Council’s letter of 7 August 2020 to the Inspector on the ONS 2018-based Household Projections (ED101)

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Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10342

Received: 13/01/2021

Respondent: Mrs Jane Singleton

Representation:

Paragraph no. 4.

I disagree with the Council’s conclusion in ED101 that the ONS 2018 based household projections do not represent a meaningful change in the OAN.

Using consistent methodology based on the 2018 data would give an OAN of 307 or 311. The Plan’s housing requirement of 330dpa is therefore no longer soundly based.

The Iceni report has concluded that the OAN should be lower at 322 (representing a difference of 2.5%) which the Council conclude doesn’t represent a meaningful change. However, as stated in the previous representations on the Iceni report, the percentage is actually 6.1% lower or 7.5% lower than 330.

I would argue that this represents a meaningful change and is further evidence that no Green Belt removal is necessary in the Plan period.

Full text:

I disagree with the Council’s conclusion in ED101 that the ONS 2018 based household projections do not represent a meaningful change in the OAN.

Using consistent methodology based on the 2018 data would give an OAN of 307 or 311. The Plan’s housing requirement of 330dpa is therefore no longer soundly based.

The Iceni report has concluded that the OAN should be lower at 322 (representing a difference of 2.5%) which the Council conclude doesn’t represent a meaningful change. However, as stated in the previous representations on the Iceni report, the percentage is actually 6.1% lower or 7.5% lower than 330.

I would argue that this represents a meaningful change and is further evidence that no Green Belt removal is necessary in the Plan period.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10459

Received: 21/01/2021

Respondent: Mr Paul Johnson

Representation:

See evidence attached to MM/0087, MM009 and MM010, please.

Full text:

The remaining Housing Allocations in MM/026 place an unfair burden on Killamarsh, which has way behind other settlements in terms of Infrastructure, public transport, employment opportunities and green space. It also damages the Green Belt protecting Killamarsh, whilst ‘saving’ other similar GB sites.

The removal of other sites now means that Killamarsh must accept the largest share of development in the tier 1 settlements, more than any other site other than the strategic ones, and more than the two closest tier one site put together.

No infrastructure additions have been shown in any Plan and the compensatory elements of plans submitted are entirely dependent upon developer contributions. These are highly unlikely to happen due to site viability issues.

The final sentence of this MM refers to compensatory improvements re Green Belt land refers to these being required ‘where appropriate’. This should be changed to ‘unless deemed unnecessary by the local planning authority’.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10487

Received: 21/01/2021

Respondent: Mr David Meechan

Representation:

Section headed ‘ONS 2018-based Household Projections’

I disagree with the Council’s conclusion in ED101 that the ONS 2018 based household projections do not represent a meaningful change in the OAN. Their supporting evidence from Iceni is inconsistent with previous methodology. It no longer adjusts ONS projections for migration but continues to adjust household formation rates (HFRs). Either the ONS projections should not be adjusted at all or should be adjusted in a consistent manner to that used previously (both migration and HFRs). Applying both of these methods to the 2018 projections would lead to a meaningful change in the OAN, down to 307 and 311 dpa respectively. The Plan’s housing requirement of 330 dpa is therefore no longer soundly based

Full text:

Section headed ‘ONS 2018-based Household Projections’

I disagree with the Council’s conclusion in ED101 that the ONS 2018 based household projections do not represent a meaningful change in the OAN. Their supporting evidence from Iceni is inconsistent with previous methodology. It no longer adjusts ONS projections for migration but continues to adjust household formation rates (HFRs). Either the ONS projections should not be adjusted at all or should be adjusted in a consistent manner to that used previously (both migration and HFRs). Applying both of these methods to the 2018 projections would lead to a meaningful change in the OAN, down to 307 and 311 dpa respectively. The Plan’s housing requirement of 330 dpa is therefore no longer soundly based

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10750

Received: 30/01/2021

Respondent: Mr Eric Singleton

Representation:

Respondent indicates objection on representation form.

• The Council’s conclusion in ED101 that the ONS 2018 based household projections do not represent a meaningful change in the OAN is not correct.
o The supporting evidence, ED101A, is inconsistent with previous methodology and represents a desperate attempt to justify an aspirational dpa target which the Council has used to underpin a bogus argument of exceptional circumstances.
o ED101A no longer adjusts ONS projections for migration but continues to adjust household formation rates (HFRs). Either the ONS projections should not be adjusted or should be adjusted in a consistent manner to that used previously (both migration and HFRs)
o Applying both of these methods to the 2018 projections would lead to a meaningful change in the OAN, down to 307 and 311 dpa respectively.
o The Plan is based on a requirement of 330 dpa representing an excess of 380-460 dwellings over the Plan period.
o A consistent method produces a reduction in need that more than offsets planned development on green belt.

• Consequently, all green belt allocations must be removed from the Plan for it to be considered sound.

Full text:

• The Council’s conclusion in ED101 that the ONS 2018 based household projections do not represent a meaningful change in the OAN is not correct.
o The supporting evidence, ED101A, is inconsistent with previous methodology and represents a desperate attempt to justify an aspirational dpa target which the Council has used to underpin a bogus argument of exceptional circumstances.
o ED101A no longer adjusts ONS projections for migration but continues to adjust household formation rates (HFRs). Either the ONS projections should not be adjusted or should be adjusted in a consistent manner to that used previously (both migration and HFRs)
o Applying both of these methods to the 2018 projections would lead to a meaningful change in the OAN, down to 307 and 311 dpa respectively.
o The Plan is based on a requirement of 330 dpa representing an excess of 380-460 dwellings over the Plan period.
o A consistent method produces a reduction in need that more than offsets planned development on green belt.

• Consequently, all green belt allocations must be removed from the Plan for it to be considered sound.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10780

Received: 29/01/2021

Respondent: Matthew Mosely

Agent: ADAS

Representation:

Council Officer has summarised.

The Council places heavily reliance on an early review to make the plan ‘sound’ and dismisses concerns over the disruption to supply caused by the restrictions relating to the Covid-19 pandemic. This approach, combined with the significant reduction in units due to the removal of housing allocations, does not represent a plan that is prepared positively or will meet the needs of the District.

The Iceni report notes the possibility of supply constraints related to Covid; in light of this we urge the plan to adopt a precautionary approach to ensure the plan delivers sufficient housing.

We have concerns in relation to the apparent reliance of the Council on delivering later in the plan period to 2034 in the event of disruption.

It is disappointing that the Council has removed the uplift to support economic growth. We would question whether it is appropriate to assume previous levels of economic growth will carry through the plan-period.

Full text:

We are grateful for the opportunity to respond again to the consultation on the North East Derbyshire Local Plan. This representation is submitted by ADAS on behalf of the landowners of Land to the east of Summerwood Road, Dronfield. The site is known as Site Ref. DRO/2403 in the Council’s Land Availability Assessment (LAA) 2017, and as Site Ref. DRO/GB/082 in the Green Belt Review (GBR). We wish to make representations in relation to the following:
• Main Modification MM/026: Removal of DR1 and DR2
• Council’s Letter to the Inspector, 7th August 2020 (ED101)
• Omission site – Land east of Summerwood Road, Dronfield
ADAS has previously made representations in relation to the site, including most recently in August 2019. In our previous representations, we confirmed the immediate availability and deliverability of the site to provide much needed housing to meet the needs of the District in the plan-period.
These representations are made in response to the Proposed Main Modifications (MM/026) to remove Green Belt housing allocation DR2 from the plan and the partial removal of site DR1. These modifications raise significant concerns over the ability of the plan to deliver the homes that the District needs over the plan-period, and therefore the soundness of the plan is compromised. In the absence of additional allocations to compensate for the loss, this modification also threatens to greatly undermine the spatial strategy set out in the plan.
Our representations also relate to the Council’s letter to the Inspector (7th August 2019), in which the Council places a heavy reliance on an early review to make the plan sound, and which dismisses concerns over the disruption to supply caused by the restrictions relating to the Covid-19 pandemic. This approach, combined with the significant reduction in supply due to the removal of housing allocations, does not in our view represent a plan that is prepared positively or will meet the needs of the District in a strategic and sustainable manner.
In addition, we wish to draw the Inspector’s attention to the above site (LAA Site Ref. DRO/2403; GBR site ref. DRO/GB/082) to the east of Summerwood Road, Dronfield. The Council’s own evidence base finds this to be a suitable site, and we confirm that the site is deliverable and would make a meaningful contribution of circa 50 dwellings within the first 5 years of the plan. The site received a green score in the Green Belt Review Supplementary Assessment and all minor technical queries identified in the LAA have now been addressed. There is now absolutely no sound or reasonable justification for this site to be omitted while similar sites such as DR3 remain included, particularly in light of the significant housing need that exists in the settlement.
This representation also consists of the following documents in relation to Land east of Summerwood Road, Dronfield:
• Location Plan
• Indicative Layout Plan
• Transport Assessment
• Coal Risk Mining Assessment (set through file share).
Main Modification MM/026 – Removal of site DR2 and part of DR1
Main Modification MM/026 proposes the full removal of site DR2 from the plan and the partial removal of Site DR1, resulting in a significant reduction in housing numbers to be delivered in Dronfield over the plan-period. No additional or replacement sites have been identified by the Council. This reduction raises serious questions about the Council’s ability to robustly meet its housing needs over the plan-period, particularly considering the potential disruption caused by the ongoing Covid-19 pandemic and associated restrictions.
Dronfield is a ‘Level 1 Settlement’ and considered to be one of the most sustainable locations in the district for new development. The removal of allocations in Dronfield without replacement will significantly undermine the Local Plan spatial strategy of directing development in accordance with the settlement hierarchy and will harm Dronfield’s role in driving economic growth for the District. The physical locational advantages of Dronfield being located halfway between Sheffield and Chesterfield places a significant pressure on the town to provide suitable housing to meet this locational driven housing requirement.
We would strongly urge the Council to plan positively and include all suitable sites to meet its identified housing needs over the plan-period.
We confirm that omission site DRO/2403 is immediately deliverable and available and should be allocated to assist with meeting the needs of Dronfield and the District as a whole. This site can deliver housing within the first five years of the plan in a highly sustainable location. Further information on the suitability of this site is provided in this representation.
Council’s Letter to the Inspector – 7th August 2020
We wish to make representations on the Council’s Letter to the Inspector, which was issued on 7th August 2020. In the letter, the Council places heavily reliance on an early review to make the plan ‘sound’ and dismisses concerns over the disruption to supply caused by the restrictions relating to the Covid-19 pandemic. This approach, combined with the significant reduction in units due to the removal of housing allocations, does not in our view represent a plan that is prepared positively or will meet the needs of the District.
The Council comments that there is incomplete evidence on the effects of Covid-19 on supply, but any effects are likely to suppress delivery. We would urge the Council to plan positively in a pro-active way to ensure that supply is maintained. The Iceni report cited by the Council does note the possibility of supply constraints related to Covid, so in light of this we would strongly urge the plan to adopt a precautionary approach to ensure the plan delivers sufficient housing to meet its needs and to ensure a 5-year supply of deliverable housing sites.
In addition, we have concerns in relation to the apparent reliance of the Council on delivering later in the plan period to 2034 in the event of disruption. The letter notes that “it is acknowledged that the Covid-19 situation could impact on housing market activity and economic growth prospects, but there is currently insufficient evidence available to predict…in particular given that the plan looks to 2034”. The plan should be positively prepared and provide for a 5-year housing land supply at the point of adoption, rather than relying on delivery to improve later in the plan-period. Every effort should be made to deliver the District’s Local Housing Need.
Further, it is disappointing that the Council has removed the uplift to support economic growth. The Council’s Letter states that this is due to housing delivery rates in the period 2014-2020, however we would question whether it is appropriate to assume previous levels of economic growth will carry through the plan-period, in particular in the first five years amid an unprecedented period of uncertainty relating to the Covid-19 pandemic.
Land East of Summerwood Road, Dronfield (LLA Site DRO/2403; GBR Parcel DRO/GB/082)
As set out above, ADAS has previously submitted representations in support of the allocation of Land East of Summerwood Road, Dronfield. We maintain that this is a highly logical and sustainable site for the delivery of housing. The site is located immediately adjacent to the settlement boundary for Dronfield – a Level 1 Settlement, and is well contained by boundary vegetation and physically contained by the B6056 along the northern site boundary. The Council has included an allocation immediately to the west of the site (Site DR3), demonstrating and establishing the fact that the Council considers this to be a sustainable location for new housing.
The location of the site in relation to Dronfield and allocation DR3 can be seen in the excerpt from the Submission Local Plan Policy Map below:
As previously noted, the site scored highly in the Council’s Green Belt Review Supplementary Assessment, where it received a ‘green’ overall score. Of particular note, the Green Belt Review noted the following in relation to ‘defensible boundaries’ in safeguarding the countryside from encroachment (purpose 3):
“Development of the parcel would arguably strengthen the Green Belt boundary. The current boundary is mainly defined by trees and hedgerow, the resultant boundary would be contained by a road (Stubley Hollow)”
The site also scored well across a whole range of suitability criteria in the Council’s own Land Availability Assessment.
As noted within the Councils LAA, there are no policy constraints that would preclude development of the site for housing. The site is not subject to any national or local designation for landscape quality or ecology, and there are no heritage assets that would be affected by the proposals.
We confirm that the site is available and deliverable. The suitability of the site is summarised in the following paragraphs.
The site received a green score in the Green Belt Review.
The Green Belt Review (GBR) Supplementary Assessment found the site made a poor contribution to all five purposes of the Green Belt except purpose 3 due to the greenfield nature of the site. Crucially, the Green Belt Review notes that the development of this parcel could strengthen the Green Belt boundary. This is particularly notable following the proposed release and allocation of site DR3 (GBR Ref. DRO/GB/081) immediately to the west of the site, also to the south of Summerwood Road.
FIGURE 1. SUBMISSION LOCAL PLAN
FIGURE 2. LOCATION PLAN
The site performed positively on opportunities and constraints in the GB review.
The Green Belt Review noted in its Assessment of Constraints and Opportunities (‘Stage C’), that the site was subject to no constraints that would be considered prohibitive to development. The summary of constraints within the Green Belt Review was that the site is ‘unlikely to be constrained’. This is the same outcome that Site DR3 received immediately to the west (GBR Ref. DRO/GB/081), which has now been proposed for removal from the Green Belt and allocated for housing.
The site performed positively on deliverability in the GB Review.
The site received a positive assessment for deliverability, indeed exactly the same assessment of site DR3 to the west (GBR Ref. DRO/GB/081), which has since been proposed for removal and allocation for housing.
We confirm that the site is available now with a willing landowner and could deliver housing within the first five years of the plan.
Land Availability Assessment – All queries have now been addressed.
The Council’s Land Availability Assessment (LAA) 2017 considered the site under site ref. DRO/2403. A number of constraints were highlighted, which presumably resulted in the Council not progressing with the allocation. We are pleased to confirm that all these constraints were minor and speculative in nature, and are now robustly addressed as follows:
LAA Comment
Our response
1. Is the site available for development?
Landowner unknown - Red
The landowner is Matthew Mosley who has confirmed that he is willing to support the site for housing - Green
3. Is the site located within the Green Belt?
Amber as the site received a Green Score
The site received a ‘green’ score in the Green Belt Review, and is therefore considered to perform poorly against the key purposes set out in the Framework - Green
5. Is the site susceptible to fluvial or surface water flooding?
Surface water flooding in east - Amber
There is a surface water flooding on the site. There is a very small area at medium risk immediately to the north east corner. This could be easily managed with appropriate SuDS. Green
7. Will development of the site be compatible with existing and/or proposed neighbouring land uses?
Noise from A61 - Amber
There is potential for some noise in the eastern extent of the site, however this could be mitigated through a range of measures such as acoustic fencing and mechanical ventilation within the residential units, and appropriate design and layout. Amber
9. Can suitable access be made to the transport network?
Significant level difference between the site and highway - Amber
A Transport Statement (TS) has been produced, which confirms that a new vehicular access can be provided to the northern site boundary. The TS confirms that the required visibility splays could be achieved on the site. Green
10. Will the development impact upon highway safety and or highway capacity?
Possibly – further investigations required. Amber.
A Transport statement (TS) has been produced in support of the site, which finds that the surrounding highway network would operate satisfactorily without resulting in highway or safety issues with the increase in traffic. Green
Are there any land stability constraints?
Main part of the parcel is within a Development High Risk Area (Coal Authority Referral Area). Amber
A Coal Mining Risk Assessment has been produced which recommends that development on the site could progress on the basis of a number of mitigation measures. The site has land which is stable and ready to be built out for residential development. Green
This table (above) demonstrates that the site is free of any significant constraints to development. The site is in a highly sustainable location immediately adjacent to the existing built-up area of Dronfield. It is available now and deliverable with a willing landowner and would deliver housing within the first five years of the plan.
Conclusion:
This representation raises a number of soundness matters that must be addressed in relation to the main modification (MM/026) that seek to remove several large allocations in Dronfield without any additional housing allocations to meet local housing need. These modifications raise significant concerns over the ability of the plan to deliver the homes that the District needs over the plan-period, and therefore the soundness of the plan. Furthermore, the significant reduction in housing allocations in Dronfield – a ‘Level 1 Settlement’ and focus for growth, will significantly undermine the Council’s spatial strategy and potentially lead to unsustainable patterns of development.
The plan must be positively prepared, effective, justified, and consistent with national policy. The Council must begin by ensuring that its housing needs are provided in full, including a five-year housing land supply on adoption.
We have significant concerns in relation to the Council’s approach set out within the Letter to the Inspector dated 7th August 2019, which places heavy reliance on an early review to make the plan ‘sound’, and which dismisses concerns over the disruption to supply caused by the restrictions relating to the Covid-19 pandemic. This approach, combined with the significant reduction in housing allocations in Dronfield, does not in our view represent a plan that is prepared positively or will meet the needs of the District and certainly not sustainable as it will fail to plan proactively for the sustainable growth of Dronfield.
We are concerned by the lack of due consideration given to the likely effects of Covid-19 on disrupting supply and would urge the Council to take a more pro-active approach.
Considering the above comments, we would strongly recommend allocation of Land east of Summerwood Road, Dronfield (LAA Ref. 2403). Site 2403 has been found to make a poor contribution to the key purposes of the Green Belt and is remarkably free of physical constraints. It is in a highly sustainable location that would deliver homes within the first 5 years of the plan-period. We confirm that this site is available now with a willing landowner.