Employment Land Provision

Showing comments and forms 1 to 7 of 7

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6937

Received: 22/03/2018

Respondent: Mr Andrew Goodwin

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Paragraph 6.28 and Table 6.2- Ruling out plots that have deliver-ability issues leaves 28.87 hectares of employment land in the South of the district and just 2.85 hectares in the north. The strategic regeneration area at Callywhite Lane in has access issues that "will be resolved much later." There is incomplete explanation of these issues within the Local Plan. The new link road from Chesterfield Road is not referred to; it was proposed in the 2017 draft plan but is prohibitively expensive as it would need to cross the train line. New employment at Callywhite Lane is highly questionable.

Change suggested by respondent:

It seems that it may not be possible to resolve access issues, even "much later".
Reduce the number of houses on the local plan by communicating with cross boarder authorities. Thus reducing the number of proposed residents in new homes and the need for "New employment".

Full text:

Paragraph 6.28 and Table 6.2- Ruling out plots that have deliver-ability issues leaves 28.87 hectares of employment land in the South of the district and just 2.85 hectares in the north. The strategic regeneration area at Callywhite Lane in has access issues that "will be resolved much later." There is incomplete explanation of these issues within the Local Plan. The new link road from Chesterfield Road is not referred to; it was proposed in the 2017 draft plan but is prohibitively expensive as it would need to cross the train line. New employment at Callywhite Lane is highly questionable.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 6961

Received: 22/03/2018

Respondent: Mrs Sylvia Thompstone

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

These greenbelt developments are not sustainable because of increased pollution
From more traffic from extra car owners and putting pressure on already stretched services and infrastructure. At Coal Aston the Eckington road is already a busy fast and dangerous road which would be made worse by extra housing, say by at least one car per household, meaning 200 more vehicles. There are over 100 empty houses in Dronfield, why are they not being compulsory purchased to make them habitable.

Change suggested by respondent:

Lower housing number target to a more realistic level, nearer to that from the government proposed standard methology.
Include other alternative options for housing sources such as brownfield sites, small develoments which are less intrusive, fill-in sites, bring back into use local authority houses which have fallen into dis-repair to contribute to government targets.oor(

Full text:

These greenbelt developments are not sustainable because of increased pollution
From more traffic from extra car owners and putting pressure on already stretched services and infrastructure. At Coal Aston the Eckington road is already a busy fast and dangerous road which would be made worse by extra housing, say by at least one car per household, meaning 200 more vehicles. There are over 100 empty houses in Dronfield, why are they not being compulsory purchased to make them habitable.

Attachments:

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7103

Received: 26/03/2018

Respondent: Mrs H Tilly

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Reference to paragraph 6.28 and table 6.2 Employment Land Provision

These greenbelt development are not sustainable, will increase pollution through additional commuting and put unmanaged pressures on services and infrastructure.

Change suggested by respondent:

Lower housing target to a realistic level nearer that from the Government's proposed standard methodology.

Include alternative housing sources, brownfield sites, windfalls, small sites, sites near neighbouring authority, empty houses as contributors to target.

Full text:

These greenbelt development are not sustainable, will increase pollution through additional commuting and put unmanaged pressures on services and infrastructure.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7264

Received: 26/03/2018

Respondent: Maralyn and Bill Dommett

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Reference made to paras 6.28, 7.3, 7.4, 7.9, 7.10, 9.22-9.33, 9.59, 9.63-9.65, Table 6.2, Policy ID6

Amount of new housing in north of district needs to be reduced to account for mismatch in employment growth between north and south. Rail services are not that frequent. Car use to station necessary due to steep gradients distance, parking is limited. Increased traffic congestion raises safety issues. Dronfields banks and centre supermarket have closed not mentioned in plan. Proposals to build on green belt contravene the District Council's own policy on green infrastructure. No space for increased facilities at named medical centres or local schools.

Change suggested by respondent:

Opportunities to provide new jobs in the north of the district are limited, meaning this area is much less sustainable. Building new houses where there are very limited employment opportunities / growth within easy reach drives up commuting car use / pollution and is against the NPPF. A different spatial strategy is required and a reduction in the new housing in the north of the district needs to be made. Infrastructure considerations must be re-visited, based on a reliable and meaningful assessment.

Full text:

Amount of new housing in north of district needs to be reduced to account for mismatch in employment growth between north and south. Rail services are not that frequent. Car use to station necessary due to steep gradients distance, parking is limited. Increased traffic congestion raises safety issues. Dronfields banks and centre supermarket have closed not mentioned in plan. Proposals to build on green belt contravene the District Council's own policy on green infrastructure. No space for increased facilities at named medical centres or local schools. Further text of considerable length is attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7437

Received: 04/04/2018

Respondent: PMW Property

Agent: Cerda Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The approach taken to employment land allocation is inflexible and is likely to lead the plan to fail.

Change suggested by respondent:

Allocate further employment land such as the omission site at Temple Normanton.

Full text:

Table 6.2 sets out how 46.44 hectares of employment land will be made available within North East Derbyshire.

Objections are lodged on the basis that Table 6.2 ought properly to be identified in the plan as part of a policy expressly written to set out what, where and how employment land is to be brought forward to 2033.

Furthermore, Table 6.2 does not provide clarity on employment land allocations; for example, 27.44 hectares of the 46.44 hectares are identified as land within existing employment areas and is therefore already accounted for in terms of economic land availability.

As set out in other representations, the Council are seeking to deliver economic growth on only four strategic site allocations. Of these, approximately 50% of North East Derbyshire's entire employment requirement to 2033 are identified on land South of Markham Vale, Long Duckmanton. This is an inherently inflexible approach and any issues with the delivery of employment land at Markham Vale, in terms of the overall quantum of economic land to be delivered and the timing of delivery, will cause the Plan to fail.

This is important in the context of the recent historical trends in economic land in North East Derbyshire. Paragraph 6.4 of the Emerging Plan makes clear that there have been significant changes to the local economy and business base following the decline of traditional engineering and mining related activities in the 1980's. Given the uncertain recent past, there is nothing to say that there will not be an uncertain future in respect of economic development in North East Derbyshire. The Plan should therefore be inherently flexible to deal with rapid change and any unforeseen restructuring in the economic base area. Allocating only four strategic sites for employment development will not provide the opportunities for flexibility and the ability for the Plan to deal with rapid change.

Further justification in needing to provide for a broader distribution of sites across North East Derbyshire is set out at Paragraph 6.24 of the Emerging Plan. This states that there is an imbalance in the location of the portfolio of sites. Delivering economic growth on only four sites will perpetuate this imbalance and will not enable the benefits of new economic development to be spread, nor the delivery of economic growth co-located with housing which is an inherently sustainable approach to locating developments.

In light of the above, an omission site is put forward for land at Temple Normanton adjacent to the existing Langham Park site. The land extends to approximately 2 hectares, it is a contained parcel surrounded on four sides by road infrastructure. The site is a frontage to the existing employment site and can clearly be seen as an extension to the existing employment buildings.

The site can readily be serviced, there is primary road frontage, and allocating the site will sit four square with the NPPF which seeks to plan for the location, promotion or expansion of employment whilst also supporting new economic buildings in open countryside.

Given that the Council presently rely upon an out of date evidence base in respect of economic land delivery, and that the updated evidence base will almost certainly identify the need for additional employment land, the site performs well and can deliver economic growth early in the plan period.

The site is washed over as Green Belt however the Council recognise, finally, the need for reviewing the Green Belt and in this regard part of the evidence base underpinning the Emerging Plan is consideration of locations for release from the Green Belt.

Our assessment is that the site does not perform well against the five purposes for Green Belt as set out at Paragraph 80 to the NPPF. The development on the site would have a neutral impact in respect of sprawl of large built up areas, in this instance the proposals will be an extension to the existing economic buildings and could not be seen as being unrestricted since the site is bounded on all sides by roads. There are no issues in respect of neighbouring towns merging into one another, and whilst the site is currently open countryside in policy terms it does not convey the characteristics of traditional countryside given that it is bound by strategic highway network to the north, existing employment buildings immediately to the south with roads on the eastern and western boundaries. In that sense the site is a unique opportunity within North East Derbyshire comprising, in effect, a well-defined development plot, already serviced by virtue of the employment buildings immediately to the south, and is essentially inset from open countryside and Green Belt other than in respect of policy designation.

Returning to the five purposes of Green Belt as set out at Paragraph 80 to the NPPF, development on the site would have a neutral impact in respect of the setting and special character of historic towns, and finally the proposals would not result in the recycling of derelict land but would result in the development of what can be described as other urban land given the site characteristics described above.

As set out on the attached plan, the land at Temple Normanton is therefore put forward as an omission site capable of delivering approximately 2 hectares of employment land early in the plan period.

The approach would be consistent with the Emerging Plan which identifies at Policy WC1 an extension of the Callywhite Lane Industrial Estate, Dronfield which the Emerging Plan identifies as an extension to the existing Industrial Estate for B1, B2 and B8 uses on land extending to six hectares.

The omission site at Temple Normanton would follow a similar approach and, as with the Callywhite Lane Dronfield site, would in essence be a Phase II to existing economic activity.

Given that the existing employment land at Temple Normanton is identified as a primary employment area at Policy WC2, and therefore is protected as the highest priority employment land in North East Derbyshire, it follows that if protection of the existing employment land is important to the Council so too must be the continued expansion and support of that land to deliver further economic growth.

Allocating a Phase II to existing primary employment land at Temple Normanton would demonstrate the Council's commitment to supporting the existing businesses already located there.

Turning to the evidence base, the omission site at Temple Normanton was assessed as part of the Employment Sites Review in 2014. The site is identified as reference 229 and Paragraph 4.48 of the Employment Sites Review records as follows;


"Temple Normanton currently comprises of one large employment unit to the south and a smaller unit to the north, both appear fully active. A development platform appears to have been prepared within the site however this site is designated as Green Belt land and as such is not currently marketed. Should this site be released from the Green Belt it could prove to be attractive to the market".

This is important evidence of the deliverability of the omission site, as set out within the Councils own evidence base, supporting the representations that are being made in seeking removal of the site from the Green Belt and allocation for employment purposes.

As a result, Section 5 of the Employment Sites Review sets out land availability and recommendations and identifies the omission site at Temple Normanton as being available. The conclusion reached is that consideration of the site should be given for future employment use. In concluding on the omission site, the only constraint identified to delivery of employment land on the omission site is the Green Belt designation, and is a designation which can be addressed through the Emerging Plan.

In terms of the Green Belt Review undertaken by Nathaniel Lichfield and Partners in 2017, the omission site is identified along with the existing employment buildings as parcel reference TN/GB/005 extending to an area of approximately 6.1 hectares.

A key objection to the methodology applied to the Green Belt Review is that the site has been identified and assessed for housing delivery whereas the omission site put forward is for economic development.

Objections are also lodged to the methodology given that the existing site is assessed against Green Belt in addition to the omission site, and despite already being built upon the existing site fails a series of Green Belt criteria which is illogical and perverse.

Notwithstanding, it is not accepted that the parcel is not contained. The northern boundary is the Mansfield Road, part of the strategic highway network in this location. The Green Belt Review accepts that the site has strong and defensible boundaries to the north which we would agree with; it is not however accepted that the site does not have a strong boundary to the south given the southern boundary is defined by existing employment buildings which are urban in appearance and permanent in structure.

There is no justification to state that releasing the site from the Green Belt would result in a significantly weaker Green Belt boundary given the findings of the Green Belt Review which confirms that there is a strong defensible boundary to the north and these representations have set out that there is a strong defensible boundary by virtue of the existing buildings to the south.

So far as the second purpose for Green Belt, the Green Belt Review alleges that the removal of the parcel from the Green Belt would result in a strategic gap of 0.5 kilometres between Temple Normanton and Grassmoor and that removing the site would reduce the strategic gap. However, Grassmoor is situated to the south and the omission site is situated to the north of the existing employment buildings; consequently there would be no material change to the strategic gap to Grassmoor as a result since development would be away from Grassmoor rather than closer towards it.

There is a factual inaccuracy in respect of Purpose C2 since the parcel is substantially covered by more than 50% of built development by virtue of the omission site being assessed along with the existing building.

The Green Belt Assessments conclusions to Purpose C2 is in direct conflict with the response in respect of Purpose 3A, which states that the parcel is completely developed and in use as an industrial estate. This is supported by the response of Purpose 3B which confirms that the parcel is not in countryside use.

In terms of Purpose 4, the Green Belt Review acknowledges that there is no conflict in terms of preserving the setting and character of historic towns; whilst the site also supports urban regeneration (Purpose 5).

Having regard to the assessment made in the Green Belt Review, there is no conflict in respect of Purposes 4 and 5. The review alleges conflict with Purpose 1 and Purpose 2 with a largely neutral impact in respect of Purpose 3.

The promoters position is that for Purpose 1 allocation of the omission site would be within strong defensible boundaries and release of the parcel from Green Belt would not result in a significantly weaker Green Belt boundary. In terms of Purpose 2 the proposals would have no impact on a strategic gap, whilst there are factual inaccuracies and the parcel is substantially covered by more than 50% of built development. The correct assessment in respect of Purpose 2 is that the omission site should be identified as Green.

Finally, in respect of Purpose 3 whilst the Green Belt Review provides an amber assessment given that the site is completely developed and in use as an industrial estate, and the parcel is not in countryside use the omission site should be identified as Green.

The promoter's conclusions utilising the methodology set out in the Green Belt Review is therefore as follows;

* Purpose 1 - Green
* Purpose 2 - Green
* Purpose 3 - Green
* Purpose 4 - Green
* Purpose 5 - Amber (as with all Green Belt parcels assessed).

In light of the above, the omission site at Temple Normanton can be brought forward to meet economic needs in North East Derbyshire to 2033 without adversely affecting the five purposes for designating Green Belt.

The site also has the potential to form part of a mixed use function with employment and a community use such as a church. Enquiry's have been received by the promoter showing market interest in the site for this purposes which demonstrating both the site's deliverability and also ability to meet both an economic and social function.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7468

Received: 04/04/2018

Respondent: Dronfield Green Belt Resident's Group

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Only 2.85ha employment land is realistically deliverable in north sub-region during plan period.
Callywhite Lane requires new access road with expensive bridge to cross river and railway line. Funding no longer coming from railway electrification.
Norwood industrial land in Killamarsh too close to school and recreation space, road access uncertain.
28.87ha employment land deliverable in South (after deducting Hepthorne in Tupton which is questionable.
Settlement hierarchy, which directs most growth to largest towns, is not sound as 3 of 4 towns are in north sub-region where there will be little new employment growth.See also rep 7449 with group statement

Change suggested by respondent:

Delete allocations on all six green belt sites in north as not sustainable.
Utilise smaller brownfield sites spread over more settlements instead.
See suggestions in group statement attached to rep 7449

Full text:

Only 2.85ha employment land is realistically deliverable in north sub-region during plan period.
Callywhite Lane requires new access road with expensive bridge to cross river and railway line. Funding no longer coming from railway electrification.
Norwood industrial land in Killamarsh too close to school and recreation space, road access uncertain.
28.87ha employment land deliverable in South (after deducting Hepthorne in Tupton which is questionable.
Settlement hierarchy, which directs most growth to largest towns, is not sound as 3 of 4 towns are in north sub-region where there will be little new employment growth.See also rep 7449 with group statement

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Representation ID: 7914

Received: 04/04/2018

Respondent: Bolsover Land Ltd

Agent: iSec Group

Representation Summary:

Council Officer has amended the summary to approximately 100 words. Full representation attached.

Earlier representations provided comments in respect of general employment land provision and specifically site SS7 (South of Markham Vale). We note that the Council has since revisited its employment land evidence base and is allowing for 46ha (para. 6.2) and has removed the potential allocation of SS7 Markham Vale South. We fully support this new approach, had the Plan undermined the deliverability of its only Priority Regeneration Area, it could have been considered unsound in terms of not being effective, deliverable or based on a robust up-to-date evidence base.

In terms of the supporting text to Policy SS6(Paragraphs 4.50 - 4.54) , we support the general approach taken. We are looking to submit a revised scheme and consider it a sensible and sound approach for the Council not to rely on the site in terms of the delivery of housing.

Full text:

Generally support the policy subject to some amendments as suggested in the cover letter.

Supporting Text to Policy SS6
In terms of the supporting text (Paragraphs 4.50 - 4.54), we support the general approach taken. Comments in respect of the impact of HS2 reflect the current position, and as stated above, we are looking to submit a revised scheme in light of this. We therefore consider it a sensible and sound approach for the Council not to rely on the site in terms of the delivery of housing.
Figure 4.4
We support the removal of the previously included masterplan and consider it a far sounder approach to provide a site location plan for the proposed allocation of the site as a Priority Regeneration Area. Again, this provides a more flexible approach.
Employment Land Provision
Earlier representations provided comments in respect of general employment land provision and specifically site SS7 (as it was referenced in the Draft Local Plan in April 2017), Markham Vale South. We followed these comments up by providing a market commentary report (prepared by Knight Frank and appended to this letter) which indicated a chance of market saturation should Site SS7 also be released to the market alongside the former Coalite site, greatly undermining the viability and deliverability of the former Coalite site across both BDC and NEDDC.
We note that the Council has since revisited its employment land evidence base and is allowing for 46ha (para. 6.2) and has removed the potential allocation of SS7 Markham Vale South. For the reasons set out above we fully support this new approach, had the Plan undermined the deliverability of its only Priority Regeneration Area, it could have been considered unsound in terms of not being effective, deliverable or based on a robust up-to-date evidence base.
Some comments are also provided within the Local Plan about the M1 corridor and
Supporting Text to Policy SS6.
In terms of the supporting text (Paragraphs 4.50 - 4.54), we support the general approach taken. Comments in respect of the impact of HS2 reflect the current position, and as stated above, we are looking to submit a revised scheme in light of this. We therefore consider it a sensible and sound approach for the Council not to rely on the site in terms of the delivery of housing.