MM/083

Showing comments and forms 1 to 2 of 2

Object

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

Representation ID: 10082

Received: 04/12/2020

Respondent: Wilson Bowden Developments

Agent: Savills (Birmingham Office)

Legally compliant? Yes

Sound? No

Representation:

Objection
MM/083 makes amendments to Table 6.2 to reflect changes to employment site areas.

We consider that the new information provided by this Main Modification is inaccurate. Due to this, MM/083 81 is not “based on proportionate evidence” or “relevant up-to-date evidence” and fails to comply with paragraph 31 and Paragraph 35 of the NPPF.

MM/083 states that a provision of 4.00ha remains at Markham Vale. However, the Markham Vale Enterprise Zone website states that only 2.91 acres (1.17ha) remain.

Proposed Changes
To review the remaining provision at Markham Vale and to reassess the potential of land surrounding the allocation for further employment development.

Full text:

Land South of Markham Vale

Objection to MM/083

MM/083 makes amendments to Table 6.2 to reflect changes to employment site areas. We object to this Main Modification as we consider these amendments to be inaccurate.

As a result, the Main Modification is neither “underpinned by relevant up-to-date evidence” nor “based on
proportionate evidence” and therefore fails to comply with Paragraph 31 and Paragraph 35 of the NPPF.

Due the proximity of the land South of Markham Vale site to the Markham Vale (West of M1) Long Duckmanton
employment site we have regularly reviewed its take-up. We consider that this is the most desirable and
attractive location for high quality industrial and logistics development in North East Derbyshire and are aware
of recent developments such as the 297,000sqft extension to Markham Vale North which began in June 2020 and the “take-up” of Plot 5 North at Markham Vale East.

The Markham Vale Enterprise Zone website (https://markhamvale.co.uk/availability/) states that just 2.91 acres (1.17ha) remain at Plot 4 East of the site. This figure is significantly lower than the 4.00ha of development land that Table 6.2 has recorded as part of MM/083.

This results in a lower provision for Markham Vale and a lower total provision for the District which makes it
even more essential to commission a swift review of the existing employment evidence to avoid demand
outstripping supply.

We consider that the extremely high take-up of land at Markham Vale is a positive sign for the District and that
additional employment land provision should be sought in this location.

Paragraph 6.24 of the emerging plan (which remains unchanged by these main modifications) states that
employment reports have “identified issues with poor quality stock and an imbalance in the location of portfolio
sites, with further land needed in areas of stronger demand (such as in closer proximity to the M1 Junction);
and to cater for the continued demand for B2 floorspace.”
This further highlights to importance of the Markham Vale allocation to North East Derbyshire and its unique
capacity to address the growing demand for employment space.

Please also refer to related objections, lodged on behalf of Wilson Bowden Developments Ltd, to MM/009,
MM/014 and MM/082.

Proposed Changes
To review the remaining provision at Markham Vale and to reassess the potential of land surrounding the
allocation for further employment development.

Support

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

Representation ID: 10888

Received: 31/01/2021

Respondent: Mr Paul Stock

Representation:

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.

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.

Attachments: