MM/023

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Object

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

Representation ID: 10510

Received: 22/01/2021

Respondent: Dr Alan Thomas

Legally compliant? Not specified

Sound? No

Representation:

Ref MM/023, p65, para 5.3

The Plan still shows 6,600 homes to be delivered, but the number allocated in the Plan has been reduced by some 30%. Now only 53% of the total are allocated. This change to the Plan is justified by ‘the 2020 numbers’ which are unlikely to be repeated in the difficult years ahead. Failure to allocate a larger number of dwellings makes the Plan unrealistic and therefore unsound. (This is in addition to the likely failure to achieve the affordable or specialist housing required elsewhere in the Plan (see LC2, LC4)).

Full text:

Ref MM/023, p65, para 5.3

The Plan still shows 6,600 homes to be delivered, but the number allocated in the Plan has been reduced by some 30%. Now only 53% of the total are allocated. This change to the Plan is justified by ‘the 2020 numbers’ which are unlikely to be repeated in the difficult years ahead. Failure to allocate a larger number of dwellings makes the Plan unrealistic and therefore unsound. (This is in addition to the likely failure to achieve the affordable or specialist housing required elsewhere in the Plan (see LC2, LC4)).

Attachments:

Object

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

Representation ID: 10817

Received: 31/01/2021

Respondent: John D Laxton

Legally compliant? Not specified

Sound? No

Representation:

Council Officer has summarised.

Para 5.3 shows a reduction of allocations to only 53% of the total requirement. This is justified by ‘the 2020 numbers’. I contend that the UK post-BrExit & Covid-19 will experience reduced growth in the years ahead. It is unlikely there will be a repeat of the 2020 numbers in the short and medium term. The decision to reduce the number allocated is therefore mistaken.

The Plan must strike the right balance between allocated and unallocated sites. The more that are allocated the easier it makes infra-structure planning. 53% is too low – where will the additional school teachers, health visitors, etc be needed? On which highways will the burden fall? The more that is left to ‘the market’ the more small sites we have and the incentive for any developers to create sites grows.

Failure to allocate more dwellings makes the Plan unrealistic and inadequate as a tool for infrastructure planning and therefore unsound.

Full text:

Ref MM/010, p43, table 4.3

I contend that the Plan as drafted is rendered unsound by the likely conflict between the proposed reduction of 24% in the housing provision in the towns (table 4.3) and Policy LC4: Type and Mix of Housing.

If the reduction is confirmed there will be consequential effects. One will be to reduce the average size of the sites in towns. There will then be a reduced number of sites (in towns) that can accommodate over 10 dwellings. These are the sites where affordable, accessible and adaptable homes can be required. LC4 states that development proposals for new housing should ‘seek to ensure’ an appropriate mix of dwelling types. So to meet policy objective LC4 the towns need sites that will take over 10 dwellings - but the distribution of housing proposed in MM/010 works against this and therefore LC4 is unlikely to be realised in a meaningful way.

This point should be borne in mind when considering (town by town) any proposal further to reduce the number of sites.

Ref MM/023, p65, para 5.3

1. The Plan shows 6,600 homes to be delivered between 2014 and 2034, but the number allocated in the Plan has been reduced by some 30%. In the last sentence of para 5.3 only 53% of the total has been allocated. The Plan argues that this change is justified by ‘the 2020 numbers’ but I contend that the UK post-BrExit & Covid-19 will experience reduced growth (a recession?) in the years ahead. The public sector might be used to stimulate the economy but it is unlikely there will be a repeat of the 2020 numbers in the short and medium term. The decision to reduce the number allocated is therefore mistaken.

2. The Plan must strike the right balance between allocated and unallocated sites. The more that are allocated the easier it makes infra-structure planning. 53% is too low – where will the additional school teachers, health visitors, etc be needed? On which highways will the burden fall? The more that is left to ‘the market’ the more small sites we have and the incentive for any avaricious developers to create sites grows. Sites created by buying back gardens and maybe one property to be demolished for access create an environment in which environmental standards fall and density increases (see MM/102). Not only will immediate neighbours be affected (properties close to boundaries mean less privacy and more noise) but the immediate area will have to carry the unplanned increase in population.

Overall, failure to allocate more dwellings makes the Plan unrealistic. But it is also inadequate as a tool for infrastructure planning and therefore unsound.

Ref MM/025, p66, para 5.9

It is right that the Plan includes provision for a review of the Local Plan in the event of significant under-delivery of the housing requirement or doubt about the land supply. But the criteria proposed for determining whether a review is necessary are unlikely to register any disproportionately high under-delivery of specific types of housing.

I suggest an addition to para 5.9, final sentence, as below in bold type:

‘Where the Housing Delivery Test indicates that the delivery of housing was substantially below (less than 75% of) the housing requirement over the previous
three years, or it becomes apparent that the delivery will not provide appropriate levels of social housing, affordable housing, specialist homes and/or accessible and adaptable homes to meet local needs, or in situations where it is anticipated that the Council …….

(Note: the increase in demand (i.e. need) for social housing is demonstrably increasing. The waiting list maintained by Rykneld Housing has increased by an average of 12% a year, over the last four years.)

Ref MM/032, p71, para 5.24

The Plan will be consistent and therefore sound if para 5.24 is extended to acknowledge the value of the trees that line Stubley Hollow. I suggest that the paragraph be amended by the addition of the following:
‘There are trees along the north west of the site, fronting and rising above Stubley Hollow, and giving it atmosphere. The trees should be retained within the layout of the development (in line with Policy SDC2), and mark the edge of the area of permitted development.’

It has been argued by Dronfield Town Council that retention of this site is ‘unacceptable’. The Council has publicly referred to four recent and emerging sites that will deliver new housing in the ‘immediate’ locality, implying that alternatives to DR2 are available. Three of those sites have planning permission and they provide (or will be providing):
• 6 executive detached homes (4 or 5 bed)(formerly the Hearty Oak pub site)
• 8 detached homes (all of them with 4 double beds) (formerly the Talbot pub site)
• 4 executive detached homes (1x 4 bed, 3x 5 bed) at Mickley, Northern Common.

This is not the mix of housing required by Policy LC4. People looking for affordable or mid-range housing will have to look elsewhere – and if the Plan is to be sound it has to put forward proposals like DR2 or alternatives identified through the land allocation process.

Ref MM/066, p84, policy LC4

I support Policy LC4 as amended but I worry that it is ‘pious’ and will not to be delivered if the towns’ total is reduced from 2024 to 1540 (see ref MM/010 above). The Plan’s shortcomings will be exacerbated if the number of sites providing 10 or more homes is further reduced in response to the current consultation. The Policy should be applied to each of the four towns (given the distance between them) as well as to the total area of the district.

Ref MM/112, p153-154

I contend that a sound policy would not attempt to optimise housing densities in towns but instead would seek to continue existing densities to preserve the character of those towns. A policy to maximise densities would lead to over-population and I fear would ultimately pave the way for the towns’ premature decay, already signalled elsewhere in the Plan.

Attachments: