North East Derbyshire Publication Draft Local Plan (Reg 19)

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Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy SS1: Sustainable Development

Representation ID: 7700

Received: 30/03/2018

Respondent: CPRE South Yorkshire & Friends of the Peak District

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Representation not received on representation form; Council officer has made interpretation. Compliance/soundness tests interpreted by Council officer.

The opening policy of the Plan, SS1, should be much more than the generalized wish-list it currently is. It should offer a sequential guide to the way the rest of the plan works in the pursuit of sustainable place-making.

Change suggested by respondent:

Amend the plan along the following lines:

"The Local Plan:
* Sets out how the places in North-East Derbyshire should evolve and become more sustainable, in terms of their infrastructure, social fabric and environmental wellbeing (policies.......);
* identifies a hierarchy of places and sets out policies that focus development in the right places to enhance those places (policies......)
* provides sites and policies for the types and locations of built development that should be encouraged in order to implement the plan (policies.....)"

Full text:

Full submission attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy SS2: Spatial Strategy and the Distribution of Development

Representation ID: 7704

Received: 30/03/2018

Respondent: CPRE South Yorkshire & Friends of the Peak District

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Representation not received on representation form; Council officer has made interpretation. Compliance/soundness tests interpreted by Council officer.

Objection raised to the housing target and the distribution of housing development.

* Grouping Clay Cross, the three northern towns and the strategic sites together as Level 1 settlements is not appropriate, because Dronfield, Eckington and Killamarsh are much more related to Sheffield and should essentially be considered as a separate housing market area
* Housing growth in Dronfield, Eckington and Killamarsh is much more likely to attract additional Sheffield commuters than to contribute to the sustainable development of the northern towns.

This means that exceptional circumstances to release Green Belt land around those settlements have not been demonstrated, and this amounts to an appropriate and justifiable constraint on the District meeting its OAN. The housing requirement should be reduced accordingly.

Change suggested by respondent:

Adjust downwards the Local Plan housing target

Full text:

Full submission attached.

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Settlement Development Limits

Representation ID: 7709

Received: 30/03/2018

Respondent: CPRE South Yorkshire & Friends of the Peak District

Representation Summary:

Representation not received on representation form; Council officer has made interpretation. Compliance/soundness tests interpreted by Council officer.

Support for paragraph 4.59.

Full text:

Full submission attached.

Support

North East Derbyshire Publication Draft Local Plan (Reg 19)

Safeguarded Land

Representation ID: 7712

Received: 30/03/2018

Respondent: CPRE South Yorkshire & Friends of the Peak District

Representation Summary:

Representation not received on representation form; Council officer has made interpretation. Compliance/soundness tests interpreted by Council officer.

Support the approach.

Full text:

Full submission attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy SS10: North East Derbyshire Green Belt

Representation ID: 7714

Received: 30/03/2018

Respondent: CPRE South Yorkshire & Friends of the Peak District

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Representation not received on representation form; Council officer has made interpretation. Compliance/soundness tests interpreted by Council officer.

The policy is limited to a development management role for land within the Green Belt, and there is no policy to provide for the enhancement of the Green Belt as set out in NPPF Para 81 (also found in revised draft NPPF para 140).

Change suggested by respondent:

Amend the policy to provide for a Green Belt enhancement plan for the implementation of NPPF Para 81 in this way.

Full text:

Full submission attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy SS11: Local Settlement Gaps

Representation ID: 7718

Received: 30/03/2018

Respondent: CPRE South Yorkshire & Friends of the Peak District

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Representation not received on representation form; Council officer has made interpretation. Compliance/soundness tests interpreted by Council officer.

The policy does not take a net-gain approach, so is not consistent with neither our recommendations nor revised draft NPPF (para 8).

Full text:

Full submission attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy LC1: Housing Allocations

Representation ID: 7720

Received: 30/03/2018

Respondent: CPRE South Yorkshire & Friends of the Peak District

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Representation received on representation form; Council officer has made interpretation. Compliance/soundness tests interpreted by Council officer.

Object to housing sites DR1, DR2, DR3, EC1, KL1 and KL2 on the grounds that exceptional circumstances for Green Belt allocations have not been demonstrated, and the Green Belt changes would enable unsustainable patterns of development.

Object to housing sites H01, PI1 and SH2 on the basis of landscape impact and other local impacts.

Change suggested by respondent:

Delete housing allocations DR1, DR2, DR3, EC1, KL1, KL2, HO1, PI1, and SH2.

Full text:

Full submission attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy LC2: Affordable Housing

Representation ID: 7722

Received: 30/03/2018

Respondent: CPRE South Yorkshire & Friends of the Peak District

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Representation not received on representation form; Council officer has made interpretation. Compliance/soundness tests interpreted by Council officer.

This policy which only seeks to address affordable housing provision as a proportion or contribution delivered by S106 agreements on market housing schemes will only serve to deliver a tiny fraction of the affordable housing target. It must therefore be considered ineffective.

Change suggested by respondent:

Re-word the policy as suggested - detailed wording changes in full submission.

Full text:

Full submission attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy SP1: Dronfield

Representation ID: 7723

Received: 30/03/2018

Respondent: CPRE South Yorkshire & Friends of the Peak District

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Representation not received on representation form; Council officer has made interpretation. Compliance/soundness tests interpreted by Council officer.

No objection in principle. However, to assure its effectiveness the policy should include a statement that proposals that do not secure a package of benefits to the settlements as set out in the policy will normally be rejected.

Full text:

Full submission attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy SP2: Clay Cross

Representation ID: 7724

Received: 30/03/2018

Respondent: CPRE South Yorkshire & Friends of the Peak District

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Representation not received on representation form; Council officer has made interpretation. Compliance/soundness tests interpreted by Council officer.

No objection in principle. However, to assure its effectiveness the policy should include a statement that proposals that do not secure a package of benefits to the settlements as set out in the policy will normally be rejected.

Full text:

Full submission attached.

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