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)

Showing comments and forms 1 to 27 of 27

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10097

Received: 09/12/2020

Respondent: Mr Robert Barron

Representation Summary:

Paragraph No. 20 of ED101A

DRO/2701 Gladys Buxton Community Centre site only shown.
No recognition of sites such as the ground where the former Talbot Arms pub was, Hearts of Oak pub on Northern Common, the potential site of The Three Tuns pub on Chesterfield Road, and small sites such as Cross Lane, Eckington Rd.
On a wider scale across the NE Derbyshire region which the plan encompasses, there is no recognition of the 5 year plan being up to date of housing provision now available in Holmewood and Clay Cross areas.

No account of business casualties from Covid 19 pandemic freeing up empty premises as businesses fail.

Full text:

Referring to diagram DR1 The planned retention of the intention to build 160 houses at the Chesterfield Road site does not accommodate an up to date evaluation of available land on “windfall sites” and development of “brown field sites” in the local area. There is no cognisance given to current and completed house building in the wider area of NE Derbyshire which the Local Plan covers.


DRO/2701 Gladys Buxton Community Centre site only shown.
No recognition of sites such as the ground where the former Talbot Arms pub was, Hearts of Oak pub on Northern Common, the potential site of The Three Tuns pub on Chesterfield Road, and small sites such as Cross Lane, Eckington Rd.
On a wider scale across the NE Derbyshire region which the plan encompasses, there is no recognition of the 5 year plan being up to date of housing provision now available in Holmewood and Clay Cross areas.

No account of business casualties from Covid 19 pandemic freeing up empty premises as businesses fail.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10133

Received: 10/12/2020

Respondent: Mrs Jane Singleton

Representation Summary:

Council Officer has summarised.

Paragraph No. 19

The Iceni report is yet another example of working backwards from an aspirational target set previously. The 2018-based projections are based on a two year trend. Previously the SHMA used a ten year migration trend as it “provided a reliable basis for drawing conclusions on housing need.” Also set out in the Council’s Hearing Statement at 4.3.2. The ten year migration figure gave a higher figure than the 2014-based projections. Adjusting the migration figures in the 2018-based projections to use 10 year trends would bring the figures down to below the 2014-based projections. Any idea that Covid-19 or Brexit might have a negative effect on the economy and reduce housing need is dismissed. It is clear that the 70,000 jobs (LEP) SCR at midpoint will not be realised. It would seem unsound to use two years of data for a Plan to 2034 rather than the reliable 10 years of data. Continuing to use two years of data for a Plan to 2034 is not sound or positively prepared.

Full text:

19. Iceni considers that the household representative rates in the 2016- and 2018-based household projections should be treated with considerable caution, as projections based on just two data points will have notable potential error margin.

The Iceni report is yet another example of working backwards from an aspirational target set previously. The 2018-based projections are based on a two year trend. Previously the SHMA used a ten year migration trend as it “provided a reliable basis for drawing conclusions on housing need.” In the Council’s Hearing Statement at 4.3.2., “The case is made for a 10 year migration basis for the demographic projections. It accounts for an economic cycle and is better related to the 20 year plan period.” The ten year migration figure gave a higher figure than the 2014-based projections. Adjusting the migration figures in the 2018-based projections to use 10 year trends would bring the figures down to below the 2014-based projections. Any idea that Covid-19 or Brexit might have a negative effect on the economy and reduce housing need is dismissed because “there is currently insufficient evidence to predict or quantify with any certainty, what impact this might have, in particular as the Plan looks to 2034”. It is clear that the 70,000 jobs (LEP) SCR at midpoint (2015-2025) will not be realised. It would seem unsound to use two years of data for a Plan to 2034 rather than the reliable 10 years of data, but it seems the Iceni Report was commissioned on the basis that it had to concur with the 330, come what may, even though it represents an uplift of 62%. Continuing to use two years of data for a Plan to 2034 is not sound or positively prepared.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10296

Received: 03/01/2021

Respondent: Mr Eric Singleton

Representation Summary:

Council Officer has summarised.

Respondent indicates objection on representation form.

Representation refers to paragraph 5, 8

• This report is a desperate attempt to justify an excessively high OAN.

• The report uses 2 years of inward migration data to support a 20 year extrapolation
o Extrapolation results become more unreliable over time.
o Iceni make no attempt to estimate the error range.
o Iceni argue their methodology is consistent with 2014-20 data but this period represents a post Great Recession recovery and is therefore above long term trend.
o The Council have previously argued that 10 year migration trend data was necessary to provide “a reliable basis for drawing conclusions on housing need.”

• The Local Plan is based on a malignant strategy of using an ‘aspirational’ housing figure (OAN) and prescriptive spatial strategy to create an artificial shortage of land in specific areas.

• This shortage was used as a justification for the exceptional circumstances required for reviewing Green Belt boundaries and the release of Green Belt land owned by developers.

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

Full text:

• This report is a desperate attempt to justify an excessively high OAN.

• The report uses 2 years of inward migration data to support a 20 year extrapolation (para 5, 8).
o Extrapolation results become more unreliable as one moves further beyond the data (even for a simple linear function, the error grows quadratically).
o Whilst Iceni acknowledge the projections have a 'notable potential error margin' (para 19) they make no attempt to estimate the error range.
o Iceni attempt to justify their methodology by arguing it is consistent with 2014-20 data (para 37). However, Iceni acknowledge this period is when “the housing market began to pickup” i.e. it represents a post Great Recession recovery and is therefore above long term trend.
o The Council have previously argued that 10 year migration trend data was necessary to provide “a reliable basis for drawing conclusions on housing need.” (NEDDC Hearing Statement Matter 4 - Housing OAN FINAL, para 4.2.1), 22-Oct-2018)

• It is quite apparent the Local Plan is based on a malignant strategy of using an ‘aspirational’ housing figure (OAN) and prescriptive spatial strategy to create an artificial shortage of land in specific areas.

• This shortage was used as a justification for the exceptional circumstances required for reviewing Green Belt boundaries and the release of Green Belt land owned by developers.

• 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: 10297

Received: 03/01/2021

Respondent: Mr Eric Singleton

Representation Summary:

Council Officer has summarised.

Respondent indicates objection on representation form.

Representation refers to paragraphs 35, 38, 39, 40

• This report is a desperate attempt to justify an excessively high OAN.

• The report fails to justify a DPA beyond the ONS projected 279 dwellings.

• The report fails to justify a DPA 18% above the housing need methodology and 32% higher than Chesterfield and Bolsover.

• Separate uplifts are applied for both young household formation and affordable housing which represents double counting.

• The conclusion is based on a highly speculative extrapolation of the most favourable migration data available.

• It notes the potential impact of Covid but no negative factors are considered.

• The Local Plan is based on a malignant strategy of using an ‘aspirational’ housing figure (OAN) and prescriptive spatial strategy to create an artificial shortage of land in specific areas.

• This shortage was used as a justification for the exceptional circumstances required for reviewing Green Belt boundaries and the release of Green Belt land owned by developers.

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

Full text:

• This report is a desperate attempt to justify an excessively high OAN.

• The report fails to justify a DPA beyond the 279 supported by official ONS demographic projections (para 36).

• The report fails to justify a DPA 18% above that determined by the Government housing need methodology and 32% higher than Chesterfield and Bolsover when these areas are in the same SHMA (para 40).

• Separate uplifts are applied for both young household formation (para 38) and affordable housing (paras 35, 40). Young households will tend to be more represented in affordable housing; these uplifts represent double counting.

• The conclusion is based on a highly speculative extrapolation of the most favourable migration data available (detailed in a separate representation).

• It notes the potential impact of Covid (para 39) but makes no attempt to assess the likely effect of the associated unprecedented economic shock. No negative factors are considered.

• It is quite apparent the Local Plan is based on a malignant strategy of using an ‘aspirational’ housing figure (OAN) and prescriptive spatial strategy to create an artificial shortage of land in specific areas.

• This shortage was used as a justification for the exceptional circumstances required for reviewing Green Belt boundaries and the release of Green Belt land owned by developers.

• 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: 10339

Received: 13/01/2021

Respondent: Mrs Jane Singleton

Representation Summary:

Paragraph no. 19.

The Iceni report on the implications of the 2018-based Household Projections (ED101A) uses a different methodology to that used in the evidence base.

EB-HOU4 used population projections adjusted for 10-year migration trends (an ‘industry standard’), recognising that migration can be variable over time. ED101A uses unadjusted ONS projections based on migration trends over just a 2-year period. The inconsistency is not justified.

ONS projections based on 10-year migration data show a figure of 47,280 households for NE Derbyshire in 2034. This is 3.44% lower than that used by Iceni and reduces housing need from 322 to 311 dpa. The Plan is based on an OAN of 330 dpa, so the requirement has been inflated by 6.1%. This would mean an excess of 380 houses over the Plan period.

Inconsistent methodology has been used to assess the OAN, which is not justified, sound or positively prepared, particularly when the removal of land from the Green Belt is being proposed.

Full text:

The Iceni report on the implications of the 2018-based Household Projections (ED101A) uses a different methodology to that used in the evidence base.

EB-HOU4 used population projections adjusted for 10-year migration trends (an ‘industry standard’), recognising that migration can be variable over time. ED101A uses unadjusted ONS projections based on migration trends over just a 2-year period. The inconsistency is not justified.

ONS projections based on 10-year migration data show a figure of 47,280 households for NE Derbyshire in 2034. This is 3.44% lower than that used by Iceni and reduces housing need from 322 to 311 dpa. The Plan is based on an OAN of 330 dpa, so the requirement has been inflated by 6.1%. This would mean an excess of 380 houses over the Plan period.

Inconsistent methodology has been used to assess the OAN, which is not justified, sound or positively prepared, particularly when the removal of land from the Green Belt is being proposed.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10340

Received: 13/01/2021

Respondent: Mrs Jane Singleton

Representation Summary:

Paragraph No. 19 & 22

Iceni report (ED101A) is inconsistent in its approach to trend data.

It uses migration data over a 2-year period (rather than 10-years used in EB-HOU4) but continues to use longer-term trends dating back to 1971 to adjust upwards household formation rates because ‘projections based on just two data points will have a notable potential error margin’.
This adjustment raises their demographic-based need for housing from 279 to 293 dpa.

If Iceni believe that it is now appropriate to use unadjusted ONS projections based on 2-year migration data, it should be consistent and use unadjusted ONS projections based on household formation data from 2001 and 2011 Census points. This would reduce the assessed need by 4.8% from 322 dpa to 307 dpa.

The Plan is based on a requirement of 330 dpa. Iceni data is 7.5% higher, representing an excess of 460 houses over the Plan period. The Inspector must assess whether this is a justified and sound approach, particularly when the Plan is proposing Green Belt removal.

Full text:

Iceni report (ED101A) is inconsistent in its approach to trend data.

It uses migration data over a 2-year period (rather than 10-years used in EB-HOU4) but continues to use longer-term trends dating back to 1971 to adjust upwards household formation rates because ‘projections based on just two data points will have a notable potential error margin’.
This adjustment raises their demographic-based need for housing from 279 to 293 dpa.

If Iceni believe that it is now appropriate to use unadjusted ONS projections based on 2-year migration data, it should be consistent and use unadjusted ONS projections based on household formation data from 2001 and 2011 Census points. This would reduce the assessed need by 4.8% from 322 dpa to 307 dpa.

The Plan is based on a requirement of 330 dpa. Iceni data is 7.5% higher, representing an excess of 460 houses over the Plan period. The Inspector must assess whether this is a justified and sound approach, particularly when the Plan is proposing Green Belt removal.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10341

Received: 13/01/2021

Respondent: Mrs Jane Singleton

Representation Summary:

Paragraph No. 38

There is no justification for Iceni’s conclusion that, although the 2018-based household projections are based on trend data; it would be appropriate to make upward adjustments to them to support improved household formation amongst younger households.

Given that Iceni consider it no longer appropriate to adjust ONS projections because of higher recent in-migration, it should no longer make upward adjustments to household formation rates. This represents double counting and is inappropriate given the long-term damage to the economy from the Coronavirus pandemic forecast by the Office for Budget Responsibility.
The mixed methodology appears to be an attempt to reach the predetermined OAN of 330 which was always based on aspiration rather than realism. It is an unsound approach.

Full text:

There is no justification for Iceni’s conclusion that, although the 2018-based household projections are based on trend data; it would be appropriate to make upward adjustments to them to support improved household formation amongst younger households.

Given that Iceni consider it no longer appropriate to adjust ONS projections because of higher recent in-migration, it should no longer make upward adjustments to household formation rates. This represents double counting and is inappropriate given the long-term damage to the economy from the Coronavirus pandemic forecast by the Office for Budget Responsibility.
The mixed methodology appears to be an attempt to reach the predetermined OAN of 330 which was always based on aspiration rather than realism. It is an unsound approach.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10378

Received: 14/01/2021

Respondent: Dronfield Civic Society

Representation Summary:

Paragraph 12

The Iceni report on the implications of the 2018-based Household Projections (ED101A) uses a different methodology to that used in the evidence base for the Plan. This inconsistency cannot be justified. EB-HOU4 used population projections adjusted for 10-year migration trends (an ‘industry standard’), recognising that migration can be variable over time. ED101A uses unadjusted ONS projections based on migration trends over just a 2-year period. ONS projections based on 10-year migration data show a figure of 47,280 households for NE Derbyshire in 2034, 3.44% lower than that used by Iceni. Iceni should have used a consistent methodology to that used originally in EB-HOU4, based on 10-year migration data, resulting in a corresponding 3.44% reduction in housing need from 322 dpa to 311 dpa. The Plan is based on a requirement of 330 dpa, 6.1% higher than this, representing an excess of 380 houses above assessed need over the Plan period.

Full text:

ED 101A, Paragraph 12

The Iceni report on the implications of the 2018-based Household Projections (ED101A) uses a different methodology to that used in the evidence base for the Plan. This inconsistency cannot be justified. EB-HOU4 used population projections adjusted for 10-year migration trends (an ‘industry standard’), recognising that migration can be variable over time. ED101A uses unadjusted ONS projections based on migration trends over just a 2-year period. ONS projections based on 10-year migration data show a figure of 47,280 households for NE Derbyshire in 2034, 3.44% lower than that used by Iceni. Iceni should have used a consistent methodology to that used originally in EB-HOU4, based on 10-year migration data, resulting in a corresponding 3.44% reduction in housing need from 322 dpa to 311 dpa. The Plan is based on a requirement of 330 dpa, 6.1% higher than this, representing an excess of 380 houses above assessed need over the Plan period.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10379

Received: 14/01/2021

Respondent: Dronfield Civic Society

Representation Summary:

Paragraph 25

The Iceni report (ED101A) is inconsistent in its approach to trend data. It uses migration data over a 2-year period (rather than 10-years used in EB-HOU4) but continues to use longer-term trends dating back to 1971 to adjust upwards household formation rates because ‘projections based on just two data points will have a notable potential error margin’. This adjustment raises their demographic-based need for housing from 279 dwellings per annum to 293 dpa. If Iceni believe that it is now appropriate to use unadjusted ONS projections based on 2-year migration data, it should be consistent and use unadjusted ONS projections based on household formation data from 2001 and 2011 Census points. This would reduce the assessed need by 4.8% from 322 dpa to 307 dpa. The Plan is based on a requirement of 330 dpa, 7.5% higher than this, representing an excess of 460 houses over the Plan period.

Full text:

ED 101A, Paragraph 25

The Iceni report (ED101A) is inconsistent in its approach to trend data. It uses migration data over a 2-year period (rather than 10-years used in EB-HOU4) but continues to use longer-term trends dating back to 1971 to adjust upwards household formation rates because ‘projections based on just two data points will have a notable potential error margin’. This adjustment raises their demographic-based need for housing from 279 dwellings per annum to 293 dpa. If Iceni believe that it is now appropriate to use unadjusted ONS projections based on 2-year migration data, it should be consistent and use unadjusted ONS projections based on household formation data from 2001 and 2011 Census points. This would reduce the assessed need by 4.8% from 322 dpa to 307 dpa. The Plan is based on a requirement of 330 dpa, 7.5% higher than this, representing an excess of 460 houses over the Plan period.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10380

Received: 14/01/2021

Respondent: Dronfield Civic Society

Representation Summary:

Paragraph 32

We strongly support Iceni’s conclusion that, given recent higher in-migration and housing delivery levels, when using the latest (2018-based) demographic projections, it is no longer necessary to apply an uplift to support economic growth in drawing conclusions on the objectively-assessed housing need.

Full text:

ED 101A, Paragraph 32

We strongly support Iceni’s conclusion that, given recent higher in-migration and housing delivery levels, when using the latest (2018-based) demographic projections, it is no longer necessary to apply an uplift to support economic growth in drawing conclusions on the objectively-assessed housing need.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10381

Received: 14/01/2021

Respondent: Dronfield Civic Society

Representation Summary:

Paragraph 38

We disagree with Iceni's conclusion that, although the 2018-based household projections are based on trend date; it would be appropriate to make upward adjustments to them to support improved household formation amongst younger households. Given that Iceni considers it no longer appropriate to adjust ONS projections because of higher recent in-migration, it should no longer make upward adjustments to household formation rates. This represents double counting and is inappropriate given the long-term damage to the economy from the coronavirus pandemic forecast by the Office for Budget Responsibility.

Full text:

Paragraph 38

We disagree with Iceni's conclusion that, although the 2018-based household projections are based on trend date; it would be appropriate to make upward adjustments to them to support improved household formation amongst younger households. Given that Iceni considers it no longer appropriate to adjust ONS projections because of higher recent in-migration, it should no longer make upward adjustments to household formation rates. This represents double counting and is inappropriate given the long-term damage to the economy from the coronavirus pandemic forecast by the Office for Budget Responsibility.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10382

Received: 14/01/2021

Respondent: Dronfield Civic Society

Representation Summary:

ED101 Section headed "ONS 2018-based Household Projections"

We 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:

ED101 Section headed "ONS 2018-based Household Projections"

We 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: 10486

Received: 20/01/2021

Respondent: Mr Paul Johnson

Representation Summary:

Please see evidence document attached to my representation regarding MM008, MM009 and MM010.

Full text:

The Main Modification does not help to provide the OAN for affordable housing, if site KL/1 is retained as an allocation.
This site, in a former mining area, has immense costs associated with it, bringing into question the viability, due to significant remediation costs – referred to by the site agent.
Five mine entrances need to be filled and capped, large amounts of contaminated soil need to be dug up and replaced (containing carcinogens), there is no air quality assessment of the site, changes to submitted plans will be needed, as the current plan ignored the presence of a main drain across the site.
This will mean a reduction in house numbers and other changes.
Archaeological remains have been discovered on the site, which will mean construction delays and costs.
Site viability will mean a significant reduction in the provision of affordable housing and associated benefits.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10488

Received: 21/01/2021

Respondent: Mr David Meechan

Representation Summary:

Paragraph 12

The Iceni report on the implications of the 2018-based Household Projections (ED101A) uses a different methodology to that used in the evidence base for the Plan. This inconsistency cannot be justified. EB-HOU4 used population projections adjusted for 10-year migration trends (an ‘industry standard’), recognising that migration can be variable over time. ED101A uses unadjusted ONS projections based on migration trends over just a 2-year period. ONS projections based on 10-year migration data show a figure of 47,280 households for NE Derbyshire in 2034, 3.44% lower than that used by Iceni. Iceni should have used a consistent methodology to that used originally in EB-HOU4, based on 10-year migration data, resulting in a corresponding 3.44% reduction in housing need from 322 dpa to 311 dpa. The Plan is based on a requirement of 330 dpa, 6.1% higher than this, representing an excess of 380 houses above assessed need over the Plan period.

Full text:

The Iceni report on the implications of the 2018-based Household Projections (ED101A) uses a different methodology to that used in the evidence base for the Plan. This inconsistency cannot be justified. EB-HOU4 used population projections adjusted for 10-year migration trends (an ‘industry standard’), recognising that migration can be variable over time. ED101A uses unadjusted ONS projections based on migration trends over just a 2-year period. ONS projections based on 10-year migration data show a figure of 47,280 households for NE Derbyshire in 2034, 3.44% lower than that used by Iceni. Iceni should have used a consistent methodology to that used originally in EB-HOU4, based on 10-year migration data, resulting in a corresponding 3.44% reduction in housing need from 322 dpa to 311 dpa. The Plan is based on a requirement of 330 dpa, 6.1% higher than this, representing an excess of 380 houses above assessed need over the Plan period.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10489

Received: 21/01/2021

Respondent: Mr David Meechan

Representation Summary:

Paragraph 25

The Iceni report (ED101A) is inconsistent in its approach to trend data. It uses migration data over a 2-year period (rather than 10-years used in EB-HOU4) but continues to use longer-term trends dating back to 1971 to adjust upwards household formation rates because ‘projections based on just two data points will have a notable potential error margin’. This adjustment raises their demographic-based need for housing from 279 dwellings per annum to 293 dpa. If Iceni believe that it is now appropriate to use unadjusted ONS projections based on 2-year migration data, it should be consistent and use unadjusted ONS projections based on household formation data from 2001 and 2011 Census points. This would reduce the assessed need by 4.8% from 322 dpa to 307 dpa. The Plan is based on a requirement of 330 dpa, 7.5% higher than this, representing an excess of 460 houses over the Plan period.

Full text:

The Iceni report (ED101A) is inconsistent in its approach to trend data. It uses migration data over a 2-year period (rather than 10-years used in EB-HOU4) but continues to use longer-term trends dating back to 1971 to adjust upwards household formation rates because ‘projections based on just two data points will have a notable potential error margin’. This adjustment raises their demographic-based need for housing from 279 dwellings per annum to 293 dpa. If Iceni believe that it is now appropriate to use unadjusted ONS projections based on 2-year migration data, it should be consistent and use unadjusted ONS projections based on household formation data from 2001 and 2011 Census points. This would reduce the assessed need by 4.8% from 322 dpa to 307 dpa. The Plan is based on a requirement of 330 dpa, 7.5% higher than this, representing an excess of 460 houses over the Plan period.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10490

Received: 21/01/2021

Respondent: Mr David Meechan

Representation Summary:

Paragraph 32

I strongly support Iceni’s conclusion that, given recent higher in-migration and housing delivery levels, when using the latest (2018-based) demographic projections, it is no longer necessary to apply an uplift to support economic growth in drawing conclusions on the objectively-assessed housing need.

Full text:

I strongly support Iceni’s conclusion that, given recent higher in-migration and housing delivery levels, when using the latest (2018-based) demographic projections, it is no longer necessary to apply an uplift to support economic growth in drawing conclusions on the objectively-assessed housing need.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10491

Received: 21/01/2021

Respondent: Mr David Meechan

Representation Summary:

Paragraph 38

I disagree with Iceni’s conclusion that, although the 2018-based household projections are based on trend data; it would be appropriate to make upward adjustments to them to support improved household formation amongst younger households. Given that Iceni considers it no longer appropriate to adjust ONS projections because of higher recent in-migration, it should no longer make upward adjustments to household formation rates. This represents double counting and is inappropriate given the long-term damage to the economy from the coronavirus pandemic forecast by the Office for Budget Responsibility.

Full text:

I disagree with Iceni’s conclusion that, although the 2018-based household projections are based on trend data; it would be appropriate to make upward adjustments to them to support improved household formation amongst younger households. Given that Iceni considers it no longer appropriate to adjust ONS projections because of higher recent in-migration, it should no longer make upward adjustments to household formation rates. This represents double counting and is inappropriate given the long-term damage to the economy from the coronavirus pandemic forecast by the Office for Budget Responsibility.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10577

Received: 26/01/2021

Respondent: Cllr William F Jones, Dronfield Town Councillor

Representation Summary:

There are a number of intangible matters around the C19 pandemic which needs to be re-visited in the light of it’s impact on the delivery/demand of housing. Namely ,but not limited to :

· Impact of working from home .
· Upward mobility of professionals from smaller properties to larger properties in rural locations, I.e. outward migration.
· Release of smaller properties within Dronfield due to the above bullet point.

Full text:

The response from Dronfield Town Council is a coherent and logic based analysis of the housing requirements of Dronfield. The case for the removal of DR1 and DR2 has been made by drawing upon the in-depth knowledge of the Town which resides in a number of the longer standing councillors.
There are a number of items which I have concerns over :

· It appears to be the norm that such Plans as these never, fully interrogate acknowledged incapacities in existing medial, education, wastewater treatment and related infrastructure. I consider this to be a failure and weak point in the argument for the Plan.
· There is a sound analysis of the availability of ongoing/potential land release from within the existing boundary of the Dronfield conurbation.

I fully endorse the Dronfield Town Council response in respect to the case for removal of DR1 and DR2 areas from the Plan.

There are a number of intangible matters around the C19 pandemic which needs to be re-visited in the light of it’s impact on the delivery/demand of housing. Namely ,but not limited to :

· Impact of working from home .
· Upward mobility of professionals from smaller properties to larger properties in rural locations, I.e. outward migration.
· Release of smaller properties within Dronfield due to the above bullet point.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10629

Received: 27/01/2021

Respondent: Dronfield Town Council

Representation Summary:

Meaningful change: even the reduction of 8 dwellings per year over the 20 year plan period is 160 dwellings and therefore it is strongly urged that DR1 should be removed from the emerging Plan.

The Town Council questions that the 10% uplift for affordable housing is justifiable. 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 Plan itself.

The report suggest it is too early to know how much Covid-19 impacts on housing market activity. There is a need for additional research on this point given that we are further on through the pandemic now. Covid-19 may also impact on migration rates due to less movement and impacts could be longer lasting. 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.

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

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10694

Received: 31/01/2021

Respondent: Dr Lynne Gadsden

Representation Summary:

The ONS projections used in this re-assessment of OAHN are based on just 2 years of migration trends, which compromises data reliability. Caution is also needed in drawing conclusions in these rapidly changing times as the full impact of Brexit and the global Coronavirus pandemic is still unfolding. Any increase in OAHN would certainly be wholly unjustfied. It is sadly likely that more existing properties will become available through untimely deaths from Covid 19. It is justified to lower the OAHN or accept a modest shortfall and to conclude that there are no exceptional circumstances for greenbelt release.

Full text:

The ONS projections used in this re-assessment of OAHN are based on just 2 years of migration trends, which compromises data reliability. Caution is also needed in drawing conclusions in these rapidly changing times as the full impact of Brexit and the global Coronavirus pandemic is still unfolding. Any increase in OAHN would certainly be wholly unjustfied. It is sadly likely that more existing properties will become available through untimely deaths from Covid 19. It is justified to lower the OAHN or accept a modest shortfall and to conclude that there are no exceptional circumstances for greenbelt release.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10748

Received: 30/01/2021

Respondent: Mr Eric Singleton

Representation Summary:

Respondent indicates objection on representation form.

Representation refers to paragraphs 5 and 8.

• The report uses a methodology inconsistent with that used in the Plan evidence base.
o EB-HOU4 used population projections adjusted for 10-year migration trends (an ‘industry standard’), recognising that migration can be variable over time.
o ED101A uses unadjusted ONS projections based on migration trends over a 2-year period.
o Using the same methodology as EB HOU4 with the 2018 data produces a requirement for 47,280 households in 2034; a reduction in housing need from 322 dpa to 311 dpa.
o The Plan is based on 330dpa, representing an excess of 380 dwellings above re- assessed need over the Plan period using consistent methodologies.
o Applying 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 report uses a methodology inconsistent with that used in the Plan evidence base.
o EB-HOU4 used population projections adjusted for 10-year migration trends (an ‘industry standard’), recognising that migration can be variable over time.
o ED101A uses unadjusted ONS projections based on migration trends over a 2-year period.
o Using the same methodology as EB HOU4 with the 2018 data produces a requirement for 47,280 households in 2034; a reduction in housing need from 322 dpa to 311 dpa.
o The Plan is based on 330dpa, representing an excess of 380 dwellings above re- assessed need over the Plan period using consistent methodologies.
o Applying 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: 10749

Received: 30/01/2021

Respondent: Mr Eric Singleton

Representation Summary:

Respondent indicates objection on representation form.

Representation refers to paragraphs 5, 19, 23 and 24.

• The report is inconsistent in its use of data.
o It uses migration data over a 2-year period (rather than 10-years used in EB-HOU4) but continues to use longer-term trends dating back to 1971 to adjust upwards household formation rates because ‘projections based on just two data points will have a notable potential error margin’.
o This adjustment raises demographic-based need from 279 dpa to 293 dpa.
o If Iceni believe that it is now appropriate to use unadjusted ONS projections based on 2-year migration data, it should be consistent and use unadjusted ONS projections based on household formation data from 2001 and 2011 Census points.
o This reduces the assessed need from 322 dpa to 307 dpa.
o The Plan is based on a requirement of 330 dpa representing an excess of 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 report is inconsistent in its use of data.
o It uses migration data over a 2-year period (rather than 10-years used in EB-HOU4) but continues to use longer-term trends dating back to 1971 to adjust upwards household formation rates because ‘projections based on just two data points will have a notable potential error margin’.
o This adjustment raises demographic-based need from 279 dpa to 293 dpa.
o If Iceni believe that it is now appropriate to use unadjusted ONS projections based on 2-year migration data, it should be consistent and use unadjusted ONS projections based on household formation data from 2001 and 2011 Census points.
o This reduces the assessed need from 322 dpa to 307 dpa.
o The Plan is based on a requirement of 330 dpa representing an excess of 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: 10801

Received: 30/01/2021

Respondent: Cllr Angelique Foster, Dronfield Town, District and County Councillor

Representation Summary:

Some of the Icenci report findings show that we will see a potential reduction of eight dwellings per year, effectively reducing the housing target by 160 houses over a 20 year period. I believe these findings should be taken into account. There would be no reasonable need for DR1 to be included within the Plan at all. I therefore ask that DR1 is removed from the Local Plan.

Full text:

I am writing in response to the consultation on the Schedule of Main Modifications, associated changes to the Policies Map and other supporting documents, I would like to submit my objection to the Draft local Plan as well as my comments and concerns with regards to the proposed Main Modifications.

MM/031.
Please note my support of the decision to remove the Green Belt allocation DR2 at Coal Aston from the plan, and therefore retain the site as Greenbelt. This site plays an important role as Green Belt Land for the community of Coal Aston and Dronfield as a whole.

MM/026. MM/030.MM/032
However, I strongly object to the two Green Belt sites DR1 (Chesterfield Road/Shakespeare Crescent) and DR2 (Stubley Hollow) (previously DR3) being kept in the Local Plan and ask that they should be removed from the Plan and retained as Greenbelt land.

I do not believe that the exceptional circumstances required in order to release land from Green Belt have been demonstrated by the District Council. Both of these sites still fulfil Green Belt criteria and therefore should remain as Green Belt. Furthermore there are many issues with developing those sites , in terms of the topography, access and traffic impact, and viability.
I strongly object to the Green Belt site DR1(Chesterfield Road/Shakespeare Crescent) being kept in the Local Plan on the grounds that, as aforementioned, the District Council has not demonstrated the exceptional circumstances necessary for release of Green Belt land at this location.

Any development on this site will still risk settlement coalescence between Dronfield and Unstone by reducing the historic gap between the two settlements. This is something that neither of these two communities want to see happen.

There are other sites in Dronfield that would be more suitable for housing development. Examples of these were put forward by residents during the consultation on Dronfield Neighbourhood Plan, and a list has been provided before by the Town Council as an appendix to the Dronfield Neighbourhood Plan. Some of the sites mentioned have progressed further over the last year. For example, the Gladys Buxton site has now been sold and the developer is progressing with a planning application for approximately 35 dwellings. The Talbot Arms Pub site has now been developed and is delivering an additional 8 dwellings. These are two concrete examples showing that Dronfield is and will continue to see some housing growth over the coming years. Dronfield Town Council has also demonstrated in their representation that other viable alternative sites present opportunities for more than 200 dwellings across the Town and there is no need to release Green Belt land.

Furthermore, access to the site remains unclear. An additional junction onto the main road will 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 these have not been identified. There is real concerns that a potential junction onto the main road would increase the risk to pedestrians and cyclists. A dedicated cycling lane is near completion and therefore more cyclists are expected on that stretch of road. There are also concerns that any other routes via Shakespeare Crescent or Burns Drive might be presented as likely alternatives. However either of these suggestions are unacceptable as they would present added road safety risk to existing residents. Burns Drive is a narrow street which leads to a cul-de-sac. Visibility is poor around the bend at the top of the street. The current trend is that young adults live longer with their parents, which means that very often we have a ratio of 3 cars per house. This causes car parking issues which makes it difficult for pedestrians at times, especially mothers with pushchairs, who often have to use the road instead. Shakespeare Crescent is a long winding road with similar difficulties. It is also a bus route and complaints have been recurring over the years about buses not being able to get through at times due to the number of parked cars on either side of the road. This present an added concern for emergency services access.

Additionally, the Unstone floods in 2019 demonstrated that there is an issue regarding flooding. Substantial flooding was noted in Unstone village derived from fields at or near this site - despite the District Local plan suggesting that this was unlikely. This is substantiated by a recent flooding report that was commissioned by Dronfield Town Council and submitted in their representations. The site is also currently used as agricultural land and continues to be home to a number of wildlife species.
I object to the site DR2 (Stubley Hollow) being kept in the emerging local Plan. As per the above statement, the exceptional circumstances have not been demonstrated by the District Council. There are additional specific issues concerning this site. Its topography presents difficulties of access, which would bring added risk to existing road users and pedestrians. It is recognised in the District Plan that this site presents potential ecological constraints which could lead to the destruction of ecological habitats. The Greenbelt review has also classed this site as still “assisting in safeguarding the countryside from encroachment”.

MM/033. I believe that the same arguments used by the Inspector to justify the removal of Green Belt land in Eckington, and other sites in the District should be applied to the two Dronfield sites DR1 and DR2 and similarly provide justification to retain them as Green Belt.

MM/004. MM/005. I strongly believe that the housing supply cut off date should be extended. There has been a number of planning permissions granted and appeal decisions across the District over the last year, which should be reflected in the Plan. The figures in table 4.1 should be updated to reflect these. The cut off date should be brought forward to 31st December, which would result in a much more accurate picture.
I refer for examples to application on sites such as Clay Cross (84 dwellings), Holmewood (250 dwellings) and Higham (24 dwellings).
Furthermore, the Inspector has accepted the fact that a further 660 houses at the former Coalite site could come forward during this Plan period (in MM/15). I strongly suggest that there are caused for including these figures in this Plan and this would negate the need to release Green Belt land.

Response to document D. In addition, some of the Icenci report findings show that we will see a potential reduction of eight dwellings per year, effectively reducing the housing target by 160 houses over a 20 year period. I believe these findings should be taken into account. There would be no reasonable need for DR1 to be included within the Plan at all. I therefore ask that DR1 is removed from the Local Plan.
Response to Document F. There has been a considerable change in circumstances due to Covid 19 in recent month, which could potentially affect anticipated completions. There is ground for the District Council to scrutinise the housing supply and demand in the area. Demand for employment sites will reduce as both the private and public sector are looking to put in place remote working strategies with a view to increase numbers of employees working from home. Therefore current employment land could potentially be repurposed for housing across the District. It is also highly likely that we will see a reduction in demand for employment sites for retail and hospitality space as evidenced in Dronfield where a number of pub sites have now been redeveloped to provide housing. 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. We have such an example already in Dronfield where one restaurant developer is now seeking support to change his site to a housing site. This site is likely to deliver between 8 and 10 dwelling in the same area where the DR1 is.
Finally, I would like to point out that residents have worked hard over the years to bring reasonable solutions to the issues presented to them by the District Council. In doing so, they have presented a number of very well researched and valid arguments to show that there is no need for the release of Green Belt land in our area. There is sufficient evidence to support this and I would urge the District and the Independent Inspector to take this into consideration, revise their Local Plan and keep the Dronfield Green Belt untouched and protected.


Follow up email:
Further to my email yesterday I would like to add an additional point with regards to the unsuitability of DR1 as development land.
I refer to the Flood report provided by Dronfield Town Council. It shows that the current flooding issues we have experienced in Unstone would be increased substancially should the land on DR1 be developed, unless a number of mitigating measures are put in place. The substantial cost of these mitigating measures would be added to any development plans and potentially decrease their financial visibility, hence making the delivery of that site unlikely.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10807

Received: 30/01/2021

Respondent: Cllr Mark Foster, Town and District Cllr for Coal Aston

Representation Summary:

Some of the Icenci report findings show that we will see a potential reduction of eight dwellings per year, effectively reducing the housing target by 160 houses over a 20 year period. I believe these findings should be taken into account. There would be no reasonable need for DR1 to be included within the Plan at all. I therefore ask that DR1 is removed from the Local Plan.

Full text:

Please accept this document as my response to the consultation to the main modifications of the local plan. I would also like to submit my objection to the Draft local Plan.

MM/031.
Please note my support of the decision to remove the Green Belt allocation DR2 at Coal Aston from the plan, and therefore retain the site as Greenbelt. This site plays an important role as Green Belt Land for the community of Coal Aston and Dronfield as a whole.

MM/026. MM/030.MM/032
I strongly object to the two Green Belt sites DR1 (Chesterfield Road/Shakespeare Crescent) and DR2 (Stubley Hollow) (previously DR3) being kept in the Local Plan and ask that they should be removed from the Plan and retained as Greenbelt land.

I do not believe that the exceptional circumstances required in order to release land from Green Belt have been demonstrated by the District Council. Both of these sites still fulfil Green Belt criteria and therefore should remain as Green Belt. Furthermore there are many issues with developing those sites , in terms of the topography, access and traffic impact, and viability.
I strongly object to the Green Belt site DR1(Chesterfield Road/Shakespeare Crescent) being kept in the Local Plan on the grounds that, as aforementioned, the District Council has not demonstrated the exceptional circumstances necessary for release of Green Belt land at this location.

Any development on this site will still risk settlement coalescence between Dronfield and Unstone by reducing the historic gap between the two settlements. This is something that neither of these two communities want to see happen.

There are other sites in Dronfield that would be more suitable for housing development. Examples of these were put forward by residents during the consultation on Dronfield Neighbourhood Plan, and a list has been provided before by the Town Council as an appendix to the Dronfield Neighbourhood Plan. Some of the sites mentioned have progressed further over the last year. For example, the Gladys Buxton site has now been sold and the developer is progressing with a planning application for approximately 35 dwellings. The Talbot Arms Pub site has now been developed and is delivering an additional 8 dwellings. These are two concrete examples showing that Dronfield is and will continue to see some housing growth over the coming years. Dronfield Town Council has also demonstrated in their representation that other viable alternative sites present opportunities for more than 200 dwellings across the Town and there is no need to release Green Belt land.
Furthermore, access to the site remains unclear. An additional junction onto the main road will 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 these have not been identified. There is real concerns that a potential junction onto the main road would increase the risk to pedestrians and cyclists. A dedicated cycling lane is near completion and therefore more cyclists are expected on that stretch of road. There are also concerns that any other routes via Shakespeare Crescent or Burns Drive might be presented as likely alternatives. However either of these suggestions are unacceptable as they would present added road safety risk to existing residents. Burns Drive is a narrow street which leads to a cul-de-sac. Visibility is poor around the bend at the top of the street. The current trend is that young adults live longer with their parents, which means that very often we have a ratio of 3 cars per house. This causes car parking issues which makes it difficult for pedestrians at times, especially mothers with pushchairs, who often have to use the road instead. Shakespeare Crescent is a long winding road with similar difficulties. It is also a bus route and complaints have been recurring over the years about buses not being able to get through at times due to the number of parked cars on either side of the road. This present an added concern for emergency services access.
Additionally, the Unstone floods in 2019 demonstrated that there is an issue regarding flooding. Substantial flooding was noted in Unstone village derived from fields at or near this site - despite the District Local plan suggesting that this was unlikely.
I would especially like to draw the attention towards the flood risk assessment and outline sustainable drainage strategy recently undertaken by Detectronic and submitted as evidence by Dronfield Town Council. The report demonstrates that the proposed development is at risk of flood from surface water and will increase flood risk to others unless the recommended flood mitigation strategies are implemented. The strategies detailed in the report are substantial and make prospect of a financially viable development on the proposed site very unlikely.
Furthermore, the site is still currently used as agricultural land and continues to be home to a number of wildlife species.
MM/033. I believe that the same arguments used by the Inspector to justify the removal of Green Belt land in Eckington, and other sites in the District should be applied to the two Dronfield sites DR1 and DR2 and similarly provide justification to retain them as Green Belt.

MM/004. MM/005. I strongly believe that the housing supply cut off date should be extended. There has been a number of planning permissions granted and appeal decisions across the District over the last year, which should be reflected in the Plan. The figures in table 4.1 should be updated to reflect these. The cut off date should be brought forward to 31st December, which would result in a much more accurate picture.
I refer for examples to application on sites such as Clay Cross (84 dwellings), Holmewood (250 dwellings) and Higham (24 dwellings).
Furthermore, the Inspector has accepted the fact that a further 660 houses at the former Coalite site could come forward during this Plan period (in MM/15). I strongly suggest that there are caused for including these figures in this Plan and this would negate the need to release Green Belt land.

Response to document D. In addition, some of the Icenci report findings show that we will see a potential reduction of eight dwellings per year, effectively reducing the housing target by 160 houses over a 20 year period. I believe these findings should be taken into account. There would be no reasonable need for DR1 to be included within the Plan at all. I therefore ask that DR1 is removed from the Local Plan.
Response to Document F. There has been a considerable change in circumstances due to Covid 19 in recent month, which could potentially affect anticipated completions. There is ground for the District Council to scrutinise the housing supply and demand in the area. Demand for employment sites will reduce as both the private and public sector are looking to put in place remote working strategies with a view to increase numbers of employees working from home. Therefore current employment land could potentially be repurposed for housing across the District. It is also highly likely that we will see a reduction in demand for employment sites for retail and hospitality space as evidenced in Dronfield where a number of pub sites have now been redeveloped to provide housing. 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. We have such an example already in Dronfield where one restaurant developer is now seeking support to change his site to a housing site. This site is likely to deliver between 8 and 10 dwelling in the same area where the DR1 is.
Lastly I would urge the district and the inspector to listen to the concerns and respect the wishes of the community of Dronfield. Many valid arguments have been put forward as to why the greenbelt around Dronfield should be kept and protected. Residents have also made clear that they are not against development but that it should be in the right place. This is evidenced by the Dronfield Neighbourhood Plan.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10811

Received: 30/01/2021

Respondent: Paul Parkin

Representation Summary:

Some of the Icenci report findings show that we will see a potential reduction of eight dwellings per year, effectively reducing the housing target by 160 houses over a 20 year period. I believe these findings should be taken into account. There would be no reasonable need for DR1 to be included within the plan at all. I therefore ask that DR1 is removed from the Local Plan.

Full text:

I object to the two Green Belt sites DR1 (Chesterfield Road/Shakespeare Crescent) and DR2 (Stubley Hollow) (previously DR3) being kept in the Local Plan and believe that they should be removed from the Plan and retained as Greenbelt land.
I do not believe that the exceptional circumstances required in order to release land from Green Belt have been demonstrated by the District Council. Both of these sites still fulfil Green Belt criteria and therefore should remain as Green Belt. Furthermore there are many issues with developing those sites , in terms of the topography, access and traffic impact, and viability.
I also object to the Green Belt site DR1(Chesterfield Road/Shakespeare Crescent) being kept in the Local Plan on the grounds that, as aforementioned, the District Council has not demonstrated the exceptional circumstances necessary for release of Green Belt land at this location. Any development on this site will still risk settlement coalescence between Dronfield and Unstone by reducing the historic gap between the two settlements. This is something that neither of these two communities want to see happen.
There are other sites in Dronfield that would be more suitable for housing development in Dronfield. Examples of these were put forward by residents during the consultation on Dronfield Neighbourhood Plan, and a list has been provided by the Town Council as an appendix to the Dronfield Neighbourhood Plan. Some of the sites mentioned have progressed further over the last year. For example, the Gladys Buxton site has now been sold and the developer is progressing with a planning application for approximately 35 dwellings. The Talbot Arms Pub site has now been developed and is delivering an additional 8 dwellings. These are two concrete examples showing that Dronfield is likely to see some housing growth over the coming years. Dronfield Town Council has also demonstrated that other viable alternative sites present opportunities for more than 200 dwellings across the Town and there is no need to release Green Belt land.
Furthermore, access to the site remains unclear. An additional junction onto the main road will 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 these have not been identified. There is real concerns that a potential junction onto the main road would increase the risk to pedestrians and cyclists. A dedicated cycling lane is near completion and therefore more cyclists are expected on that stretch of road. There are also concerns that any other routes via Shakespeare Crescent or Burns Drive might be presented as likely alternatives. However either of these suggestions would be unacceptable as they would present added road safety risk to existing residents. similar difficulties. It is also a bus route and there have been sever issues with buses not being able to get through due to the number of parked cars on either side of the road. This presents an added concern for emergency services access.

Response to document D.
In addition, some of the Icenci report findings show that we will see a potential reduction of eight dwellings per year, effectively reducing the housing target by 160 houses over a 20 year period. I believe these findings should be taken into account. There would be no reasonable need for DR1 to be included within the plan at all. I therefore ask that DR1 is removed from the Local Plan.
Response to Document F. There has been a considerable change in circumstances due to Covid 19 in recent months, which could potentially affect anticipated completions. There is ground for the District Council to scrutinise the housing supply and demand in the area. Demand for employment sites will reduce as both the private and public sector are looking to put in place remote working strategies with a view to increase numbers of employees working from home. Therefore current employment land could potentially be repurposed for housing across the District. It is also highly likely that we will see a reduction in demand for employment sites for retail and hospitality space as evidenced in Dronfield where a number of pub sites have now been redeveloped to provide housing. 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. We have such an example already in Dronfield where one restaurant developer is now seeking support to change his site to a housing site. This site is likely to deliver between 8 and 10 dwelling in the same area where the DR1 is.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10876

Received: 31/01/2021

Respondent: Unstone Parish Council

Agent: Cllr Alex Dale

Representation Summary:

Council Officer has summarised.

“meaningful change”: even the reduction of 8 dwellings per year over the 20 year plan period is 160 dwellings and therefore it is strongly urged that DR1 should be removed from the emerging Plan.

While the report suggest it is too early to say what the long term impacts will be, it is reasonable to assume that there may be some impact on migration rates due to less movement. Changing work patterns may also drive changes in the housing market with technology advances enabling more people able to work at home. This in turn could free up more development in inner cities as land previously used for office-based employment can be converted into residential. This further weakens the arguments that building on the green belt is justified.
It is questionable whether the 10% uplift for affordable housing is necessary and whether this will actually impact on the affordability of housing. It may be better to dealt with via policies within the Plan itself.

Full text:

I am writing on behalf of Unstone Parish Council in response to your consultation on the Local Plan Main Modifications. Unstone Parish is located in the North of the District of North East Derbyshire, south of the Parish of Dronfield and adjacent to the parish of Eckington. Unstone Parish includes the villages and hamlets of Unstone, Apperknowle, Summerley, Hundall and Middle, Nether and West Handley.
In summary, the Parish Council’s view is that, while supportive of a number of Main Modifications and namely those to remove Green Belt allocations at DR2 at Coal Aston and EC1 at Eckington, on the whole the amendments do not go far enough in protecting the green belt and Parish Councillors still have a number of concerns and objections.
The Parish Council strongly objects to the retention of sites DR1 and DR2 (previously DR3) in the Local Plan, which will see many acres of vital Green Belt land lost in order to build 200 new dwellings in our neighbouring town. In the case of DR1, the site clearly fulfils the key purposes of the Green Belt according to the NPPF and perhaps most importantly to prevent the coalescence of communities. Such significant development on this land will erode a hugely important and historic gap between the settlements of Dronfield and Unstone and therefore the Parish Council wish to object in the strongest possible terms to its continued inclusion in the Local Plan.
In addition, the Parish Council wish to cast significant doubt over the justification for any development on the Green Belt within the Local Plan, due to changes in the housing figures over recent years and therefore the remaining Green Belt allocations in Dronfield (DR1 and DR2, formerly DR3) and Killamarsh (KL1 and KL2) should also be removed from the final version of the Plan.
The Parish Council strongly urges the Inspector to reconsider these issues and withdraw the remaining Green Belt allocations from the Plan.
In relation to the specific Main Modifications and other associated documents, the Parish Council wishes to make the following points:
MM/004-MM/005:
• The figures quoted in these MMs should be brought more up to date to reflect more recent permissions which have been granted. The latest cut off date of 31/03/2020 is now 10 months out of date and therefore excludes some key recent developments.
• It is noted that in correspondence between the Inspector and the Council in 2019 (ED65 and ED85), Inspector took the welcome step of reducing and removing some key Green Belt development sites from the Local Plan and in doing so suggested that the resultant shortfall (257) from achieving the 6600 housing target, would not in itself make the Plan unsound. In ED85 (July 2019) the Council clarify that in the intervening months that shortfall had reduced further still to only 80. Between April 2019 and March 2020 an application for 84 dwellings at Coney Green, Clay Cross has achieved permission which had not been planned as part of the Local Plan process. This has therefore eliminated that shortfall entirely and achieves a small surplus of 4 dwellings.
• Since 31st March 2020 there have been three further large developments approved on appeal which again fall outside of the Local Plan process, including one which only very recently was decided. These are:
o Appeal Reference: APP/R1038/W/20/3251224 – Land South East of Williamthorpe Road and West of Tibshelf Road, Holmewood – 250 dwellings
o Appeal Reference: APP/R1038/W/20/3244154 – Land North of 92 Chesterfield Road, Higham – 24 dwellings
o Appeal Reference: APP/R1038/W/20/3259758 - Land South of Hallfieldgate Lane, Shirland, DE55 6AA – 90 dwellings
• Taken together the above amounts to a surplus of 368 dwellings on the full Plan period housing target of 6600. The Parish Council requests that these more recent approvals are noted within the Plan and that it is brought as up to date as possible.
• 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 Plan period, none of which have been included towards meeting the housing requirement in the Plan previously due to HS2 blight on the site. Again, the Parish Council requests that these further 660 houses are included towards meeting our housing needs.
• It follows that if the Inspector was willing to allow a shortfall of over 250 houses to remove two and half green belt allocations from the Plan, while not making the Plan itself unsound, now that there is a significant surplus of between 368 and 1028 (dependent on whether the Coalite site is counted), it cannot be said there is any reasonable justification for removing any land from the green belt as the District’s housing needs are clearly being more than met.
• The Parish Council strongly urges the Inspector to remove the remaining green belt allocations from the Plan on this basis.
MM/008-MM/009:
• The less prescriptive approach is strongly welcomed and furthermore gives additional justification for removing the remaining green belt allocations in the north of the District.
• It should be acknowledged that the Parish Council is not against local development taking place within non-green belt, sustainable locations within the northern settlements. We are aware of a number of developments which have been put forward as alternatives within the Dronfield area and these should be very seriously considered by the Inspector as alternatives to the Plan’s current green belt allocations.
MM/015-MM/016:
• The inclusion of 660 dwellings at the Coalite site is strongly supported by the Parish Council and we would ask that the Inspector includes these as contributing towards meeting our District-wide housing target.
MM/026:
• The Parish Council objects to the continued inclusion of the green belt allocations (DR1, DR2, KL1, KL2) and most particularly DR1 which threatens the erosion of the historic boundary between Unstone and Dronfield.
MM/030:
• The Parish Council strongly objects to the continued inclusion of DR1 within the Local Plan.
• It is our view that the site continues to fulfil all five of the purposes of green belt, as specified in the NPPF, not least in preventing the coalescence of Dronfield and Unstone. The Inspector’s previous decision to reduce the original size of the site does not in effect have any material difference in the erosion of the historic gap between the two settlements as the bulk of the development will still be extremely visible from the outskirts of Unstone. For those driving between the two communities it would be extremely difficult to identify where one community finishes and the other begins due to the urban sprawl. It is worth highlighting that the same is true to the south of Unstone where development is currently being pursued. The result is that travellers on the B6057 would be able to travel from Chesterfield, almost to the edge of Sheffield without ever leaving a “built-up” area for anything longer than a few yards.
• Another key concern for us is the impact on local flooding in Unstone – during 2019, the B6057 in Unstone (opp Fleur De Lys pub) was flooded on three separate occasions causing water ingress into some homes and road closure and disruption. The amounts of surface water from the fields in the surrounding area, including those which make up DR1, pooling in a natural low spot was one of the key causes. Development on DR1 could only further worsen the possible impacts of flooding occurring again in the future on the basis that there will be significantly less land to soak away the surface water.
• We understand from residents living close to the site that it is home to a number of important species and the Parish Council is concerned about the impact on wildlife populations.
• The Parish Council has significant concerns over access onto the site from the very busy Chesterfield Road and the possible road safety impacts.
MM/031:
• The removal of this site at Eckington Road, Coal Aston (DR2) is welcomed.
MM/032:
• The Parish Council oppose the inclusion of this site at Stubley Lane, Dronfield, within the Local Plan on the basis of the above reasons (that it is a green belt site and the exceptional circumstances required to removal land from the green belt have not been adequately demonstrated).
MM/033:
• The removal of this site (on land South of Eckington) is welcomed but the same logic should be applied to those green belt allocations which remain within the Plan. It is not clear what makes this site less appropriate than those above which have already been discussed.
MM/118:
• The land safeguarded for education purposes is supported.

Document D – Iceni Report:
• Iceni and the District Council suggest that the updated ONS population statistics justify a target of 322 dwellings per annum, which does not represent a “meaningful change” from the original target of 330 dwellings per annum and therefore there is not a need to change the 330 figure. However, even the reduction of 8 dwellings per year over the 20 year plan period (2014-34) is 160 dwellings – the equivalent to the DR1 site and this is therefore further justification for removing DR1 from the Local Plan.
• In addition, Iceni allude to the impact of Covid-19 and while it is too early to say what the long term impacts will be, it is reasonable to assume that there may be some impact on migration rates due to less movement (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 in turn could free up more development in inner cities as land previously used for office-based employment can be converted into residential. This further weakens the arguments that building on the green belt is justified.
• Finally, it is questionable whether the 10% uplift for affordable housing is necessary and whether this will actually impact on the affordability of housing in the District. It is arguable that delivery of affordable housing would be better dealt with via policies within the Plan itself.

Comment

Supporting Documents to Main Modifications (for comment)

Representation ID: 10896

Received: 29/01/2021

Respondent: Cllr Alex Dale, County, District, Town, Parish Cllr Dronfield

Representation Summary:

Council Officer has summarised.

Meaningful change is disputed. The reduction of 8 dpa over the 20 year life of the Plan is 160 houses – equal to the size of the proposal at DR1. The surplus would stand at between 528 and 1188.

I would question whether the 10% uplift for affordable housing is necessary and whether this will actually impact on the affordability of housing. It may be better to dealt with via policies within the Plan itself.

While the report says it is too early to make assumptions on the long term impacts of Covid19, it is plausible to assume that the changes to work patterns, with more people working from home, may become a more permanent feature, which will free up significant amounts of land and buildings within town centres. Significant regeneration and re-utilisation of town centres is therefore likely to be necessary in the coming years, which further highlights the need to protect the green belt in order that it fulfils the purpose of promoting town centre regeneration.

Full text:

I am writing in response to the above consultation as a local Councillor representing the areas of eastern Dronfield, Coal Aston, Unstone, Apperknowle, Hundall and the Handleys at different tiers of local Government, including County, District, Town and Parish.

While I support some of the Main Modifications (MMs), and in particular those which seek to reduce the impact of development on the green belt, I remain strongly opposed to several of the remaining sites in the Local Plan and in my view the MMs do not go far enough in alleviating the impact on the green belt. I urge the Inspector to go further in her judgements from February 2019 and remove the remaining green belt allocations at DR1, DR2 (formerly DR3), KL1 and KL2.

My comments can be broadly categorised under the following headings:


Lack of adequate justification and exceptional circumstances to release land from the green belt (MMs 004, 005, 008, 009, 015, 016 and Document D Iceni Report)

The figures quoted for recent completions and commitments should be brought more up to date to reflect more recent permissions which have been granted. The latest end date of 31/03/2020 is now 10 months out of date and therefore excludes some key recent developments.

It is noted that in correspondence between the Inspector and the Council in 2019 (ED65 and ED85), Inspector took the welcome step of reducing and removing some key Green Belt development sites from the Local Plan and in doing so suggested that the resultant shortfall (257) from achieving the 6600 housing target, would not in itself make the Plan unsound. In ED85 (July 2019) the Council clarify that in the intervening months that shortfall had reduced further still to only 80. Between April 2019 and March 2020 an application for 84 dwellings at Coney Green, Clay Cross has achieved permission which had not been planned as part of the Local Plan process. This has therefore eliminated that shortfall entirely and achieves a small surplus of 4 dwellings.

However, since 31st March 2020 there have been three further large developments approved on appeal which again fall outside of the 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
• Appeal Reference: APP/R1038/W/20/3259758 - Land South of Hallfieldgate Lane, Shirland, DE55 6AA – 90 dwellings

Together the above amounts to a surplus of 368 dwellings on the full Plan period housing target of 6600. The Parish Council requests that these more recent approvals are noted within the Plan and that it is brought as up to date as possible. Additionally, in MM/015, the Inspector also suggests that a further 660 houses at the former Coalite site could come forward during the Plan period, none of which have been included towards meeting the housing requirement in the Plan and I would urge the Inspector to consider that these further 660 houses are included towards meeting our housing needs.

If the Inspector was willing to allow a shortfall of over 250 houses to remove two and half green belt allocations from the Plan, while not making the Plan itself unsound, now that there is a significant surplus of between 368 and 1028 (dependent on whether the Coalite site is counted), it cannot be said there is any reasonable justification for removing any land from the green belt as the District’s housing needs are clearly being more than met.

I would strongly urge the Inspector to remove the remaining green belt allocations (DR1, DR2, KL1, KL2) from the Plan on the basis that there are no exceptional circumstances met which would permit their removal from their green belt status. To further solidify this point, the Iceni report demonstrates that the updated ONS population projections can now only justify a housing target of 322dpa. While Iceni believes this does not represent a meaningful change from the existing target of 330dpa, this point is disputed. The reduction of 8 dpa over the 20 year life of the Plan is 160 houses – equal to the size of the proposal at DR1. If this reduction of 160 houses were noted and taken into account, the surplus would stand at between 528 and 1188.

I would go further too in questioning whether the 10% uplift applied by Iceni for affordable housing is justifiable and whether provision for affordable housing would be better protected by policies within the Plan itself.

Moreover, while Iceni say it is too early to make assumptions around the impact of Covid-19, it is entirely plausible to assume that the changes to work patterns, with more people working from home, may become a more permanent feature, which will free up significant amounts of land and buildings within our town centres and particularly that which has previously been used for offices. Significant regeneration and re-utilisation of town centres is therefore likely to be necessary in the coming years, which further highlights the need to protect the green belt in order that it fulfils the purpose of promoting town centre regeneration, as clearly specified within the NPPF.

And finally, in relation to MM/008 and MM/009, the more flexible approach provided by removing the 50% rule is very much welcomed, but again provides further reasoning for removing the remaining green belt sites. It is worth making very clear that those communities affected by these sites are not opposed to development taking place in their local area, but feel that there are far more appropriate alternatives that do not involve the loss of large swathes of green belt land. For example, I am aware that residents in Dronfield have submitted several alternative sites within the town which I would urge the Inspector to reconsider and explore as a means of removing the impact on the local green belt.


Failure to follow a consistent justification when dealing with the green belt allocations (MMs 026, 030, 031, 032, 033)

While the removal of sites at Eckington Road, Coal Aston (former DR2) and land south of Eckington (EC1) are strongly welcomed, it is difficult to understand why the same logic behind the decision to remove them was not applied to the remaining green belt sites. They all arguably fulfil the same green belt purposes as set out in the NPPF.

As an example, in relation to DR1, the site continues to fulfil all five of the purposes of green belt, as specified in the NPPF, and particularly in preventing the coalescence of Dronfield and Unstone. The Inspector’s previous decision to reduce the original size of the site does not in effect have any material difference on the erosion of the historic gap between the two settlements as the bulk of the development will still be extremely visible from the outskirts of Unstone. For those driving between the two communities it would be extremely difficult to identify where one community finishes and the other begins due to the urban sprawl. It is worth highlighting that the same is true to the south of Unstone where development is currently being pursued. The result is that travellers on the B6057 would be able to travel from Chesterfield, almost to the edge of Sheffield without ever leaving a “built-up” area for anything longer than a few yards.

Another key concern in relation to DR1 is the impact on local flooding in Unstone – during 2019, the B6057 in Unstone (opp Fleur De Lys pub) was flooded on three separate occasions causing water ingress into some homes and road closure and disruption. The amounts of surface water from the fields in the surrounding area, including those which make up DR1, pooling in a natural low spot was one of the key causes. Development on DR1 could only further worsen the possible impacts of flooding occurring again in the future on the basis that there will be significantly less land to soak away the surface water.

I understand from residents living close to the site that it is home to a number of important species and I share their concerns about the impact on wildlife populations. Additionally I am concerned about the access arrangements and road safety, given that Chesterfield Road in particularly is busy main thoroughfare route.

The Inspector will undoubtedly have been made aware of many similar concerns around the other green belt sites at DR2, KL1 and KL2 and I strongly support the comments of residents and Dronfield Town Council in highlighting the many significant barriers to developing these sites.

I would urge the Inspector to follow a consistent logic in dealing with the green belt sites by removing all of them on the same grounds as she did with the former DR2 and EC1 sites.

It is clear to me, as it is to many residents in the communities that I represent that there is simply no need, nor justification, for removing land from the green belt and we sincerely hope that the Inspector will come to the same conclusion as a result of this consultation.