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Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7061

Received: 27/03/2018

Respondent: Ms Jan Gibbons

Representation:

As with the previous draft local plan I found this document to be very complex,long and difficult to understand. There is a lack of plain English and easily understandable explanations of planning and legal terms. Rather than being objective the language used seemed to be trying to justify the proposed outcomes. The Green Belt Topic Paper and the Duty to co-operate statement of compliance were not available to the public until 9 working days (excluding Bank Holidays) before the end of the consultation period. The plan does not appear to meet all of the requirements of community involvement strategy.

Full text:

As with the previous draft local plan I found this document to be very complex,long and difficult to understand. There is a lack of plain English and easily understandable explanations of planning and legal terms. Rather than being objective the language used seemed to be trying to justify the proposed outcomes. The Green Belt Topic Paper and the Duty to co-operate statement of compliance were not available to the public until 9 working days (excluding Bank Holidays) before the end of the consultation period. The plan does not appear to meet all of the requirements of community involvement strategy.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7065

Received: 27/03/2018

Respondent: Mrs Sylvia Machin

Representation:

Exceptional circumstances should be assessed
according to whether the strategy makes as
much use as possible of suitable brownfield
sites and underutilised land
through the Statement of Common Ground.

A Council with 'lax views'.

No exceptional circumstances demonstrated to take

Green Belt land.

No evidence of uplift on density to make effective

use of land available.

Taking the easiest option.

This Plan has not been positively prepared. It is not

justified and because the Green Belt Topic Paper is

not in the evidence base at the time of the

consultation, the Plan is probably not legally

compliant.

Full text:

Green Belt (Policy SS10) and Housing Allocations (LC1)



On 5th March 2018, the Prime Minister Theresa
May said that, "the answer to the housing crisis
does not lie in tearing up the Green Belt."
"The defining characteristic of the Green Belt is its openness.
Green Belts exist not to preserve landscapes but to prevent Urban Sprawl.
That is the Valuable purpose they still serve today."
She then encouraged increasing housing density, use of Brownfield and building upwards not outwards.
It is highly questionable whether NE Derbyshire
has demonstrated that they are in line with this
thinking within their Local Plan.

The Prime Minister also said that, "we'll expect
any development, whether in the Green Belt or
outside it, to look First at sites that have
previously been built on rather than opting
immediately for virgin countryside.
Planning rules already say that Green Belt boundaries should be changed only in "exceptional circumstances". But too many local authorities and developers have been taking a lax view of what "exceptional circumstances" means.
They have been allocating Green Belt sites for development as an easy option rather than a last resort."
To prevent this, we're strengthening existing policies so that authorities can only amend Green Belt boundaries if they can prove they have fully explored every other reasonable option for building the homes their community needs."

With this in mind, I would like to put forward that
NE Derbyshire is a clear example of an authority
taking a 'lax view' and taking the easy option.

NE Derbyshire has not made the case for

exceptional circumstances to justify taking any land

out of the Green Belt for housing.

The Green Belt Topic Paper is still missing from the evidence base as of 13/03/2018, so the process

should be halted until this vital piece of evidence is

there. The Plan is unsound without it and it would

not be legally compliant to add it retrospectively.

Does this provide the evidence in itself that this

authority has a 'lax view' of what exceptional

circumstances mean?

If as was stated in the full Council meeting on 5th

March, the Council had been advised to do a Green

Belt Review many months ago or perhaps now two

years ago, then surely the exceptional

circumstances should be in the evidence base for us

to consider.


Was the Green Belt Review even necessary?

What Is the real reason behind the fact that this

Paper is not there? As it is now half way through the

consultation period on the Publication Draft, and as

this document is still not in the public domain, surely

this is clear evidence that Green Belt sites have been

the easy option for housing allocations by this

Council.

The evidence base states that there is no shortage

of residential land within the HMA. There is

Brownfield land readily available, but because it

doesn't fit the Spatial Strategy, the Council through

their Plan is choosing to withhold it until after the

Plan period, prioritising Green Belt for the northern

towns of Killamarsh, Eckington and Dronfield with

allocations for 1275 houses underpinned by an

exaggerated assessment of need, as the only option

for housing allocations in the north. It is not.

Through the consultation last year and previously,

the residents of Dronfield have made NE Derbyshire

District Council aware of a Brownfield site adjacent

to a residential area but frontingCallywhite Lane. For

more than ten years the land and buildings upon it

were derelict, being the site of the old Padley and

Venables company which relocated to the northern

end of Callywhite Lane in new premises. After years

of neglect, dereliction and vandalism, the old

buildings were removed and the site levelled. There

has been long term vacancy.

That land has deliberately been protected by this

authority as employment land without any uptake in

years. It now stores pipes.

Bloor Homes were prepared to take the site on and mitigate any effects from the nearby industrial area with buffer zones and planting schemes.

They submitted a number of planning applications. The NPPF makes it clear that long-term protection of sites should not be happening, but this Council continues to designate this as employment land. Please examine the history of this site and it will demonstrate a strong case to deliver affordable housing, providing that a suitable access can be found which does not compromise existing residents.

The NPPF point 117 states that strategic plans
should "contain a clear strategy for
accommodating objectively assessed needs, in
a way that makes as much use as possible of
previously developed or brownfield land."


Whilst discounting available brownfield land, this

Council has also discounted another site because it

is next to a neighbouring authority which hadn't

asked for help with housing allocations. The site at

Hasland is still within NE Derbyshire and could

accommodate 160 dwellings. This approach is

surely counter-productive and a clear demonstration

that the Duty to Co-operate has not been complied

with.

A 'cutting off one's nose to spite one's face'

approach.

NE Derbyshire is guilty of taking the easy option in

line with a developer-led Plan before examining

rigorously options on uplift to housing density. This

is contrary to the NPPF which encourages efficient

use of land. The Plan does not demonstrate that

using different densities on the different sites

available has been examined thoroughly before

Green Belt land was sought. Rather than applying a

limited range in regard to density across the whole

area, the Plan should have demonstrated the

characteristics of the individual sites and adjusted

the achievable densities to make maximum use of

land availability on the brownfield sites as a priority.

Assuming 'exceptional circumstances' can be
demonstrated, the land that is to be removed from
the Green Belt which is countryside and in the main
used for agricultural purposes is being allocated to
large-scale development of 200, 235, 330 and 400
houses. All four sites when numbers are divided by
area equate to between 20 and 25 dwellings per
hectare.
Whilst this is not a true measure of density because
of access, green space and topographical
constraints, it nevertheless represents development
at very low densities which equates to suburban
sprawl. Examining all 35 sites where there are
housing allocations, reveals densities in the main of
20-30 dwellings. There are five sites where
densities are below 20 and four of densities above
30 dwellings per hectare. Those above 30 dwellings
per hectare equate to 126 houses. Those below
equate to 175 houses.

Point 123 of the NPPF states that it is especially
important that planning policies and decisions
avoid homes being built at low densities, and
ensure that developments make optimal use of
the potential of each site.
It is therefore appropriate to set out a range of
densities that reflect the accessibility and
potential of different areas rather than one
broad density range. They should respond to
local character and history, including the
surrounding built environment and landscape
setting, while not preventing or discouraging
appropriate innovation or change (such as
increased densities).

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7349

Received: 03/04/2018

Respondent: Mrs Kelly Warburton

Representation:

Plan does not demonstrate exceptional circumstances for releasing Greenbelt for housing.
Housing target overestimated: based on unrealistic economic forecasts and unnecessary inflation for affordable housing delivery.
Alternatives inappropriately excluded: brownfield sites, windfalls, small sites, site near neighbouring authority, empty houses, increased density on brownfield to meet affordable housing need.
Housing developments in north of District not aligned with economic strategy as major employment growth is in south and east.
These Greenbelt developments are not sustainable: will increase pollution through additional commuting and put unmanageable pressure on services, infrastructure.
Consultation poor. Parts of evidence missing, out of date or added retrospectively

Full text:

Plan does not demonstrate exceptional circumstances for releasing Greenbelt for housing.
Housing target overestimated: based on unrealistic economic forecasts and unnecessary inflation for affordable housing delivery.
Alternatives inappropriately excluded: brownfield sites, windfalls, small sites, site near neighbouring authority, empty houses, increased density on brownfield to meet affordable housing need.
Housing developments in north of District not aligned with economic strategy as major employment growth is in south and east.
These Greenbelt developments are not sustainable: will increase pollution through additional commuting and put unmanageable pressure on services, infrastructure.
Consultation poor. Parts of evidence missing, out of date or added retrospectively