North East Derbyshire Local Plan

Showing comments and forms 1 to 12 of 12

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6917

Received: 10/03/2018

Respondent: Mrs Jane Singleton

Representation:

Council officers have amended the summary to approximately 100 words:
This Plan was presented at the Dronfield consultation in February 2017 as a fait accompli by Councillor Michael Gordon and Senior Planner Philip Tschavoll-Selenko. The consultation process had only just begun.
At 264 pages the Plan was too long and too complicated, with planning jargon and opaque language and therefore was exclusive to a proportion of the community, high level analytical skills are required. This is contrary to the principles of the Statement of Community Involvement.
The length or complexity of the Publication Draft Version has not been changed. It represents a muddle of policies and objectives, with no cohesion or understanding of how these work together. Changes have not been made in light of the results from the consultation where only 14% of respondents supported it and the majority of responses, (76%) were about the Green Belt and Dronfield.

Full text:

Rep refers to paragraph 1.10
This Plan was presented at the Dronfield consultation in February 2017 as a fait accompli by Councillor Michael Gordon and Senior Planner Philip Tschavoll-Selenko. The consultation process had only just begun.
At 264 pages the Plan was too long and too complicated, being peppered with planning jargon and opaque language and therefore was exclusive to a proportion of the community. To make much sense of it required high level analytical skills. This is contrary to the principles set out in the Statement of Community Involvement to use plain English.
Little has been done to reduce the length or complexity of the Publication Draft Version. It represents a muddle of policies and objectives and there is no cohesion or understanding of how these work together. Neither have changes been made in the light of the results from the consultation where only 14% of respondents supported it and the majority of responses, (76%) were about the Green Belt and Dronfield.
The Publication Draft which in strategy is the same as the previous version but with another name, is evidence of the fait accompli presentation of the Plan in February 2017. Whilst popularity is not a test of soundness, there clear evidence that the results of the consultation have not been taken into account.
The Local Plan Steering Group headed by Councillor Michael Gordon, was set on driving this through pretty much at all costs with a 'better to have a bad plan than no plan' approach. It has been put together under time pressure, with threat of intervention by Planning Inspectors and in the knowledge that NE Derbyshire was named as one of fifteen authorities not to have a Plan in place since pre 2011.

Compare chapter headings of Chesterfield Borough Council Plan and NE. Chesterfield has: Homes and Housing, Jobs, Centres and Facilities, Travel and Transport.
NE has Living Communities, Working Communities and Economic Development, Sustainable Development and Communities. Straight away it is obvious which Plan will be clearer.
It is weak on policy. There should be a chapter devoted to issues like Addressing Climate Change. Instead this important issue is watered down within other chapters.
The NE Derbyshire Plan contains waffle and is a ramble about what things mean, what the Council should be doing and what Government policy states about planning. It is not a Plan at all; just a document about planning generally.
Supporting documents are attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6976

Received: 14/03/2018

Respondent: Neil Ashby-Senior

Representation:

Council Officers have amended the summary to approximately 100 words. Full representation attached.

Para 1.1
This Plan was presented at the Dronfield consultation in February 2017 as a fait accompli by Councillor Michael Gordon and Senior Planner Philip Tschavoll-Selenko. The consultation process had only just begun.
At 264 pages the Plan was too long and too complicated, with planning jargon and opaque language and therefore was exclusive to a proportion of the community, high level analytical skills are required. This is contrary to the principles of the Statement of Community Involvement.
The length or complexity of the Publication Draft Version has not been changed. It represents a muddle of policies and objectives, with no cohesion or understanding of how these work together. Changes have not been made in light of the results from the consultation where only 14% of respondents supported it and the majority of responses, (76%) were about the Green Belt and Dronfield.

Full text:

Para 1.1
This Plan was presented at the Dronfield consultation in February 2017 as a fait accompli by Councillor Michael Gordon and Senior Planner Philip Tschavoll-Selenko. The consultation process had only just begun.
At 264 pages the Plan was too long and too complicated, being peppered with planning jargon and opaque language and therefore was exclusive to a proportion of the community. To make much sense of it required high level analytical skills. This is contrary to the principles set out in the Statement of Community Involvement to use plain English.
Little has been done to reduce the length or complexity of the Publication Draft Version. It represents a muddle of policies and objectives and there is no cohesion or understanding of how these work together. Neither have changes been made in the light of the results from the consultation where only 14% of respondents supported it and the majority of responses, (76%) were about the Green Belt and Dronfield.
The Publication Draft which in strategy is the same as the previous version but with another name, is evidence of the fait accompli presentation of the Plan in February 2017. Whilst popularity is not a test of soundness, there clear evidence that the results of the consultation have not been taken into account.
The Local Plan Steering Group headed by Councillor Michael Gordon, was set on driving this through pretty much at all costs with a 'better to have a bad plan than no plan' approach. It has been put together under time pressure, with threat of intervention by Planning Inspectors and in the knowledge that NE Derbyshire was named as one of fifteen authorities not to have a Plan in place since pre 2011.

Compare chapter headings of Chesterfield Borough Council Plan and NE. Chesterfield has: Homes and Housing, Jobs, Centres and Facilities, Travel and Transport.
NE has Living Communities, Working Communities and Economic Development, Sustainable Development and Communities. Straight away it is obvious which Plan will be clearer.
It is weak on policy. There should be a chapter devoted to issues like Addressing Climate Change. Instead this important issue is watered down within other chapters.
The NE Derbyshire Plan contains waffle and is a ramble about what things mean, what the Council should be doing and what Government policy states about planning. It is not a Plan at all; just a document about planning generally.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7106

Received: 28/03/2018

Respondent: Mrs Sylvia Taylor

Representation:

I object to the proposed number of houses that are planned to be built on the "green belt area" on Eckington Road Coal Aston. I feel 200 is far too many as this number of houses will have a great detremental effect as far as extra traffic is concerned along this very busy road. Also loss of our Green Belt would be a tragedy. Surely number of houses could be reduced thus not encroaching too much on the "Green Belt. Have other "Brown site" areas been considered thus incorporating number of houses within Coal Aston itself.

Full text:

I object to the proposed number of houses that are planned to be built on the "green belt area" on Eckington Road Coal Aston. I feel 200 is far too many as this number of houses will have a great detremental effect as far as extra traffic is concerned along this very busy road. Also loss of our Green Belt would be a tragedy. Surely number of houses could be reduced thus not encroaching too much on the "Green Belt. Have other "Brown site" areas been considered thus incorporating number of houses within Coal Aston itself.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7202

Received: 01/04/2018

Respondent: Mrs Julie Farrell

Representation:

I feel there are no exceptional circumstances for green belt release, all other options have not been looked into.
Brown field sites and vacant homes can be used. There is a risk of merging areas into one as existing narrow gaps between settlements is swallowed up. There are more houses allocated than needed in Dronfield. Building on greenbelt will not deliver affordable housing. Removing greenbelt land will increase traffic and pollution, more people will commute to Sheffield and Chesterfield

Full text:

I feel there are no exceptional circumstances for green belt release, all other options have not been looked into.
Brown field sites and vacant homes can be used. There is a risk of merging areas into one as existing narrow gaps between settlements is swallowed up. There are more houses allocated than needed in Dronfield. Building on greenbelt will not deliver affordable housing. Removing greenbelt land will increase traffic and pollution, more people will commute to Sheffield and Chesterfield

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7223

Received: 02/04/2018

Respondent: Mrs. Joanna Boardman

Representation:

The plan to build new housing in and around Dronfield, using up precious green belt land is flawed in many ways. No consideration has been made as to how local services and infrastructure will manage. Most of the population of Dronfield commute into Sheffield and Chesterfield, roads and public transport will not be able to cope with increased housing . Schools and doctors are full to bursting point. There are no exceptional circumstances to warrant building on greenbelt land, other options need to be used. More appropriate and sustainable sites should be utilised.

Full text:

The plan to build new housing in and around Dronfield, using up precious green belt land is flawed in many ways. No consideration has been made as to how local services and infrastructure will manage. Most of the population of Dronfield commute into Sheffield and Chesterfield, roads and public transport will not be able to cope with increased housing . Schools and doctors are full to bursting point. There are no exceptional circumstances to warrant building on greenbelt land, other options need to be used. More appropriate and sustainable sites should be utilised.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7224

Received: 04/04/2018

Respondent: D Bullers

Representation:

As the plan stands the councils vision,objectives and polices do not match those of a large number of the residents in some of the areas of NEDDC this plan covers. This plan is at odds with the principal stated in The Localism Act to allow communities to control development by a Neighbourhood Plan. As NEDDC have failed to take into account the views of Dronfield Town Councils draft plan to oppose development on Green Belt land, Parts of the plan are Non sustainable and fail to protect the environment for existing residents

Full text:

As the plan stands the councils vision,objectives and polices do not match those of a large number of the residents in some of the areas of NEDDC this plan covers. This plan is at odds with the principal stated in The Localism Act to allow communities to control development by a Neighbourhood Plan. As NEDDC have failed to take into account the views of Dronfield Town Councils draft plan to oppose development on Green Belt land, Parts of the plan are Non sustainable and fail to protect the environment for existing residents

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7302

Received: 03/04/2018

Respondent: Mrs Sandra Fraser

Representation:

There appears to be no logic as to why certain areas like Killamarsh are expected to lose both green belt land and any remaining green spaces in the village to housing developments yet other villages in NE Derbyshire are exempt e.g. Renishaw was originally to have 270 houses-now none are proposed. Also Spinkhill does not feature.

Full text:

There appears to be no logic as to why certain areas like Killamarsh are expected to lose both green belt land and any remaining green spaces in the village to housing developments yet other villages in NE Derbyshire are exempt e.g. Renishaw was originally to have 270 houses-now none are proposed. Also Spinkhill does not feature.

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7327

Received: 03/04/2018

Respondent: Peak District National Park Authority

Representation:

We note that the introduction states that the Local Plan will cover the area of North East Derbyshire outside of the Peak District National Park (paragraph 1.2). However we would also welcome the inclusion that part of North East Derbyshire District Council falls within the Peak District National Park, and the Peak District National Park Authority (designated under the National Parks and Access to the Countryside Act 1949 (as amended) is the planning authority for that area of the District. (We note this is outlined within Chapter 2, however we feel that it should also be included within the Introduction).

Full text:

We note that the introduction states that the Local Plan will cover the area of North East Derbyshire outside of the Peak District National Park (paragraph 1.2). However we would also welcome the inclusion that part of North East Derbyshire District Council falls within the Peak District National Park, and the Peak District National Park Authority (designated under the National Parks and Access to the Countryside Act 1949 (as amended) is the planning authority for that area of the District. (We note this is outlined within Chapter 2, however we feel that it should also be included within the Introduction).

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7499

Received: 04/04/2018

Respondent: Dr Clare Freeman

Agent: Dr Clare Freeman

Representation:

"Dronfield Green Belt Residents' Group objects to The NEDDC Local Plan with respect to 1275 houses proposed on six Green Belt sites in Dronfield, Coal Aston, Eckington and Killamarsh. The Local Plan is not sound and not legally compliant with respect to these proposals for two principal reasons:
i. Exceptional Circumstances for the release of Green Belt land in North East Derbyshire for the purposes of house building do not exist.
ii. These Green Belt sites are in poorly sustainable locations when compared to reasonable alternatives

Full text:

"Dronfield Green Belt Residents' Group objects to The NEDDC Local Plan with respect to 1275 houses proposed on six Green Belt sites in Dronfield, Coal Aston, Eckington and Killamarsh. The Local Plan is not sound and not legally compliant with respect to these proposals for two principal reasons:
i. Exceptional Circumstances for the release of Green Belt land in North East Derbyshire for the purposes of house building do not exist.
ii. These Green Belt sites are in poorly sustainable locations when compared to reasonable alternatives

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7503

Received: 04/04/2018

Respondent: Mr Paul Stocks

Representation:

"Dronfield Green Belt Residents' Group objects to The NEDDC Local Plan with respect to 1275 houses proposed on six Green Belt sites in Dronfield, Coal Aston, Eckington and Killamarsh. The Local Plan is not sound and not legally compliant with respect to these proposals for two principal reasons:
i. Exceptional Circumstances for the release of Green Belt land in North East Derbyshire for the purposes of house building do not exist.
ii. These Green Belt sites are in poorly sustainable locations when compared to reasonable alternatives

Full text:

"Dronfield Green Belt Residents' Group objects to The NEDDC Local Plan with respect to 1275 houses proposed on six Green Belt sites in Dronfield, Coal Aston, Eckington and Killamarsh. The Local Plan is not sound and not legally compliant with respect to these proposals for two principal reasons:
i. Exceptional Circumstances for the release of Green Belt land in North East Derbyshire for the purposes of house building do not exist.
ii. These Green Belt sites are in poorly sustainable locations when compared to reasonable alternatives

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7504

Received: 04/04/2018

Respondent: Mr Jeremy Kenyon

Representation:

The consultation process has been inadequately and incorrectly publicised and the large majority of residents have not been made aware of the consultation in a timely manner by the District Council.

Full text:

The consultation process has been inadequately and incorrectly publicised and the large majority of residents have not been made aware of the consultation in a timely manner by the District Council.

The law on Local Plans says:

Preparation of a local plan
18.—(1) A local planning authority must—
(a) notify each of the bodies or persons specified in paragraph (2) of the subject of a local plan which the local planning authority propose to prepare, and
(b) invite each of them to make representations to the local planning authority about what a local plan with that subject ought to contain.
(2) The bodies or persons referred to in paragraph (1) are—
...
(c) such residents or other persons carrying on business in the local planning authority's area from which the local planning authority consider it appropriate to invite representations.

The previous iteration of the Local Plan was consulted on from 24th Feb 2017 to 7th April 2017. The only significant mention of this consultation was in the Spring 2017 edition of 'The News', the four monthly newsletter of NE Derbyshire District Council. I am not sure exactly when that was circulated, but it is highly unlikely, even if it arrived in time, that many residents noticed the mention of the Local Plan, which was buried on page 15, with no mention of this vital consultation on the front cover. There is a sentence in a section on page 3, which says there is 'some information about our Local Plan' but it does NOT say it is a consultation.
This is very from 'invite each of them to make representations'. In particular, the residents of the towns where green belt is proposed to be removed should have received individual leaflets summarising the proposals and a timely request to respond to the consultation.

The most recent iteration of the Local Plan is being consulted on from 20th Feb 2018 to 3rd April 2018. This was not mentioned in the Winter 2017 edition of 'The News', and when mentioned in the Spring 2018 version it was buried on page 15.

In The News, Spring 2018, it is described as follows:

Consultation responses at this stage must be set out in a specific way to address legal matters referred to as the 'tests of soundness'. Put simply, we will ask people to consider two questions: Is the Local Plan legal? and is the Local Plan sound?

This gives the impression you can only respond to two specific questions: 'Is it legal' and 'Is it sound'.

It strongly indicates you cannot make other comments, by saying 'Consultation responses at this stage must be set out in a specific way to address legal matters referred to as the 'tests of soundness'.'

This completely misrepresents the situation and appears to be written to put people off commenting.

The open sessions have further misled people into thinking the process is all over and the plan is final - this has put people off making comments. At the sessions, people heard things such as 'the plan is final', 'it is a done deal', and I myself was told by a planning officer that 'The Plan can't be changed now', with the clear implication that there was no point in commenting.

Many people have said that they were under the impression that the consultation had already ended, even at the end of 2017, and that it was too late to comment. This message was repeated at the consultation events. These comments are clearly incorrect - the only 'done deal' is that the plan is going to be submitted to the next stage as written - that is the START of the formal consultation process, not the end.

List of 'The News' and how the plan was publicised: http://www.ne-derbyshire.gov.uk/index.php/your-council/publications

The District Council has not fulfilled the basic requirements of a consultation, and has not made anything like sufficient effort to consult clearly and broadly with residents.

It has been left to local campaigners to bring the Local Plan to the attention of most residents, and often those campaigners have also had to help people through the extremely complex process to successfully make their comments.

This lack of openness and proper consultation also makes one wonder how sound the rest of the plan is - how well were alternatives to building on the green belt looked for or explored?

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7507

Received: 04/04/2018

Respondent: Miss Hermione Salt

Representation:

Flawed Consultation and Document Set;
The current consultation was commenced without key documents being available; some were still unavailable 4 weeks into the consultation period.

The Green Belt Topic Paper was not available for 4 weeks of the consultation period.

Recent dated documents are not referenced in the plan. These documents clearly do not inform the plan; they are unequivocal evidence of a retrospective attempt to justify long-standing elements of the plan.

There are multiple versions of some documents in the evidence base; it is not clear whether all versions are relevant or only the latest.

Full text:

Objection: Flawed Consultation and Document Set

The current consultation was commenced without key documents being available; some were still unavailable 4 weeks into the consultation period.

The Green Belt Topic Paper was not available for 4 weeks of the consultation period.

Recent dated documents are not referenced in the plan. These documents clearly do not inform the plan; they are unequivocal evidence of a retrospective attempt to justify long-standing elements of the plan.

There are multiple versions of some documents in the evidence base; it is not clear whether all versions are relevant or only the latest.

The following referenced evidence documents are not available on the NEDDC website:

* Paragraph 1.27: 'North East Derbyshire District Corporate Plan 2015 - 2019'
* Paragraph 1.31: 'The Housing and Economic Development Strategy 2015-20'


The 'Green Belt Topic Paper, January 2018', was not made available until 22/03/18 - 4 weeks into a 6 week consultation period. This document is stated as containing "Detailed evidence setting out the exceptional circumstances justifying the release of Green Belt". Without this document it is not been possible to scrutinise this crucial and contentious aspect of the plan.



The following evidence documents are not referenced in the Local Plan:

* 'Employment-Land-Review-Update---Economic-Growth-Analysis-2018.pdf'; dated 01/01/18
* 'Considering-NED-OAN-Final-Report-February-2018.pdf'; dated 20/02/18
* 'Housing topic paper Jan 2018 final'


The document 'Housing topic paper Jan 2018 final' whilst dated January 2018 bizarrely references 'Considering-NED-OAN-Final-Report-February-2018.pdf'; dated 20/02/18 and also the 'Green Belt Topic Paper, January 2018' which whilst dated January was not published until March.



It is clear the evidence documents dated 2018 have not informed a plan published on 20th February 2018; these are all provided as an attempt to retrospectively justify the high dwelling target and consequential intention to allow development on current green belt land. The forward dated references demonstrate the chaotic way these documents have been developed.

The evidence base contains 6 copies of the Sustainability Appraisal spanning 2007-2017. No guidance is provided as to whether these documents are cumulative or only the most recent is applicable.

Further documents indicate to an inconsistency in the structuring of the evidence base, with multiple documents appearing to cover similar topics e.g Employment Land Review (2008, 2013, Update 2017); Employment Land Review Update - Economic Growth Analysis 2018 (does this supersede the three previous land reviews?); Employment Land Availability Assessment 2018; Table of existing Employment sites incl. assessment (2018).