MM/016

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Object

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

Representation ID: 10061

Received: 30/11/2020

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Representation:

The Environment Agency comments on Section 2b

We note that the wording in section b) of the policy SS6: Coalite Priority Regeneration Area has been amended to now state that no residential development takes place until the whole of the site has been fully remediated. The previous wording stated ‘prior to the development commencing’ which suggested all development would not happen until the site was remediated. We would ask that this wording is written to ensure that any development that isn’t residential is only allowed once that particular section of development has been remediated, whilst only allowing the residential development to be allowed once the whole site has been remediated.

Full text:

Thank you for the opportunity to respond to the proposed main modification consultation for North East Derbyshire District Council.

We note that as part of this main modification there are two new policies proposed; LC8: Allocation of Traveller Sites and ID6: Safeguard land for education sites. The Environment Agency has the following comments on these new policies.

LC8: Allocation of Traveller Sites

Developments at the two proposed sites i) The Old Potato Store, Dark Lane, Calow and ii) Dark Lane, North Wingfield will need to follow the requirements of the Planning Practice Guidance, Section: Water Supply, wastewater and water quality, paragraph 20 if they are not connecting to the mains sewer. An Environmental Permit may be required and the council may wish to include this as part of any future requirements or information for the sites.

We also note that Dark Lane, North Wingfield has a requirement for a phase 1 ground investigation whilst the Old Potato Store, Dark Lane, Calow does not. We note that The Old Potato Store site is situated 30m away from a historic landfill site and the council may wish to add this requirement in for this site as well.

ID6: Safeguard land for education sites

We note that there are 4 proposed areas for safeguarding land for future education sites. We understand that at the moment there is no development planned at these sites but the safeguarding is to ensure the land is available for future education purposes ranging from extensions to existing educational settings, new educational settings, or to offer sports fields for existing facilities.

Part of the area of land allocated at Unstone Junior School, Main Road, Unstone is situated next to the main river the River Drone, and is situated within flood zones 2 and 3. We would ask that where possible this proposal amends the boundary allocated to remove any future development outside of the flood zones and leaves at least an 8m buffer zone to the River Drone. Future development proposals should ensure that access is allowed to the River Drone in case future maintenance is required. Any future development within 8m of the River Drone may also require a Flood Risk Activity Permit. Further information can be found at gov.uk at:
https://www.gov.uk/guidance/flood-risk-activities-environmental-permits

Additional Comments

Ref: MM/016

b. Enable the full reclamation of the site prior to the
development commencing, in line with an agreed
programme of work and delivery plan which should
also ensure that no residential development takes
place until the whole of the site has been fully
remediate;

We note that the wording in section b) of the policy SS6: Coalite Priority Regeneration Area has been amended to now state that no residential development takes place until the whole of the site has been fully remediated. The previous wording stated ‘prior to the development commencing’ which suggested all development would not happen until the site was remediated. We would ask that this wording is written to ensure that any development that isn’t residential is only allowed once that particular section of development has been remediated, whilst only allowing the residential development to be allowed once the whole site has been remediated.


Ref: MM/109 & MM/110

We note that the requirements to look at reducing and surface water runoff rates from existing greenfield rates where possible has been removed from Policy SDC11: Flood Risk and Drainage and placed within the paragraph that supports the policy. Whilst surface water is not the Environment Agency’s remit at the planning application stage we support the intentions of the wording to ask developers to look at reducing run off rates where possible in future developments.

Support

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

Representation ID: 10345

Received: 13/01/2021

Respondent: Historic England

Representation:

Historic England supports proposed Main Modification MM/016 to amend Policy SS6: Coalite Priority Regeneration Area part 2 c, to read “Sustain and enhance the significance of heritage assets, in particular the Grade 1 Listed Bolsover Castle and Sutton Scarsdale Hall”, as this wording will ensure that the Policy is consistent with the NPPF.

Full text:

Historic England supports proposed Main Modification MM/016 to amend Policy SS6: Coalite Priority Regeneration Area part 2 c, to read “Sustain and enhance the significance of heritage assets, in particular the Grade 1 Listed Bolsover Castle and Sutton Scarsdale Hall”, as this wording will ensure that the Policy is consistent with the NPPF.

Support

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

Representation ID: 10620

Received: 27/01/2021

Respondent: Dronfield Town Council

Representation:

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

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

Object

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

Representation ID: 10885

Received: 31/01/2021

Respondent: Mr Paul Stock

Legally compliant? Not specified

Sound? No

Representation:

Council Officer has summarised and identified Modification reference.

We disagree with Main Modifications MM/015 and MM/016 which together propose to insert provision for 660 new dwellings on the former Coalite Chemical works site. We consider the insertion of the new paragraph 4.53 as proposed by Main Modification MM/015 and the consequential proposed amendment in MM/016 to Policy SS6 for the location of up to 660 new dwellings at this extensively contaminated site, which is poorly linked to surrounding areas, is misguided and not in accordance with the overall objectives and spatial strategy of the Plan.

For the reasons referred to in our previously submitted representations to the Publication draft plan plus the points raised in paragraph 3.5.2 above we strongly believe any reference to housing development in this location should be deleted from the Plan. Failure to do so will continue to make the Plan unsound in respect of this important matter.

Full text:

Representation Statement


1. EXECUTIVE SUMMARY

i. This Statement provides our written representations on the Consultation on the proposed Main Modifications on the North East Derbyshire Publication draft plan (the Plan) published in November 2020.


2.1 Previous Submissions
2.1.1 We have previously been involved in the submissions of representations on specific matters relating to consultations undertaken by the Council in the preparation of the North East Derbyshire Local Plan 2014 to 2014, as set out below:

• Schedule of Potential Housing Sites – Consultation (March 2015)
• Strategic Policies and Initial Site Allocations (March 2015)
• Response to Council’s letter dated 20th October 2016
• North East Derbyshire Local Plan – Consultation Draft (April 2017)
• North East Derbyshire Local Plan – Publication Draft (April 2018)
• Green Belt Topic Paper – May 2018.
• Inspectors’ Main Matters, Issues and Questions - 5,6,7,8,9,10 and 11 (October 2018)
• North East Derbyshire District Council’s Targeted Consultation on the Matter of the Five Year Housing Land Supply. (June 2020).

Copies of these previously submitted representations are not appended to the present statement as they already form part of the evidence base for the Local Plan examination.

3.1 Representations on Proposed Main Modifications.

3.1.1 Main Modification MM/008
3.1.2 We believe the amended text is misleading in that it does not recognise the sizeable contribution that will also be made by level 2 settlements which are proposed to provide a total housing supply of some 2,216 dwellings as shown in the amended Table 4.4 Distribution by Level 1 and 2 Settlements. This accounts for 33% of the total new housing supply over the plan period 2014 to 2034.

3.1.3 We consider the text should be further amended to recognise and give weight to the important contribution to be played by level 2 settlements in the implementation of Policy S22 - Spatial Strategy and Distribution of Development in the Plan.

3.2.1 Main Modification MM/009
3.2.2 Renishaw is an area of high demand for growth. The tight constraints of the Green Belt have restricted development in recent years leading to rising house prices and unmet housing need. The lack of available and suitable land within the existing settlement means that meaningful levels of housing growth can only be accommodated by release of land on the southern edge of the settlement within the Green Belt.

3.2.3 The proposed Modification MM/009 makes reference to new housing being focused on level 1 towns, the two strategic sites and level 2 settlements as defined in the Settlement Hierarchy in Table 4.2. However we have previously drawn attention to the Council and the Inspector that in the case of the level 2 settlement of Renishaw it will actually see a reduction of 3 dwellings (our emphasis) over the next 20 years of the plan as shown in the amended Table 4.3. Bizarrely, and for no explained reasons, this is the only level 2 settlement which will see an actual reduction in the total numbers of dwellings available in the Plan period between 2014 and 2034.

3.2.4 This clear inconsistency and serious failing on the part of the Plan is further highlighted by the proposed amendment to Policy S22 (7b) in the Plan which states it will “Support and facilitate the regeneration of...” level 2 settlements. Clearly this will not be possible in the case of the level 2 settlement of Renishaw where it is currently proposed to see a reduction of 3 dwellings in the total land supply over the plan period.

3.2.5 This is a serious failing on the part of the Plan which will cause major economic and social damage to the prosperity and sustainability of the settlement and further prevent any initiatives to meet the challenges of unmet social housing need and prevent housing-led regeneration. Even at this late stage in the plan making process we strongly believe that urgent attention needs to be given to rectify this important matter.

3.2.6 Failure to make changes to the Plan along the lines suggested above will in our opinion make the Plan unsound.

3.3.1 Main Modification MM/010
3.3.2 As part of the Main Modification MM/010 and the proposed amendments to Table 4.3: Housing Distribution by Level 1 & Level 2 Settlements we believe it is essential for a positive housing land supply figure to be found for the level 2 settlement of Renishaw rather than the present negative housing supply of minus 3 dwellings. Should the present position be allowed to continue it will be major failure of planning for the local residents and wider community of Renishaw.

3.3.3 In order to underline the point made in paragraph 3.3.2 above we have set out below a copy of the specific representations submitted to the Publication draft plan on this matter. This explains in greater detail that in the absence of such policy change to the Plan it will be impossible to support the wider policy objectives of regeneration to the settlement, the provision of much needed affordable housing and widen the choice and tenure of housing.

7.3.11 The proposed housing distribution for the Plan is shown in Table 4 – Housing Distribution by Level 1 & Level 2 Settlements. This indicates that for the sustainable Level 2 settlement of Renishaw a provision of only 6 dwellings is proposed in the period 2014 to 2034 even though in Policy WC2 Principal Protected Employment Areas and Table 6.2 it refers to the protection 2.5 hectares of employment land at the Renishaw Industrial Estate for employment use. With such an important employment allocation it is clear there will be considerable local economic pressures for the settlement to grow which have not been catered for in the Publication Plan. Currently the settlement is severely constrained in planning policy terms by being contained on all sides by Green Belt which thwarts much needed expansion on the edge of the settlement. This will have a significant and harmful effect on the ability of the settlement to regenerate and cater for these new requirements, including affordable housing. For this reason we consider the present Policy SS2 and Policy SS10 (Green Belt) is not justified and therefore unsound.

7.3.12 We believe the best way in which to ensure the delivery of housing targets is to ensure all settlements within the Level 2 settlement category receive a sufficient housing provision to cater for development pressures over the plan period. Whilst the new strategic allocations will help meet housing demands in the medium/long term, the level of infrastructure required to deliver the site is costly and substantial it is therefore likely to take time to implement. We would contend however that a greater percentage of should be directed to Level 2 settlements to ensure they meet their short and medium term housing needs.

7.3.13 It is our view the spatial strategy needs to give further consideration for the release of other land from the Green Belt plus the identification of safeguarded sites in order to sufficiently meet the present housing target and spatial strategy and cater for pressures in the future.

7.3.14 Without the release of further land from the Green Belt, the identification of safeguarded areas for the provision of housing in the future, and the provision of further housing allocations at sustainable Level 2 settlements such as Renishaw, we consider that it would be problematic for the proposed spatial strategy to deliver housing needs. We therefore consider the Policy to be inconsistent with National Policy and not justified nor effective, and as such unsound.

7.3.15 We are concerned that the formulated strategy does not support the future housing needs of each settlement within the Level 2 settlement category or the needs of those communities in terms of local facilities in either quality or quantity. As in the case of Renishaw which has a wide range of facilities including a primary school local doctor’s surgery, food shop, public house , Post office, church, village hall and recreation ground plus several bus services (No 71,73,74, 131 and 231, providing wider access to services and sources of employment in nearby Barlborough and Killamarsh. It also has extensive local employment opportunities at Renishaw Park with a further 2.5 hectares of land available for expansion to accommodate more new businesses.

3.4.1 Main Modification MM/011
3.4.2 We disagree with Main Modification MM/011 which proposes to amend paragraphs 4.40 to 4.43 and in particular insert the following new wording “…. currently there is no defined route for this link road and no likelihood of funding before at least 2024. For these reasons a definitive route cannot be safeguarded on the Policies Map.” In our opinion this is a significant retrograde step which will seriously undermine the likelihood of the proposed link road from the A61 to the A617 ever being built and delivered. In turn this will be to the detriment of the overall development of the strategic Avenue site, plus the wider adjacent local road network of Wingerworth.

3.4.3 In our opinion this part of the proposed amendment in MM/011 should be deleted and replaced with a policy requirement in the Plan which directly links the rate of housing development at the strategic Avenue site with the building and delivery of this critical element of infrastructure. In absence of such action we consider the Plan will continue to be unsound in this important respect.

3.5.1 Main Modification MM/015 & MM/016
3.5.2 We disagree with Main Modifications MM/015 and MM/016 which together propose to insert provision for 660 new dwellings on the former Coalite Chemical works site. We consider the insertion of the new paragraph 4.53 as proposed by Main Modification MM/015 and the consequential proposed amendment in MM/016 to Policy SS6 for the location of up to 660 new dwellings at this extensively contaminated site, which is poorly linked to surrounding areas, is misguided and not in accordance with the overall objectives and spatial strategy of the Plan.

3.5.3 For the reasons referred to in our previously submitted representations to the Publication draft plan plus the points raised in paragraph 3.5.2 above we strongly believe any reference to housing development in this location should be deleted from the Plan. Failure to do so will continue to make the Plan unsound in respect of this important matter.

3.6.1 Main Modification MM/025
3.6.2 We disagree with Main Modifications MM/025 and the proposal to insert the following amended wording in paragraph 9 of the Plan, that - “From the start of the Plan Period there has been no significant underdelivery in relation to the Government’s Housing Delivery Tests.” In our opinion the insertion of this new wording into the Plan is misleading of the true overall picture. As demonstrated in our previously submitted representations to the consultation on the Publication draft plan and the Targeted Consultation on the Matter of the Five Year Housing Land Supply the Council has consistently underdelivered on its housing requirement over extended periods of time. As such we are still of the view that a 20% buffer should be applied to the overall housing land requirement in the Plan.

3.7.1 Main Modification MM/O26
3.7.2 We object to the proposed changes to the amended Policy LC1 Housing Allocations because it does not make any reference to new housing allocation in the level 2 settlement of Renishaw. As explained elsewhere in the present Representation statement we believe this to be a serious failing of the present Spatial Strategy and Distribution of Development policy in the Publication draft plan.

3.7.3 We had hoped the matter would be addressed in the present consultation of proposed Main Modifications, but regrettably it is not the case. We consider this to be a major sin of omission on the part of the present schedule of Main Modifications. Therefore without urgent action to rectify the matter it will in our opinion make the Plan unsound at adoption.

3.8.1 Main Modification MM/083
3.8.2 The Main Modification MM/083 deals with the amended Table 6.1 which shows the Local Plan Employment Land Availability. In this Table of existing employment sites and allocations with development land still remaining the industrial estate at Renishaw is shown to have 2.5 hectares of employment land available. It again demonstrates the underlying sustainability of the level 2 settlement, plus the urgent need to accommodate housing–led regeneration in this location.

3.9.1 Main Modification MM/118
3.9.2 With the sustainable level 2 settlement of Renishaw proposed to have a negative housing land supply over the plan period it is particularly pertinent to note that it is still considered necessary to safeguard land for education purposes under Policy ID 6 and also to extend formal sports designation under Policy ID 10 at the primary school off Hague Lane. For a settlement where the Plan is proposing an actual contraction in growth with clear detrimental knock-on effects to the community in social and economic terms the County Council takes a different view and recognizes the existence of immediate and underlying pressures for growth in this popular and sustainable level 2 settlement, that will not be accommodated nor satisfied by the present policies in the Publication draft plan.

4.1 SUGGESTED FURTHER MODIFICATIONS

4.1.1 We consider significant sins of omissions exist in the present schedule of proposed Main Modifications and as such we are of the opinion that other changes to the Publication draft plan need urgently to be addressed by means of schedule of Further Modifications in order for the Plan to be sound on adoption. We recognize this would of course necessitate another round of consultations.

4.1.2 Our suggested Further Modifications to the Publication draft plan are set out below.

NORTH EAST DERBYSHIRE GREEN BELT – SAFEGUARDED LAND.

4.1.3 Under the heading North East Derbyshire Green Belt the Plan refers to national guidance and states in paragraph 4.71 that :
“The identification of safeguarded land between the urban area and the Green Belt can help to meet longer-term development needs that extend beyond the current plan period, thereby avoiding the need for a review of the Green Belt with Local Plan review”.

4.1.4 In representations previously submitted on the Publication draft plan we expressed support for the idea of such safeguarded land, but considered it was also required to meet both short and medium term development needs within the plan period. As such we urged the Council to undertake a consultation process to identify such potential Safeguarded Land rather than leaving it vague and unspecified.

4.1.5 We consider the decision reached by the Council not to identify any safeguarded land is arbitrary and not justified and therefore makes the plan unsound. The absence of such safeguarded sites will undermine robustness of the plan to cater for futures pressures.

4.1.6 Regrettably the opportunity provided by the present consultation on proposed Main Modifications has not been used to amend Policy SS10 North East Derbyshire Green Belt and include reference to safeguarded land. We consider this to be a major failing particularly when serious concerns were expressed by a wide range of parties that submitted representations to the Publication draft plan over the need for greater robustness and resilience in the housing supply over the plan period.

Housing Allocations
4.1.7 Renishaw is an area of high demand for growth. The tight constraints of the Green Belt have restricted development in recent years leading to rising house prices and unmet housing need. The lack of available and suitable land within the existing settlement means that meaningful levels of housing growth can only be accommodated by release of land on the southern edge of the settlement within the Green Belt.

4.1.8 We have previously drawn attention to the Council and the Inspector that in the case of the level 2 settlement of Renishaw it will actually see a reduction of 3 dwellings over the 20 years of the plan period as set out in the amended Table 4.3. Bizarrely and for no explained reasons in the Plan this is the only level 2 settlement which will see an actual reduction in the total numbers of dwellings available in the plan period between 2014 and 2034.

4.1.9 This is a serious failing on the part of the Plan that will cause major economic and social damage to the prosperity and sustainability of the settlement over the plan period and further prevent any initiatives to meet the challenges of unmet social housing need and give support to housing-led regeneration. Even at this late stage in the plan making process we strongly believe this serious failing on the part of the Publication draft Plan needs to be urgently addressed.

4.1.10 Regrettably the opportunity provided by the present consultation on proposed Main Modifications has not been used to amend Policy LC1 Housing Allocations and include reference to a site on the southern edge of the settlement of Renishaw. We consider this to be a major failing in the Plan which if left unchanged will make the Plan unsound.

5.1 CONCLUSION

5.1.1 In conclusion we hope careful and sympathetic consideration will be given to the various representations set out in this Statement, which has been prepared in response to the present consultation on proposed Main Modifications to the North East Derbyshire Publication draft plan.

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