MM/002

Showing comments and forms 1 to 5 of 5

Support

Main Modifications to the North East Derbyshire Local Plan (Publication Draft), 2020

Representation ID: 10227

Received: 21/12/2020

Respondent: EPC-UK Explosives Plc

Agent: Leith Planning Group

Representation:

We support the Council’s objective for rural diversification; however, careful consideration should be paid for all applications proposed in rural areas. Whilst our client’s site is allocated as an Existing Employment Site, the rural nature of the adjacent land and within the consultation zone means that this vision does have an impact on our client. Non-agricultural uses within the outer consultation zone should not be considered acceptable, due to the nature of our client’s operations, and the risk to public safety the operations could pose.

Full text:

Representations are being made on the proposed Main Modifications to the North East Derbyshire Local Plan (Publication Draft) 2020, in relation to the EPC-UK site known as Rough Close Works which is located in Bolsover, but for which the Health and Safety Consultation Zones extend into North East Derbyshire.

Comments

The following comments are headed by the relevant main modification.

MM/002

We support the Council’s objective for rural diversification; however, careful consideration should be paid for all applications proposed in rural areas. Whilst our client’s site is allocated as an Existing Employment Site, the rural nature of the adjacent land and within the consultation zone means that this vision does have an impact on our client. Non-agricultural uses within the outer consultation zone should not be considered acceptable, due to the nature of our client’s operations, and the risk to public safety the operations could pose.

MM/006 & MM/007

We support the Council’s ambition of a net increase of employment land in the district. However, we wouldn’t support new employment uses located within the consultation zones associated with Rough Close Works, as this could not only pose a risk to health but could also limit or minimise the extent of operations our client can undertake at their site, potentially inhibiting the future viability of the business.

MM/008

We are wholly supportive of Main Modification 8, which seeks to ensure that the Level 1 Towns and Strategic Sites will be the focus for all new employment land provision, as well as housing and commercial development. Ensuring such developments are directed towards the main urban areas, assists in ensuring that our client’s operation at Rough Close Works will be protected from development encroachment. This also helps to secure the long-term viability of our client’s site and creates opportunity for future expansion of their business if or when necessary.

MM/025

We are wholly supportive of this modification, which will ensure that should the Council be unable to demonstrate 5 year’s supply of housing land a review of the Local Plan will be immediately triggered. If a Council can’t demonstrate a 5-year housing land supply Paragraph 11(d) of the National Planning Policy Framework will apply. The approach taken through this modification will help to ensure that development will not be permitted in locations that may normally be considered inappropriate, including the consultation zones associated with Rough Close Works.

MM/082

The modification would suggest that there is currently an identified shortfall of 4.58ha of land available for new employment development. It’s understand the Council will be robustly monitoring the employment land supply annually to ensure there is sufficient land to meet the identified need. We support the Council’s intention to stringently monitor the employment land supply to meet future needs, but would like to reiterate that no development, including employment related development, should be proposed or approved within close proximity to our client’s site. This is not only in the interest of protecting our client’s current operations and their option for future expansion, but also in the interest of public safety. New employment land should come forward throughout the plan period, but this should not compromise existing and established employment sites.

Conclusions

We are broadly supportive of the proposed Main Modifications proposed to the North East Derbyshire Local Plan. However, any proposed developments, allocations or policies which could undermine the viability of Rough Close Works or impinge on my clients’ ability to secure the future of the site and expand operations will be robustly objected to. This will be in the interest of both an existing commercial operator, but also in relation to the important matter of public safety.

Attachments:

Object

Main Modifications to the North East Derbyshire Local Plan (Publication Draft), 2020

Representation ID: 10461

Received: 20/01/2021

Respondent: Mr Paul Johnson

Legally compliant? Yes

Sound? No

Representation:

The site allocation of KL/1 is not sustainable and does not meet the 2012 NPPF requirement to ‘meet the needs of the present without compromising the ability of future generations to meet their own needs’.
This site is currently in the Green Belt, with five footpaths crossing it, giving lovely views to the west of Derbyshire. These will all be lost and walking/health opportunities will disappear (social). This site is located at the extreme edge of the settlement, with poor public transport and steep hill challenging walkers or cyclists visiting the centre, which is 2km away.
There are no new jobs currently available, planned, or likely within documented infrastructure projections. Commuting by vehicle will be unavoidable, damaging air quality – already the worst in the District. The financial benefit will accrue to Sheffield (economic).
Environmental damage will be massive, destroying habitats, including those of protected species established trees, ancient hedgerows and a functioning Greenway (environmental).

Full text:

The site allocation of KL/1 is not sustainable and does not meet the 2012 NPPF requirement to ‘meet the needs of the present without compromising the ability of future generations to meet their own needs’.
This site is currently in the Green Belt, with five footpaths crossing it, giving lovely views to the west of Derbyshire. These will all be lost and walking/health opportunities will disappear (social). This site is located at the extreme edge of the settlement, with poor public transport and steep hill challenging walkers or cyclists visiting the centre, which is 2km away.
There are no new jobs currently available, planned, or likely within documented infrastructure projections. Commuting by vehicle will be unavoidable, damaging air quality – already the worst in the District. The financial benefit will accrue to Sheffield (economic).
Environmental damage will be massive, destroying habitats, including those of protected species established trees, ancient hedgerows and a functioning Greenway (environmental).

Support

Main Modifications to the North East Derbyshire Local Plan (Publication Draft), 2020

Representation ID: 10611

Received: 27/01/2021

Respondent: Dronfield Town Council

Representation:

The clarification that supporting housing-led neighbourhood regeneration opportunities is welcomed in the Vision

Full text:

In response to the consultation on the Schedule of Main Modifications, associated changes to the
Policies Map and other supporting documents, Dronfield Town Council would like to submit the
attached table of comments on a selection of the proposed Main Modifications and associated
documents as their feedback to the consultation, along with the accompanying flood report.
The Town Council would like to highlight that while they support a number of the proposed main
modifications, particularly the decision to remove the Green Belt allocation DR2 at Coal Aston from
the plan, thus retaining the site a Greenbelt, the council have strong objections to a number of the
modifications.

The housing supply cut off date should be extended
The figures shown as proposed modifications do not reflect the additional permissions that have been
granted – the cut-off is 9 months out of date. Figures in table 4.1 should be updated to reflect planning
permissions and appeal decisions up until 31st December 2020 to provide a more accurate picture.

Greenbelt sites should remain in the greenbelt
The retention of the Green Belt sites DR1 and DR2 (previously DR3) in the Local Plan remains totally
unacceptable as the District Council and the Inspector have still not demonstrated the exceptional
circumstances necessary for release of Green Belt land in this location. These sites are valued as
Greenbelt by residents and still fulfil the Greenbelt criteria and therefore should remain as Greenbelt.
There are numerous issues with developing the sites including the topography, access and traffic
impact, and viability, further details of which are provided within the council’s official response.
The Iceni report has demonstrated that there could be a reduction of eight dwellings per year, which
over a 20 year period would reduce the housing target by 160 houses, thereby negating the need for
DR1 to be included within the plan at all. In addition, the cut off date for additional planning permission
granted across the District to be considered should be updated to the 31st December 2020. This
would contribute to an additional 358 dwelling in the Plan and further reduce the need for use of
Greenbelt Land. The Town Council, therefore strongly request that DR1 should be removed from the
emerging Local Plan.
Furthermore, we attached a list of alternative sites that were put forward by Dronfield residents during
the drafting of Dronfield Neighbourhood Plan, which shows that there are sufficient alternative sites
available, which would preclude the need to use any of Dronfield Greenbelt for development.
In conclusion we would like the District Council to acknowledge receipt of the Town Council’s
feedback on the consultation, which can be found in the attached table and accompanying report.
Included within the table below are also the Town Councils comments and response to Document D:
Report on the Implications of the ONS 2018-based Household Projections on the objectively-assessed
housing need in North East Derbyshire prepared by Iceni on behalf of the Council and their response to Document F: Five Year Housing Land Supply Statement at adoption (updated data to 31 March 2020).

MM/002 Support, Y The clarification that supporting housing-led neighbourhood regeneration opportunities is welcomed in the Vision

MM/003 Support, Y The clarification that supporting housing-led neighbourhood regeneration opportunities is welcomed for this objective

MM/004 Object, N The figures shown as proposed modifications do not reflect additional permissions that have been granted giving an up to date position. The cut off date of 31/3/2020 is now 9 months out of date. The Town Council request that this is brought up to date until 31st December 2020.
In February 2019 (ED65) the Inspector removed Green Belt sites at Coal Aston, Eckington and reduced the size and capacity of DR1, Dronfield. Noting that this will mean a shortfall on reaching the 6600 housing target, she does not suggest that this in itself would make the plan unsound.
In July 2019 (ED85) – the Council wrote back to the Inspector clarifying that the above, at the time, would mean a shortfall from the 6600 target of 257. However, since February 2020, the Council has updated commitments and completions and their April monitoring figures suggested that the shortfall figure stood at just 80, due to higher than anticipated completions and permissions. Application reference 16/01260/OL (Land North Of Pilsley Road And West Of Coney Green Road (Plot L), Clay Cross) represents a significant development of 84 dwellings which has come about outside of the District Local Plan process and was not therefore “planned”. This eliminates the shortfall detailed
above entirely and leaves a small surplus of 4 dwellings.
Since 31st March 2020 there have been two further large developments approved on appeal which again fall outside of the District Local Plan process. These are:
• Appeal Reference: APP/R1038/W/20/3251224 – Land South East of Williamthorpe Road and West of Tibshelf
Road, Holmewood – 250 dwellings
• Appeal Reference: APP/R1038/W/20/3244154 – Land North of 92 Chesterfield Road, Higham – 24 dwellings
Taken together. the above amounts to a surplus of 278 dwellings on the full District Plan period housing target of
6600, providing the Inspector with ample justification to remove further Green Belt allocations from the emerging
District Local Plan.
In addition to the above, in MM/015, the Inspector also suggests that a further 660 houses at the former Coalite site could come forward during the District Plan period, none of which have been included towards meeting the housing requirement in the District Plan previously due to HS2 blight on the site. The Town Council request that these figures are included.
It is strongly urged that the Inspector removes sites DR1 and DR2 from the District Local Plan allocations given the above justification.

MM/005 Object, N This Table should be updated to reflect planning permissions and appeal decisions up until 31st December 2020 including the sites such as Clay Cross (84 dwellings), Holmewood (250 dwellings) and Higham (24 dwellings).

MM/008 Support, Y The less prescriptive approach is welcomed.

MM/009 Support, Y
The increased emphasis on supporting and facilitating regeneration of level 1 towns is welcomed, however, this is not borne out by the continuing emphasis on release on Green Belt land for housing when there are opportunities for brownfield redevelopment within the town centre of Dronfield as referred to by the Town Council in their response to the Main Matters at the Hearing Sessions. The Governments White Paper ‘Planning for the Future’ reiterates the long standing requirement that the development potential of brownfield land is maximized.
The list of potential brownfield sites in Dronfield was submitted by the Town Council at that time and was also
referred to in the Dronfield Neighbourhood Plan (Page 20, third aim to prioritise the use of brownfield sites for
housing and other forms of development and Policy HOU1 which supports windfall housing withing the existing urban area).
The following brownfield sites represent immediate opportunities for development within the District Local Plan timescale.
• Gladys Buxton, Dronfield North. 35 houses. Planning application being progressed.
• The Talbot pub site, Gosforth Valley. 8 houses. Construction started.
• Alma land, Dronfield North. 20 houses. Discussion have been held in the past with NEDDC but not completed.
• Padley &Venables land. 50-55 houses. Application put forward in the past. Not been used in more than 10
years.
• Manor Farm car park. 6 houses. NEDDC have put advanced plans forward.
Alternative sites put forward by residents for development through the NP is
• Thorpe Avenue. Approximately 10-15 units. The owner is willing to build and has been in touch with NEDDC.
(scrub land located very close to the built form of the town)
• Wreakes Lane/Sheffield Road site approximately 70 -80 units, the developer is currently at an advanced stage
of bringing an application forward with NEDDC.
Since the NP was published, the following site has emerged for potential development
• Miners Arms, Carr Lane, 8-12 units
In total these sites would yield 201-239 dwellings. The Inspector is strongly urged to reconsider the approach to
housing allocations in the Dronfield area given these opportunities which would support redevelopment/regeneration in the town.

MM/010 Object. N Should the recommendations by Dronfield Town Council be accepted and DR1 and DR2 (previously DR3) removed from the District Local Plan, the table should be updated to reflect this position.

MM/015 Support The inclusion of 660 dwellings and associated facilities at the Coalite Priority Regeneration Area site in the District Local Plan is supported.

MM/016 Support The inclusion of 660 dwellings and associated facilities at the Coalite Priority Regeneration Area site in the District Local Plan is supported.

MM/026 Object, N Sites DR1, DR2 (previously DR3) should not be allocated in this District Local Plan and removed entirely from this table.

MM/030 Object, N The retention of this Green Belt site DR1 in the District Local Plan is unacceptable as the Council has not demonstrated the exceptional circumstances necessary for release of Green Belt land in this location.
The site is unsuitable for development for the following reasons:
• Development on this site continues to risk settlement coalescence between Dronfield and Unstone by
reducing the historic gap between the settlements.
• Access to the site remains unclear. An additional junction onto the main road could have safety issues which render it unviable. The Inspector said in February 2019: “access arrangements should be identified in order to ensure that the site would be deliverable” but there is no information to suggest they have been identified.
• The Unstone floods in 2019 demonstrated that there may be an issue: substantial flooding was noted in
Unstone village derived from fields at or near this site - despite the plan suggesting that this was unlikely. The
site should be removed from the plan on this basis.
• The site is home to a number of wildlife species.
• The site is still used as agricultural land
Notwithstanding these reasons for removing the site from the District Local Plan, the site area shown in the
modifications is larger than envisaged by the Inspector in her interim findings that required the Council to reduce the site to ‘two fields’. The Council in their response to this have asked that the site is larger than suggested by the Inspector to ‘round off’ the site and align more closely with the existing built development. The Inspector has agreed to a proposed boundary line for the site (ED79). The new site size is 6.52 hectares and with a density of 30 dwellings per hectare would yield 196 dwellings. However, MM/111 clarifies that an assumption should be made that 80% of site areas between 6 and 10ha will be considered developable. This would yield 156 dwellings. The Town Council object to the words ‘approximately 160 dwellings’ in the modified policy. Should the site remain in the District Local Plan it is essential for clarity that the proposed modified Policy DR1 should read ‘a maximum of 160 dwellings’.
In addition, the design of the site should recognize the important ‘gateway’ location of the site and require that the design and layout of the site responds to this context in addition to taking account of the gradients already
mentioned in the policy. More wording should be added to the modified policy to reflect this position, should the site remain in the District Local Plan.
In conclusion, the site is less suitable than sites which have been taken out of the Plan and it is strongly urged that the site should be removed from the District Local Plan.

MM/031 Support The removal of this Green Belt allocation DR2 is supported

MM/032 Object. N The retention of this site in the District Local Plan is unacceptable as there are number of issues with this site still outstanding. The development of this site would have an unacceptable impact upon the vicinity of the site for a number of reasons –
Topography: the site is on a steep slope with a steep bank between the site and Stubley Hollow which will make it difficult to develop. The hill side slope will have surface water run off implications which are likely to have an adverse impact on the valley bottom, Sheffield Road and the railway line.
Access/traffic impact: Stubley Hollow is a narrow lane, not easily widened and with no on street parking, it is the main access road to Dronfield Woodhouse despite its width. There have been longstanding issues with HGV vehicles, particularly truck deliveries to the Gunstones Bakery on Stubley Lane. No detail has been provided as to an appropriate access point for the new housing.
Viability: 40 units is not of economic size to justify the S106 receipts available to mitigate the impact of the
development or make the infrastructure improvements required.
Location: development of this site would result in the demise of the separation between Dronfield Woodhouse
(formerly a separate parish) and the rest of Dronfield which would have an adverse impact on the historic context of the area.
Recent and emerging housing sites will deliver new housing in the immediate locality of up to 30 units. (6 houses at the Hearty Oak pub, Northern Common; 8 houses at The Talbot located off Carr Lane; The Miners Arms which is currently up for sale or lease – 8 to 12 houses; 4 units being built on the Northern Common currently.)
In conclusion, the site is less suitable than sites which have been taken out of the Plan and it is strongly urged that the site should be removed from the District Local Plan.

MM/033 Comment The removal of this Green Belt Allocation appears illogical when compared to the lack of merit of sites DR1 & DR2.
The same arguments that the Inspector has used to remove this site from the District Local Plan could be applied to Dronfield sites.

MM/111 Support The new paragraph gives more clarity on the yield expected from new allocated sites.

MM/118 Support The safeguarding of land for education facilities is supported.

Response to document D: Report on the Implications of
the ONS 2018-based Household Projections on the
objectively-assessed housing need in North East
Derbyshire prepared by Iceni on behalf of the Council
(ED101A)
Dronfield Town Council has the following comments to make on the Iceni Report:
• 2018 ONS data suggests a higher level of population and household growth than predicted in 2014 or 2016. It sets baseline demographic need at 279 dwellings pa.
• This is elevated to 293 dpa, in order to support “improved household formation amongst younger households”.
• Due to higher levels of migration into the District recorded in the ONS 2018 figures, it is no longer necessary to “add on” the extra dpas to justify the ambitious economic growth scenario envisaged in the 2018 Submission version of the District Plan.
• However, they are still applying a 10% uplift to support
affordable housing delivery and therefore set the target as (293 + 10% =) 322 dpa
• Iceni and the District Council suggest that it does not
represent a “meaningful change” from the original target of 330. However, even the reduction of 8 dwellings per year over the 20 year plan period (2014-34) is 160 dwellings and therefore it is strongly urged that DR1 should be removed from the emerging District Local Plan.
The Town Council questions that the 10% uplift for affordable housing is justifiable. Iceni allude to Government planning advice suggesting that it is reasonable, but this overall uplift is unlikely to make a direct material difference on affordable housing delivery and it would be better to address that issue through policies and allocations within the District Plan itself to promote affordable housing.
Iceni allude to the impact of Covid-19 on housing market activity but suggest it is too early to know by how much. There is a need for additional research on this point given that we are further on through the pandemic now and have a realistic understanding that Covid-19 will continue to have a significant impact until well into 2021. Covid-
19 may also impact on migration rates due to less movement and impacts could be longer lasting (people wanting to stay closer to home, family, friends etc). Changing work patterns may also drive changes in the housing market with technology advances enabling
more people able to work at home. This could therefore mean that C19 has an impact both on the delivery and the demand for new housing.

Response to Document F: Five Year Housing Land Supply Statement at adoption (updated data to 31 March 2020)
In the housing land supply documents, for both major and minor sites with planning permission, the District Council has taken the decision to “halve the site promoters’ anticipated completions in 2020/21 as a
minimum precaution” due to Covid-19 (paragraph 11). There is little evidence to support this approach available as yet, but the housing supply and demand in the area and the wider region should be closely scrutinised by the District Council to see if the emerging trends support this approach.
It is highly likely there will be a reduction in demand for employment sites such as office, retail and hospitality space (see reuse/redevelopment of pub sites in Dronfield). More brownfield sites or commercial buildings are likely to become available for housing or conversion in the near future due to the impact of Covid 19.

Attached:
Flood Risk Assessment & Outline Sustainable Drainage Strategy - Residential Development Chesterfield Road, Dronfield, Dronfield Town Council, January 2021

National Risk Register, 2020 edition, HM Government

Support

Main Modifications to the North East Derbyshire Local Plan (Publication Draft), 2020

Representation ID: 10675

Received: 30/01/2021

Respondent: Dr Lynne Gadsden

Representation:

Support vision and objectives.
Greenbelt housing allocations DR1, DR2, KL1 should be removed as they contravene them. They won't provide type and tenure of housing to meet needs of growing, ageing population: neighbourhood regeneraton requires smaller, less environmentally-damaging, less car-dependent developments, within closer, flatter reach of amenities.
Greenbelt sites insufficiently viable to deliver affordable housing quotas.
Expensive, challenging mitigation measures needed:
- counterbalance negative climate change, flood risk, pollution impacts.
- counterbalance biodiversity, green infrastructure loss
- reroute PROWs
- road, pedestrian access to sites (challenging topography)
- Section 106 monies for transport, health, education facilities (with physical capacity challenges.)

Full text:

Support vision and objectives.
Greenbelt housing allocations DR1, DR2, KL1 should be removed as they contravene them. They won't provide type and tenure of housing to meet needs of growing, ageing population: neighbourhood regeneraton requires smaller, less environmentally-damaging, less car-dependent developments, within closer, flatter reach of amenities.
Greenbelt sites insufficiently viable to deliver affordable housing quotas.
Expensive, challenging mitigation measures needed:
- counterbalance negative climate change, flood risk, pollution impacts.
- counterbalance biodiversity, green infrastructure loss
- reroute PROWs
- road, pedestrian access to sites (challenging topography)
- Section 106 monies for transport, health, education facilities (with physical capacity challenges.)

Object

Main Modifications to the North East Derbyshire Local Plan (Publication Draft), 2020

Representation ID: 10697

Received: 27/01/2021

Respondent: Mrs Christine E Johnson

Legally compliant? No

Sound? No

Representation:

Council Officer has summarised representation.

Site KL/1 fails to meet any of the three sustainability criteria in the NPPF 2012.

Since 73 years site KL/1 has been a green space, despite the colliery being located on the opposite side of the road. Footpaths through the fields of KL1 have been used for recreation, healthy and safe walks and to visit the play area. This will no longer be possible.

Killamarsh has been assessed as having less green space than necessary. Development of KL/1 will worsen that situation, which is particularly poorly served for open and recreational space as land beside the nearest public house to this site (Nag’s Head) was allocated for house building, removing football pitches and green space.

Development of site KL/1 will decimate the local ecology, removing habitats and a wildlife greenway. These negative effects will last a literal lifetime for many Killamarsh residents.

Full text:

Site KL/1 fails to meet any of the three sustainability criteria in the NPPF 2012.

I have lived in Killamarsh for 73 years, having been born here and living here currently.

Site KL/1 has been a green space for that time, despite the colliery being located on the opposite side of the road. My friends and I used the footpaths through the fields at the site of KL/1 for recreation and healthy, safe walks. This will no longer be possible.

We used the footpaths to visit the play area then there. It was destroyed to allow building there – now a medium sized housing estate with no green space of childrens’ play facilities.

Killamarsh has been assessed as having less green space than necessary. The removal of the land at KL/1 will worsen that situation, which is particularly poorly served for open and recreational space as land beside the nearest public house to this site (Nag’s Head) was allocated for house building, removing football pitches and green space.

(Continued)

The development of site KL/1 will decimate the local ecology, removing habitats and a wildlife greenway. These negative effects will last a literal lifetime for many Killamarsh residents.