Policy SS3: The Avenue

Showing comments and forms 1 to 7 of 7

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6852

Received: 16/03/2018

Respondent: DJ Atkinson Construction

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Representation not received on representation form; Council officer has made interpretation.
The Grassmoor Coal Yard site (see map) should be included within the Avenue Strategic Site Allocation (SS3) due to its close proximity to it.

Change suggested by respondent:

Include Grassmoor Coal Yard site within the Avenue Strategic Site Allocation (SS3).

Full text:

Full representation attached.

Attachments:

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7129

Received: 27/03/2018

Respondent: Chesterfield Borough Council

Representation:

Representation not received on representation form: Council officer has made interpretation

SS3 The Avenue
The council SUPPORTS the allocation of the Avenue site as a Priority Regeneration Area. The development of this site will need to be the subject of ongoing co-operation on cross boundary impacts, in particular the cumulative impact of additional traffic on the highways network and specifically on the A61 corridor.

Full text:

Thank you for the opportunity to comment upon the draft North East Derbyshire Local Plan and related documents.
Detailed comments and observations are set out below. As well as commenting on the Publication
Draft of the Local Plan, we have also provided comments on the Duty to Co-operate Statement of Compliance and Green Belt Topic paper. Where appropriate, reference is made to the council's comments on the draft Local Plan published in February 2017. The comments have been prepared by officers and approved by the Council's Executive Member for Planning.
Wherever possible, comments have been related to a specific policy or paragraph of the Local Plan publication draft.
Subject to the detailed comments set out below, overall the council is of the view that the plan has been positively prepared, is justified, effective and consistent with national policy as expressed in the National Planning Policy Framework.
We note that the consultation on the Local Plan ends on 4th April 2018 but that further documents may be published for consultation. The council may make further representations that relate to the Local Plan as a result of these further consultations.

NORTH EAST DERBYSHIRE LOCAL PLAN
VISION AND OBJECTIVES
D3 Tourism
SUPPORT the inclusion of Chesterfield Canal as a district wide objective. This project is the subject of on-going co-operation between the districts and councils through the Chesterfield Canal Partnership.
D7 Settlement Identity
SUPPORT objective
D14 Strategic Co-operation
SUPPORT the inclusion of the objective. Mechanisms and pathways for Co-operation on cross boundary issues between Chesterfield Borough and North East Derbyshire District are already well established through the HMA wide Local Plan Liaison Group, Sheffield City Region Planning Policy Officers Group, and Derbyshire Planning Policy Officers group. This co-operation has resulted in a strong shared evidence base across the LPA including the SHMA (currently being updated), Retail Study, Gypsy and Traveller Accommodation Assessment, and agreed methodologies for Land Availability Assessment and Green Belt Reviews.
N2 Countryside Recreation
SUPPORT reinstatement of Chesterfield Canal
S2 Regeneration
SUPPORT recognition of the role of Chesterfield as a key employment area

SPATIAL STRATEGY
Paras 4.7 to 4.12 and Policy SS2 Spatial Strategy and the Distribution of Development
We note the revised housing target of 330 dwellings per annum and SUPPORT the overall approach to meeting the District's Objectively Assessed Housing Need of 283 dwellings per annum within the district across the plan period, as previously discussed and agreed through the Local Plan Liaison group. The approach of setting a higher target to address affordability issues and support economic growth within the District is a reasonable approach and supported by robust evidence (as set out in para 9.26 of the joint North Derbyshire and Bassetlaw OAN update).
We note that an allowance has been made of 13% on top of the dwellings target. We do feel the plan could be clearer about how this buffer has been calculated, setting out the approach described in the council's Housing Topic Paper.
The council does note that the buffer relies almost entirely on windfalls and the associated topic paper sets out the evidence for this. As a result, any significant increase in lapse rate, or under delivery on numbers on allocated sites, could result in a shortfall of allocated housing supply and may increase pressure on neighbouring districts to allocate further land or to take the shortfall into account when calculating housing supply. Windfall and lapse rates should be closely monitored throughout the plan period.
SS3 The Avenue
The council SUPPORTS the allocation of the Avenue site as a Priority Regeneration Area. The development of this site will need to be the subject of ongoing co-operation on cross boundary impacts, in particular the cumulative impact of additional traffic on the highways network and specifically on the A61 corridor.
SS5 Markham Vale
SUPPORT the policy intention to bring forward development in line with the approved Design Framework.
SS6 Coalite Priority Regeneration Area
The council SUPPORTS the allocation of the Coalite site as a Priority Regeneration Area. The development of this site will need to be the subject of ongoing co-operation on cross boundary impacts, in particular the impact of additional traffic on the highways network and specifically on the capacity of J29a of the M1 and the Chesterfield Road/Rectory Road junction, taking into account the cumulative impacts of this proposal, land south of Markham Vale (policy SS7), the associated development of the Coalite site in Bolsover District, and the Staveley Works and Eastern Villages proposals in the adopted Chesterfield Borough Core Strategy and emerging draft Local Plan.
Whilst recognising the uncertainty in the end form of development created by the revised route of HS2 through the site, we do believe that the policy should nonetheless identify the range of uses that would be considered acceptable on the site and some indication of the potential scale of development.
Settlement Development Limits
Regarding Settlement Limits, the plan states that:

"4.58 This approach complies with the plan-led approach advocated in national policy(NPPF); since the Local Plan identifies sufficient housing provision for the District to meet both a five year supply of housing on adoption of the Plan and the development requirements for the Plan period. Further land outside Settlement Development Limits is therefore not required to meet this need."

The borough council does not have any comment regarding the use of SDLs as a policy tool, but are concerned that there is limited flexibility in delivering the housing requirement (13% buffer reliant on windfalls). In this regard it would be helpful if the Plan would explain why a review of SDLs was not assessed as a reasonable option in the plan preparation.
GREEN BELT
Para 4.69
SUPPORT the methodology used in undertaking a Green Belt review. We can confirm that the council was consulted on the methodology.
SS10 North East Derbyshire Green Belt
NOTE that the Proposals Map key refers to policy SS7 rather than SS10.
We note that that some areas of release are close to the borough boundary (and immediately adjacent in the case of releases south of Eckington) but have no objections in principle to the proposed releases.

HOUSING
LC1 Housing Allocations
SUPPORT the approach to meeting housing need. We note that sufficient allocations have been made to meet the outstanding housing need arising from applying the housing target in SS2 when completions are taken into account.
LC4 Type and Mix of Housing -
SUPPORT the policy approach to require a proportion of accessible and adaptable dwellings to reflect demographic projections within the HMA.
PROVISION FOR GYPSIES AND TRAVELLERS
Para 5.103 to para 5.106
Chesterfield Borough Council wishes to lodge a holding OBJECTION to this section of the Local Plan. This may be withdrawn if robust evidence is published on site identification and assessment.
The council is concerned that the NEDDC Local Plan does not allocate any sites for Gypsies and Travellers to meet the need identified in the Derbyshire Peak District and East Staffordshire Gypsies & Travellers Accommodation Assessment 2014. Whilst there is no objection in principal to the use of a criteria based policy where no suitable sites can be identified, to date no information on site identification and assessment has been published that supports the proposed criteria based policy approach. A request for assistance under the Duty to Cooperate to find sites for Gypsies and Travellers has been made by NEDDC to the borough council on the basis of a lack of suitable sites:
'NEDDC would request under the Duty-to-Cooperate that consideration be given to enabling one to two pitches to contribute towards meeting Travellers needs in North East Derbyshire, given this Council is struggling to identify suitable sites through the Local Plan process and is likely to have to rely upon a criteria based policy. NEDDC is still positively seeking to identify potential sites, however if CBC is in a position to assist this would give more flexibility to provision at the wider level and help meet the identified need in the 'North Derbyshire' Gypsy and Traveller housing market area.' The council considers that any site identification and assessment work undertaken by NEDDC should be published as soon as possible and reasonable time given to allow interested parties to make informed responses on the publication NEDDC Local Plan prior to submission to the SoS.
If the identified pitch requirements (15 pitches) are not met within NEDDC there will be a shortfall across the North Derbyshire GT HMA. This may result in additional pressure for sites within the borough and may lead to an increased risk of unauthorised encampments.
LC8 Provision for Traveller Sites
We acknowledge the difficulties with finding available and suitable sites and consider that the proposal to allow Gypsy and Traveller sites in the countryside (LC8 2) is a positive step to increasing provision in the North Derbyshire GT HMA , but could be strengthened by the inclusion of appropriate wording in policy SS9 to make it clear that Gypsy and Traveller Sites are a category in terms of criteria 1 of policy SS9.
Chesterfield Borough Council OBJECTS to the wording of Criteria 3 of policy LC8 and is concerned that the wording of LC8 (3) may prevent otherwise suitable sites from being delivered in NEDDC which could help to meet the needs identified for the HMA needs, particularly in the absence of any site allocations. Bolsover District Council has stated they cannot meet their own pitch requirements and Chesterfield Borough Council is in the process of assessing sites and cannot confirm whether sufficient sites can be found to meet needs within the borough. Planning applications for traveller sites should be determined on their merits and in accordance with the other criteria set out in policy LC8 and other parts of the plan, and in accordance with the national Planning Policy for Traveller Sites, without having to individually demonstrate a need.
WORKING COMMUNITIES AND ECONOMIC DEVELOPMENT
Para 6.17
SUPPORT the approach to allowing some capacity for losses of employment land over the plan period.
RETAIL AND TOWN CENTRES
WC5 Retail Hierarchy and Town Centre Uses
SUPPORT the sequential approach taken to the location of retail development. We note that in some locations, sequential assessments for planning applications for retail development may need to consider sites within Chesterfield Borough but expect this to be resolved through normal Development Control processes.
WC6 Visitor Economy and Tourism
SUPPORT the policy approach and specific reference to Chesterfield Canal.

SUSTAINABLE PLACES
SUPPORT the general approach taken to identifying and planning for key settlements. Agree that the settlements identified are the correct ones for the policy approach set out.
SP2 Clay Cross
We acknowledge the need for ongoing engagement across boundaries and with DCC regarding the impact of new development on the A61 corridor. This is already occurring under the umbrella of the A61 Growth Strategy and Investment Plan being led by Derbyshire County Council.
SP3 Eckington & SP4 Killamarsh
We note that Yorkshire Water have previously raised concerns about the ability of the Staveley Waste Water Treatment Works to accommodate additional growth in the east of Chesterfield Borough without further investment in capacity.
SDC10 decentralised, renewable and low carbon energy generation
We note that no sites have been identified within the district as suitable for windfarm development. SDC11 Flood Risk
SUPPORT the policy approach, in particular as a number of watercourses in NEDDC also run through areas of high flood risk in Chesterfield Borough (including the rivers Hipper and Rother). We note that interventions to reduce flood risk within Chesterfield Borough may involve works within North East Derbyshire; including the Avenue improvement schemes on the Rother and the Tin Mill storage reservoir on the River Hipper. At the time of writing these are identified on Chesterfield Borough's draft Local Plan IDP and within the scope of its CIL Regulation 123 list, which could enable contribution to these and similar schemes from developments within the borough.
We note the role of DCC as lead local flood authority and that proposed work on the Integrated Chesterfield Flood Model may also be beneficial for NEDDC too.
SDC13 Environmental Quality
SUPPORT the policy approach to requiring appropriate assessments. We note that this may involve identifying locations within Chesterfield Borough that will need to be assessed in relation to specific planning applications (particularly in relation to the A61/Derby Road and air quality) and expect this to be resolved through the normal Development Control processes.

INFRASTRUCTURE AND DELIVERY
We note that effective delivery of infrastructure may require cross boundary and multi LPA cooperation on specific schemes using mechanisms already in place through Derbyshire County Council (and the emerging Derbyshire Infrastructure Plan in particular) and the North Derbyshire and Bassetlaw Local Plan Liaison Group.

Para 9.5
SUPPORT the general approach to infrastructure provision set out. We note that there are likely to be specific instances of infrastructure provision where the Duty to Co-operate may apply, particularly in respect of the Staveley Waste Water works and the Tin Mill Flood reservoir. We note that Chesterfield Borough has implemented CIL and there exists the potential that some of this expenditure could support projects within North East Derbyshire to the benefit of both LPAs.
ID6 Green Infrastructure
SUPPORT the policy aim of improving and extending the network. We are committed to working jointly where links can be made across LPA boundaries.
ID8 Chesterfield Canal -
SUPPORT policy. Believe the policy could be further enhanced by adding text to actively seek enhancement/restoration of the canal where new development is proposed/permitted on or adjacent to it.
ID2 provision and safeguarding of transport infrastructure
SUPPORT the policy and in particular the Identification of "The A61 corridor from south of Chesterfield to Clay Cross as a priority area for a combination of sustainable transport measures and highways improvements".
ID1 infrastructure delivery and developer contributions
SUPPORT policy approach and note that this may require cross boundary co-operation on delivery of specific infrastructure proposals and that suitable mechanisms exist through the Derbyshire County Council Infrastructure Plan process and Local Plan Liaison Group to identify these on an ongoing basis.

DUTY TO CO-OPERATE STATEMENT OF COMPLIANCE
Chesterfield Borough Council and North East Derbyshire have a long history of co-operation, as neighbouring council's, as part of the North Derbyshire and Bassetlaw HMA and as members of both Sheffield City Region and D2N2 Local Enterprise Partnerships. The council supports the Statement as being an accurate record of co-operation between the two planning authorities.
The list of joint evidence base documents at Table 2 is a full and complete record, as are the tables of joint working groups set out in tables 3 and 4.
Chesterfield Borough, North East Derbyshire District, Bolsover District and Bassetlaw District are currently preparing a joint Statement of Common Ground, which will provide further evidence in support of the Duty to Co-operate.

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7206

Received: 02/04/2018

Respondent: Coverland UK Ltd

Representation:

Whilst we do not object to the strategic allocation of The Avenue site, the fact that it has been allocated since 2001, without any development being brought forward, suggests that the Council should explore other contingency sites in the vicinity of Wingerworth to ensure an adequate supply of housing to 2033. SHLAA site WW/1606 would represent an opportunity for additional housing land close to existing residential development, subject to its partial release from the green belt.

Full text:

Whilst we do not object to the strategic allocation of The Avenue site, the fact that it has been allocated since 2001, without any development being brought forward, suggests that the Council should explore other contingency sites in the vicinity of Wingerworth to ensure an adequate supply of housing to 2033. SHLAA site WW/1606 would represent an opportunity for additional housing land close to existing residential development, subject to its partial release from the green belt.

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7357

Received: 03/04/2018

Respondent: Natural England (Lincoln office)

Representation:

Natural England supports the bullet points aiming to improve green infrastructure and biodiversity gains.

Full text:

Natural England recognises Policy SS3:The Avenue was previously Policy SS4 but that there have been no other significant changes to the policy wording. Our previous comments still applies in that we welcome bullet point g) Provide effective pedestrian and cycle links to Chesterfield and nearby settlements, including through green infrastructure where this would not have an adverse impact on biodiversity and also support point j) which aims to Maintain and improve existing known areas of wildlife habitat and species, and include measures for habitat creation.
This site has great potential to make positive green infrastructure and biodiversity gains for the benefits of both wildlife and local residents. Therefore these opportunities should be maximised during the earliest stages of the development.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7626

Received: 03/04/2018

Respondent: Robert Wilson

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Policy/paragraph identified by Council officer.

There is too much development concentrated on one main road artery (A61) between Clay Cross and Chesterfield:

- Wingerworth (897 houses already granted + industrial use + 247 houses pending).
- Tupton (104 houses granted +497 houses pending)
- BiWater site (980 dwellings)

The impact on this already busy road appears huge; it already suffers considerable delays at peak times.

Change suggested by respondent:

A comprehensive survey on the traffic impact of all these combined developments on the A61 and the villages affected along it is required.

Full text:

There is too much development concentrated on one main road artery (A61) between Clay Cross and Chesterfield:

- Wingerworth (897 houses already granted + industrial use + 247 houses pending).
- Tupton (104 houses granted +497 houses pending)
- BiWater site (980 dwellings)

The impact on this already busy road appears huge; it already suffers considerable delays at peak times.

Supporting document is attached.

Attachments:

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7711

Received: 04/04/2018

Respondent: Sport England

Representation:

Compliance/soundness tests interpreted by Council officer.

Support protection, enhancement and provision of sports facilities in line with NPPF, and up to date evidence base work now undertaken to inform the policy.

Full text:

Support protection, enhancement and provision of sports facilities in line with NPPF, and up to date evidence base work now undertaken to inform the policy.

Attachments:

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 8047

Received: 04/04/2018

Respondent: Mr Paul Stock

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

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

There are concerns over the speed of delivery of the Strategic Allocation which will lead to a lack of housing supply in the early part of the Plan period and a shortfall of supply across the entire Plan. This needs to be addressed with further allocations.

Given this site was a major housing allocation in the 2005 Adopted North East Derbyshire and District Local Plan and did not deliver one new dwelling we consider there must be a high degree of uncertainty as to whether it will deliver the anticipated number of 700 new homes that the Plan expects to be delivered within the plan period.

Change suggested by respondent:

Faced with the undoubted housing shortfall, additional sites will be required in the short to medium term to ensure housing delivery is maintained and a 5-year housing land supply can be demonstrated across the plan period. We are therefore of the view that realistic delivery assumptions should be applied to the delivery of strategic sites and that these allocations are supplemented by increased provision from sustainable Level 2 settlements in the settlement hierarchy, such as Renishaw, so as to support the sustainability of settlements and in doing so bolster the ability to demonstrate a robust housing land supply.

Full text:

NORTH EAST DERBYSHIRE LOCAL PLAN - Publication Draft
Vision & Objectives
The vision for the District is set out within paragraph 3.1 of the Publication Draft Plan. Whilst we are fully supportive of the ambitious nature of this vision for a "vibrant and sustainable North East Derbyshire", it is critical the plan provides the policies which are capable of delivering this vision.
Policy SS1 - Sustainable Development
We are fully supportive of the sentiment expressed in paragraphs 4.3 and 4.4 that:
"The Local Plan's vision and objectives are centred on sustainable growth, which means encouraging sustainable development as means of .... Growing the District's economy, and supporting the health and wellbeing of the District's communities."
"Achieving sustainable development to create more sustainable patterns and forms of development in the district is the fundamental principle underpinning each policy of the Local Plan."
This affirms the Local Planning Authority's commitment to making local planning decisions based on a presumption in favour of sustainable development. It provides assurance of a local approach to planning that will proactively seek to improve the social, environmental and economic well-being of the area by ensuring that development demonstrably contributes to the specific strategic and local vision and objectives of the Local Plan. The ethos of sustainable development is the key to assessing planning proposals. It is the golden thread running through the NPPF.
Policy SS2 - Spatial Strategy and Distribution of Development
Housing Target
In paragraph 4.7 of the plan it refers to the methodology being similar to the Government's proposed standard methodology but remains silent on explaining the differences which could well be critical at arriving at the appropriate OAN figure. The lack of transparency on this point is worrying and must call into the doubt the final figure that has been calculated.
In paragraph 4.8 of the plan the Council is apparently dismissive of the combined effect of the Sheffield City Region and D2N2 Local Enterprise Partnerships on the growth of population and housing in the Housing Market Area. We consider the Council should be required to place greater emphasis in clarifying the position rather than stating it is "difficult to determine" and then leaving the matter.
We consider this has the potential to require a significant increase in the OAN figure required.
In paragraph 4.9 of the plan it states the Council's Regeneration Scenario takes into account the potential for higher growth in certain key sectors reflecting the Council's and wider LEP's Economic Development Strategies, but then states the "assumption used is somewhat conservative"
We consider the statement made in paragraph 4.24 is too generalised a District wide comment
"The housing and economic evidence presented above indicates that the proposed employment land provision and housing provision are well balanced, the latter providing sufficient population to support growth in the economy"
We consider the proposed housing target of 330 dwellings a year and 6,600 over the plan 2014-2034 is not sufficient. In light of our overarching comments expressed in section 6 of these representations and the comments set out above we object to Policy SS2 in that it fails to identify the full need for housing across the Housing Market Area (HMA) which is unjustified and therefore unsound.
Balancing Housing and Economic Growth
We consider the statement made in paragraph 4.24 that is too generalised a District wide comment
"The housing and economic evidence presented above indicates that the proposed employment land provision and housing provision are well balanced, the latter providing sufficient population to support growth in the economy"
We consider the proposed housing target of 330 dwellings a year and 6,600 over the plan 2014-2034 is not sufficient. In light of our overarching comments expressed in section 6 of these representations and the comments set out above we object to Policy SS2 in that it fails to identify the full need for housing across the Housing Market Area (HMA) which is unjustified and therefore unsound.
Balancing Housing and Economic Growth
We consider the statement made in paragraph 4.24 that is too generalised a District wide comment
"The housing and economic evidence presented above indicates that the proposed employment land provision and housing provision are well balanced, the latter providing sufficient population to support growth in the economy"
It does not reflect local cases where the proposed employment land provision and housing provision are not well balanced. A good example of this is in the case of the settlement of Renishaw which is a Level 2 sustainable settlement with a proposal for 2.5 hectares of employment land but the plan makes no provision for new housing over the life of the plan period to 2034.
Distribution of Growth & the Settlement Hierarchy
With regard to Policy SS2, we support in general terms the provision made under the heading Housing, Item 4, that
"The remaining housing development will be focused on the District's other most sustainable settlements defined as Level 2 settlements in the Settlement Hierarchy at Table 4.2."
We also support the reference in Settlements, Item 8b and c to
"Regenerate towns Level 2 settlements with identified needs."
and
"Maintain the role of settlements by supporting their ability to sustain services and facilities through new development that is appropriate in scale and reflects their position in the Settlement Hierarchy."
Arbitrarily In the case of the sustainable Level 2 settlement of Renishaw the Plan makes no new housing provision which we consider is not justified and unsound. This is set out in further detail of section 8 of this submission.
The proposed housing distribution for the Plan is shown in Table 4 - Housing Distribution by Level 1 & Level 2 Settlements. This indicates that for the sustainable Level 2 settlement of Renishaw a provision of only 6 dwellings is proposed in the period 2014 to 2034 even though in Policy WC2 Principal Protected Employment Areas and Table 6.2 it refers to the protection 2.5 hectares of employment land at the Renishaw Industrial Estate for employment use. With such an important employment allocation it is clear there will be considerable local economic pressures for the settlement to grow which have not been catered for in the Publication Plan. Currently the settlement is severely constrained in planning policy terms by being contained on all sides by Green Belt which thwarts much needed expansion on the edge of the settlement. This will have a significant and harmful effect on the ability of the settlement to regenerate and cater for these new requirements, including affordable housing. For this reason we consider the present Policy SS2 and Policy SS10 (Green Belt) is not justified and therefore unsound.
We believe the best way in which to ensure the delivery of housing targets is to ensure all settlements within the Level 2 settlement category receive a sufficient housing provision to cater for development pressures over the plan period. Whilst the new strategic allocations will help meet housing demands in the medium/long term, the level of infrastructure required to deliver the sites is costly and substantial it is therefore likely to take time to implement. We would contend however that a greater percentage of should be directed to Level 2 settlements to ensure they meet their short and medium term housing needs.
It is our view the spatial strategy needs to give further consideration for the release of other land from the Green Belt plus the identification of safeguarded sites in order to sufficiently meet the present housing target and spatial strategy and cater for pressures in the future.
Without the release of further land from the Green Belt, the identification of safeguarded areas for the provision of housing in the future, and the provision of further housing allocations at sustainable Level 2 settlements such as Renishaw, we consider that it would be problematic for the proposed spatial strategy to deliver housing needs. We therefore consider Policy inconsistent with National Policy and not justified or effective and as such unsound.
We are concerned that the formulated strategy does not to support the future housing needs of each settlement within the Level 2 settlement category or the needs of those communities in terms of the of local facilities in either quality or quantity. As in the case of Renishaw which has a wide range of facilities including a primary school, local doctor's surgery, food shops, public house and Post office, church, village hall and recreation ground plus several bus services (No: 71, 73, 74, 131 and 9.1.2 231), providing access to wider services and sources of employment at Barlborough and Killamarsh It also has extensive local employment opportunities at Renishaw Park with a further 2.5 hectares of land available for expansion to accommodate more new businesses.
In the absence of further justification, we submit that the spatial strategy and distribution of development outlined in the Plan has not been justified as is therefore unsound.
Policies SS3 & SS4 Strategic Housing Allocations
We note the proposal for two strategic housing allocations at the Avenue and the former Biwater site. We are however concerned that the scale, complexity and development requirements is such that their anticipated deliverability is questionable and consequently considers that the Plan contains unrealistic expectations for the delivery of new housing in such developments.
We considers there must be some degree of uncertainty as to whether the two strategic housing sites will deliver the anticipated number of new homes that the Plan expects to be delivered within the plan period which will be significantly less than set out in the policy.
The need for a considerable amount of infrastructure to be provided plus significant lead-in times associated with each site calls into question the ability to deliver 1,541 units by 2034 from this source.
Policies SS3 and SS4 also set out a comprehensive and detailed list of requirements which will need to be provided as part of each strategic housing site, including 30% affordable housing, employment provision, a package of transport improvements, new healthcare facilities, new district and neighbourhood centres, a secondary school, primary schools and early- years facilities amongst other requirements.
This raises the question of development viability, cash flow in financing the sites and in the ultimate deliverability. The legal agreements associated with any planning proposals for the site will similarly be lengthy and complex which will add significantly to the lead-in times associated with the site.
Faced with this undoubted housing shortfall, additional sites will be required in the short to medium term to ensure housing delivery is maintained and a 5-year housing land supply can be demonstrated across the plan period. We are therefore of the view that realistic delivery assumptions should be applied to the delivery of strategic sites and that these allocations are supplemented by increased provision from sustainable Level 2 settlements in the settlement hierarchy, such as Renishaw, so as to support the sustainability of settlements and in doing so bolster the ability to demonstrate a robust housing land supply.
Policy SS3: The Avenue
We are concerned that the scale, complexity and development requirements is such that the anticipated deliverability is questionable and consequently considers the Plan contains unrealistic expectations for the delivery of new housing at this location. A Framework Plan has still to be prepared which will require provision for 4 hectares of employment land provided and provision of a new primary school, sport and recreational facilities, provision of a new link road from A61 to A617 and new pedestrian and cycle links.
Given this site was a major housing allocation in the 2005 Adopted North East Derbyshire and District Local Plan and did not deliver one new dwelling we consider there must be a high degree of uncertainty as to whether it will deliver the anticipated number of 700 new homes that the Plan expects to be delivered within the plan period. It is also likely any development scheme will encounter local market resistance due to it well known legacy of extensive contamination on the site.
Policy SS4: Former Biwater Site, Clay Cross
Again we are concerned that the scale, complexity and development requirements is such that their anticipated deliverability is questionable and consequently considers that the Plan contains unrealistic expectations for the delivery of new housing at this location. A Framework Plan has still to be prepared which requires a comprehensive remediation and mixed use development, including 8 hectares of employment land, range of small shops, provide new sports and recreational facilities. Provide new pedestrian and cycle links and provide a new through road from the A61 to A617.
Given this site was a major housing allocation in the 2005 Adopted North East Derbyshire and District Local Plan there must be a high degree of uncertainty as to whether the anticipated number of 825 new homes that the Plan expects to be delivered within the plan period will be significantly less than set out in the policy.

See supporting documents attached.