MM/006

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Support

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

Representation ID: 10228

Received: 21/12/2020

Respondent: EPC-UK Explosives Plc

Agent: Leith Planning Group

Representation:

This representation relates to MM/06 & MM/07.

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.

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.

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