North East Derbyshire Publication Draft Local Plan (Reg 19)

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Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy LC4: Type and Mix of Housing

Representation ID: 7892

Received: 04/04/2018

Respondent: M.D Stapleton Developments Ltd

Agent: A & D Architecture Ltd.

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Council officers have amended the summary to approximately 100 words. Full representation attached.

The Plan should recognise the important role static caravans play in meeting housing needs and providing for housing choice. As such the Plan should make specific land allocations to meet the need for this type of housing.

Consequential changes suggested to policy SS2, paragraphs 5.85 to 5.88, & 6.50, and the Key Diagram.

Change suggested by respondent:

The Council must call for sites suitable for static caravan expansion.

The Council must allocate sites specifically to significantly boost the supply of static caravans in the District and to widen housing choice for the group of people who wish to live permanently in static caravans.

Cited policies, statements and the key diagram must be adjusted accordingly.

Full text:

The Council must boost significantly the supply of housing (NPPF Para. 47) and plan for the needs of different groups in the community (NPPF Para. 50) to widen housing choice. People living in static caravans are an important group. The Council must recognise the special site-finding difficulties facing developer-operators seeking to serve this group by expanding existing static caravan housing sites in line with projected annual growth in the district (Para 4.9 p.34). Such developer-operators face similar infrastructure costs (5.85 pp. 82-83) as do developers of conventional housing and much longer term operational and regulatory costs whilst sale returns are much lower than for conventional housing (see attached statement by the BH & HPA especially Paragraph 11 page 2). The Council has made no call for sites for static caravans to accommodate this group. No recognition is given to the usefulness of this housing type to address demographic change as older people downsize to static caravans despite increasing local need (2.13 p.16) or to deliver much-needed accommodation at affordable rents (5.67 p.77). Instead static caravan housing growth is confined in the Local plan to existing sites where maximum density has been reached (6.50 p.109). The Council provides no evidence that spare capacity exists within static caravan sites built for the purpose or that capacity is adequate to meet needs to 2034 and well beyond as it must having determined the need for a Green Belt Boundary Review in the District (NPPF Paragraphs 83 and 85.5). Unfairly suppressing housing choice for this group, the Local Plan is not positively planned and is unjustified, ineffective and contrary to National Policy.

Attachments:

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Distribution of Growth & the Settlement Hierarchy

Representation ID: 7894

Received: 04/04/2018

Respondent: M.D Stapleton Developments Ltd

Agent: A & D Architecture Ltd.

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The towns of Dronfield, Eckington, Clay Cross and Killamarsh are recognised as the most sustainable growth sites in the district (7.1 p.111, 4.29 p.38). National Policy requires the Council to balance land uses so that people can be encouraged to minimise journey lengths and to facilitate the use of sustainable transport modes of transport (NPPF para's 30 & 37). It is therefore unjustified and contrary to National Policy for the Local Plan to contain a settlement hierarchy that does not differentiate between Level 3 settlements according to their proximity to Level 1 settlements. Marsh Lane is far more sustainable for housing growth than Wadshelf but the settlement hierarchy does not recognise that fact (see attached Statement MDS2).

Change suggested by respondent:

The settlement hierarchy should differentiate between the sustainability of Level 3 settlements that are close to Level 1 settlements and Level 3 settlements that are not close to Level 1 settlements.

Table 4.2 should be amended accordingly.

Full text:

The Council must boost significantly the supply of housing (NPPF Para. 47) and plan for the needs of different groups in the community (NPPF Para. 50) to widen housing choice. People living in static caravans are an important group. The Council must recognise the special site-finding difficulties facing developer-operators seeking to serve this group by expanding existing static caravan housing sites in line with projected annual growth in the district (Para 4.9 p.34). Such developer-operators face similar infrastructure costs (5.85 pp. 82-83) as do developers of conventional housing and much longer term operational and regulatory costs whilst sale returns are much lower than for conventional housing (see attached statement by the BH & HPA especially Paragraph 11 page 2). The Council has made no call for sites for static caravans to accommodate this group. No recognition is given to the usefulness of this housing type to address demographic change as older people downsize to static caravans despite increasing local need (2.13 p.16) or to deliver much-needed accommodation at affordable rents (5.67 p.77). Instead static caravan housing growth is confined in the Local plan to existing sites where maximum density has been reached (6.50 p.109). The Council provides no evidence that spare capacity exists within static caravan sites built for the purpose or that capacity is adequate to meet needs to 2034 and well beyond as it must having determined the need for a Green Belt Boundary Review in the District (NPPF Paragraphs 83 and 85.5). Unfairly suppressing housing choice for this group, the Local Plan is not positively planned and is unjustified, ineffective and contrary to National Policy.

Attachments:

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Green Belt Review

Representation ID: 7895

Received: 04/04/2018

Respondent: M.D Stapleton Developments Ltd

Agent: A & D Architecture Ltd.

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Council officers have amended the summary to approximately 100 words. Full representation attached.

Land adjacent Bramley Park Static Caravan park Marsh Lane is located sufficiently close to Eckington (one of four towns that are the most sustainable locations in the District - 7.1 p.111) to support sustainable development in the form of an extension to an established static caravan park. This land does not need to be kept permanently open (see attached statement MDS3 Rev A). The landowner has confirmed that the land is available for development now. Such development would increase housing supply and housing choice for that group of people who wish to live in a static caravan in accordance with National Policy (NPPF Paras. 47 & 50) and growth forecasts of 0.4% p.a. to 2034 (4.9 p.34). This unfairly suppresses housing choice for this group.

Change suggested by respondent:

The Council must call for sites suitable for static caravan expansion.

The Council must allocate sites specifically to significantly boost the supply of static caravans in the District and to widen housing choice for the group of people who wish to live permanently in static caravans.

Cited policies, statements and the key diagram must be adjusted accordingly.

Full text:

The Council must boost significantly the supply of housing (NPPF Para. 47) and plan for the needs of different groups in the community (NPPF Para. 50) to widen housing choice. People living in static caravans are an important group. The Council must recognise the special site-finding difficulties facing developer-operators seeking to serve this group by expanding existing static caravan housing sites in line with projected annual growth in the district (Para 4.9 p.34). Such developer-operators face similar infrastructure costs (5.85 pp. 82-83) as do developers of conventional housing and much longer term operational and regulatory costs whilst sale returns are much lower than for conventional housing (see attached statement by the BH & HPA especially Paragraph 11 page 2). The Council has made no call for sites for static caravans to accommodate this group. No recognition is given to the usefulness of this housing type to address demographic change as older people downsize to static caravans despite increasing local need (2.13 p.16) or to deliver much-needed accommodation at affordable rents (5.67 p.77). Instead static caravan housing growth is confined in the Local plan to existing sites where maximum density has been reached (6.50 p.109). The Council provides no evidence that spare capacity exists within static caravan sites built for the purpose or that capacity is adequate to meet needs to 2034 and well beyond as it must having determined the need for a Green Belt Boundary Review in the District (NPPF Paragraphs 83 and 85.5). Unfairly suppressing housing choice for this group, the Local Plan is not positively planned and is unjustified, ineffective and contrary to National Policy.

Attachments:

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Green Belt Review

Representation ID: 8159

Received: 02/05/2018

Respondent: M.D Stapleton Developments Ltd

Agent: A & D Architecture Ltd.

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Council Officer has amended summary to approx. 100 words. Full rep attached.

Representation refers to Green Belt Topic Paper paragraphs 1, 12

Paper is not fit for purpose. It nowhere explains how growth in the static caravan sector to widen choice/boost supply is to be achieved without targeted Green Belt boundary change. Council must increase supply/choice for static caravan residents choosing to live in the north of the District to 2034 and beyond, but Green Belt boundaries currently obstruct growth for this group.

GBTP does not explain how static caravan sites in the north of the district (already at capacity due to Model Byelaws) can meet increased demand without Green Belt boundary change

Without making specific provision for this group, the Council has not discharged its duty to ensure Green Belt boundaries will not need to be altered by 2034.

Change suggested by respondent:

The GBTP must either explain how static caravan provision is to be boosted to widen housing choice in the north of the District without Green Belt boundary change or explain where land is to be set aside for that growth. The Council must as soon as possible call for sites to accommodate growth in the supply of homes in the static caravan sector to serve the group of people in choosing this life-style and wanting to live in the north of the District.

Full text:

The Green Belt Topic Paper (GBTP) is not fit for purpose because it nowhere explains how growth in the static caravan sector to widen choice and boost supply is to be achieved without targeted Green Belt boundary change. The Council must increase supply and choice for static caravan residents and aspirants choosing to live in the north of the District to 2034 and beyond but Green Belt boundaries currently obstruct growth for this group. It has been shown in this representor's response to the LPPD consultation that static caravan site operators cannot compete in the market for housing land with developers of conventional housing and therefore need specific site allocations to meet the growing demand of people wanting to live in static caravans. Nowhere does the GBTP explain how static caravan sites in the north of the district that are already at capacity due to Model Byelaws can meet increased demand without Green Belt boundary change. In a rural District where increasing housing density on non-Green Belt sites is inappropriate (5.5.3 p40) increasing housing density on Green Belt sites is no less inappropriate and is specifically banned in the case of static caravan sites by model standards. Without making specific provision for this group, the Council has not discharged its duty to ensure Green Belt boundaries will not need to be altered by 2034. Due to this shortcoming of the GBTP the Local Plan is neither positive nor consistent with National Policy and is therefore unsound.

Attachments:

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Green Belt Review

Representation ID: 8160

Received: 02/05/2018

Respondent: M.D Stapleton Developments Ltd

Agent: A & D Architecture Ltd.

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Council Officer has amended the summary to approx. 100 words. Full rep attached.

Representation refers to Green Belt Topic Paper Table 1, 2.4

The Paper contains an unjustifiable generalisation about the sustainability of Level 3 settlements and allocates no housing growth of any kind at Marsh Lane. Marsh Lane is very close to Eckington/ Dronfield (which the GBTP acknowledges are the most sustainable settlements in the District) and good bus services connect Marsh Lane to these towns. Therefore, Marsh Lane is much more sustainable than other Level 3 settlements.
The GBTP fails to acknowledge the duty to provide housing for all groups of the community, or to state how it will be discharged for the benefit of the group of residents in Marsh Lane and is therefore unfit for purpose.
Due to the shortfall in the GBTP the Local Plan is inconsistent with National Policy and unsound.

Change suggested by respondent:

The GBTP must be rewritten to acknowledge the Council's duty to meet housing growth needs in Marsh Lane beyond 2034 and must state how Green Belt boundaries will be changed accordingly. This is because the Council cannot provide there is no need for housing growth including growth in static caravan sector at Marsh Lane to 2034 and beyond and cannot prove Marsh Lane is and will continue beyond 2034 to be irrelevant to the economy of district and city region. This is because Bramley Park residents are far from irrelevant to the local economy and because there are housing growth needs at Bramley Park Static Caravan Site (more data available on request). These needs can only be met by removal of land from the Green Belt specifically to meet the urgent needs of the static caravan housing-provider sector. The Council should begin with a call for sites in Marsh Lane.

Full text:

The Green Belt Topic Paper (GBTP) contains an unjustifiable generalisation about the sustainability of Level 3 settlements and consequently allocates no housing growth of any kind at Marsh Lane. Marsh Lane is very close to Eckington and Dronfield (which the GBTP acknowledges are the most sustainable settlements in the District) and good bus services connect Marsh Lane to these towns. Therefore, Marsh Lane is much more sustainable than other Level 3 settlements. Having committed to a Green Belt Boundary, the Council is bound to provide for the housing growth needs of all groups in the community of Marsh Lane beyond 2034 so that Green Belt boundaries will not need to be changed in 2034. The GBTP fails to acknowledge this duty or to state how it will be discharged for the benefit of the group of residents in Marsh Lane and is therefore unfit for purpose. Due to the shortfall in the GBTP the Local Plan is inconsistent with National Policy and unsound.

Attachments:

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Green Belt Review

Representation ID: 8182

Received: 02/05/2018

Respondent: M.D Stapleton Developments Ltd

Agent: A & D Architecture Ltd.

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Council Officer has amended the summary to approx. 100 words. Full rep attached.

Representation refers to Green Belt Topic Paper paragraphs 12, 4.19.

The Paper is not fit for purpose because it fails to acknowledge the special desirability of boosting the supply of static caravans in the north of the District to boost the local leisure economy. When people downsize to a static caravan from traditional housing when they are at/ near retirement age, there is a significant release of equity, much of which could be spent boosting the local leisure economy. It also fails to acknowledge the desirability of increasing static housing supply in response to an ageing demographic profile. Green Belt boundaries are obstructing sustainable development in the form of increasing static caravan supply and the GBTP is silent about this supply crisis. The Local Plan makes no provision for growth in the static caravan housing sector and effectively suppresses housing choice.

Change suggested by respondent:

The GBTP must be rewritten to acknowledge the need to boost the supply of static caravans in the North of the District to boost the local economy and to offer older people increased housing choice. The GBTP should go much further and explain how Green Belt boundaries are to be changed now to meet that need. The GBTP should state that there is an urgent need for the Council to call for sites in Marsh Lane to accommodate an increased supply of static caravans in the north of the District to 2034 and beyond.

Full text:

12, 4.19
The Green Belt Topic Paper (GBTP) is not fit for purpose because it fails to acknowledge the special desirability of boosting the supply of static caravans in the north of the District to boost the local leisure economy. It has been observed by the Representor that when people downsize to a static caravan from traditional housing when they are at or near retirement age, there is a significant release of equity, much of which is spent boosting the local leisure economy (more data available on request). The GNTP also fails to acknowledge the desirability of increasing static housing supply in response to an ageing demographic profile (4.19 p26). Current Green Belt boundaries are obstructing sustainable development in the form of increasing static caravan supply and the GBTP is silent about this supply crisis. Due to this shortfall the Local Plan makes no provision for growth in the static caravan housing sector and effectively suppresses housing choice. This is inconsistent with national policy and renders the Local Plan unsound.

Attachments:

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Green Belt Review

Representation ID: 8183

Received: 02/05/2018

Respondent: M.D Stapleton Developments Ltd

Agent: A & D Architecture Ltd.

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Council Officer has amended the summary to approx. 100 words. Full rep attached.

Representation refers to Green Belt Topic Paper paragraphs 14, 15.

The Paper is not fit for purpose because despite emphasising White Paper priorities to mitigate Green Belt loss it fails to acknowledge the special suitability of static caravan parks on the edges of small settlements in landscapes valued for their openness. Being of an open character themselves compared to conventional housing estates, static caravan parks are often washed over in Green Belt designations in recognition of that special open character. Promoting static caravans in the north of the District is therefore a permanently effective means of conserving the essential character of open landscapes when Green Belt boundaries change. Due to this omission in the GBTP the Local Plan makes no provision for growth in the static caravan housing sector and effectively suppresses a key means to accommodate sustainable development.

Change suggested by respondent:

The GBTP must be rewritten to acknowledge the desirability of promoting growth in the static caravan housing sector by expansion of Bramley Park Static Caravan Park in Marsh Lane. Expansion of this site would be highly sustainable because marsh Lane is very close to and very well-connected by public transport to both of the most sustainable towns in the District (Eckington and Dronfield) and would mitigate Green Belt loss due to the inherent and unique openness of sites for this kind of housing.

Full text:

14.15
The Green Belt Topic Paper (GBTP) is not fit for purpose because despite emphasising White Paper priorities to mitigate Green Belt loss it fails to acknowledge the special suitability of static caravan parks on the edges of small settlements in landscapes valued for their open-ness. Being of an open character themselves compared to conventional housing estates, static caravan parks are often washed over in Green Belt designations in recognition of that special open character. Promoting static caravans in the north of the District is therefore a permanently effective means of conserving the essential character of open landscapes when Green Belt boundaries change and a legitimate means to mitigate the landscape impact of Green Belt loss without burdening business as required by national policy (NPPF 21). Due to this omission in the GBTP the Local Plan makes no provision for growth in the static caravan housing sector and effectively suppresses a key means to accommodate sustainable development whilst mitigating Green Belt loss and misses a key opportunity to allocate land at Marsh Lane for the expansion of Bramley Park static caravan Park in Marsh Lane accordingly. Due to this shortcoming of the GBTP the Local Plan is not positive and is unsound.

Attachments:

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