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Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy LC1: Housing Allocations

Representation ID: 7566

Received: 04/04/2018

Respondent: Hallam Land Management

Agent: Pegasus Group (East Midlands Office)

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

A Design and Access Statement for the planning application 17/00485/OL was also submitted but cannot be uploaded due to the size of the document; however, it can be viewed on the Council's online planning application system. Council officer made interpretation of Duty-to-Cooperate.

Hallam Land Management contend that the housing requirement should be increased to 7,560 dwellings and that additional allocations are required to meet this requirement. It is important that the Council's spatial strategy has proper regard to the geographical characteristics of the district with distinct sub-areas to north of Chesterfield and to the south around Clay Cross. Allocations should ensure sufficient provision of development around the Town of Clay Cross.
Hallam Land Management has interests in land at Coupe Lane. This represents a suitable and sustainable site that should be included as an allocation in the Plan.

Change suggested by respondent:

Policy LC1 should be amended to include land at Coupe Lane as an additional allocation to provide up to 300 dwellings.
(see supporting documents)

Full text:

Hallam Land Management contend that the housing requirement should be increased to 7,560 dwellings and that additional allocations are required to meet this requirement.
It is important that the Council's spatial strategy has proper regard to the geographical characteristics of the district with distinct sub-areas to north of Chesterfield and to the south around Clay Cross. Allocations should ensure sufficient provision of development around the Town of Clay Cross.
Hallam Land Management has interests in land at Coupe Lane. This represents a suitable and sustainable site that should be included as an allocation in the Plan.
Supporting documents are attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy SS2: Spatial Strategy and the Distribution of Development

Representation ID: 7568

Received: 04/04/2018

Respondent: Hallam Land Management

Agent: Pegasus Group (East Midlands Office)

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Council officer made interpretation of Duty-to-Cooperate.

Policy SS2 sets out a housing requirement of 6,600 dwellings for the plan period 2014-2034, equating to 330 dwellings per year. Paras 4.6-4.12 of the Submission Plan explain that this is based on the SHMA Update which set out a 'regeneration scenario' to reflect 'realistic and reasonable' future economic growth.
It is considered that, as a result of this approach the plan is unsound as it has not been positively prepared, is not justified and is not effective.
The attached report by DLP Planning concludes that the housing requirement for the plan period should be increased to 7,560 dwellings - 378 dwellings a year.

Change suggested by respondent:

Policy SS2 should be amended to state that the Local Plan will make provision for 7,560 dwellings over the period 2014-2034.
(see supporting document)

Full text:

Policy SS2 sets out a housing requirement of 6,600 dwellings for the plan period 2014-2034, equating to 330 dwellings per year. Paras 4.6-4.12 of the Submission Plan explain that this is based on the SHMA Update which set out a 'regeneration scenario' to reflect 'realistic and reasonable' future economic growth.
It is considered that, as a result of this approach the plan is unsound as it has not been positively prepared, is not justified and is not effective.
The attached report by DLP Planning concludes that the housing requirement for the plan period should be increased to 7,560 dwellings - 378 dwellings a year
Supporting documents are attached.

Attachments:

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy LC1: Housing Allocations

Representation ID: 7607

Received: 04/04/2018

Respondent: Hallam Land Management

Agent: DPDS Consulting (Derby office)

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Concern is that land between the bypass (A617) and to the rear of 109 to 247 Mansfield Road, Hasland has not been allocated for development within the draft Local Plan, and in particular Policy LC1 despite the site benefiting from previous outline planning consent determined at appeal.
The site is considered to be in a sustainable location where housing numbers would contribute towards NED's housing supply. It is considered that draft Policy LC1 should be amended to include and allocate Land Between Bypass (A617) and the rear of 109 to 247 Mansfield Road, Hasland for 160 dwellings.
(See attached submission)

Change suggested by respondent:

It is considered that draft Policy LC1: Housing Allocations should be amended to include and allocate Land Between Bypass (A617) and the rear of 109 to 247 Mansfield Road, Hasland for 160 dwellings.
(See attached submission)

Full text:

Concern is that land between the bypass (A617) and to the rear of 109 to 247 Mansfield Road, Hasland has not been allocated for development within the draft Local Plan, and in particular Policy LC1 despite the site benefiting from previous outline planning consent determined at appeal.
The site is considered to be in a sustainable location where housing numbers would contribute towards NED's housing supply. It is considered that draft Policy LC1 should be amended to include and allocate Land Between Bypass (A617) and the rear of 109 to 247 Mansfield Road, Hasland for 160 dwellings.
(See attached submission)

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Safeguarded Land

Representation ID: 7810

Received: 04/04/2018

Respondent: Hallam Land Management

Agent: DLP (Planning) Ltd - Sheffield office

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Representation not received on form; Council Officer has made interpretation. Full representation attached.

DLP promotes the identification of the land South of Bochum Parkway to be removed from the Green Belt and allocated as Safeguarded Land.

Green Belt release will be required to bring this site forward, but it is considered that the exceptional circumstances exist to justify such a release, as it contributes little to the wider function of the Green
Belt in this location. The site forms a logical extension to Sheffield and is one of the few opportunities for the city to expand.

The site is available, suitable (not constrained)and achievable (in terms of viability and lack of constraints) and deliverable in a 15 year period.

Change suggested by respondent:

Land South of Bochum Parkway should be removed from the Green Belt and allocated as Safeguarded Land.


Full text:

This representation covers the following points:
a. The General Strategy and the duty to cooperate
b. Object to the Sustainability Assessment in the failure to properly assess
reasonable alternatives
c. Objects to Policy SS2 in relation to the level and distribution of Housing.
Alternate policy wording is provided;
d. Objects to Policy SS10 and promotes the identification of Safeguarded Land and
the identification of land South of Bochum Parkway to be removed from the
Green Belt and allocated as Safeguarded land;
e. Objects to the scoring of the two sites subject to this objection in the Green Belt
Review 2017;

Full representation attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy SS2: Spatial Strategy and the Distribution of Development

Representation ID: 7907

Received: 04/04/2018

Respondent: Hallam Land Management

Agent: Freeths LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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

-HLM OBJECTS to the housing requirement figure of a minimum of 6,600 dwellings within Policy SS2. DLP have reviewed the housing requirement for NED and an Objectively Assessed Need report in Appendix A.
-HLM OBJECTS to the Plan as no provision has been made to cater for any of Sheffield's unmet need. NED is strategically well located to assist Sheffield in meeting its needs and the Plan contains no credible evidence to demonstrate why NED is unable to assist with SCC's needs.
-HLM also OBJECT to the distribution of development, it is evident that there is an imbalance in the Plan- insufficient housing is being directed to the most sustainable settlements. The imbalance between housing in the north compared to the south will create unsustainable journeys to work and has insufficient regard for providing both market and affordable housing in the northern settlements.

Change suggested by respondent:

The following amendments are required to the Plan in order for it to be considered sound:
 - Increase in OAN to 378 dwellings per annum
 - Allocation of further housing land to satisfy increase of OAN and unmet need from SCC
- Increase allocation of land in the northern settlements to deliver a more
sustainable Plan that better meets the needs of the District, including sustainable
travel to work patterns

Full text:

Housing Requirement
HLM OBJECTS to the housing requirement figure of a minimum of 6,600 dwellings within Policy SS2. HLM has instructed DLP Planning Limited to review the housing requirement for NED and an Objectively Assessed Need report is provided as Appendix A to these representations. In summary it is submitted that the OAN figure for the District is 378 dwellings per annum based on revised projections which align to the Council's preferred Regeneration Scenario. This represents an uplift of 48 dwellings per annum or over the life of the Plan period 960 dwellings. The increase in OAN alone, and without a examination of supply on a site by site basis, would compromise the ability of the Plan to demonstrate a five year supply of housing, contrary to national policy.

Sheffield's Unmet Need
Paragraph 182 of the NPPF requires that Local Plan's should be 'positively prepared' and that this includes devising a strategy to meet 'unmet requirements from neighbouring authorities where it is reasonable to do so'.

HLM OBJECTS to the Plan on the basis that no provision has been made to cater for any of Sheffield's unmet need. As referenced within the Duty to Co-Operate section it has been established that SCC requires assistance in meeting their own housing needs. NED is strategically well located to assist Sheffield in meeting its needs and the Plan and it supporting documents contains no credible evidence to demonstrate why NED is unable to assist with SCC's needs. If NED is unsure on the level of development that SCC may need assistance with, it could have explored options within the Local Plan that would only be released upon SCC adopting its Local Plan

The ambiguity to the issue of Sheffield's unmet need is not acceptable. NED has been undertaking Plan preparation for a prolonged period. NED has been considering the strategic requirements of their Plan for at least nine years, with the Publication Draft the 5th different stage they have reached. The Duty to Co-operate was introduced in 2011 and the NPPF in 2012. In short NED has had plentiful time to meaningfully grapple with the issue of accommodating unmet need from Sheffield and has simply failed to do so, contrary to the requirements of national policy.

Distribution of Development
Notwithstanding the objection to the quantum of development proposed in the Plan. HLM also OBJECT to the distribution of development.

Policy SS2 states that the majority (over 50%) of new housing development will be focussed on the four towns of Clay Cross, Dronfield, Eckington and Killamarsh and on the Avenue and former Biwaters Strategic Sites. Table 1 below shows the number of dwellings within the Level 1 Settlements and the two Strategic sites and this amounts to 53%.
Table 1 in report attached.
However, whilst the Biwaters site is located at Clay Cross, the Avenue is at Wingerworth which is a Level 2 settlement. In reality therefore if you remove the 716 dwellings from the calculation in Table 1, only 43% of the dwellings for the Plan period are within a Level 1 settlement.

Table 2 in the attached report shows how development has been divided between the settlement levels. Immediately therefore it is evident that there is an imbalance in the Plan in respect of directing development to the most sustainable parts of the District. The Settlement Hierarchy Study Update (December 2017) appraises the settlements of the District for their sustainability based on a range of factors. However, the North Derbyshire Settlement Sustainability Ranking, contained in table 67, doesn't include the four towns of Clay Cross, Dronfield, Eckington and Killamarsh as there is such an acknowledged difference between the sustainability credentials of the towns to the remainder of the District. The Settlement Study states "The four main towns will be given a level 1 designation as they far exceed the other settlements in terms of population, services and facilities, public transport and employment opportunities as shown through the information gathered in Appendices D, E, F & G."8

Since the Consultation Draft of February 2017, the level of development directed to Level 1 Settlements (excluding Biwaters) in the Plan has decreased from 2508 to 2024 (-484). For Level 2 Settlements the total level of development has increased from 1962 in the 2017 version to 2517 in the Plan (+555). Whilst the number of dwellings at the Former Biwaters site has increased by 265 (from 560 to 825), the inescapable direction of travel is that as the Plan has progressed, it has become less sustainable.

The above is clearly a consequence of planning permissions being granted in level 2 settlements, as opposed to northern towns of Dronfield, Eckington and Killamarsh which are severely constrained by their Green Belt status and indeed the Housing Capacity Study for the Northern Towns demonstrates within these settlements options for development are extremely limited9. It is notable that of the 2024 dwellings proposed in Level 1 settlements, 580 dwellings have planning permission (29%) and 1444 are proposed for allocation (71%). By comparison of 2517 dwellings within Level 2 Settlements, 2197 have planning permission (87%) and 400 are proposed for allocation (13%).

The imbalance in terms of directing development to the most sustainable settlement level is not the only distribution flaw in the Plan. Taking Level 1 and Level 2 settlements only, there is a total housing provision of 6,082. Dwellings proposed for the northern settlements, comprising Dronfield, Eckington, Killamarsh and Renishaw account for 1,701 (28%). In comparison 4381(72%) dwellings are proposed in the southern settlements. The population of the northern settlements stands at 39,653, whilst the southern settlements is very similar at 40,981 (level 1 and 2 only)10. Whilst it is recognised that the north is constrained by Green Belt and this will be significant factor in the distribution of development, it is clear that the current proposed distribution disproportionately reduces development in the north. This is not through an absence of need but as a consequence of planning permissions that have been granted during the Plan preparation period.

The impact of the distribution of development not only suppresses supply and affordability in the north, it will create unsustainable travel to work patterns. The employment evidence11 confirms that the District has high levels of out commuting, primarily to Sheffield and Chesterfield. The high proportions of housing proposed in the southern half of the District will result in increased unsustainable trips north, beyond Chesterfield and onwards to Sheffield. Appendix B is a highway technical note from BWB which analyses this in more detail, including the potential traffic impacts on Chesterfield Town Centre itself, where significant impact on junction capacity is anticipated.

Policy LC2 sets out the plans approach to the provision of Affordable Housing and requires that on proposals comprising of more than 10 dwellings "at least" 30% of Affordable Housing will be required in high value areas and 20% in low value areas. The policy goes on to identify that provision of Affordable Housing may be varied in circumstances which are assessed on:

a) Viability.
b) Practical difficulties in terms of onsite provision in which case financial contributions will be sought to "broadly equivalent value" to onsite provision.
c) The delivery would extend over a long period along within which market conditions may vary.

Whilst it is recognised that provision of Affordable Housing is part of a larger market, housing developments are not the only mechanism for delivery of Affordable Housing in the District and for example Policy LC3 allows for provision of Affordable Housing on exception of sites at 100% with a potential for some subsidiary market housing. In certain circumstances it is highly likely that the vast majority of Affordable Housing will be delivered during a plan period of larger scale market housing developments under Policy LC2. It is therefore inevitable that Policy LC2 and the delivery of Affordable Housing through the plan period will be highly reliant on the delivery and viability and of allocated and committed sites that comprise housing land supply.

Paragraph 5.70 of the submission plan identifies that the SHMA point to an overall need for Affordable Housing of 172 affordable units per annum i.e. some 3440 units through the plan period.

In assessing housing need the SHMA indicated an adjustment to meet Affordable Housing need and an upward adjustment from the conclusions on demographic need to support Affordable Housing delivery should be considered (para. 5.43 2017 SHMA Updates) that is indeed what the plan seeks to do in increasing the housing target to 330, in addition to supporting economic growth and 10% of this adjustment is attributed to supporting enhanced Affordable Housing delivery. However, even this increase will not deliver the identified need for Affordable Housing of 172 units per annum which is recognised as being unrealistic. It will be noted that if Affordable Housing need were to be met it would constitute more than 50% of the proposed housing delivery of 6600 dwellings over the plan period.

The approach to Affordable Housing delivery in Policy LC2 in applying differential proportions in the identified higher and lower value areas would if successfully implemented result in approximately 30% of the Affordable Housing need being met from the proposed allocations of LC1. Whilst it is accepted that LC1 housing allocations do not represent the total proposed supply over the plan period of 6600 it is important to recognise that Affordable Housing delivery through completions has been in most cases below "at least" requirements of Policy LC2 on completed sites thus far.

It is also important to recognise that a proportion of the proposed allocations in Policy LC1 that lie within higher value areas is less than 10%. It is axiomatic that developments in lower value areas are more likely to be of challenging viability. This is demonstrated in the two strategic sites identified in Policy LC1 at Clay Cross and at Wingerworth, both of which have been thus far unable to meet the "at least" Affordable Housing target for lower value areas of 20% with only 10% at Clay Cross and 15% in the first phase at Wingerworth, notably these sites being where either cross subsidy from retail or other development has also been allowed and in the case of Wingerworth where infrastructure obligations were accepted at below consultee requirements by approximately 20%.

The implications of the allocations identified in Policy LC1 therefore for the delivery of Affordable Housing required by Policy LC2 are significant and almost certainly will result in a substantial shortfall in delivery of Affordable Housing during the plan period. Put simply by concentrating 90% of the Affordable Housing delivery capability in the low value areas of the district the plan will fail to meet even the sub-optimal Affordable Housing target delivery that it sets out to achieve.

A further consequence of the strategy adopted in Policy LC1 by reference to Affordable Housing is that the distribution of Affordable Housing delivery that will arise will be disproportionate to the locations where the affordability gap is at its greatest. As noted above only 10% of proposed allocations are in higher value areas and the vast majority of Affordable Housing delivery is in lower value areas where market housing affordability is greater. Basically, therefore the strategy will result in less Affordable Housing in the areas of greatest need and represents a further flaw to the distribution of development.

The Housing Needs, Market and Affordability Study (2011) is out dated but represents the latest evidence on affordable housing need at a level lower than the overall district. Figure H of this document states that based on the results of the housing needs assessment the north has the largest requirement expressing a new annual housing need of 244 compared to 218 in the south and 33 in the rural west. This evidence requires updating, but the LPA should be taking a clear steer on affordable housing need when considering the distribution of development and represents a further reason to increase housing in the north. This is further evidenced by the Whole Viability Assessment (2018) which, as referenced above, identifies high and low value areas for the purpose of affordable housing requirement. The high value area is 30% and covers much of the rural west of the District but also includes Dronfield. It is the LPA's evidence therefore that Dronfield should be capable of accommodating higher levels of affordable housing and this offers further justification for a higher housing provision in this settlement.

Summary on Distribution of Development
The above submissions identify that the distribution of development as proposed by the Plan is flawed in that insufficient housing is being directed to the most sustainable settlements within the District. Further, the imbalance between housing in the north compared to the south will create unsustainable journeys to work and has insufficient regard for providing both market and affordable housing in the northern settlements. The spatial strategy has no regard for assisting in meeting Sheffield's unmet housing requirement, either through additional allocations or through safeguarding land. The northern settlements of the District are strategically well placed to resolve some of the unmet need for Sheffield, being so closely related in respect of employment opportunities and having regard the high level of out commuting to Sheffield.

For the above reasons Policy SS2 and the Plan as a whole fails all four tests of Paragraph 182 of the NPPF. It is not 'positively prepared' in that it fails to meet unmet requirements from neighbouring authorities (SCC). It is also not 'justified' given that it does not represent the most appropriate strategy and indeed it's strategy is spatially flawed. The Plan has failed to demonstrate effective joint working on the cross boundary strategic priority of delivering housing. Finally, it is not consistent with national policy in that it's overall strategy is not sustainable.







Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy SS10: North East Derbyshire Green Belt

Representation ID: 7946

Received: 04/04/2018

Respondent: Hallam Land Management

Agent: DLP (Planning) Ltd - Sheffield office

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Representation not received on form. Council Officer has interpreted form. Please refer to the accompanying report and appendices.

The approach to safeguarded land is unsound as it does not conform to national guidance notably paragraphs 83, 84 and 85 in so far as the boundaries presently being proposed are
even according to the plan itself unlikely to endure beyond the plan period. It also does not consider Sheffield City's housing needs or consider the needs beyond the plan period.

The need to meet future needs in sustainable locations provides clear exceptional circumstances for the identification of safeguarded land. Exactly which areas of land maybe identified as safeguarded is down to the site specific exceptional circumstances.

The Green Belt Review has shortcomings in relation to parcels SHEFF/GB/004 & 5 Land on Bochum Parkway and Land on Bochum Parkway / Lightfoot Lane.

Change suggested by respondent:

DLP wish to amend the wording to para 4.71 and Policy SS10 as follows:

4.71 National guidance requires that when defining Green Belt boundaries authorities should have regard to their permanence in the long term, so that they are capable of enduring beyond the plan period. The identification of 'safeguarded land' between the urban area and the Green Belt can help to meet longer-term development enduring beyond the plan period9 . The identification of 'safeguarded land' between the urban area and the Green Belt can help to meet longer-term development needs that extend beyond the current plan period, thereby avoiding the need for a review of the Green Belt with each Local Plan review. DELETE "However given the inherent uncertainty of accurately predicting development needs beyond the plan period, it is difficult to say how much land would be required and whether the locations selected now would be appropriate in the future. This makes it difficult to demonstrate exceptional circumstances for removing the land from the Green Belt for the purposes of safeguarding and therefore in the absence of clear evidence, the Plan does not identify any safeguarded land."
INCLUDE: "There exist exceptional circumstances to review the green belt boundary as set out in paragraph 4.68 of the plan and in Green Belt Topic paper (January 2018). This review however concerns itself with meeting the needs of the district in the most sustainable way while supporting the strategy of the plan. In considering how the future needs of the area might also be met in the most sustainable way account needs to be taken of unmet need arising from Sheffield City and the contribution any release of land adjacent to the city might assist the city in meeting its needs in the most sustainable way. Naturally this will require a different approach to that applied in the Green Belt Topic Paper. While the exact level of future development requirement is not known it is considered appropriate that a number of sites are identified adjacent to the three main settlements within the district as well as sites adjacent to the City so that future sustainable development maybe accommodated without the need for green belt release in the future. This approach while removing more sites from the green belt than required to meet present needs will maintain the credibility of the planning system by maintaining the longevity of the green belt boundary beyond the plan period."

Policy SS10:
INCLUDE:
"4. The following sites are excluded from the green belt and identified as "Safeguarded Land" the purpose of this allocation is to allow for future development needs to be met without requiring a further review of the greenbelt.
These sites have been selected to meet both the locally generated needs beyond the plan period and the needs of Sheffield City once these become known. As such some of these sites might come forward for development within the plan period while others may remain underdeveloped for a considerable period of time. Safeguarded Sites as shown on the Policies Map, will be protected from inappropriate development except in very special circumstances and where the potential harm to the Green Belt is clearly outweighed by other material planning considerations or unless required to meet identified development needs which cannot be met elsewhere. Safeguarded sites might be allocated for development in the review or atrial review of the plan."

Full text:

This representation covers the following points:
a. The General Strategy and the duty to cooperate
b. Object to the Sustainability Assessment in the failure to properly assess
reasonable alternatives
c. Objects to Policy SS2 in relation to the level and distribution of Housing.
Alternate policy wording is provided;
d. Objects to Policy SS10 and promotes the identification of Safeguarded Land and
the identification of land South of Bochum Parkway to be removed from the
Green Belt and allocated as Safeguarded land;
e. Objects to the scoring of the two sites subject to this objection in the Green Belt
Review 2017;

Full representation attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Policy SS2: Spatial Strategy and the Distribution of Development

Representation ID: 7947

Received: 04/04/2018

Respondent: Hallam Land Management

Agent: DLP (Planning) Ltd - Sheffield office

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Representation not received on form. Council Officer has made interpretation.

The overall level of development being planned for is objected to as it does not take into account the unmet needs from Sheffield. It is recognised, in our objection to the overall strategy and to Policy SS9 Green Belt, that the precise level of unmet need from Sheffield cannot be determined at the present stage. Nevertheless, if the green belt boundaries are to be altered in this plan (as we consider they should be) then it is necessary for such amendments to be in accordance with the Framework that the future requirements for Sheffield are considered.

In light of this the plan should allocate land to meet the 7,580 dwelling requirement, as suggested in the accompanying report prepared by SPRU. It should also make reference to meeting the as yet undefined level of unmet need of Sheffield.

Change suggested by respondent:

Policy SS2: Spatial Strategy and the Distribution of Development
1) The Local Plan will promote prosperous and sustainable communities by delivering
ambitious levels of new development INCLUDE *which recognise its relationship with the remainder of the Sheffield City Region", whilst protecting the high quality
environment that makes North East Derbyshire an attractive place to live and work.

4) The remaining housing development will be focused on the district's other most
sustainable settlements, INCLUDE "including housing adjacent to Sheffield and Chesterfield," defined as Level 2 settlements in the Settlement Hierarchy at Table 4.2.

INCLUDE:

" Green Belt
The existing Green Belt boundaries will be reviewed in accordance with
the Duty to Cooperate with Chesterfield and Sheffield."

Table 4.3: Housing Distribution DELETE "by Level 1 & Level 2 Settlement"
INCLUDE the following in a revised table 4.3:
Main Settlements and Dwelling requirement
Claycross 1,000
Dronfield and Coal Aston 1,000
Eckington 750
Grassmoor 350
Killamarsh 1,000
Shirland 600
Wingerworth 1,600
Housing Adjacent to Sheffield 1,500
Housing Adjacent to Chesterfield 500
Total 8,300

Full text:

This representation covers the following points:
a. The General Strategy and the duty to cooperate
b. Object to the Sustainability Assessment in the failure to properly assess
reasonable alternatives
c. Objects to Policy SS2 in relation to the level and distribution of Housing.
Alternate policy wording is provided;
d. Objects to Policy SS10 and promotes the identification of Safeguarded Land and
the identification of land South of Bochum Parkway to be removed from the
Green Belt and allocated as Safeguarded land;
e. Objects to the scoring of the two sites subject to this objection in the Green Belt
Review 2017;

Full representation attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Relationship with other Local Plans and the Duty to Co-operate

Representation ID: 7949

Received: 04/04/2018

Respondent: Hallam Land Management

Agent: DLP (Planning) Ltd - Sheffield office

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Representation not received on rep form. Council Officer has made interpretation.

Sheffield has a clean relationship with the northern towns of NEDDC. DLP have raised concerns that there is no evidence of having effectively cooperated to plan for issues with cross-boundary impacts and no clear evidence of how the impact of the local plan will address the issue of unmet need from Sheffield. The definition of the Housing Market Sub Area is also difficult to understand.

DLP consider that the plan therefore fails the test of soundness, is not effective (lack of effective joint working on cross-boundary strategic priorities) and is not consistent with national policy as its does not enable the delivery of sustainable development as it is inflexible. A flexible plan would have identified a number of potential green belt releases to protected as safeguarded land and only released if and when they are required to meet Sheffield needs.

Change suggested by respondent:

DLP have raised concerns that there is no evidence of NEDD having effectively cooperated to plan for issues with cross-boundary impacts and no clear evidence of how the impact of the local plan will address the issue of un met need from Sheffield. DLP consider that the plan therefore fails the test of soundness and is not consistent with national policy as its does not enable the delivery of sustainable development as it is inflexible. A flexible plan would have identified a number of potential green belt releases to protected as safeguarded land and only released if and when they are required to meet Sheffield needs.

Full text:

This representation covers the following points:
a. The General Strategy and the duty to cooperate
b. Object to the Sustainability Assessment in the failure to properly assess
reasonable alternatives
c. Objects to Policy SS2 in relation to the level and distribution of Housing.
Alternate policy wording is provided;
d. Objects to Policy SS10 and promotes the identification of Safeguarded Land and
the identification of land South of Bochum Parkway to be removed from the
Green Belt and allocated as Safeguarded land;
e. Objects to the scoring of the two sites subject to this objection in the Green Belt
Review 2017;

Full representation attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

Sustainability Appraisal

Representation ID: 7951

Received: 04/04/2018

Respondent: Hallam Land Management

Agent: DLP (Planning) Ltd - Sheffield office

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Representation not received on rep form. Council Officer has made interpretation. Full representation attached.

This representation objects to the Sustainability Appraisal which assessed a number of sites against the SA framework. The concern is that Green Belt release should be considered against its alternative of no Green Belt release. In this case the consideration of reasonable alternatives would be to consider the allocation of safeguarded sites rather than dismissing the concept of safeguarded sites on the ground that the level of need was uncertain. It would also be appropriate to consider a variety of sites that could be released to meet different levels of unmet need in Sheffield.

Change suggested by respondent:

The Sustainability Assessment should consider Green Belt and no Green Belt sites, in this case the consideration of reasonable alternatives would be to consider the allocation of safeguarded sites rather than dismissing the concept of safeguarded sites on the ground that the level of need was uncertain. It would also be appropriate to consider a variety of sites that could be released to meet
different levels of unmet need in Sheffield.

Full text:

This representation covers the following points:
a. The General Strategy and the duty to cooperate
b. Object to the Sustainability Assessment in the failure to properly assess
reasonable alternatives
c. Objects to Policy SS2 in relation to the level and distribution of Housing.
Alternate policy wording is provided;
d. Objects to Policy SS10 and promotes the identification of Safeguarded Land and
the identification of land South of Bochum Parkway to be removed from the
Green Belt and allocated as Safeguarded land;
e. Objects to the scoring of the two sites subject to this objection in the Green Belt
Review 2017;

Full representation attached.

Object

North East Derbyshire Publication Draft Local Plan (Reg 19)

EC1. Eckington South

Representation ID: 7975

Received: 04/04/2018

Respondent: Hallam Land Management

Agent: Freeths LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Representation not received on form. Council Officer has made interpretation and the soundness test. Full representation attached.

EC1: Eckington South
HLM SUPPORTS the proposed allocation of Eckington South in principle. However, it is considered that there is significant potential to increase the size of the allocation for this Local Plan and also, potentially, to safeguard further land to the south of Eckington. Indeed this is required if the Plan is to fulfil its aspiration of assisting the regeneration of Eckington and delivering the objectives of the Eckington Town Centre Development Framework ("ETCDF").

Please see accompanying Freeths LLP Representations Statement
Section 6 - Policy LC1 (Allocation EC1)

Change suggested by respondent:

- potential exists for a much larger development, encompassing land formerly proposed as safeguarded land and beyond. The indicative layout of a larger development proposal (5208-L-27) is contained in Appendix C and shows the principles of such a development, the key components of which are in the order of 1800 dwellings, substantial open space infrastructure, education facilities and a southern Eckington By-Pass route which could significantly reduce traffic from the town centre.

Full text:

Policy LC1 Housing Allocations - EC1 - Eckington South
HLM SUPPORTS the proposed allocation of Eckington South in principle. However, it is considered that there is significant potential to increase the size of the allocation for this Local Plan and also, potentially, to safeguard further land to the south of Eckington.
Indeed this is required if the Plan is to fulfil its aspiration of assisting the regeneration of Eckington and delivering the objectives of the Eckington Town Centre Development Framework ("ETCDF").
Firstly, in respect of the proposed allocation the Green Belt Review 2017 confirms that the site only meets one of the purposes of Green Belt, preventing encroachment into the countryside and its omission from the Green Belt would result in a stronger boundary.
The site represents a logical addition to the built up pattern of development of Eckington and would not cause any significant harm to the wider purposes of the Green Belt.
Eckington is a sustainable settlement, identified as a Level 1 town in the Plan, and easily accessible to Dronfield and Sheffield. The town centre would adequately serve the needs of proposed residents. Suitable vehicular access can be achieved from Chesterfield Road and the town centre is within reasonable walking and cycling distance.
However, at 400 dwellings, the proposed allocation is not of a sufficient size to provide a meaningful impact on the regeneration of Eckington. Policy SP3 of the Plan12 which relates to Eckington, states at paragraph 4, that appropriate development proposals will be expected to demonstrate how they contribute to the successful delivery of the ETCDF's strategic objectives, which are listed within the policy. Site Allocation LC1 is the only allocation proposed for Eckington and so any potential for meeting these ambitions is highly likely to fall on this site.
The Whole Plan Viability Assessment (2018) identifies four value areas in the District, with Value Area 1 being the lowest at £1,650 per m² and Value Area 4 the highest at £2,800 per m². Eckington sits within Value Area 2 at £2100 per m²13. Within the Viability Assessment a deliverability scenario is run based on a notional 400 unit development (the same level as proposed under EC1) at 30 dwellings per hectare. The Assessment states in respect of Value Area 2:
Table 8.5 demonstrates that the 10% affordable housing scenario produces a residual land value of £166,099 per gross hectare in Value Area 2 where average private property values of £2,100 per m2 are assumed. The 400 unit at 30dph scenario is not sufficiently viable to deliver a developer surplus towards an affordable housing contribution and Community Fund/ CIL in this value area."
Whilst it is appreciated that this is not a site specific assessment, it nevertheless ably demonstrates that viability is a challenge in Value Area 2 zones such as Eckington and even at 400 dwellings, there is severe question mark over whether the scheme would achieve the 20% affordable housing target of Policy LC2. It is therefore extremely doubtful whether in the event that 20% is achieved, that there would be sufficient viability in the scheme to assist in delivering the regeneration aspirations of Policy SP3.
Paragraph 7.36 of the Plan, which is supporting text to Policy SP3, lists the main town centre development opportunities. The paragraph concludes "It is important that these opportunities are capitalised upon within the Local Plan." It is our view that there is a clear disconnect between this ambition and the level of development that is proposed within Eckington to achieve the requirements of Policy SP3 and the ETCDF.
It is concluded that the proposed allocation of EC1 is not sound in that the level of
development does not correlate with the Sub Area Objective N1 'The North' in respect of supporting change through the Regeneration Frameworks. The current proposed allocation fails the 'justified' test in that it is not the most appropriate strategy. This can be rectified through a larger allocation and through safeguarding land to the south of Eckington, as it set out below.
Amendments Required to Plan
As stated during the Consultation Draft response of 2017, potential exists for a much larger development, encompassing land formerly proposed as safeguarded land and beyond. The indicative layout of a larger development proposal (5208-L-27) is contained in Appendix C and shows the principles of such a development, the key components of which are in the order of 1800 dwellings, substantial open space infrastructure, education facilities and a southern Eckington By-Pass route which could significantly reduce traffic from the town centre.

Please see accompanying Freeths LLP Representations Statement
Section 6 - Policy LC1 (Allocation EC1)

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