Supporting Documents to Main Modifications (for comment)
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Supporting Documents to Main Modifications (for comment)
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)
Representation ID: 10876
Respondent: Unstone Parish Council
Agent: Cllr Alex Dale
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.
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:
• 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.
• 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.
• 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.
• 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.
• 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.
• The removal of this site at Eckington Road, Coal Aston (DR2) is welcomed.
• 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).
• 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.
• 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.