Question 12

Showing comments and forms 1 to 12 of 12

Support

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9185

Received: 07/01/2019

Respondent: Environment Agency

Representation:

Officers have summarised the representation.

CAL/2301T, NW/2301T, GT/06 - These sites are situated on a secondary aquifer. If the site is located next to a main sewer we would recommend that the development connects up to this. If this is not the case the foul drainage will need to be connected to a Package Treatment Plant (PTP) in line with the hierarchy information highlighted in the Planning Practice Guidance, Section: Water Supply, wastewater and water quality, paragraph 20.

GT/09 - This site is situated on a primary aquifer. The site appears to be situated near to an existing combined sewer and foul drainage should be connected to this if feasible. If this is not the case the foul drainage will need to be connected to a Package Treatment Plant (PTP) in line with the hierarchy information highlighted in the Planning Practice Guidance, Section: Water Supply, wastewater and water quality, paragraph 20.

Full text:

Thank you for the consultation on this examination. We have the following general comments in response to the Matters, Issues and Questions (MIQs), question 12.

Site 1: The Old Potato Store, Dark Lane, Calow
This site is situated on a secondary aquifer. If the site is located next to a main sewer we would recommend that the development connects up to this. If this is not the case the foul drainage will need to be connected to a Package Treatment Plant (PTP) in line with the hierarchy information highlighted in the Planning Practice Guidance, Section: Water Supply, wastewater and water quality, paragraph 20.

Site 2: Dark Lane, North Wingfield
This site is situated on a secondary aquifer. If the site is located next to a main sewer we would recommend that the development connects up to this. If this is not the case the foul drainage will need to be connected to a Package Treatment Plant (PTP) in line with the hierarchy information highlighted in the Planning Practice Guidance, Section: Water Supply, wastewater and water quality, paragraph 20.

Site 3: Greenway, Wingerworth
This site is situated on a secondary aquifer. If the site is located next to a main sewer we would recommend that the development connects up to this. If this is not the case the foul drainage will need to be connected to a Package Treatment Plant (PTP) in line with the hierarchy information highlighted in the Planning Practice Guidance, Section: Water Supply, wastewater and water quality, paragraph 20.

Site 4: Temperance Hill, Woolley Moor
This site is situated on a primary aquifer. The site appears to be situated near to an existing combined sewer and foul drainage should be connected to this if feasible. If this is not the case the foul drainage will need to be connected to a Package Treatment Plant (PTP) in line with the hierarchy information highlighted in the Planning Practice Guidance, Section: Water Supply, wastewater and water quality, paragraph 20.

Object

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9222

Received: 09/01/2019

Respondent: Sue Fletcher

Representation:

I fail to understand the reasoning around declining the building of new houses in the area and you want travellers to take up residence.

Full text:

I fail to understand the reasoning around declining the building of new houses in the area and you want travellers to take up residence. ...redacted...?

Support

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9223

Received: 09/01/2019

Respondent: The Coal Authority

Representation:

Thank you for your notification of 4 January 2019 seeking the views of the Coal Authority on the above consultation.

I have reviewed the information made available on the LPA website and can confirm that we have no specific comments to make.

Full text:

Thank you for your notification of 4 January 2019 seeking the views of the Coal Authority on the above consultation.

I have reviewed the information made available on the LPA website and can confirm that we have no specific comments to make.

Support

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9327

Received: 29/01/2019

Respondent: High Speed Two (HS2) Limited

Representation:

Thank you for consulting HS2 Ltd on the above consultation.
Having reviewed the plans and documents associated with the Local Plan, I can confirm that HS2 Ltd raise no objection to the proposals.

Full text:

Thank you for consulting HS2 Ltd on the above consultation.
Having reviewed the plans and documents associated with the Local Plan, I can confirm that HS2 Ltd raise no objection to the proposals.

Support

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9472

Received: 08/02/2019

Respondent: National Federation of Gypsy Liaison Groups

Representation:

We generally support the approach taken to meeting the needs of Travellers.

However, it is clear that the sites proposed at Wingerworth and Wooley Moor will result in strong local opposition and may be difficult to deliver. Even if these sites can be delivered, there will remain a shortfall. Accordingly, we believe that the criteria based policy to deal with sites which come forward for approval should be as flexible as possible.

With regard to the other two sites put forward for allocation, at Calow and North Wingfield, we support these, although we believe that the site at North Wingfield is likely to provide only two pitches. On the other hand, we consider that the site at Calow could be extended to the south to create a site for three pitches in total. There is a willing owner. We dispute the doubts raised about the adequacy of the access.

Full text:

These comments are made in response to the consultation on the above Plan. We generally support the approach taken to meeting the needs of Travellers.

However, it is clear that the sites proposed at Wingerworth and Wooley Moor will result in strong local opposition and may be difficult to deliver. Even if these sites can be delivered, there will remain a shortfall. Accordingly, we believe that the criteria based policy to deal with sites which come forward for approval should be as flexible as possible.

With regard to the other two sites put forward for allocation, at Calow and North Wingfield, we support these, although we believe that the site at North Wingfield is likely to provide only two pitches. On the other hand, we consider that the site at Calow could be extended to the south to create a site for three pitches in total. There is a willing owner. We dispute the doubts raised about the adequacy of the access.

Object

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9555

Received: 14/02/2019

Respondent: rob mallender

Representation:

Access to the site is limited and the type of vehicles accessing the land will make access roads congested.
the site is already congested with buildings taken over in an unsafe manner with cars being broken down on site. this will then escalate and the local authority do not have the controls in place to monitor this. The site is in a quiet area of the village and local residents are mainly elderly in the bungalows which overlook the site. Horses are already grazing in local fields and on the local park.

Full text:

Access to the site is limited and the type of vehicles accessing the land will make access roads congested.
the site is already congested with buildings taken over in an unsafe manner with cars being broken down on site. this will then escalate and the local authority do not have the controls in place to monitor this. The site is in a quiet area of the village and local residents are mainly elderly in the bungalows which overlook the site. Horses are already grazing in local fields and on the local park.

Object

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9610

Received: 14/02/2019

Respondent: Stretton Parish Council

Agent: Charlotte Stainton

Representation:

Summary by Officer.

The site selection process is not soundly based. There was no consultation with residents prior to January 2019 and consultation included only people on the Local Plan database. No letters were sent to the immediate neighbours to the sites. There is no evidence that the location of the proposed allocations is supported by the Gypsy and Traveller community.
Landscape Impact did not feature in the Step 2 Site Screening. Potentially suitable NEDDC/ DCC owned site excluded for unsound reasons. The conclusions do not accord with conclusions reached in the Council's evidence.
The Site Selection methodology has not been consistently applied to all the sites considered over the years. Site GT/09 should have been discounted at step one. The site selection process is not robust as the Council has failed to consider key evidence.

Full text:

See Attachment.

Support

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9622

Received: 13/02/2019

Respondent: Historic England

Representation:


Historic England is aware that the Council is no longer considering taking forward site GT/06 Greenway, Wingerworth at this time. Notwithstanding this, I can advise that Historic England has no concerns to raise in relation to its remit for the historic environment and the four sites set out in the consultation document.

Full text:


Historic England is aware that the Council is no longer considering taking forward site GT/06 Greenway, Wingerworth at this time. Notwithstanding this, I can advise that Historic England has no concerns to raise in relation to its remit for the historic environment and the four sites set out in the consultation document.

Object

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9667

Received: 15/02/2019

Respondent: NEDDC Conservative Group

Agent: Mr Alex Dale

Representation:

Summary by Officer.

The Council has failed to provide adequate information in relation to various aspects of their site selection processes within the Topic Paper. For example, the initial list of 385 sites has not been provided, nor have they adequately explained how they were sifted down to 38. Moreover, the process of sifting the 840 sites down to 8 has not been explained. We believe that this information should be in the public domain so that local residents can assess whether reasonable alternatives have been given proper consideration.

We are extremely disappointed with the way in which this consultation has been approached by the Council.

Full text:

I am writing in response to the above consultation on behalf of the Conservative Group on North East Derbyshire District Council. As you will be aware, we are the main opposition group on the Council.

As a group of Councillors, we are aware of very serious concerns from the public over a number of aspects of the proposed new sites and particularly the way in which the consultation has been handled by the Council.

We wish therefore to raise concerns over a number of aspects in relation to this consultation, which can broadly be categorised as follows:
* Out of date needs assessment, methodology and data
* Lack of justification regarding site selection processes
* Poor handling of the consultation

Needs assessments
Firstly, we are concerned that the Council's assessment of the accommodation needs of gypsies and travellers is still based on the GTAA which was conducted in 2014. This of course was based on 2007 guidance issued by the Department for Communities and Local Government, which has subsequently been withdrawn by the Government in 2016.

In addition, the Government produced new policy guidance in 2015 which altered the definition of gypsies and travellers in planning terms. The use of this new definition should exclude those who have permanently ceased from travelling.

The GTAA is therefore now considerably out of date and we believe it no longer represents a relevant needs assessment on which the Council can base its provision requirements. The Council should have undertaken a new needs assessment following the changes in 2015/16 and it is our view that this would have resulted in the authority identifying a significantly lower level of need and thus less pressure on finding suitable sites.

We are also concerned that the GTAA relies on the data from surveys conducted in 2014, contrary to paragraph 31 of the NPPF which highlights the need for up-to-date evidence to be used when preparing a Local Plan.

Finally, the methodology used as part of the GTAA relies on inadequate assumptions - for example that the inflow and outflow of gypsies and travellers would be equal, when there is no evidence provided to support this. The GTAA also suggests that the respondents were self-selecting as those who were more likely to stay in the area, which therefore distorts the objectivity of the needs assessment because it does not accurately take account of those who do not wish to stay.

Site selection processes
The Council has failed to provide adequate information in relation to various aspects of their site selection processes within the Topic Paper. For example, the initial list of 385 sites has not been provided, nor have they adequately explained how they were sifted down to 38. Moreover, the process of sifting the 840 sites down to 8 has not been explained. We believe that this information should be in the public domain so that local residents can assess whether reasonable alternatives have been given proper consideration.

Consultation
We are extremely disappointed with the way in which this consultation has been approached by the Council.

Clearly the rest of the Local Plan is in a late stage in its development and has already now been subject to an inquiry process. For every other proposal within the Local Plan, residents, community groups and other stakeholders have had at least two separate consultations through which to make their views known. While we still have concerns about the way in which these previous consultations were advertised to members of the public, to bring a consultation forward over such a sensitive topic so late in the day in the Plan-making process is of deep concern to us. Residents in communities such as Wingerworth, Woolley Moor, North Wingfield and Sutton understandably feel let down by the Council for failing to bring these proposals to their attention hitherto.

It is our view that the Council has been far too slow to act in bringing together its proposals for gypsy and traveller provision and this has been to the detriment of local residents who have had only a very short timeframe to digest, understand and comment on significant proposals which only became public on 4th January.

The Council's withdrawal of the Wingerworth site part way through the consultation, while a welcome decision, has only served to confuse the public over the status of this site and whether or not there was still a need to engage with the consultation.

In summary we do not believe the Council's approach to gypsy and traveller provision is a sound one and there are far too many flaws in the needs assessment and site selection processes, as well as the consultation itself.

We would be grateful if the above comments could be taken into account as part of the inquiry process moving forward. We also wish to indicate our desire to speak at the planning inquiry sessions on this topic once they have been arranged.

Object

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9669

Received: 15/02/2019

Respondent: Sheelagh Judge

Representation:

Summary by Officer.

The Sustainability Assessment of GT/09 is flawed. Site is next to or within a level 4 settlement and should have been discounted for detailed site assessment as part of the updated LAA methodology. The Topic Paper updated the LAA methodology to widen the scope of sources of available land to bring in new sites. GT/09 was not screened in accordance with this agreed criteria (para 4.19). The Site Selection Approach 2018 did not seek to amend this criteria but sought to identify publicly owned land for site screening and to focus upon family-sized sites. The council was erroneous in their late inclusion of site GT/09 for the detailed assessment stage and GT/09 should have been discounted.

Have NEDDC policies been applied consistently and in accordance with their legal duty to do so and in particular whether the decision to include GT/09 for further detailed assessment is contrary to their own policy - SS1.

Full text:

Please find below my comments in relation to NEDDC's proposed traveller site GT/09, Temperance Hill, Woolley Moor. These are set out in response to the Examination Consultation MIQs.
Main Matter 15
Issue - Whether the plan is based on a robust assessment of need for gypsies and travellers
Question 2:
The GTAA is not in line with planning policy as set out in the PPTS 2015. It pre-dates the changes set out in PPTS 2015 and the Housing and Planning Act 2016.
The GTAA uses an outdated definition of traveller which includes those who have 'permanently ceased' to travel.
Two thirds of the 21 respondents surveyed in NEDDC (i.e. 91.3% of the traveller population households - para 6.3 and 6.4 page 81 of GTAA) stated that they did not intend to move suggesting that these respondents did not themselves fall within the 2015 definition. In addition the GTAA identifies a requirement for 1.9 pitches to be allocated to travellers currently in housed accommodation who may have ceased to travel.
The methodology used in the GTAA is therefore outdated and not robustly based. The results of the GTAA assessment does not provide an indication of current need.
This issue is raised by the Inspector in her letter to the Council dated 28/7/2018. In the Council's reply dated 3/8/2018, Helen Fairfax stated that the council will not commission further assessment but will await a refresh of the GTAA due in 2019/2020. Helen Fairfax concludes that the impact of the new definition may be to reduce the requirement slightly, if at all.
This assumption is not based upon evidence and, given the proportion of respondents who would be excluded from the revised definition, it is likely that the reduction in the requirement will be more than slight.
Further, there were no unauthorised encampments (suggesting limited need) in the NEDDC area in 2014 (GTAA table 9.2 page 143). The purpose of the new definition is to prevent unauthorised encampment. It could be concluded that the requirement for pitches may be low.
Since the rules changed in 2015, many councils have found that they need fewer pitches. Tewkesbury, for instance, cut its assessment from 147 caravan spaces to only eight. Four London boroughs, which at the last count said they needed around 50 new pitches between them, now say they require none. Friends, Families and Travellers, a charity, compiled a list of such changes in south-east England. Of the 27 authorities with comparable data, 21 plan to provide less space than before.

Issue - Whether or not the proposed sites identified for gypsy and traveller accommodation would be soundly based in terms of their location and site specific impacts
Question 12 Is the site selection process soundly based and has it been informed by the relevant factors including site location, access to services and facilities, site size and other relevant constraint?
Question13 Has the site selection process been informed by Sustainability Appraisal and is it clear how this has informed the Identification of the sites proposed for gypsy and traveller accommodation?

The Sustainability Assessment of Site GT/09 is flawed
1. Site GT/09 is next to or within a level 4 settlement and should have been discounted for detailed site assessment as part of the updated LAA methodology
Woolley Moor has been designated as a level 4 settlement (see North East Derbyshire District Council Development Limits Review published January 2019).
The Gypsy and Travellers Topic Paper NEDDC May 2018 updated the Land Assessment Availability methodology so as to widen the scope of sources of available land to bring in new potential sites for travellers

Paragraph 4.19 states that:

'As a first step, these sites were screened through the use of criteria similar to Step 1& 2 of the site selection process. Sites are discounted if they:
* are located within the Green Belt or a Local Settlement Gap area; or
* are situated within or next to Level 4 settlements7;'
Site GT/09 was identified as a potentially available site very late in the process. It was not screened in accordance with this agreed criteria. The Site Selection Approach 2018 (ED44b) did not seek to amend this criteria but sought to identify publicly owned land for site screening and to focus upon family-sized sites. It is submitted that the council was erroneous in their late inclusion of site GT/09 for the detailed assessment stage and GT/09 should have been discounted as part of the initial screening process based on Step1 and Step 2.
Para 2.8 of ED44b clarifies adjustments made to the criteria in order to avoid excluding potentially suitable sites too early. Document ED44b does not amend the criteria in respect of proximity to Level 4 settlements.
The reason that all identified sites situated within or next to Level 4 settlements were automatically excluded is because level 4 settlements are defined as having very limited sustainability and sites in these areas will be unsuitable in terms of location.
I would ask the Inspector to examine whether the stated policies of the NEDDC have been applied consistently and in accordance with their legal duty to do so and in particular whether the decision to include GT/09 for further detailed assessment is contrary to their own policy - SS1.

1. The detailed sustainability appraisal of site GT/09 is inaccurate.
Notwithstanding the issues outlined above I would ask the Inspector to consider the following significant errors in the screening and sustainability appraisal of GT/09.
In document ED44d appendix 5
POLICY ASSESSMENT 28. The suitability conclusion is flawed as it is based upon errors regarding local services and visibility splays as detailed below.
POLICY ASSESSMENT 1. The identified site size is inaccurate. The site is smaller than 1500 square metres and will not accommodate 3 pitches of 500 sq metres. The area will be further reduced if the principals of DCLG Good Practice Guidance on Designing Gypsy and Traveller Sites (May 2008) are followed.
POLICY ASSESSMENT 11. The visibility splays have not been calculated with reference to the mitigation recommendations for the eastern boundary.
POLICY ASSESSMENT 25. There is not a post office less than 500 metres away from the site. The nearest post office is in Ashover 2.2miles away. The shop referred to at Stretton is a garage and to describe this as a shop is misleading.
POLICY ASSESSMENT 18. The impact upon nature conservation has been inadequately assessed. The conclusion that 'ecological impacts are not considered likely to be significant' lacks robust investigation and evidence. (see further comment below under Question 28.)
POLICY ASSESSMENT 22. The conclusion as to scale is disputed. This site is near to the remains of old Woolley which forms a separate hamlet and is of significance to the historic environment. It consists of some 12 houses. 3 pitches would be disproportionate in scale to the adjoining hamlet representing a 25% increase.
In document ED44b
Para 3.17.5 GT/09 is not within the target distance of a NHS hospital that provides A&E and mainstream treatment. Clay Cross hospital is an appointment based clinic for orthopaedic and related services. The nearest hospital is Chesterfield Royal Hospital 8.4 miles away.
Para 3.17.6 This conclusion is not supported by evidence. It disregards the stream in the valley below which could become polluted by surface water or other effluent draining away from the site. This stream feeds into Ogston Reservoir which is an SSI. The paragraph makes no mention of noise pollution that may emanate from the site. This part of Woolley Moor is divided by a valley and the undulating topography means that even low level noise, such as conversation, travels and reverberates from one hill to the other with surprising clarity. Further assessment should be carried out regarding possible noise pollution and possible lack of privacy for site occupants. Caravans do not insulate noise efficiently, business may be carried out from the site and animals will most likely be present.
Para 3.17.8: GT/09 the description of the site is misleading. The existing screening around the site is on the part of the site that slopes downhill from the area of level ground where the proposed pitches will be sited. The wooded area will not shield the site sufficiently from view or prevent it from altering the landscape, which is within an area of primary sensitivity according to the Areas of Multiple Environmental Sensitivity Study. The undulating topography provides opportunities for views across the landscape. Much of the surrounding countryside is at a higher level and will look down on site GT/09 and it will be not be possible to shield it from view.
In document ED44c Landscape Appraisal Technical Note for Site GT/09
The Appraisal The appraisal rightly gives weight to the fact that the sensitivity of the area is recognised in the assessment carried out as part of the Areas of Multiple Sensitivity Assessment (Derbyshire County Council, November 2010) which identifies the site as lying within an area of 'Primary Significance' in relation to ecological features, the historic environment and visual unity.

The appraisal fails to give recognition that this site is an open piece of land essential to maintain the setting and the historic environment and character of the village. The history of this open ground is that old cottages were demolished some 50 years ago. The demolition resulted in 'exceptional change' and created an open space on the edge of the village. The NEDDC review of SDL's 2019 recognises 'exceptional change' and states that 'exclusion of a created open space from further development may be desirable to maintain the new setting and the character of a town or village'. In the case of Woolley Moor there are compelling arguments to retain this piece of open land not only to protect the landscape character type (LCT) but to preserve the historical integrity of the area. The cottages and buildings to the south of this land are the remaining properties of the old village of Woolley. This piece of land provides an open view of what remains of old Woolley and acts as a demarcation between these old and traditionally styled properties and the more diverse character of what became new Woolley Moor.


The Conclusion: 'Proposals such as Gypsy and Traveller Accommodation are unlikely to be able to be brought forward without adverse effects on the landscape character of this LCT and the visual amenity of receptors within the local context.' This conclusion is accepted and it is submitted that the issues identified in this response would strengthen this conclusion.

The Mitigation Recommendations:

The first recommendation is to retain the existing natural planting and to respect its root system.

The second recommendation is stated as follows:

'The eastern boundary to the site is open and lacks a physical boundary. Any future proposal for the site should include boundary treatments that respect the character of the local context and help to filter potential views towards the site from the local context, for example, a native, mixed hedgerow with hedgerow trees.'

This recommendation is flawed for the following reasons:
i. The suggested boundary treatments cannot be achieved as envisaged because of the visibility splays that will be required to access the site by vehicles. The mitigation of the boundary treatments would be defeated by on road parking.
ii. Any planting will have to be set back into the site as any overhang would impede pedestrians. This combined with an area to protect the root system would impinge significantly into the site area which is conceded by the council to be smaller than the 1500 sq metres stated.
iii. The planting suggested would not be effective during the winter months and would take many years to establish
iv. The planting suggested would only shield the site from the view of the highway as the surrounding land to the east is at a higher level and looks down upon the site.
v. As GT/09 is approached by car or foot, the openness of the piece of land affords views to the west, southwest and north. It provides an opportunity for a view of the village and to lose the open character of this land would be detrimental to the visual unity of the landscape area.
vi. There are no steps that could mitigate the loss of this open space created by 'Exceptional change' and which is central to the new setting and character of Woolley Moor


Even if the mitigation recommendations were achievable in full they would not prevent the adverse effects that the proposed site would have on the landscape character of this LCT.

The conclusion of the report ED44c recognises the limitations of the mitigation recommendations and continues to conclude:
' .....Proposals which do not respect or enhance the local context, such as Gypsy and Traveller Accommodation, are likely to have an adverse effect on the character of this sensitive landscape.'


I would ask the Inspector to consider that adequate mitigation cannot be achieved nor would it address the issue raised at point vi) regarding the historical character of the village. The benefit to be gained from the provision of a small number of Gypsy and Traveller pitches (less than 3) would not outweigh the irretrievable detriment to the local landscape.



Question 28
Would the proposed allocation be justified and appropriate in terms of its location including access to services and facilities and the site size?
This question has been addressed in part by my comments in relation to the Sustainability Appraisal.
Location and Access to services and facilities
* Location - Woolley Moor is not on an established travelling route for gypsies and travellers.
* The size and location of the site is inadequate and would not provide space to run a business. There are no identifiable sites in close proximity suitable for a business purpose. See para 2.3 of EB G&T2 and page 5 Planning Policy for Travellers Sites, Department for Communities and Local Government (DCLG) August 2015.
* Para 3.1 DCLG Good Practice Guidance on Designing Gypsy and Traveller Sites (May 2008) refers - there is poor access on foot to the primary school in Woolley Moor. From Temperance hill the road is narrow with no pavement and has a dangerous blind bend. There is no street lighting. In the interests of safety it is likely that primary school children will be transported the short distance by car as are other children from within the village.
* There are no other services available within 2.2 miles of Temperance Hill and these are not accessible by foot due to narrow roads without continuous pavements or street lighting.
* Public transport is very limited. It does not serve the nearest shop identified in ED44b. Accessing employment and amenities/ health care would be very difficult because of the restricted service and inadequate times of the service bus.

Site Size
* The size of the site is too small to accommodate 3 pitches. The available space is less than the stated 1500 square metres which will be reduced further by the mitigation recommendations and required access roads. The GTAA page 175 sets out required 'on pitch' facilities. There is no provision for grazing of animals.
* The site is of insufficient size to provide off road parking for both private and business vehicles and for visitors. On road parking would restrict movement of vehicles on Temperance Hill (a narrow lane) and would reduce the visibility towards the junction of Beresford Lane and to the south of Temperance Hill. There is restricted visibility in both directions because of the natural lay of the road. Parking across the pavement would put pedestrians at risk. On road parking would also counteract the mitigation recommendations.


1. Question 29
Can a satisfactory form of development be achieved having regard to:
* The local environment including the impact on landscape quality
The comments made above in relation to the Sustainability Appraisal are relevant to this question. It is submitted that a satisfactory development cannot be achieved for the following reasons:
Loss of village amenity space and green open space - this parcel of open land has been used for the general benefit of villagers for in excess of 50 years.
The close proximity to an SSI and the close proximity to an area of woodland on the National Forest inventory.
Adverse impact upon the natural habitat. The site supports an abundance of wildlife including badgers.
GT/09 is a parcel of land that has not been farmed. It has remained unimproved for in excess of 50 years. It is mown once per year following the flowering season. It is likely to represent valuable grassland and may contain many species. It is unimproved, species-rich grassland. This is grassland that hasn't been reseeded, fertilised or drained and as such it tends to be full of flowers and wildlife. Loss of unimproved grassland impacts upon the numbers of butterflies and breeding birds, such as curlew and lapwing which continue to decline. The NEDDC have a responsibility to preserve valuable natural resources and I would ask the Inspector to conclude that this site should not be included as available until a full evidence based assessment has been undertaken by environmental conservation specialists.

* Access onto the local highway network
It is argued that there will be an adverse impact on highway safety. It is not accepted visibility splays can be achieved.
The road is relatively narrow with bad junctions at each end of Temperance Hill. The exit from Beresford lane onto Temperance Hill is a junction with very poor visibility. The poor visibility at all these junctions makes it particularly difficult for larger vehicles and for towing vehicles to turn safely for themselves and for safety of the oncoming traffic.

Conclusion

The benefit of providing a maximum of 2 pitches in an area with only very limited sustainability cannot outweigh the harm that would be caused to the landscape character and local environment nor would it be proportionate. This is especially the case when the identified need for pitches is not consistent with current policy.

Object

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9722

Received: 15/02/2019

Respondent: Cllr Barry Lewis

Representation:

Inspector's question identified by Officer

What is not made clear in this consultation and I therefore pose, as a question that needs a clear answer, is what a 'Pitch' actually constitutes? In other words, how many caravans and how many vehicles can constitute a single pitch?

What consultation has been done, prior to launching this one, with the traveller and gypsy community to ascertain the suitability of these sites?

I would like to make the point, one doubtless made by many others, that this consultation was poorly advertised to start with and seemed to elicit a desire or hope that this would slip under the radar of the public. I am sure the Authority will no doubt deny this but in an age of proactive communications and social media no Local Authority should launch such a potentially contentious consultation in such a low-key way.

Full text:

I am writing as the County Councillor for Wingerworth and Shirland Division and Ward Member for NEDDC for Wingerworth to express my concern about the proposed Gypsy and Traveller Sites for both Wingerworth and Woolley Moor, which closely borders my electoral division. Therefore, please accept this as my submission to the consultation.

I have received 11 emails relating to the Temperance Hill site Woolley Moor and Greenway, Wingerworth.

I realise that the Greenway site has been removed from the process but I am also given to understand you are still accepting views on the matter. I support the views of many residents local to this location that the proposed site is unsuitable for the purpose and would exacerbate an already difficult local traffic situation - a view arrived at, I believe, by officers of NEDDC following consultation with DCC as Highways Authority. I also understand, and which may be the more likely reason for the sites withdrawal, there is a covenant on the site as a condition of gifting it to NEDDC that stipulates that the usage of the site should be restricted to recreation. Could you clarify please?

What is not made clear in this consultation and I therefore pose, as a question that needs a clear answer, is what a 'Pitch' actually constitutes? In other words, how many caravans and how many vehicles can constitute a single pitch?

That aside, the Temperance Hill proposed site at Woolley Moor is located in a countryside location, on a green field that in my view is inappropriate for a development of this nature. The location affords little access to amenities or services nearby, such as doctors, shops, chemists or post office.

This leads me to my second question, what consultation has been done, prior to launching this one, with the traveller and gypsy community to ascertain the suitability of these sites?

Finally, I would like to make the point, one doubtless made by many others, that this consultation was poorly advertised to start with and seemed to elicit a desire or hope that this would slip under the radar of the public. I am sure the Authority will no doubt deny this but in an age of proactive communications and social media no Local Authority should launch such a potentially contentious consultation in such a low-key way.

Object

Examination Consultation Provision for Gypsies and Travellers

Representation ID: 9727

Received: 10/02/2019

Respondent: Mr Paul Gibbons

Representation:

Summary by Officer

The two large sites adjacent to the existing County Council site known as "Corbriggs" in the Parish of Temple Normanton should be allocated in the Local Plan (GT2 & GT3). This could also be site TN/1603T in Table 3.1 of the Sustainability Appraisal.

Old Potato Store
North Wingfield
Temperance Hill

As I understand it two of these three sites already belong to gypsies. The intention is to occupy them for their own use. These should be Allocated in the Local Plan.

There are two general points:
The only main services needed is mains water standpipe. The main services are paid for by the applicant and are not a charge on public funds - so it does not matter to the Planning Authority.

Air quality in the area has improved with the closure of heavy industries i.e. Wingerworth Coke Ovens; Coalite, Bolsover; Clay Cross Biwater.

Full text:

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