North East Derbyshire Publication Draft Local Plan (Reg 19)

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North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy SS6: Coalite Priority Regeneration Area

Representation ID: 7733

Received: 04/04/2018

Respondent: Bolsover Land Ltd

Agent: iSec Group

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Council Officer has amended the summary to approximately 100 words. Full representation attached. Compliance/soundness test interpreted by Council Officer.

No Objection in principle.
We have suggested a number of amendments to the wording of Policy SS6, related to phasing, but we generally support the approach taken in terms of allocating the site for future development and providing flexibility for this in light on HS2. We support the general approach taken in the supporting text. We consider it a sensible and sound approach for the Council not to rely on the site in terms of the delivery of housing.
We support the removal of the previously included masterplan and consider it a far sounder approach to provide a site location plan for the Priority Regeneration Area allocation. This provides a more flexible approach.

Change suggested by respondent:

Policy SS6 (a)
Whilst we support comments in respect of a 'comprehensive approach', it should be noted that we do not expect the masterplan for the BDC part of the site to change in light of HS2, and remediation and infrastructure work has already commenced in respect of the BDC site. Future proposals for the NEDDC part of the site will reflect the BDC permission/development, but not change it. We consider the use of the word 'reflect' is more flexible.
"2a. Reflect a comprehensive masterplan for re-development on the whole site (including the land in Bolsover District) including infrastructure requirements and delivery);"
2 (b).
We object to the inclusion of this criterion. Whilst we accept there was an obligation to ensure full remediation of the BDC and NEDDC site before the commencement of development of residential uses on the NEDDC land, this obligation was only agreed due to risks to public health issues (e.g. odour) and controlled water. Now the masterplan is evolving to an employment-led scheme, this obligation may no longer be needed to protect the public health of future residents. This obligation has the potential to stall development, when in public health terms it could be acceptable. Details of phasing / obligations should be dealt with through Development Control, it is the role of the Local Plan to set objectives and strategy such as the remediation of the site, not to define the detailed phasing of this process, particularly where the final masterplan is unknown. In its current form, this aspect of the policy has the potential to impact on deliverability. Suggest this criterion is deleted.
2 (c)
We note the need to consider the setting of heritage assets which may be impacted upon by the development of the site. However, we consider the policy should be amended to be consistent with NPPF, namely that 'public benefits' should also be considered where harm may be being caused. The policy is currently too rigid and does not allow for any impact on the setting of the heritage assets." Suggested wording:
"c. Where possible, protect the setting of heritage assets, in particular the Grade 1
Listed Bolsover Castle and Sutton Scarsdale Hall, or demonstrate sufficient public benefits to outweigh harm."
2(d)
Whilst we support the general approach to protecting and enhancing the biodiversity of the Doe Lea corridor and promoting links, this should only be 'where possible', creating links beyond the site is outside of the landowners control.
Suggested wording:
"d. Protect and enhance the biodiversity value of the Doe Lea Corridor and where possible promote linkages to the wider green infrastructure network;"
2(g)
We agree that HS2 should be a material consideration in the determination of future applications for the site. This criteria reflects the most up to date evidence and is justified in its approach.

Full text:

Generally support the policy subject to some amendments as suggested in the cover letter.

Supporting Text to Policy SS6
In terms of the supporting text (Paragraphs 4.50 - 4.54), we support the general approach taken. Comments in respect of the impact of HS2 reflect the current position, and as stated above, we are looking to submit a revised scheme in light of this. We therefore consider it a sensible and sound approach for the Council not to rely on the site in terms of the delivery of housing.
Figure 4.4
We support the removal of the previously included masterplan and consider it a far sounder approach to provide a site location plan for the proposed allocation of the site as a Priority Regeneration Area. Again, this provides a more flexible approach.
Employment Land Provision
Earlier representations provided comments in respect of general employment land provision and specifically site SS7 (as it was referenced in the Draft Local Plan in April 2017), Markham Vale South. We followed these comments up by providing a market commentary report (prepared by Knight Frank and appended to this letter) which indicated a chance of market saturation should Site SS7 also be released to the market alongside the former Coalite site, greatly undermining the viability and deliverability of the former Coalite site across both BDC and NEDDC.
We note that the Council has since revisited its employment land evidence base and is allowing for 46ha (para. 6.2) and has removed the potential allocation of SS7 Markham Vale South. For the reasons set out above we fully support this new approach, had the Plan undermined the deliverability of its only Priority Regeneration Area, it could have been considered unsound in terms of not being effective, deliverable or based on a robust up-to-date evidence base.
Some comments are also provided within the Local Plan about the M1 corridor and
Supporting Text to Policy SS6.
In terms of the supporting text (Paragraphs 4.50 - 4.54), we support the general approach taken. Comments in respect of the impact of HS2 reflect the current position, and as stated above, we are looking to submit a revised scheme in light of this. We therefore consider it a sensible and sound approach for the Council not to rely on the site in terms of the delivery of housing.

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Employment Land Provision

Representation ID: 7914

Received: 04/04/2018

Respondent: Bolsover Land Ltd

Agent: iSec Group

Representation Summary:

Council Officer has amended the summary to approximately 100 words. Full representation attached.

Earlier representations provided comments in respect of general employment land provision and specifically site SS7 (South of Markham Vale). We note that the Council has since revisited its employment land evidence base and is allowing for 46ha (para. 6.2) and has removed the potential allocation of SS7 Markham Vale South. We fully support this new approach, had the Plan undermined the deliverability of its only Priority Regeneration Area, it could have been considered unsound in terms of not being effective, deliverable or based on a robust up-to-date evidence base.

In terms of the supporting text to Policy SS6(Paragraphs 4.50 - 4.54) , we support the general approach taken. We are looking to submit a revised scheme and consider it a sensible and sound approach for the Council not to rely on the site in terms of the delivery of housing.

Full text:

Generally support the policy subject to some amendments as suggested in the cover letter.

Supporting Text to Policy SS6
In terms of the supporting text (Paragraphs 4.50 - 4.54), we support the general approach taken. Comments in respect of the impact of HS2 reflect the current position, and as stated above, we are looking to submit a revised scheme in light of this. We therefore consider it a sensible and sound approach for the Council not to rely on the site in terms of the delivery of housing.
Figure 4.4
We support the removal of the previously included masterplan and consider it a far sounder approach to provide a site location plan for the proposed allocation of the site as a Priority Regeneration Area. Again, this provides a more flexible approach.
Employment Land Provision
Earlier representations provided comments in respect of general employment land provision and specifically site SS7 (as it was referenced in the Draft Local Plan in April 2017), Markham Vale South. We followed these comments up by providing a market commentary report (prepared by Knight Frank and appended to this letter) which indicated a chance of market saturation should Site SS7 also be released to the market alongside the former Coalite site, greatly undermining the viability and deliverability of the former Coalite site across both BDC and NEDDC.
We note that the Council has since revisited its employment land evidence base and is allowing for 46ha (para. 6.2) and has removed the potential allocation of SS7 Markham Vale South. For the reasons set out above we fully support this new approach, had the Plan undermined the deliverability of its only Priority Regeneration Area, it could have been considered unsound in terms of not being effective, deliverable or based on a robust up-to-date evidence base.
Some comments are also provided within the Local Plan about the M1 corridor and
Supporting Text to Policy SS6.
In terms of the supporting text (Paragraphs 4.50 - 4.54), we support the general approach taken. Comments in respect of the impact of HS2 reflect the current position, and as stated above, we are looking to submit a revised scheme in light of this. We therefore consider it a sensible and sound approach for the Council not to rely on the site in terms of the delivery of housing.

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