support the proposal set out under Renishaw (ai) in the Table accompanying Policy LC1 to allocate at least 270 dwellings on land described as to the north east of Hague Lane.
18. We consider the site represents a logical and appropriate location for development. The site adjoins to the south of the existing settlement boundary of Renishaw and is contained and enclosed on three sides by existing residential development.
19. Given Renishaw is a third tier large village in the settlement hierarchy we believe it can easily accommodate the proposed number dwellings due to its sustainability and viability. This is further reinforced when consideration is given to the desperate demand for market and affordable housing in this location.
20. The proposed housing allocation is well located in relation to existing services and facilities in the large settlement of Renishaw. The primary school, local doctor's surgery, food shops, public house and Post office are all located within easy walking distance from the site. The site is directly served by several bus services (No: 71, 73, 74, 131 and 231), providing access to wider services and sources of employment. The site accords with the principles of sustainable development.
21. The development would deliver up to 30% affordable dwellings, promoting policy compliant tenure mix. The site would provide for new formal/informal open space including an equipped child's play area for the enjoyment and use of both existing and prospective residents.
22. The proposed housing allocation is available, deliverable and achievable now. There are no physical constraints in bringing the site forward for development. It is able to contribute to meeting the growth needs of the District now, and able to deliver housing within the next five years. The landowners are committed to delivering a high quality residential scheme on the site. The development will not affect the setting of the village, and the boundaries will be sensitivity planted to soften the urban edge of the development. We believe the site can be sympathetically developed through sensitive master planning that anchors it into the landscape and builds on the existing good accessibility to the facilities at the centre of the settlement.

Policy SS3 - The Avenue.
23. We consider Plan still places an over reliance on the Avenue site to deliver 710 new dwellings during the Plan period. It is known the site has major issues in terms of ground contamination. This is extremely likely to prevent it from being able to deliver any meaningful number of new dwellings particularly in the first 5-years of the Plan period. The site was a major allocation in the previous Local Plan and delivered no new dwellings in that plan period. Given the legacy of extensive contamination and uncertainty over the trajectory of delivery the proposed housing allocation on the Avenue site should be deleted from the consultation draft Local Plan.

Policy SS3 - Biwater.
24. Again we consider the consultation draft Local Plan still places an over reliance on the Biwater site to deliver 560 new dwellings during the Plan period. The site is unlikely to deliver any meaningful number of new dwellings particularly in the first 5-years of the Plan period. The site was a major allocation in the previous Local Plan and delivered a limited number of new dwellings. Due to serious concerns over the trajectory of housing delivery for the Biwater site the proposed figure should be drastically reduced.

CONCLUSIONS
25. In conclusion we fully support:
a. the fact that the Council has now undertaken a review of the Green Belt in the District since the last iteration of the Local Plan.
b. the proposal by the Council to remove the land hatched in green from the Green Belt as shown on the Renishaw Green Belt Plan in the consultation draft Local Plan, a copy of which is set out in this representation.
c. the proposal set out in the Table 4.2 accompanying Policy SS3 (Housing Provision 2011-2033) in the consultation draft Local Plan to allocate 270 dwellings at Renishaw which is classified as a Level 2 Settlement (Large Village).
d. the proposal set out under Renishaw (ai) in the Table accompanying Policy LC1 in the consultation draft Local Plan to allocate at least 270 dwellings on land described as to the north east of Hague Lane and shown in the plan set out in this representation.

Comment

Consultation Draft (February 2017)

Representation ID: 6441

Received: 07/04/2017

Respondent: Mr & Mrs N Beecroft

Agent: Caroline McIntyre

Representation Summary:

Policy SS9 'North East Derbyshire Green Belt': The wording of this policy with regards to the exceptions listed from (a) to (f) should reflect the wording of Paragraph 89 of the National Planning Policy Framework ("NPPF") (2012). At present the policy as drafted does not reflect the NPPF and the wording of some parts of the policy is unclear.

Full text:

This representation relates to land to the west of the Millstone, Wadshelf (Ref BRAM/2301) and should be read alongside submissions made previously in respect of this site at the Call for Sites stage in January 2016.

The Site

The Site is located on the western side of the village of Wadshelf and sits adjacent to the Settlement Development Limits for Wadshelf, as identified on the Local Plan Proposals Map (2005). The Millstone, and White House beyond this, to the east of the Site fall within the Settlement Development Limits for the village.

The Site is bounded to the east by the Millstone and the White House, which is separated from the Site by the drive to the Millstone. To the south is Main Road and beyond this a number of farm and residential dwellings. To the west is the Village Hall and village play area, and beyond this further housing to the junction with Baslow Road. Despite the role of the Village Hall within village life, this does peculiarly fall outside of the Defined Settlement Boundary. To the north is agricultural land which slopes up in gradient away from the Site.

The Site is low grade agricultural grazing land and is currently unused. An existing power line crosses the Site.

Given the Site's position and relationship with both the village of Wadshelf and key village facilities we consider that its inclusion within the Green Belt and exclusion from the Settlement Development Limits of Wadshelf - along with the properties to the west of the site - is an anomaly.

We consider that the Site is available, suitable and achievable for housing and as part of the review of the settlement boundaries there is a strong case to exclude the Site from the Green Belt. We set out our justification for this below.

REPRESENTATIONS TO THE DRAFT NEDDC LOCAL PLAN

The following comments are made specifically with regards to the content of the draft Local Plan.

Housing Need: Review of Boundaries to Level 3 Settlements: Within Policy SS3 'Spatial Strategy and Distribution of Development' and Tables 4.1 and 4.2 Wadshelf is defined within Table 4.1 as a Level 3 Settlement.

The Draft Local Plan states at Paragraph 4.80 that the review of smaller settlement boundaries which is still to be undertaken. Therefore there has been no review of the boundaries of most Level 3 settlements as part of the current draft Plan.
The Plan has been prepared on the basis of the 2013 Strategic Housing Market Area Assessment ("SHMA") and the sensitivity testing in 2014 and not on an updated assessment. This document is now four years out of date, and an updated Assessment should be completed as soon as possible to determine the more localised need for new housing. This will be an important consideration in the review of the boundaries to the Level 3 Settlements.

Furthermore, the previous draft 2011 - 2031 Local Plan Part 1 Initial Draft (February 2015), which was informed by the Evidence Base, outlined that there was a need for 5 new dwellings in Wadshelf over the plan period. It is noted within the document that this figure was limited due to the lack of Sites available within the Settlement Development Limit and the Green Belt designation around the village. It is assumed that this need will be reassessed in the light of the revised Local Plan SHMA and updated housing targets process.

Although it is noted that Maps for two settlements, Cutthorpe and Holymoorside, are provided but there is no reference to these within the Draft Local Plan. As discussed below, it is considered that our clients' site, along with the land to the west, is not materially different to the area of land proposed for removal from the Green Belt at Holymoorside (Ref HOLY/GB/024). This area of land to the west of Wadshelf contains the Village Hall and playground and further existing housing as well as our clients site and forms part of the village.

Consideration should be given to the removal of this land from the Green Belt as part of the review of smaller settlement boundaries, which is still to be undertaken.

Policy SS9 'North East Derbyshire Green Belt': The wording of this policy with regards to the exceptions listed from (a) to (f) should reflect the wording of Paragraph 89 of the National Planning Policy Framework ("NPPF") (2012). At present the policy as drafted does not reflect the NPPF and the wording of some parts of the policy is unclear.

Policy SS14 'Development in the Countryside': As drafted it is considered that there is conflict between this Policy and Policy SS9 'North East Derbyshire Green Belt'. Any proposals on land which falls within both the Green Belt and also the Countryside would be covered by conflicting policy with regards to 'limited infill' development, with there being no support for such development proposals under Policy SS14.

Furthermore, there is more scope for development in Level 4 Settlements under Policy SS13 which would allow for development of 1 to 2 dwellings than there would be for Level 3 Settlements which would be more sustainable locations in terms of access to facilities and public transport.

The wording of Policy SS14 should be amended accordingly to make reference to infill development being acceptable where this meets the other objectives and considerations of Policy SS9.

Policy LC3 'Exception Sites for Affordable Housing': the continuation of an Exception Site policy is welcomed. However the reference to an element of market housing only being allowed on sites outside of the Green Belt is disappointing. The financial impetus from an element of market housing in order to deliver an affordable housing scheme on sites within the Green Belt is no different to the requirement on site outside of the Green Belt.

Furthermore it is considered that the other policies within the NPPF and elsewhere within the draft Local Plan could be used to constrain the extent of any such proposals on the Green Belt as these would need to meet an identified local need and be assessed in terms of the acceptability of any impact on the Green Belt.

Policy LC3 should also be clarified as to how proposals for specialist housing would be considered within the Green Belt. It is considered that as an exception Green Belt land is often well located to deliver such accommodation, and again any such proposals would be considered against the other policies within the Plan.

Policy SDC5 'Development within Conservation Areas': The terminology used within this Policy does not reflect the approach set out within Section 12 of the NPPF. The wording of this policy should be amended accordingly to reflect the NPPF.

SUSTAINABILITY APPRAISAL (2017)

The Sustainability Appraisal ("SA") also acknowledges at Paragraph 6.4.3 that the SHMA is now some what out of date and is being updated which may affect the housing targets within the Local Plan going forward.

Furthermore within the SA there is no assessment of the approach to focus on the larger settlements and not to provide any site allocation for Level 3 settlements. There are also no discussions regarding the assessment carried out under the Green Belt Review and the conclusions drawn from this process. These issues should be considered within the SA.

GREEN BELT REVIEW (FEB 2017)

Within this document our clients' site is included within the parcel of land assessed under WAD/GB/006. This parcel of land included both their land at land to the West of the Millstones (BRAM/2301) and a significant area of land to the north, north east and north west.

The overall conclusion on Parcel WAD/GB/006 is that this scores 'Red' in an assessment against the Purposes 1 and 3 of the Green Belt by checking unrestricted sprawl and assists in safeguarding the countryside from encroachment.

The 'Common Approach to Green Belt Review across the Sheffield City Region' (August 2014) was prepared to set out a cohesive approach across the region to the Green Belt review process. This outlines a staged approach which can be summarised as:

* Stage 1 - Identify general areas within the Green Belt
* Stage 2 - Technical site assessment
* Stage 3 - Re-appraisal of resultant land parcels.

Within the NEDDC Green Belt Review large parcels of land are generally considered, for example Parcel WAD/GB/006 covers an area of 2.4 ha. However there does not appear to be any general consideration of smaller elements within each parcel which may score different in terms of the purposes of the Green Belt and therefore may be suitable for removal without impacting on the overall objectives of the Green Belt in that location. The Review process therefore seems to be at odds with the detail of Stage 2 of the 'Common Approach to the Green Belt Review' document.

Furthermore, there is a lack of consistency in the approach to selecting parcels for assessment. Had the same approach been taken to our clients site (along with land to the west) as that taken for Parcel HOLY/GB/024 within Holymoorside, which covered an area of 0.877ha, the conclusions regarding BRAM/2301 may have been different.

In summary within a more localised assessment of BRAM/2301 the site can be considered as follows:

* Purpose 1 'To check the unrestricted sprawl of large built-up areas': Wadshelf is a remote, freestanding rural settlement and is not in close proximity to other settlements. The village of Wadshelf already extends beyond the Settlement Development Limits to the west of the current boundary. The removal of the Site from the Green Belt would not result in the sprawl of Wadshelf, as a number of existing dwellings and community facilities are already located to the west of the village, and to the west of the Site, outside of the Settlement Development Limits.

* Purpose 2 'To prevent neighbouring towns merging into one another': No comment as the Green Belt Review scored this a 'Green'.

* Purpose 3 'To assist in safeguarding the countryside from encroachment': As stated above, the existing settlement of Wadshelf already extends to the west of the Site, outside of the Settlement Development Limits for the village. The northern edge of the Site has a strong boundary and the elevation of the land to the rear of the Site would reduce any visual impact of the proposals. The removal of the Site from the Green Belt, and its inclusion within the Settlement Development Limits, and any subsequent development on this Site would not pose a significant or unacceptable threat to the countryside.

The consideration under 3a should not be afforded any weight when the percentage of an area selected it entirely related to the area selected in the first place. Had the land at Wadshelf which forms part of the village, but falls outside the Settlement Boundary, been considered in the same way the site at Holymoorside was then the percentage of the site covered by development would have been significantly higher.

* Purpose 4 'To preserve the setting and special character of historic towns': Although recorded as an Amber score, it is considered that the Conservation Area boundary for Wadshelf covers a larger area than the Settlement Development Limits, and as such any considerations regarding the setting of Wadshelf would remain governed by the relevant heritage policies. Furthermore, any development on the Site would not dilute the character of the settlement as a small agricultural settlement.

* Purpose 5 'To assist in urban regeneration, by encouraging the recycling of derelict and other urban land': No comment is provided on this given the approach taken within the Review with regards to this purpose.

The Green Belt Review Part 1 identifies that based on a range of Growth Scenarios, ranging from A to C, that in order to maintain the vitality and viability of smaller settlements through further small scale development Wadshelf would need to deliver between 7 and 23 dwellings over the Plan period.

However the review process concludes that for Wadshelf and a number of other settlements:

"There are no sites identified which are suitable for release which could accommodate the housing requirements of these settlements. As such, the housing need identified under Scenarios A, B and C would have to be accommodated in nearby settlements or alternative options set out in the Part 1 Report considered."

Had our clients' site been considered using the same approach adopted for HOLY/GB/024 then the conclusions with regards to Wadshelf within the Review may well have been different.

Therefore, in summary it is requested that the Green Belt Review of Site BRAM/2301, forming a Parcel along with land to the west of the site which functionally falls within the village of Wadshelf, be reconsidered on the same grounds as the approach taken to Parcel HOLY/GB/024.

It is considered that the release of this land from the Green Belt would regularise the position within with regards to the extent of the village and the Green Belt boundary. Furthermore the release of any land from the Green Belt forming part of this smaller parcel of land would largely relate to existing dwellings, the Village Hall and playground and with a limited opportunity for new development.

Housing Sites Assessment Report (Feb 2017)

Within this document our clients' site is assessed under Ref BRAM/2301 - Millstone, Wadshelf.

The assessment of the site is considered incorrect for the following reasons:

* Green Belt: for the reasons set out above, it is considered that there has been no consistency with the site selection process when considering parcels of land within the Green Belt Review. As a result the negative conclusion regarding parcel WAD/GB/006 works against the assessment of our client's site.

* Access: Whilst the site does not currently have access from the highway, access could be created using the same principles applied to developments to the east and west of the site. it is therefore considered that this is not an issue in respect of this site.

* Design: The policy conclusions with regards to the Conservation Area and design appears to take a more negative view than the comments elsewhere within the document. These note that "If any development of the site would be sought then it should be delivered with good design and low density." This could be achieved and a scheme sensitively designed to have regard to the views of the site and the conservation area. It is therefore considered that the policy conclusion is overly negative with respect of this issue.

* TPOS: The TPOs referred to within the Policy Conclusions relate to land which falls outside of the land being considered. Whilst they may be a consideration in terms of any future proposals for the site, in their own right they are not a constraint to the development of Site BRAM/2301.

* Services: Wadshelf scores the same as Cutthorpe within the Settlement Hierarchy Study (2016) and yet the decision has been taken to remove an area of land from the Green Belt within Cutthorpe which is largely covered by built development and forms part of the existing settlement (Ref CUT/GB/003 and Housing Study BRAM/2401). Whilst it is acknowledged that the removal of this site has resulted from the Green Belt Review rather than the Housing Sites Assessment, it is clear that the removal of sites from the Green Belt within other Level 3 settlements is being progressed within the draft Local Plan.

In summary, for the reasons outlined above the conclusion not to consider Site BRAM/2301 further as a Housing site is based on an incorrect assessment of the site and should be revisited.

SUMMARY

In summary it is considered that the site remains available, suitable and achievable and should be released from the Green Belt to the district's housing needs over the plan period. Furthermore the removal of our clients site would ensure that the approach taken to Wadshelf is consistent with that taken in Holymoorside and Cutthorpe.

We would therefore urge the Council to review the draft Local Plan and Evidence Base documents in the light of the above submission and consider the removal of our clients' site from the Green Belt as part of the review of Level 3 Settlement Boundaries which is still to be undertaken at the next stage of the Local Plan process.

Object

Consultation Draft (February 2017)

Representation ID: 6597

Received: 07/04/2017

Respondent: Mr Grey

Agent: Roger Yarwood Planning Consultant Ltd

Representation Summary:

Mr Grey points out that Policy SS9 refers to the Green Belt "as shown on the Policies Maps" but there are no such maps covering much of the District. This is a major deficiency and calls into question the validity of the consultation. The review of the Green Belt cannot be assessed in the absence of a policy map showing its extent. However, it seems clear that, the review has not been sufficiently robust or comprehensive.

Full text:

See attachment

Object

Consultation Draft (February 2017)

Representation ID: 6687

Received: 07/04/2017

Respondent: Mr Perez

Agent: Roger Yarwood Planning Consultant Ltd

Representation Summary:

Mr Perez objects to Policy SS9 and wishes that the Land adjacent to Spring House should be removed from the Green Belt. The policy would refer to the Green Belt "as shown on the Policies Maps" but there would be no such maps covering much of the District. This would be a major deficiency and calls into question the validity of the consultation. The review of the Green Belt cannot be assessed in the absence of a policy map showing its extent. However, it seems clear that, the review has not been sufficiently robust or comprehensive.

Full text:

See attachment