The Publication Draft Local Plan

Showing comments and forms 1 to 30 of 37

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6787

Received: 27/02/2018

Respondent: Heather Brown

Representation:

Plain English not used. An over-reliance on planning and council terminology. Not written for its readership. The glossary over-complicated matters instead of providing clarification and understanding.

Full text:

The Plan is not legally compliant in that it does not comply with your Statement of Community Involvement in which you pledge to keep the process simple by writing in plain English.

Throughout, the Local Plan relied heavily on planning and council terminology which made it unsuitable for the readership of local residents, and therefore not accessible to all. For me to be able to try to understand it, I continually had to refer to the glossary at the end of the document, which made for very heavy going and meant that I had to read and re-read sections several times.

Frequently, the glossary did not provide a clear explanation of terms, as in "Sustainable", which uses that word in the explanation itself and means that the reader is no closer to understanding the term!

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6792

Received: 07/03/2018

Respondent: Emma Thompson

Representation:

I made many points in my response during the 2017 draft consultation and they were consolidated into only two objection points across the whole local plan.

Full text:

In reference to paragraph 1.8 which states "Following this previous consultation, all representations received were taken into account..." - my letter of objection (and many other residents' letters/responses) in the first consultation period in 2017 was not properly assigned to different parts of the Local Plan. My letter was several pages long and broken down into many subheadings covering different separate topics. Instead of each of each topic being assigned to different parts of the plan to list the many reasons why I objected, it was instead placed in only a couple of places. My reference numbers are 4590 and 4593.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6795

Received: 08/03/2018

Respondent: Emma Thompson

Representation:

- Poor communication from NEDDC.
- Confusion arising from an obscure message received online when submitting representations.
- Contradiction over whether respondents can or cannot write general comments in the introduction section if they cannot locate a suitable section to reference elsewhere in the plan.

Full text:

In reference to paragraph 1.4, communication has been poor throughout the consultation process. While using this very system of submitting representations online, I have received a confusing message leaving me unsure as to whether my representation had been received and acknowledged. It stated:
"You must choose a respondent.
You must enter some text for your representation to be accepted.
Validation failed
I don't know which part of the document you are commenting on."

I did not know what this related to and then had to use the contact form to ask NEDDC whether my representation had been received. Respondents have been advised that they can make general comments about the plan in the introduction section if we cannot find another suitable place against which to place our comments. I did this, and yet have received a comment saying "I don't know which part of the document you are commenting on" - but this is because my comment did not necessarily relate to a specific part of the document.

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6815

Received: 28/02/2018

Respondent: Rotherham MBC

Representation:

Policy/paragraph identified by Council Officer.
Rotherham Council welcomes the opportunity the comment on the Publication Draft North East Derbyshire Local Plan.
Rotherham and North East Derbyshire Councils have engaged on strategic and cross boundary issues during the plan making process, and in fulfilling its requirements under the Duty to Co-operate the Council will continue to engage with North East Derbyshire as appropriate.
Rotherham Council supports the overall vision and objectives of the plan, and the overall spatial strategy and locations for growth set out. It broadly considers that the proposed allocations and development management policies will promote sustainable development in compliance with national planning policy and guidance, meeting the needs of the district and contributing to those of the wider Sheffield City Region.

Full text:

Rotherham Council welcomes the opportunity the comment on the Publication Draft North East Derbyshire Local Plan.
Rotherham and North East Derbyshire Councils have engaged on strategic and cross boundary issues during the plan making process, and in fulfilling its requirements under the Duty to Co-operate the Council will continue to engage with North East Derbyshire as appropriate.
Rotherham Council supports the overall vision and objectives of the plan, and the overall spatial strategy and locations for growth set out. It broadly considers that the proposed allocations and development management policies will promote sustainable development in compliance with national planning policy and guidance, meeting the needs of the district and contributing to those of the wider Sheffield City Region.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6830

Received: 13/03/2018

Respondent: Mrs Janet Hardcastle

Representation:

Point 1.10
Paragraph identified by Council officer.
When this plan as presented at Dronfield consultation in February 2017 it seemed that it was a fait accompli by the planners and the consultation process had only just begun.
The 264 pages of the plan was far too long and complicated to be understood by most members of the community. This is contrary to the principles set out in the Statement of Community involvement Leaflet 1 to use plain English.
Also the length and complexity of the Publication Draft Version is not easy to understand.

Full text:

When this plan as presented at Dronfield consultation in February 2017 it seemed that it was a fait accompli by the planners and the consultation process had only just begun.
The 264 pages of the plan was far too long and complicated to be understood by most members of the community. This is contrary to the principles set out in the Statement of Community involvement Leaflet 1 to use plain English.
Also the length and complexity of the Publication Draft Version is not easy to understand.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6835

Received: 15/03/2018

Respondent: Dronfield Green Belt Resident's Group

Representation:

A petition containing 4,105 signatures was submitted to the Council:
Petition Statement:

Petition to Councillor Graham Baxter MBE (Leader of the District Council) and
North East Derbyshire District Council.

We, the undersigned residents of Dronfield, are opposed to plans to remove land
from the Dronfield Greenbelt for development.

We call upon North East Derbyshire District Council to reject the proposed plan.

Full text:

A petition containing 4,105 signatures was submitted to the Council:
Petition Statement:

Petition to Councillor Graham Baxter MBE (Leader of the District Council) and
North East Derbyshire District Council.

We, the undersigned residents of Dronfield, are opposed to plans to remove land
from the Dronfield Greenbelt for development.

We call upon North East Derbyshire District Council to reject the proposed plan.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6837

Received: 13/03/2018

Respondent: Mr Robert Hardcastle

Representation:

Point 1.10
Paragraph identified by Council officer.

When this plan as presented at a Dronfield consultation in February 2017 it seemed that it was a fait accompli by the planners and the consultation process had only just begun.
The 264 pages of the plan was far too long and complicated to be understood by most members of the community. This is contrary to the principles set out in the Statement of Community involvement Leaflet 1 to use plain English.
Also the length and complexity of the Publication Draft Version is not easy to understand.

Full text:

When this plan as presented at a Dronfield consultation in February 2017 it seemed that it was a fait accompli by the planners and the consultation process had only just begun.
The 264 pages of the plan was far too long and complicated to be understood by most members of the community. This is contrary to the principles set out in the Statement of Community involvement Leaflet 1 to use plain English.
Also the length and complexity of the Publication Draft Version is not easy to understand.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6847

Received: 15/03/2018

Respondent: Mr Michael & Jill Lee

Number of people: 2

Representation:

Policy/paragraph identified by Council officer

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

Error on NEDDC's Plan. Appendix 1 states a deficiency of green space in the Dronfield already, being below local standard. Why should GB be lost as well?

NEDDC shows arrogance in relation to overbuilt areas. Ignoring how resident's lives will suffer from loss of GB. Callous in their failure of duty to comply with residents and NPPF. Making the Plan unsound and inconsistent with national policy.

Appendix 1 - Green Space
2.29 In 2008, there were 162 green spaces recorded, measuring 157.32 hectares in total(1.62 hectares of green space per 1,000 population), below the local standard of 1.95ha per 1000 population.

Figure made up of 40 amenity green spaces and commons, 30 cemeteries/churchyards, 3 green corridors, 81 housing green spaces and 8 parks. The Recreation Research Report Ward include maps and descriptions.

Full text:

Yet another major error on NEDDC's local plan. Appendix 1 clearly states there is a deficiency of green space in the Dronfield area already, being below local standard and the largest town in the northern area of Derbyshire. Why then should we lose our green belt as well?
The whole attitude shows NEDDC's arrogance in relation to areas which are already overbuilt. Ignoring the fact that resident's lives will suffer from loss of green belt land. Callous in their failure of duty to comply with residents and the Govt framework. Making the local plan unsound and inconsistent with national policy.
Appendix 1 - Green Space
2.29 In 2008, there were 162 green spaces recorded in North East Derbyshire, measuring 157.32 hectares in total31. This means 1.62 hectares of green space per 1,000 population, which is below the local standard of 1.95ha per 1000 population. 30 NEDDC, Recreation Research Report, 2007, and 2008 update 31 NEDDC, Recreation Research Report, 2007, and 2008 update 32 This figure is made up of 40 amenity green spaces and commons, 30 cemeteries and churchyards, 3 green corridors, 81 housing green spaces and 8 parks. The Recreation Research Report Ward papers include maps and descriptions of each of the sites

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6869

Received: 18/03/2018

Respondent: Heather Brown

Representation:

You failed to accurately-record public opinion during the first public consultation. No apparent coherent overall plan to ensure consistency of recording. You inaccurately-recorded my letter of objection. I made fourteen objections; you grouped them into two. Contrast this with one Representation ID issued to a one-line objection of "I object to any building on greenbelt"; this occurs numerous times, thus attaching the same weight to a general one-line objection as you have to a fully-referenced, comprehensive submission. Seems that it depended on who was doing the referencing as to how it was done.

Full text:

You failed to accurately-record public opinion during the first public consultation. No apparent coherent overall plan to ensure consistency of recording. You inaccurately-recorded my letter of objection. I made fourteen objections; you grouped them into two. Contrast this with one Representation ID issued to a one-line objection of "I object to any building on greenbelt"; this occurs numerous times, thus attaching the same weight to a general one-line objection as you have to a fully-referenced, comprehensive submission. Seems that it depended on who was doing the referencing as to how it was done.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6870

Received: 18/03/2018

Respondent: Heather Brown

Representation:

I counted 36 representations which you have headed up as Comment or Support but upon reading the actual representations, they are clearly Objections.
In mis-labelling representations, you have failed to accurately record public opinion, showing that the consultation process cannot be trusted.
Cllr Gordon, Portfolio Holder with Responsibility for Environment and Asset Management, included this incorrect number of objections in his Report to Cabinet, which at the Cabinet Meeting on 14 February 2018, members of the cabinet used to decide to approve the Local Plan. So cabinet have based their decision on incorrect figures!

Full text:

I counted 36 representations which you have headed up as Comment or Support but upon reading the actual representations, they are clearly Objections.
In mis-labelling representations, you have failed to accurately record public opinion, showing that the consultation process cannot be trusted.
Cllr Gordon, Portfolio Holder with Responsibility for Environment and Asset Management, included this incorrect number of objections in his Report to Cabinet, which at the Cabinet Meeting on 14 February 2018, members of the cabinet used to decide to approve the Local Plan. So cabinet have based their decision on incorrect figures!

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6871

Received: 18/03/2018

Respondent: Heather Brown

Representation:

Your first public consultation was not accessible to all residents. You held just ONE consultation event in Dronfield - the largest settlement by far in the NEDDC area. This was so full, many left without being able to speak to planners. Dronfield has a huge proportion of elderly - you needed to meet people where they are at - smaller, more numerous,more accessible roadshow-type events in key community focal points across Dronfield - the library, civic hall, Coal Aston Village Hall, doctors' surgeries, Dronfield Henry Fanshawe School, Hill Top Social Club, that ALL sections of the community could access.

Full text:

Your first public consultation was not accessible to all residents. You held just ONE consultation event in Dronfield - the largest settlement by far in the NEDDC area. This was so full, many left without being able to speak to planners. Dronfield has a huge proportion of elderly - you needed to meet people where they are at - smaller, more numerous,more accessible roadshow-type events in key community focal points across Dronfield - the library, civic hall, Coal Aston Village Hall, doctors' surgeries, Dronfield Henry Fanshawe School, Hill Top Social Club, that ALL sections of the community could access.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6874

Received: 18/03/2018

Respondent: Heather Brown

Representation:

4000+ Dronfield residents signed a petition declaring opposition to building on Greenbelt. Reflects huge levels of public interest, evident since first public consultation period in 2017. Petition presented to NEDDC 14 February 2018; residents told that petition, 5-minute speech and 30-minute debate it triggers was NOT on agenda for March 5 council meeting. Next council meeting is AFTER the consultation period! This is a blatant unwillingness to listen to residents' concerns and not in the spirit of your pledge in your SCI Leaflet One to "make it easy for you to get involved."

Full text:

4000+ Dronfield residents signed a petition declaring opposition to building on Greenbelt. Reflects huge levels of public interest, evident since first public consultation period in 2017. Petition presented to NEDDC 14 February 2018; residents told that petition, 5-minute speech and 30-minute debate it triggers was NOT on agenda for March 5 council meeting. Next council meeting is AFTER the consultation period! This is a blatant unwillingness to listen to residents' concerns and not in the spirit of your pledge in your SCI Leaflet One to "make it easy for you to get involved."

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6875

Received: 18/03/2018

Respondent: Heather Brown

Representation:

We are now more than halfway through the consultation period and residents still don't have access to key documents underpinning the Plan and referenced within it - Statement of Compliance with Duty to Co-operate, and Green Belt Topic Paper.

These are not online, nor in Dronfield library. You say via email that they will be on the website "soon".

Statement of Community Involvement Leaflet 1 states "will be inclusive by providing information in an accessible format" "Be transparent ...presenting all relevant facts ..."

In order to scrutinise the Plan as is their right, residents must have access to these documents.

Full text:

We are now more than halfway through the consultation period and residents still don't have access to key documents underpinning the Plan and referenced within it - Statement of Compliance with Duty to Co-operate, and Green Belt Topic Paper.

These are not online, nor in Dronfield library. You say via email that they will be on the website "soon".

Statement of Community Involvement Leaflet 1 states "will be inclusive by providing information in an accessible format" "Be transparent ...presenting all relevant facts ..."

In order to scrutinise the Plan as is their right, residents must have access to these documents.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6876

Received: 18/03/2018

Respondent: Heather Brown

Representation:

Over halfway into the consultation and still no Guidance Notes/representation forms in Dronfield Library or Sports Centre. Consultation process therefore not accessible to all, especially the non-internet-using residents, who are excluded from the process/disadvantaged. Not all documents forming the evidence base are available in Dronfield Library - some are missing, and there is no list indicating that further documents available online, therefore people don't know what they are not being shown. This is contrary to the SCI and does not live up to your pledge to "make it easy for you to get involved

Full text:

Over halfway into the consultation and still no Guidance Notes/representation forms in Dronfield Library or Sports Centre. Consultation process therefore not accessible to all, especially the non-internet-using residents, who are excluded from the process/disadvantaged. Not all documents forming the evidence base are available in Dronfield Library - some are missing, and there is no list indicating that further documents available online, therefore people don't know what they are not being shown. This is contrary to the SCI and does not live up to your pledge to "make it easy for you to get involved

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6877

Received: 18/03/2018

Respondent: Heather Brown

Representation:

Poor planning and late communication re capacity for public wishing to observe council meeting, as is our right.

Council aware in March 2017 of huge public interest in Plan. Reasonable to expect continuation of this into second consultation. Provision made for only 20 residents at 14/2/18 meeting (public area filled to capacity). No plans for larger room or live-streaming for 5/3/18 meeting until I publicly requested it.

Council only able to confirm live-stream on 5/3/18 itself, citing issues with delivery of technology needed due to severe weather conditions last week..."

Full text:

Poor planning and late communication re capacity for public wishing to observe council meeting, as is our right.

Council aware in March 2017 of huge public interest in Plan. Reasonable to expect continuation of this into second consultation. Provision made for only 20 residents at 14/2/18 meeting (public area filled to capacity). No plans for larger room or live-streaming for 5/3/18 meeting until I publicly requested it.

Council only able to confirm live-stream on 5/3/18 itself, citing issues with delivery of technology needed due to severe weather conditions last week..."

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6878

Received: 18/03/2018

Respondent: Heather Brown

Representation:

On behalf of Dronfield Greenbelt, Dr Gadsden requested to Cllrs Baxter and Gordon in May 2017 a meeting to enable more constructive consultation with residents. This request was not fulfilled. Our former MP, Natascha Engel, liaised with Cllr Gordon and the Planning Policy Manager on the group's behalf, to encourage face-to-face dialogue with residents. Again, request not fulfilled.

I am disappointed that Council has denied the group's chance for a more constructive voice during the public consultation phase before the plan is submitted to the Inspectorate.

Full text:

On behalf of Dronfield Greenbelt, Dr Gadsden requested to Cllrs Baxter and Gordon in May 2017 a meeting to enable more constructive consultation with residents. This request was not fulfilled. Our former MP, Natascha Engel, liaised with Cllr Gordon and the Planning Policy Manager on the group's behalf, to encourage face-to-face dialogue with residents. Again, request not fulfilled.

I am disappointed that Council has denied the group's chance for a more constructive voice during the public consultation phase before the plan is submitted to the Inspectorate.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6879

Received: 02/04/2018

Respondent: Dronfield Civic Society

Representation:

Not compliant with NPPF (minister's introduction)
Not compliant with community Involvement Strategy
Only token response to resident concerns
Not compliant because of late publication of Green Belt Topic paper.
Reserves right to revisit due to late filing of GB Topic paper

Full text:

The plan is difficult for residents to understand and is in conflict with the ministers introduction to the NPPF in which he states ''In part, people have been put off from getting involved because planning policy itself has become so elaborate and forbidding - the preserve of specialists, rather than people in communities. This National Planning Policy Framework changes that'
The proposed revisions to the NPPF aim to give people a bigger say in the planning process. The consultation process for this plan largely ignored the views of residents. any significant revisions such as the reduced use of green belt land in Dronfield is the result of owners ( Hallowes Golf Club) withdrawing their offer of land for building.
The approach is also in conflict with the Council's Community Involvement Strategy which says you will 'Keep the process simple by writing in plain English and explain any planning terms that we need to use"
The late pub;ication of the Green Belt Topic paper also makes the plan not legally compliant given that the proposed building on green belt is the most contentious element of the plan.
Reserve the right to revisit this representation due to late filing of the Green Belt topic paper

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6882

Received: 19/03/2018

Respondent: Emma Thompson

Representation:

There was nowhere in Dronfield where people who do not use the internet / email could pick up paper copies of the representation forms to send to NEDDC. It would be expected that the library, Dronfield Sports Centre One Stop Shop and the Town Council offices in the Civic Hall would be provided with copies by NEDDC for public use.

This is contrary to NEDDC's Statement of Community Involvement pledge to "make it easy for you to get involved". The Plan is not legally compliant if the Community Involvement statement is not being followed.

Full text:

There was nowhere in Dronfield where people who do not use the internet / email could pick up paper copies of the representation forms to send to NEDDC. It would be expected that the library, Dronfield Sports Centre One Stop Shop and the Town Council offices in the Civic Hall would be provided with copies by NEDDC for public use.

This is contrary to NEDDC's Statement of Community Involvement pledge to "make it easy for you to get involved". The Plan is not legally compliant if the Community Involvement statement is not being followed.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6893

Received: 18/03/2018

Respondent: Dronfield Green Belt Resident's Group

Representation:

A petition has previously been submitted to the Council and confirmed as a duly made representation. Subsequently, the lead petitioner has submitted further information, which is included in this representation.

Petition Statement:
Petition to Councillor Graham Baxter MBE (Leader of the District Council) and North East Derbyshire District Council.

We, the undersigned residents of Dronfield, are opposed to plans to remove land from the Dronfield Greenbelt for development.

We call upon North East Derbyshire District Council to reject the proposed plan.

Council refused a 30 minutes debate regards petition between Councillors. Council denied petition representative 5 minutes to address Council and justify our stance: there are no exceptional circumstances to warrant release of Green Belt land in Dronfield for development. (100 words)
(Council response to petition attached)

Full text:

A petition containing 4,105 signatures was submitted to the Council:

Petition Statement:
Petition to Councillor Graham Baxter MBE (Leader of the District Council) and North East Derbyshire District Council.

We, the undersigned residents of Dronfield, are opposed to plans to remove land from the Dronfield Greenbelt for development.

We call upon North East Derbyshire District Council to reject the proposed plan.

Council refused a 30 minutes debate regards petition between Councillors. Council denied petition representative 5 minutes to address Council and justify our stance: there are no exceptional circumstances to warrant release of Green Belt land in Dronfield for development. (100 words)
(Council response to petition attached)

Dear Dr Gadsden,
Petition in relation to the local Plan presented on 14th February 2018
Further to previous emails in which receipt of the above Petition has been acknowledged, I now write to let you know what the Council intends to do with the Petition.
Please be assured that the Council has considered the Petition seriously. The Council notes there are a large number of signatures on the Petition and that clearly there are a significant number of people who feel strongly on this. I would also like to point out that Council Petition Schemes are now not required by law. It is entirely the choice of the Council to have such a scheme or not and obviously this Council has chosen to have such a scheme.
The Petition was presented immediately after the NEDDC Cabinet had decided to publish the draft Local Plan for consultation prior to submission for examination. Although the Petition was presented before the consultation period formally began, the Council will accept it as a consultation response. It will therefore be submitted with all other consultation responses.
In relation to the Petition and whether it will be presented to Council, the Council's Petitions Scheme provides for Petitions to be rejected in certain circumstances including where the Petition is inappropriate. I believe there are 2 reasons why consideration of the Petition would be inappropriate at this stage.
Firstly the Council cannot consider the Petition request without considering the whole local plan. This is because decisions on green belt in Dronfield should not be considered in isolation from the rest of the plan provision as the decisions affect one another. As the draft is now the subject of consultation it would be inappropriate to do so at this stage.
The second reason is that the draft is out to consultation and that there are still a number of stages for the Local Plan to go through including the public Examination where you will get the chance to put your views to an independent Inspector. Only following this will the Local Plan be presented to Council for adoption with the benefit of the Inspector's report following that Examination. It would not be appropriate for the Council to consider any aspect of the draft Local Plan in advance of these stages.
Should you disagree with my decision you have a right under the Petitions Scheme to raise the matter with the relevant Scrutiny Committee. This is limited to the way the Petition has been dealt with and is not for the subject matter of the Petition to be debated. I enclose a copy of the Petitions Scheme for your information.
Yours sincerely
MO

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6902

Received: 17/03/2018

Respondent: Mrs Jane Singleton

Representation:

Objection to Brownfield Register.

It is questionable whether NEDDC has been rigorous or transparent enough with regard to their Brownfield Register or whether it is legally compliant.

Sites that have been assessed appear as a list of numbered sites within settlements in Appendix C of the LAA Housing Land Assessment and are not necessarily brownfield or previously developed land.
The NPPG states that Part 1 of a brownfield land register will comprise all brownfield sites that a local planning authority has assessed as appropriate for residential development, having carried out any procedures such as consultation which they consider appropriate. This will include sites with extant full planning permission, outline planning permission and permission in principle as well as sites without planning permission

Full text:

Objection to Brownfield Register.

It is questionable whether NEDDC has been rigorous or transparent enough with regard to their Brownfield Register or whether it is legally compliant.

Sites that have been assessed appear as a list of numbered sites within settlements in Appendix C of the LAA Housing Land Assessment and are not necessarily brownfield or previously developed land.

The NPPG states that Part 1 of a brownfield land register will comprise all brownfield sites that a local planning authority has assessed as appropriate for residential development, having carried out any procedures such as consultation which they consider appropriate. This will include sites with extant full planning permission, outline planning permission and permission in principle as well as sites without planning permission

Of the 495 Green Belt, greenfield and previously developed sites in the LAA Housing Land Assessment, only 30 appear on Part 1 of the Brownfield Register.
NEDDC has suggested that the 30 sites have been identified from "different sources of datasets (e.g. brownfield sites from Housing Land Availability Assessment, brownfield sites with granted permission, etc.) were utilised." Firstly what is meant by this, including 'etc.' in this instance and where is the evidence of the purely brownfield land across NE Derbyshire that has been assessed?

At the last consultation in February 2017, publicity material suggested that none of the housing allocations being proposed for Dronfield were on brownfield land, although a number of previously developed sites (such as land at Callywhite Lane "have been considered but dismissed due to their importance and suitability for employment and creating jobs." A 'number' implies more than one, but where is the evidence of the other brownfield sites in Dronfield and why they were dismissed as unsuitable. A neighbouring authority identified 338 brownfield sites which appear in an archived document of more than 50 pages on their website. NE has not provided this information.

Before NEDDC can make the case to remove land from the Green Belt, this information should be in the public domain, otherwise we do not know that the correct procedures and necessary effort have been made with regards to brownfield or previously developed land.

The Register should be an active document. Sites are coming forward all the time. The Brownfield Register appeared in December 2017 on NEDDC website being then a legal requirement. In the first quarter of the year one site has been removed from it (originally 31) but none have been added.

As an example, it is likely that an area of land within Dronfield's settlement development limit will become or is available. It is the site of the former Gladys Buxton School, once used with Gosforth School to accommodate pupils aged 11-14 before they transferred to the Dronfield Henry Fanshawe School. The Gosforth School site was developed for housing, flats, a medical centre and community sport's facilities some years ago. The Gladys Buxton site has up until recently been an adult education centre owned by Derbyshire County Council. The buildings require considerable repair and have been assessed as no longer viable. It is highly likely that the site will come forward, being in a sustainable location for housing development. Infrastructure is already there. Nearby is a medical centre with capacity, nearby is a Primary School with capacity, nearby is a localised shopping hub with a chemist, newsagent and small food store. If NEDDC had robustly engaged with Derbyshire County Council, through Duty to Cooperate, they would have provided the assessment evidence and the potential yield which is likely to have more than satisfied Dronfield's 'unmet' need, assuming that has been properly assessed.

If Green Belt land can be assessed in terms of the yield, then this site should have also been taken through a similar process. Its potential will have been known about for some time.

This is all questionable practice by this Local Authority. It is once again a demonstration of a lack of Duty to Cooperate, a lax view about exceptional circumstances when sites like the Gladys Buxton exist within Dronfield, a lack of ambition to forward plan for sites like these, other than to be counted as 'windfalls', and a lack of transparency about the assessment process with regard to brownfield or previously developed land.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6921

Received: 10/03/2018

Respondent: Mrs Jane Singleton

Representation:

Rep refers to para 1.7
The consultation process was flawed, and those who responded have been misrepresented in muddled, subjective analysis.

Representation numbers 5327 and 5175 are an example, where two people submitted the same content. One was recorded as a comment and the other an objection. Many other misrepresentations have been identified.

This is contrary to the SCI which says "make sure your involvement is effective by ensuring all comments received by the authority are recorded, read carefully and taken into account."
Only 14% of representations supported the Plan. However within the 'support' representations were comments which said we support an objective, but don't think the Plan will deliver it. Such were recorded as 'support'.

For this consultation, these forms are poorly designed, using over-complicated English and double negatives, probably to dissuade public participation in the process. To use plain English is what it says the Council will do in the SCI.

Full text:

Rep refers to para 1.7
The consultation process was flawed, and those who responded have been misrepresented in muddled, subjective analysis.

Representation numbers 5327 and 5175 are an example, where two people submitted the same content. One was recorded as a comment and the other an objection. Many other misrepresentations have been identified.

This is contrary to the Statement of Community Involvement which says "make sure your involvement is effective by ensuring all comments received by the authority are recorded, read carefully and taken into account."
Only 14% of representations supported the Plan. However within the 'support' representations were comments which said we support an objective, but don't think the Plan will deliver it. Such were recorded as 'support'.

For this consultation, I would suggest these forms are poorly designed, using over-complicated English and double negatives, probably to dissuade public participation in the process. To use plain English is what it says the Council will do in the SCI.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6970

Received: 23/03/2018

Respondent: Mr Michael & Jill Lee

Representation:

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

Reference to Position Statement Page 7 and 15/16 and other incorrect information previously publicised by NEDDC

Transport in Dronfield and other towns is abysmal. What happened to the traffic model in 2012 and where, what and at what cost were improvements made?

A further major study is underway. What are the costs and findings? How can agreement be made for building on green belt when NEDDC employ 'major studies', the results of which they have no idea how to deal with?

Bus services fail local people. NEDDC did nothing to improve the train station.

Representation linked to paragraph 2.24 of the Chesterfield Borough Council Delivery Plan 2011.(http://chesterfield.moderngov.co.uk/Data/Council/20111214/Agenda/Appendix%207%20-%2027399.pdf)
This is a failure in NEDDC's duty to comply, making unsound statements, against national policy. Further GB building, further transport problems, failure to encourage use of public transport.

Full text:

Local Plan position statement - Pg 15/16
Transport
A traffic model for North Derbyshire was completed in 2012. This was used to assess the cumulative traffic impact of the development being proposed by the Council at the time. Since then the situation has changed and we will need to undertake a review of and update the transport modelling as necessary in order to assess the traffic impacts of the development proposed in the Plan. A major study is currently under-way to identify potential transport improvements needed to support major housing and employment growth along the A61 Growth Corridor which will be delivered through the D2N2 Local Enterprise Growth Deal grant funding. Stage 1 of the Study has been completed, but further work is on-going through Stage 2 to further appraise and develop a preferred package of potential options to take forward in the Local Plan
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With regard to Transport, which is abysmal in Dronfield and other towns (MP, Lee Rowley has worked tirelessly with regard to attempts to improve this. Unfortunately NEDDC do not appear to be interested.
5
Instead they speak blithely about a traffic model being completed in 2012 (what happened to this, where were the improvements made? At what cost?) Now it is discovered that it was useless! Surprise, Surprise! (to no-one but NEDDC)
A further major study is currently underway. At what further cost? What are the findings? How will the localities needs be met and improved upon?
How can an agreement be made for building on green belt when NEDDC simply employ 'major studies', the results of which they have no idea how to deal with?
There will simply be more residents unable to get to work without a car because public transport, especially the bus services already fail local people. The train station which is mentioned had extremely poor services until the Friends of Dronfield station got on the case. NEDDC continued to slumber, dreaming up destruction of green belt land simply for further rates income to dissipate.
Yet another major error on the Derbyshire Council web site regarding Transport and downright untruth with regard to Dronfield's bus services or lack of them. Document link above, paragraph ID below:
http://chesterfield.moderngov.co.uk/Data/Council/20111214/Agenda/Appendix%207%20-%2027399.pdf
The Bus Network Key Issues 2.24 Chesterfield Town Centre and the outlying local and district centres are well served by the bus network, enabling resident and commuter access to the borough's key services, such as shops, schools, places of work and leisure facilities. There are also regular services to the borough's closest cities and towns such as Sheffield, Derby, Nottingham, Mansfield, Bolsover, Clay Cross, Alfreton, Dronfield and Eckington.
Proving how disinterested NEDDC is with regard to Dronfield and NE Derbyshire. Lee Rowley has spent the past few years, even before being elected local MP, working to get an improved bus service for our area. The service, by the way is pitiful. That's how much our great leaders know - or care ...
Is it because he's Conservative in a majority labour County? Is that why we are being punished? Dronfield was previously Labour but that MP, Engel, failed to care for the area too, later joining the fracking company she leafleted us to accept! An obvious failure in NEDDC duty to comply, making unsound statements. Further building, further transport problems failure in national policy to get care off the road - more people on buses.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6993

Received: 25/03/2018

Respondent: Heather Brown

Representation:

SCI: Council will "Make sure your involvement is effective by ensuring all comments received by the authority are recorded, read carefully and taken into account."

When asked for criteria used to ensure consistency in interpreting and summarising representations to Draft Plan, Council states "not possible to have criteria to inform this process."

It IS possible to handle responses systematically. Council only ever advised use of a standard form; at no time did Council warn that NOT using this form would result in Council putting its own interpretation on the representations and flagrantly misconstruing the obvious intent behind people's statements.

Full text:

SCI: Council will "Make sure your involvement is effective by ensuring all comments received by the authority are recorded, read carefully and taken into account."

When asked for criteria used to ensure consistency in interpreting and summarising representations to Draft Plan, Council states "not possible to have criteria to inform this process."

It IS possible to handle responses systematically. Council only ever advised use of a standard form; at no time did Council warn that NOT using this form would result in Council putting its own interpretation on the representations and flagrantly misconstruing the obvious intent behind people's statements.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6994

Received: 25/03/2018

Respondent: Heather Brown

Representation:

SCI: Council will "Make sure your involvement is effective by ensuring all comments received by the authority are recorded, read carefully and taken into account."

Responding to FOI request 5546 for the criteria used to ensure consistency in interpreting and summarising representations, Council states, "Comments sent in not using a form were sometimes difficult to read and or interpret."

My representations, Rep IDs 5282/5283, were type-written and properly-referenced. Difficult to read? Difficult to interpret?

No overall policy to ensure consistency = a haphazard, random and disorganised approach which does not comply with the SCI.

Full text:

SCI: Council will "Make sure your involvement is effective by ensuring all comments received by the authority are recorded, read carefully and taken into account."

Responding to FOI request 5546 for the criteria used to ensure consistency in interpreting and summarising representations, Council states, "Comments sent in not using a form were sometimes difficult to read and or interpret."

My representations, Rep IDs 5282/5283, were type-written and properly-referenced. Difficult to read? Difficult to interpret?

No overall policy to ensure consistency = a haphazard, random and disorganised approach which does not comply with the SCI.

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7062

Received: 27/03/2018

Respondent: Mr & Mrs Peter & Christine Smith

Representation:

Representation not received on representation form; Council officer has made interpretation.

I have reviewed elements of the "Plan" as promulgated by yourselves and believe it to be fit for purpose against my limited knowledge of the technicalities involved with this process and of course the related Central Government legislation.

However, I have investigated the "Evidence Base" and found that to be very accurate and sensibly presented reflecting the views of our village (Wessington) and upon which I have commented before. I feel confident that using the documents developed by your researching team the "Plan" should be very suitable for the expectations of the next 20yrs or so and wish you every success in this development providing their accuracy has continued across the other affected areas of course

Full text:

I have reviewed elements of the "Plan" as promulgated by yourselves and believe it to be fit for purpose against my limited knowledge of the technicalities involved with this process and of course the related Central Government legislation.
However, I have investigated the "Evidence Base" and found that to be very accurate and sensibly presented reflecting the views of our village (Wessington) and upon which I have commented before. I feel confident that using the documents developed by your researching team the "Plan" should be very suitable for the expectations of the next 20yrs or so and wish you every success in this development providing their accuracy has continued across the other affected areas of course

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7075

Received: 27/03/2018

Respondent: Heather Brown

Representation:

Retrospective collection of evidence post-Plan. Brownfield Register dated December 2017; Sustainability Appraisal Reg 19 Report dated February 2018 (para 1.2.1: "...has been prepared to help inform the Council's preparation of their Local Plan."); GBTP and Statement of Duty to Cooperate presented March 2018; audio tape of March 5th Council meeting, comments made that Council only heard back from other authorities January/February 2018 re assistance on housing allocations. Makes mockery of public consultations; seems Council had already decided to build on Greenbelt, then gathered "evidence" to support this. Evidence should have informed the Plan, not other way round.

Full text:

Retrospective collection of evidence post-Plan. Brownfield Register dated December 2017; Sustainability Appraisal Reg 19 Report dated February 2018 (para 1.2.1: "...has been prepared to help inform the Council's preparation of their Local Plan."); GBTP and Statement of Duty to Cooperate presented March 2018; audio tape of March 5th Council meeting, comments made that Council only heard back from other authorities January/February 2018 re assistance on housing allocations. Makes mockery of public consultations; seems Council had already decided to build on Greenbelt, then gathered "evidence" to support this. Evidence should have informed the Plan, not other way round.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7090

Received: 27/03/2018

Respondent: Mr Eric Singleton

Representation:

Para 1.27, 1.31, 4.68, evidence base
The current consultation was commenced without key documents being available; some are 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 are 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).

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7104

Received: 15/03/2018

Respondent: National Grid

Agent: AMEC Environment & Infrastructure UK Limited (Leamington Spa office)

Representation:

We have reviewed the above consultation document and can confirm that National Grid has no comments to make in response to this consultation.

Full text:

National Grid has appointed Amec Foster Wheeler to review and respond to development plan consultations on its behalf.

We have reviewed the above consultation document and can confirm that National Grid has no comments to make in response to this consultation.

Further Advice
National Grid is happy to provide advice and guidance to the Council concerning our networks. If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us.

To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Grid wishes to be involved in the preparation, alteration and review of plans and strategies which may affect our assets. Please remember to consult National Grid on any Development Plan Document (DPD) or site-specific proposals that could affect our infrastructure. We would be grateful if you could add our details shown below to your consultation database:
Hannah Lorna Bevins
Consultant Town Planner
Spencer Jefferies
Development Liaison Officer, National Grid

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7194

Received: 01/04/2018

Respondent: Dronfield Green Belt Resident's Group

Representation:

The attached document is part of a group statement of objection being prepared by Dronfield Green Belt Group. It details serious shortcomings and procedural improprieties on the part of NEDDC during the public consultation and handling of representations made on the draft local plan 2017.
Particular attention should be paid to Appendix C which lists 67 missing themes of objection to building houses on Green Belt land in Dronfield, overarching core planning principles, that were not included in the Statement of Consultation 2018. These themes demonstrate a lack of exceptional circumstances and poor sustainability regards building houses on Green Belt.

Full text:

The attached document is part of a group statement of objection being prepared by Dronfield Green Belt Group. It details serious shortcomings and procedural improprieties on the part of NEDDC during the public consultation and handling of representations made on the draft local plan 2017.
Particular attention should be paid to Appendix C which lists 67 missing themes of objection to building houses on Green Belt land in Dronfield, overarching core planning principles, that were not included in the Statement of Consultation 2018. These themes demonstrate a lack of exceptional circumstances and poor sustainability regards building houses on Green Belt.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7255

Received: 03/04/2018

Respondent: Dronfield Civic Society

Representation:

The Publication Draft Local Plan is a very dense document, supported by other, equally dense documents. The Plan is not accessible to the lay public and is, therefore,at odds with the Council's own Statement of Community Involvement ( plain English, communicating clearly, making it easy for people to get involved etc) and with the NPPF, in the introduction of which the Secretary of State observed "people have been put off from getting involved because planning policy itself has become so elaborate and forbidding-the preserve of specialists, rather than people in communities. This NPPF changes that".

Full text:

The Publication Draft Local Plan is a very dense document, supported by other, equally dense documents. The Plan is not accessible to the lay public and is, therefore,at odds with the Council's own Statement of Community Involvement ( plain English, communicating clearly, making it easy for people to get involved etc) and with the NPPF, in the introduction of which the Secretary of State observed "people have been put off from getting involved because planning policy itself has become so elaborate and forbidding-the preserve of specialists, rather than people in communities. This NPPF changes that".