MM/066

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Support

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

Representation ID: 10789

Received: 29/01/2021

Respondent: Derbyshire County Council

Representation:

Council Officer (NEDDC) has summarised.

MM/ 017 MM/065 and MM/066: Support subject to comments

DCC would request that greater flexibility be given to permit housing for the elderly / supported needs on land that might overwise be safeguarded against development in the local plan – this suggests Greenbelt development could be permitted but Greenbelt land would naturally be beyond the edges of the settlement boundaries whereas DCC is aware of a number of underutilised areas of POS / allocated recreation land close to district centres and local amenities that would better fit the bill. This would help support the County Council’s Adult Care Accommodation Strategy.

The above suggestion could be expanded further in MM/017 to permit housing development in general on POS/allocated recreation land where it can be demonstrated as being poor quality and unused. Again development of such land would seem preferable to Greenbelt development i.e. within the settlement boundaries close to amenities.

Full text:

Thank you for consulting Derbyshire County Council (DCC) on the North East Derbyshire Local Plan Main Modifications (MM). DCC’s officer technical comments on the MMs are set out below.
DCC submitted extensive comments on the North East Derbyshire Local Plan Publication Draft (LPPD) on 4 April 2018. DCC also submitted statements on behalf of the County Council relating to a number of the Inspector’s Main Matters, Issues and Questions for the Local Plan Hearing Sessions relating to:
Matter 6: Green Belt
Matter 7: Infrastructure: Highways Statement
Matter 7: Infrastructure: Education
Matter 15: Gypsies and Travellers
DCC’s officer technical comments on the MMs below are made in the context of above.
Living Communities
MM/025: Support
Comments
It is noted from the MMs that no modifications have been made to the District’s overall housing provision requirement in the LPPD of 6,600 dwellings (330 per annum). DCC supported this housing requirement through its comments on the LPPD as it was considered to be well justified and based on robust and comprehensive evidence set out in the North Derbyshire and Bassetlaw Strategic Housing Market Area Update 2017.

Based on updated monitoring information produced by the District council, it is noted in MM/025 that from the start of the Plan Period, this updated information now indicates that there has been no significant undersupply in relation to the Governments Housing Delivery Test and therefore the housing trajectory in Appendix C has sought to ensure it includes a 5% buffer within the first five years after adoption (rather than a 20% buffer as previously included in the LPCD); and that if in future monitoring years, the Housing Delivery Test indicates that there is significant under delivery over the previous three years (below 85% of the requirement), the buffer should be increased to 20% in the five year housing land supply calculations.

On the basis of the above, MM/025 is considered to be fully justified in including a 5% buffer rather than a 20% buffer to the District housing land supply as previously set out in the LPPD as this is considered to be in accordance with requirements of Government policy and guidance for provision of housing by local planning authorities, particularly relating to the Housing Delivery Test.

Gypsies and Travellers
MM/072 / MM/073 / MM/074

Comments

DCC submitted a detailed statement on Main Matter 15: Gypsy and Traveller Provision for the Local Plan Hearing Session, particularly setting out details of the Derby, Derbyshire, Peak District National Park and East Staffordshire Gypsy and Traveller Accommodation Assessment (GTAA) that it had commissioned on behalf of all the partner authorities in the assessment; and its Member and Officer comments on four proposed allocations for Traveller sites in the District, including sites at The Old Potato Store, Dark Lane Callow and Dark Lane, North Wingfield. DCC’s officer also appeared at the Local Plan Hearing Session to address questions and issues raised by the Inspector in respect of the proposed allocated sites. In the context of the above, DCC has no further comments to make on MMs 072, 073 and 074.

MM / 075: Support

Comments

It is noted that the proposed allocation of the two sites at The Old Potato Store, Dark Lane Callow and Dark Lane, North Wingfield would provide for a total of 5 pitches against a total pitch requirement of 6 pitches identified in the Derby, Derbyshire, Peak District National Park and East Staffordshire GTAA for the period 2014 – 2019.

In this context, and the shortfall of pitches proposed to be allocated, MM/075 is supported as it provides a more firm commitment that the District Council will seek to ensure the provision of further sufficient pitches within the District to meet the full accommodation needs of gypsies and travellers as assessed through the current Gypsy and Traveller Accommodation Assessment (or its replacement).

Safeguarded Land for Education provision

MM/118: Support subject to following comments

Comments

In its comments on the LPPD, DCC expressed concerns to the District Council that the LPPD Proposals Maps did not identify any of the County Council’s notified sites that it wished to retain for education purposes. Plans of the relevant sites were subsequently sent by DCC to the District Council. Furthermore, concern was expressed that the infrastructure section of the Plan did not make any specific reference to notified school sites other than loosely through Policies ID4 and ID5 regarding social infrastructure. DCC requested therefore that the District Council addressed these concerns and identified the County Council’s notified sites on the relevant Local Plan Proposals Maps and included reference to notified sites and the importance of the need for their retention for education purposes within the Social Infrastructure Section of the LPPD and Policy ID5.

DCC is pleased to see that its concerns have been largely addressed through MM/118 with proposed additional text and a supporting Policy D6: Safeguarded Land for Education Facilities, which correctly identifies the four sites DCC wishes to see identified as Notified Sites. However, it is noted that the revised Proposals Map only identifies two of the four sites at Unstone and Mickley. DCC would request, therefore, that the two other sites at a) Renishaw Primary School, Hague Lane, Renishaw; and b) Land at Lansbury Avenue, Pilsley are also identified on the Proposals Map. Plans of these sites are attached to this letter.
Highways

MM/114 MM/115 and MM/116: Support subject to comments below

Comments

DCC made extensive comments on the highways implications of the Local Plan’s policies and allocations through its comments on the LPPD and its detailed Highways Statement referred to above for the Examination Hearing Sessions. Comments through the above highlighted conclusions that had arisen through the transport modelling works undertaken to inform the Local Plan that had identified the need for highway mitigation works at the A61 Bowshaw roundabout and the B6057 Green Lane/Callywhite Lane junction arising from the proposed development at Dronfield, on the basis of cumulative impacts and the need for developer contributions to support the delivery of any necessary improvements. This work also highlighted that traffic, albeit not in large volumes arising from proposed housing development mainly at Renishaw, Eckington and Killamarsh would route to and from junction 30 of the M1 motorway. Consequently DCC would continue to liaise with NEDDC and Highways England together with the other relevant neighbouring authorities to more fully explore the cumulative impacts of planned growth on junction 30 of the M1.

In the context of the above, DCC welcomes the amendments that are proposed to the supporting text in the Local Plan under MM114 and MM115 and through amendments to Policy ID2: Provision and Safeguarding of Transport Infrastructure, that satisfactorily address DCC’s comments and issues raised on this matter.


Climate Change and Sustainable Development
MM/090: Support subject to comments below
Comment

Policy WC5: Point 2. DCC would request that the following requirement is also included:

‘In all cases proposals will be expected to have high energy efficiency and net zero carbon emissions in operation’

MM099: Support subject to comment below

Comment

Policy SDC1: Re-use and Conversion of Buildings in the Green Belt and Countryside. Under point 1 DCC request that the following requirement is also included:

‘the design incorporates high energy efficiency and low/zero carbon energy technologies’

Housing Needs of Older People and People with other Specialist Needs

MM/ 017 MM/065 and MM/066: Support subject to following comments

Comments
DCC would request that greater flexibility be given to permit housing for the elderly / supported needs on land that might overwise be safeguarded against development in the local plan e.g. at MM/065 and MM/066 – this suggests Greenbelt development could be permitted but Greenbelt land would naturally be beyond the edges of the settlement boundaries whereas DCC is aware of a number of underutilised areas of POS / allocated recreation land close to district centres and local amenities that would better fit the bill. This would help support the County Council’s Adult Care Accommodation Strategy; https://www.derbyshire.gov.uk/site-elements/documents/pdf/social-health/adult-care-and-wellbeing/accommodation-and-housing/older-peoples-housing-accommodation-and-support-strategy-2019-to-2035.pdf

The above suggestion could be expanded further in MM/017 to permit housing development in general on POS/allocated recreation land where it can be demonstrated as being poor quality and unused – DCC has examples where despite efforts to secure interest from local sports clubs the land sits fallow and has done for years becoming a drain on the County Council’s Grounds Maintenance budget – ultimately the land attracts unsocial behaviour and becomes a nuisance hot spot. Again development of such land would seem preferable to Greenbelt development i.e. within the settlement boundaries close to amenities – schools, shops, surgeries, bus routes etc.

Landscape

MM101: Support

DCC welcomes MM/101, which indicates that ‘In addition, within this landscape context, Derbyshire County Council has prepared a tranquillity map for Derbyshire. This map which expresses locally the spread of tranquillity will be a material consideration when determining proposals under Policy SDC3.

This additional text will help to clarify that tranquillity is an important perceptual quality of the landscape, and will assist in the implementation of Policy SDC3: Landscape Character.


General Comment: Provision of New Infrastructure: Public Transport
The LPPD and the Main Modifications do not make any reference to proposals to reopen the Barrow Hill rail line. A bid to the DfT has recently been submitted on behalf of DCC and the Sheffield City Region to re-open the line and as part of this there are proposals for a new station approximately midway between Eckington and Renishaw. There is also a proposal for a station to serve Killamarsh but the actual site for this is just inside South Yorkshire. Through the Main Modifications, DCC considers that there may be an opportunity to update the Local Plan to identify proposals to open the Barrow Hill rail line which, if approved by the DfT, will provide for an important new piece of transport infrastructure that could assist in facilitating proposed new growth in the District and significantly improve connectivity to and from the District.
I hope the comments above are of assistance to the District Council

Object

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

Representation ID: 10820

Received: 31/01/2021

Respondent: John D Laxton

Legally compliant? Not specified

Sound? No

Representation:

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.

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: