NEDDC Local Plan Issues and Options Consultation on the Strategic Approach to the Location of Development and Refined Sites (March 2026)

Savills (UK) Ltd is instructed by Wilson Bowden Developments (‘WBD’) to promote land south of Markham
Vale, Long Duckmanton (Site ID: 45041) (‘the Site’) for strategic industrial and logistics (‘I&L’) development.

Introduction and Scope
The Site has been identified in the consultation as one of various sites being consulted on as part of a ‘Refined
Schedule of Sites’ which have passed the site assessment process. These representations provide a detailed
response to the Council’s strategic approach to the location of development, along with a response to the
assessment of the Site within both the consultation document, the Employment Land Availability Assessment
(‘ELAA’) (2026) and the Sustainability Appraisal Addendum (March 2026).

In short, WBD considers that the Site is available and suitable for strategic-scale I&L development, and that
the constraints identified in the ELAA can be suitably mitigated at the planning application stage. As set out in
the below representations, the Site is considered to represent the only promoted land within the District which
can contribute towards meeting the wider sub-regional strategic I&L need, and therefore we consider that the
Site should be allocated in the Regulation 19 Local Plan.

This submission is accompanied by the following supporting documents:
• Appendix 1: Parameter Plan (ref: 17-060 MP09-002);
• Appendix 2: Markham Vale Sustainability Appraisal Scoring Review;
• Appendix 3: Heritage Statement (Pegasus Group, February 2026);
• Appendix 4: Landscape and Visual Site Appraisal (Pegasus Group, February 2026);
• Appendix 5: Landscape Strategy Plan and Sections (Pegasus Group, March 2026);
• Appendix 6: Economic Benefits Infographic (Pegasus Group, March 2026);
• Appendix 7: Alternative Sites Note (Savills, March 2026);
• Appendix 8: Preliminary Transport Assessment (BSP, February 2026);
• Appendix 9: Phase I Geo-Environmental Assessment (BWB, May 2019); and
• Appendix 10: Preliminary Flood Risk Assessment and Drainage Strategy report (April 2026).

The Opportunity at Land South of Markham Vale
Land south of Markham Vale comprises 35.5 hectares (87.8 acres) of agricultural land located directly to the
east of the M1 motorway and south of the A632 Chesterfield Road. The red line for the purposes of the site
promotion is provided at Appendix 1 of these representations. It should be noted that this red line area has been amended following our previous submission to the Local Plan in 2025. The original submission red line
included a wider land ownership parcel which aligned with the title for the land. However, following further
consideration of masterplanning options for the Site, the red line has been reduced to include only the land
which WBD is feasibly able to develop, and therefore promote.

The Site is located to the south of the existing Markham Vale employment area and the former Coalite mixed
use development site which is currently being developed as ‘Horizon 29’. Both Markham Vale and Horizon 29
provide I&L development (Use Class B2/B8). Land south of Markham Vale would provide a new strategic scale
I&L opportunity which would form a logical extension of Horizon 29 and would be attractive to inward investors,
as well as providing good supply chain opportunities for nearby businesses. It is envisaged that the Site could
provide c.700,000 sqft (c.65,000 sqm) of I&L floorspace across a number of units, as shown indicatively on the
submitted parameter plan (Appendix 1).

The Site is in single ownership and is relatively free of constraints. We also understand that, importantly, there
is available electricity capacity to serve the development. The Site therefore represents a deliverable and
achievable option for meeting the strategic employment needs of the FEMA, and can be developed within 3-5
years. As part of this submission an Economic Benefits Infographic (Appendix 6) has been provided to set out
how the development of the Site could boost the local and sub-regional economy.

National planning policy is supportive of planning policies helping to create the conditions in which businesses
can invest, expand and adapt, stating that significant weight should be placed on the need to support economic
growth and productivity, taking into account both local business needs and wider opportunities for development.
Additionally, the December 2025 consultation draft NPPF, which provides a clear indication of the direction of
travel of national policy, includes a proposed presumption in favour of I&L development where a need can be
evidenced. This is set out in detail at Policy S5 (1)(j)(ii) of the draft NPPF. Therefore, we consider that national
planning policy provides a clear basis for land south of Markham Vale to come forward and that this could
attract both local, regional and potentially foreign investment in the District.

Response to Regulation 18 Issues and Options Representations
We note that our representations to the 2025 Issues and Options consultation are recorded as representation
ref: PE146. Having reviewed the Consultation Statement issued in March 2026, we note that Appendix 2.4
(Focus Group Findings) states at paragraph 3.4 that “councillors emphasised that housing growth must be
aligned with employment opportunities. They stressed the need to consider where people actually work—
whether that is Sheffield, Chesterfield, or locations with strong motorway links—to ensure new communities
are well-connected and sustainable. They noted that an understanding of commuting patterns, including routes
through places like Dronfield and Killamarsh, should inform the spatial strategy.” (Savills emphasis)

WBD agrees with the above comments and considers that it is appropriate to ensure that housing and economic
growth are aligned. In light of North East Derbyshire’s relatively small settlements which sit in close proximity
to larger settlements outside of the borough such as Chesterfield, Sheffield and Bolsover, we also consider that
proximity to these labour forces should be taken into account when determining the most appropriate location
for strategic I&L growth in the region. Following the success of relatively recent developments at Markham Vale and Horizon 29, we consider that it is appropriate to situate such development around J29A of the M1 motorway at land south of Markham Vale.

Strategic Approach to the Location of Development
WBD objects to the Strategic Approach to the Location of Development set out in the consultation document.
Large and strategic-scale I&L schemes have a specific locational requirement to be located on key junctions
of the Strategic Road Network (‘SRN’), and should therefore be assessed separately to the four priority
locations set out in Figure 7 of the consultation document, which are more relevant to housing growth than to
strategic I&L.

It is important for strategic I&L development to be located in close proximity to the SRN for a number of reasons,
not least to provide easy access to the SRN for HGV vehicles which consequently keeps vehicle emissions
and amenity impacts on residential areas to a minimum. Locating I&L development near to strategic road
networks is also the most efficient way to ensure that wider supply chains can serve / be served by I&L sites.
This is significantly different from that of residential development, which naturally needs to be located close to
key services and facilities such as schools, GP surgeries and supermarkets. The same cannot be said for I&L
uses and therefore, we consider that a different methodology should be utilised for this type of development.

It is noted that the Council’s Settlement Role and Function Study (March 2026) considers the sustainability of
existing settlements within the District, providing information about the level of services and facilities each
settlement currently provides. This information has directly influenced the proposed settlement hierarchy within
the Local Plan consultation document, which has culminated in a hierarchy ranging from ‘Level 1’ (i.e.
largest/most sustainable) settlements down to ‘Level 4’ settlements. The Local Plan consultation proposes to
distribute development using a cascade approach, with Level 1 settlements prioritised for the most development
and Level 4 settlements accommodating significantly less development. Whilst WBD recognises that this study
enables the Council to build a picture as to which settlements are the most sustainable places to locate
residential development, this is not necessarily the case for strategic-scale I&L development, which benefits
from being located on key SRN junctions. These do not always correlate with the largest settlements with the
most services and facilities, and it is not necessarily the case that I&L development needs to be located close
to these facilities to be sustainable, for example in the case of schools. Therefore, an alternative spatial strategy
should be developed for employment uses, to provide a specific focus on the key SRN locations for the
allocation of I&L sites.

Paragraph 10.47 of the Bolsover, Chesterfield and North East Derbyshire Economic Needs Assessment Study
(‘ENA’) (Lichfields, March 2025) sets out nine SRN junctions which are considered to represent “areas of
opportunity” for strategic I&L development (Use Class B2 / B8). Paragraph 10.44 of the ENA explains the
reasoning behind this, stating that “the analysis involved identifying existing clusters of logistics parks across
the study area, and then defined broad areas of search, based primarily on proximity to the strategic road
network, which is generally one of the core motivations behind land searches for road-based logistics
operators”.

Of the 9 opportunity junctions, 3 fall within the North East Derbyshire LPA area, as identified by red circles on
the map below:
Figure 1: Plan showing the three “areas of opportunity” (circled red) within North East Derbyshire District (Bold black line)
See attachment

Savills has prepared an Alternative Sites Note, which is provided as Appendix 7 to these representations. This
note sets out a review of potential alternative locations to meet the strategic need identified in the ENA, both in
North East Derbyshire District and also in neighbouring Chesterfield / Bolsover. This review concludes that land
south of Markham Vale represents the only available and suitable site. Whilst the identified strategic
employment need is a sub-regional one, we consider that the Council should take a positive and proactive
approach to plan-making and act now to allocate land to contribute towards this significant economic need.
This would represent positive plan-making and would assist the emerging Local Plan in meeting the tests of
soundness, as set out at paragraph 36 of the NPPF, as well as attracting significant inward investment and
growth for this strategically important part of the district.

NPPF paragraph 87 further emphasises the need for planning policies to take account of specific locational
requirements of different sectors, including making provision for “storage and distribution operations at a variety of scales and in suitably accessible locations that allow for the efficient and reliable handling of goods,
especially where this is needed to support the supply chain, transport innovation and decarbonisation” (Savills
emphasis).

Paragraphs 3.24 – 3.29 of the Settlement Role and Function Study also set out how the number of local
employment opportunities within/adjacent to each settlement has been taken into account in assessing the
sustainability of the District’s existing settlements. Applying this approach when assessing the sustainability of settlements to accommodate residential development is considered to be an acceptable approach. However,
we object to the use of this methodology to assess the sustainability (and consequent settlement hierarchy) as
it relates to the provision of new employment development. Using this methodology will result in new
employment development being focused on market facing areas which already have significant levels of jobs,
which is backward-looking and ignores the current locational requirements of specific employment sectors such as strategic-scale I&L.

WBD considers that it would be unsound to apply the current proposed strategy to site allocations for
employment uses, as this would not take into account the relevant evidence as set out in the ENA and would
not fulfil the requirements of paragraph 87 of the NPPF. We consider that it would be more appropriate to
prepare a separate strategic approach and spatial strategy Local Plan policies for employment development
given its fundamental differences to residential development, particularly at the strategic scale, and to recognise that the identified settlement hierarchy is not relevant to employment development.

It should be recognised that a consultation on a revised draft NPPF has recently concluded (10 March 2026).
Whilst the final revised NPPF has yet to be published, the consultation draft provides an indication of the
direction of travel of national planning policy going forward. Draft Policy S5 (‘Principle of development outside
settlements’) provides details of a clear presumption in favour of sustainable development outside of
settlements at paragraph 1. Paragraph 1(j)(ii) confirms that this includes proposals comprising major
development for storage and distribution purposes, where the development would address an evidenced unmet
need. It is therefore considered that national planning policy is likely to be amended significantly to encourage
additional logistics development outside of settlements, and we therefore consider that the Council should seek
to plan positively for this type of development, which has distinctly different locational requirements when
compared with residential development.

Comments on the Refined Schedule of Sites
The consultation document also includes a Refined Schedule of Sites which are being consulted on for potential allocation. This includes sites which have passed the initial site assessment undertaken by the Council.
WBD welcomes the inclusion of text within the consultation document stating that “further evidence that may
be forthcoming from the site promoter and responses to this consultation will inform the Preferred List of Sites
that will be included in the Publication Draft Local Plan”. We consider that this represents a positive approach
to plan-making, which should be evidence-led to ensure that the most appropriate sites are selected. With this in mind, WBD has prepared a suite of technical work to respond to the initial comments on the Site which are
included in the consultation document. A summary of this work is included in Table 1 below:

Table 1: WBD response to NEDDC comments on land south of Markham Vale (ref: 45041)
See attachment

In summary, it is considered that the potential technical constraints highlighted in the consultation document
can be addressed through suitable mitigation which would come forward at the planning application stage.
Therefore, the Site is suitable for allocation in the Local Plan.

Sustainability Appraisal: Regulation 18 Addendum to the Issues and Options SA (March 2026)
It is noted that an addendum to the Issues and Options Sustainability Appraisal (‘SA’) Scoping Report has been
published to support this consultation. The SA Addendum assesses a total of 351 reasonable alternative sites
which NEDDC has put forward for consideration. This includes 272 sites for residential uses, 4 sites for strategic
mixed-use development, 54 employment sites and 21 gypsy and traveller sites.

The Site has been assessed as site reference 45041 (Land south of Markham Vale, Long Duckmanton). We
have provided a detailed review and response to any areas of the SA where the Site has scored negatively and
this is set out at Appendix 2 of these representations. In summary, it is considered that with appropriate
mitigation and amendments to the red line boundary for the Site, there are no reasons why the Site should not
score favourably in the SA and be considered for allocation in the upcoming Regulation 19 plan. We request
that any further iteration of the SA takes account of the revised red line boundary for Site 45041,
alongside the technical work provided as part of this submission.

Summary and Conclusions
In summary, WBD considers that land south of Markham Vale represents a unique opportunity to deliver largescale
I&L development within the NEDDC area: an opportunity which none of the other promoted sites are able
to accommodate. The Site should therefore be allocated for Strategic I&L development to contribute towards
the clearly identified need set out in the ENA. As set out in the accompanying Economic Benefits Infographic
(Appendix 6), the development of the Site is estimated to generate £39 million annual economic output and
971 full-time equivalent jobs, with c.£1.2 million in business rates paid per annum. This is in addition to the
significant (c.£65 million) estimated construction investment during the build programme, with £67 million GVA and 102 on-site jobs supported during the construction period.

I trust these representations are useful and look forward to receiving confirmation of safe receipt. We would
welcome the opportunity for continued positive dialogue with officers.

Savills (UK) Ltd is instructed by Wilson Bowden Developments (‘WBD’) to promote land south of Markham
Vale, Long Duckmanton (Site ID: 45041) (‘the Site’) for strategic industrial and logistics (‘I&L’) development.

Introduction and Scope
The Site has been identified in the consultation as one of various sites being consulted on as part of a ‘Refined
Schedule of Sites’ which have passed the site assessment process. These representations provide a detailed
response to the Council’s strategic approach to the location of development, along with a response to the
assessment of the Site within both the consultation document, the Employment Land Availability Assessment
(‘ELAA’) (2026) and the Sustainability Appraisal Addendum (March 2026).

In short, WBD considers that the Site is available and suitable for strategic-scale I&L development, and that
the constraints identified in the ELAA can be suitably mitigated at the planning application stage. As set out in
the below representations, the Site is considered to represent the only promoted land within the District which
can contribute towards meeting the wider sub-regional strategic I&L need, and therefore we consider that the
Site should be allocated in the Regulation 19 Local Plan.

This submission is accompanied by the following supporting documents:
• Appendix 1: Parameter Plan (ref: 17-060 MP09-002);
• Appendix 2: Markham Vale Sustainability Appraisal Scoring Review;
• Appendix 3: Heritage Statement (Pegasus Group, February 2026);
• Appendix 4: Landscape and Visual Site Appraisal (Pegasus Group, February 2026);
• Appendix 5: Landscape Strategy Plan and Sections (Pegasus Group, March 2026);
• Appendix 6: Economic Benefits Infographic (Pegasus Group, March 2026);
• Appendix 7: Alternative Sites Note (Savills, March 2026);
• Appendix 8: Preliminary Transport Assessment (BSP, February 2026);
• Appendix 9: Phase I Geo-Environmental Assessment (BWB, May 2019); and
• Appendix 10: Preliminary Flood Risk Assessment and Drainage Strategy report (April 2026).

The Opportunity at Land South of Markham Vale
Land south of Markham Vale comprises 35.5 hectares (87.8 acres) of agricultural land located directly to the
east of the M1 motorway and south of the A632 Chesterfield Road. The red line for the purposes of the site
promotion is provided at Appendix 1 of these representations. It should be noted that this red line area has been amended following our previous submission to the Local Plan in 2025. The original submission red line
included a wider land ownership parcel which aligned with the title for the land. However, following further
consideration of masterplanning options for the Site, the red line has been reduced to include only the land
which WBD is feasibly able to develop, and therefore promote.

The Site is located to the south of the existing Markham Vale employment area and the former Coalite mixed
use development site which is currently being developed as ‘Horizon 29’. Both Markham Vale and Horizon 29
provide I&L development (Use Class B2/B8). Land south of Markham Vale would provide a new strategic scale
I&L opportunity which would form a logical extension of Horizon 29 and would be attractive to inward investors,
as well as providing good supply chain opportunities for nearby businesses. It is envisaged that the Site could
provide c.700,000 sqft (c.65,000 sqm) of I&L floorspace across a number of units, as shown indicatively on the
submitted parameter plan (Appendix 1).

The Site is in single ownership and is relatively free of constraints. We also understand that, importantly, there
is available electricity capacity to serve the development. The Site therefore represents a deliverable and
achievable option for meeting the strategic employment needs of the FEMA, and can be developed within 3-5
years. As part of this submission an Economic Benefits Infographic (Appendix 6) has been provided to set out
how the development of the Site could boost the local and sub-regional economy.

National planning policy is supportive of planning policies helping to create the conditions in which businesses
can invest, expand and adapt, stating that significant weight should be placed on the need to support economic
growth and productivity, taking into account both local business needs and wider opportunities for development.
Additionally, the December 2025 consultation draft NPPF, which provides a clear indication of the direction of
travel of national policy, includes a proposed presumption in favour of I&L development where a need can be
evidenced. This is set out in detail at Policy S5 (1)(j)(ii) of the draft NPPF. Therefore, we consider that national
planning policy provides a clear basis for land south of Markham Vale to come forward and that this could
attract both local, regional and potentially foreign investment in the District.

Response to Regulation 18 Issues and Options Representations
We note that our representations to the 2025 Issues and Options consultation are recorded as representation
ref: PE146. Having reviewed the Consultation Statement issued in March 2026, we note that Appendix 2.4
(Focus Group Findings) states at paragraph 3.4 that “councillors emphasised that housing growth must be
aligned with employment opportunities. They stressed the need to consider where people actually work—
whether that is Sheffield, Chesterfield, or locations with strong motorway links—to ensure new communities
are well-connected and sustainable. They noted that an understanding of commuting patterns, including routes
through places like Dronfield and Killamarsh, should inform the spatial strategy.” (Savills emphasis)

WBD agrees with the above comments and considers that it is appropriate to ensure that housing and economic
growth are aligned. In light of North East Derbyshire’s relatively small settlements which sit in close proximity
to larger settlements outside of the borough such as Chesterfield, Sheffield and Bolsover, we also consider that
proximity to these labour forces should be taken into account when determining the most appropriate location
for strategic I&L growth in the region. Following the success of relatively recent developments at Markham Vale and Horizon 29, we consider that it is appropriate to situate such development around J29A of the M1 motorway at land south of Markham Vale.

Strategic Approach to the Location of Development
WBD objects to the Strategic Approach to the Location of Development set out in the consultation document.
Large and strategic-scale I&L schemes have a specific locational requirement to be located on key junctions
of the Strategic Road Network (‘SRN’), and should therefore be assessed separately to the four priority
locations set out in Figure 7 of the consultation document, which are more relevant to housing growth than to
strategic I&L.

It is important for strategic I&L development to be located in close proximity to the SRN for a number of reasons,
not least to provide easy access to the SRN for HGV vehicles which consequently keeps vehicle emissions
and amenity impacts on residential areas to a minimum. Locating I&L development near to strategic road
networks is also the most efficient way to ensure that wider supply chains can serve / be served by I&L sites.
This is significantly different from that of residential development, which naturally needs to be located close to
key services and facilities such as schools, GP surgeries and supermarkets. The same cannot be said for I&L
uses and therefore, we consider that a different methodology should be utilised for this type of development.

It is noted that the Council’s Settlement Role and Function Study (March 2026) considers the sustainability of
existing settlements within the District, providing information about the level of services and facilities each
settlement currently provides. This information has directly influenced the proposed settlement hierarchy within
the Local Plan consultation document, which has culminated in a hierarchy ranging from ‘Level 1’ (i.e.
largest/most sustainable) settlements down to ‘Level 4’ settlements. The Local Plan consultation proposes to
distribute development using a cascade approach, with Level 1 settlements prioritised for the most development
and Level 4 settlements accommodating significantly less development. Whilst WBD recognises that this study
enables the Council to build a picture as to which settlements are the most sustainable places to locate
residential development, this is not necessarily the case for strategic-scale I&L development, which benefits
from being located on key SRN junctions. These do not always correlate with the largest settlements with the
most services and facilities, and it is not necessarily the case that I&L development needs to be located close
to these facilities to be sustainable, for example in the case of schools. Therefore, an alternative spatial strategy
should be developed for employment uses, to provide a specific focus on the key SRN locations for the
allocation of I&L sites.

Paragraph 10.47 of the Bolsover, Chesterfield and North East Derbyshire Economic Needs Assessment Study
(‘ENA’) (Lichfields, March 2025) sets out nine SRN junctions which are considered to represent “areas of
opportunity” for strategic I&L development (Use Class B2 / B8). Paragraph 10.44 of the ENA explains the
reasoning behind this, stating that “the analysis involved identifying existing clusters of logistics parks across
the study area, and then defined broad areas of search, based primarily on proximity to the strategic road
network, which is generally one of the core motivations behind land searches for road-based logistics
operators”.

Of the 9 opportunity junctions, 3 fall within the North East Derbyshire LPA area, as identified by red circles on
the map below:
Figure 1: Plan showing the three “areas of opportunity” (circled red) within North East Derbyshire District (Bold black line)
See attachment

Savills has prepared an Alternative Sites Note, which is provided as Appendix 7 to these representations. This
note sets out a review of potential alternative locations to meet the strategic need identified in the ENA, both in
North East Derbyshire District and also in neighbouring Chesterfield / Bolsover. This review concludes that land
south of Markham Vale represents the only available and suitable site. Whilst the identified strategic
employment need is a sub-regional one, we consider that the Council should take a positive and proactive
approach to plan-making and act now to allocate land to contribute towards this significant economic need.
This would represent positive plan-making and would assist the emerging Local Plan in meeting the tests of
soundness, as set out at paragraph 36 of the NPPF, as well as attracting significant inward investment and
growth for this strategically important part of the district.

NPPF paragraph 87 further emphasises the need for planning policies to take account of specific locational
requirements of different sectors, including making provision for “storage and distribution operations at a variety of scales and in suitably accessible locations that allow for the efficient and reliable handling of goods,
especially where this is needed to support the supply chain, transport innovation and decarbonisation” (Savills
emphasis).

Paragraphs 3.24 – 3.29 of the Settlement Role and Function Study also set out how the number of local
employment opportunities within/adjacent to each settlement has been taken into account in assessing the
sustainability of the District’s existing settlements. Applying this approach when assessing the sustainability of settlements to accommodate residential development is considered to be an acceptable approach. However,
we object to the use of this methodology to assess the sustainability (and consequent settlement hierarchy) as
it relates to the provision of new employment development. Using this methodology will result in new
employment development being focused on market facing areas which already have significant levels of jobs,
which is backward-looking and ignores the current locational requirements of specific employment sectors such as strategic-scale I&L.

WBD considers that it would be unsound to apply the current proposed strategy to site allocations for
employment uses, as this would not take into account the relevant evidence as set out in the ENA and would
not fulfil the requirements of paragraph 87 of the NPPF. We consider that it would be more appropriate to
prepare a separate strategic approach and spatial strategy Local Plan policies for employment development
given its fundamental differences to residential development, particularly at the strategic scale, and to recognise that the identified settlement hierarchy is not relevant to employment development.

It should be recognised that a consultation on a revised draft NPPF has recently concluded (10 March 2026).
Whilst the final revised NPPF has yet to be published, the consultation draft provides an indication of the
direction of travel of national planning policy going forward. Draft Policy S5 (‘Principle of development outside
settlements’) provides details of a clear presumption in favour of sustainable development outside of
settlements at paragraph 1. Paragraph 1(j)(ii) confirms that this includes proposals comprising major
development for storage and distribution purposes, where the development would address an evidenced unmet
need. It is therefore considered that national planning policy is likely to be amended significantly to encourage
additional logistics development outside of settlements, and we therefore consider that the Council should seek
to plan positively for this type of development, which has distinctly different locational requirements when
compared with residential development.

Comments on the Refined Schedule of Sites
The consultation document also includes a Refined Schedule of Sites which are being consulted on for potential allocation. This includes sites which have passed the initial site assessment undertaken by the Council.
WBD welcomes the inclusion of text within the consultation document stating that “further evidence that may
be forthcoming from the site promoter and responses to this consultation will inform the Preferred List of Sites
that will be included in the Publication Draft Local Plan”. We consider that this represents a positive approach
to plan-making, which should be evidence-led to ensure that the most appropriate sites are selected. With this in mind, WBD has prepared a suite of technical work to respond to the initial comments on the Site which are
included in the consultation document. A summary of this work is included in Table 1 below:

Table 1: WBD response to NEDDC comments on land south of Markham Vale (ref: 45041)
See attachment

In summary, it is considered that the potential technical constraints highlighted in the consultation document
can be addressed through suitable mitigation which would come forward at the planning application stage.
Therefore, the Site is suitable for allocation in the Local Plan.

Sustainability Appraisal: Regulation 18 Addendum to the Issues and Options SA (March 2026)
It is noted that an addendum to the Issues and Options Sustainability Appraisal (‘SA’) Scoping Report has been
published to support this consultation. The SA Addendum assesses a total of 351 reasonable alternative sites
which NEDDC has put forward for consideration. This includes 272 sites for residential uses, 4 sites for strategic
mixed-use development, 54 employment sites and 21 gypsy and traveller sites.

The Site has been assessed as site reference 45041 (Land south of Markham Vale, Long Duckmanton). We
have provided a detailed review and response to any areas of the SA where the Site has scored negatively and
this is set out at Appendix 2 of these representations. In summary, it is considered that with appropriate
mitigation and amendments to the red line boundary for the Site, there are no reasons why the Site should not
score favourably in the SA and be considered for allocation in the upcoming Regulation 19 plan. We request
that any further iteration of the SA takes account of the revised red line boundary for Site 45041,
alongside the technical work provided as part of this submission.

Summary and Conclusions
In summary, WBD considers that land south of Markham Vale represents a unique opportunity to deliver largescale
I&L development within the NEDDC area: an opportunity which none of the other promoted sites are able
to accommodate. The Site should therefore be allocated for Strategic I&L development to contribute towards
the clearly identified need set out in the ENA. As set out in the accompanying Economic Benefits Infographic
(Appendix 6), the development of the Site is estimated to generate £39 million annual economic output and
971 full-time equivalent jobs, with c.£1.2 million in business rates paid per annum. This is in addition to the
significant (c.£65 million) estimated construction investment during the build programme, with £67 million GVA and 102 on-site jobs supported during the construction period.

I trust these representations are useful and look forward to receiving confirmation of safe receipt. We would
welcome the opportunity for continued positive dialogue with officers.

Savills (UK) Ltd is instructed by Wilson Bowden Developments (‘WBD’) to promote land south of Markham
Vale, Long Duckmanton (Site ID: 45041) (‘the Site’) for strategic industrial and logistics (‘I&L’) development.

Introduction and Scope
The Site has been identified in the consultation as one of various sites being consulted on as part of a ‘Refined
Schedule of Sites’ which have passed the site assessment process. These representations provide a detailed
response to the Council’s strategic approach to the location of development, along with a response to the
assessment of the Site within both the consultation document, the Employment Land Availability Assessment
(‘ELAA’) (2026) and the Sustainability Appraisal Addendum (March 2026).

In short, WBD considers that the Site is available and suitable for strategic-scale I&L development, and that
the constraints identified in the ELAA can be suitably mitigated at the planning application stage. As set out in
the below representations, the Site is considered to represent the only promoted land within the District which
can contribute towards meeting the wider sub-regional strategic I&L need, and therefore we consider that the
Site should be allocated in the Regulation 19 Local Plan.

This submission is accompanied by the following supporting documents:
• Appendix 1: Parameter Plan (ref: 17-060 MP09-002);
• Appendix 2: Markham Vale Sustainability Appraisal Scoring Review;
• Appendix 3: Heritage Statement (Pegasus Group, February 2026);
• Appendix 4: Landscape and Visual Site Appraisal (Pegasus Group, February 2026);
• Appendix 5: Landscape Strategy Plan and Sections (Pegasus Group, March 2026);
• Appendix 6: Economic Benefits Infographic (Pegasus Group, March 2026);
• Appendix 7: Alternative Sites Note (Savills, March 2026);
• Appendix 8: Preliminary Transport Assessment (BSP, February 2026);
• Appendix 9: Phase I Geo-Environmental Assessment (BWB, May 2019); and
• Appendix 10: Preliminary Flood Risk Assessment and Drainage Strategy report (April 2026).

The Opportunity at Land South of Markham Vale
Land south of Markham Vale comprises 35.5 hectares (87.8 acres) of agricultural land located directly to the
east of the M1 motorway and south of the A632 Chesterfield Road. The red line for the purposes of the site
promotion is provided at Appendix 1 of these representations. It should be noted that this red line area has been amended following our previous submission to the Local Plan in 2025. The original submission red line
included a wider land ownership parcel which aligned with the title for the land. However, following further
consideration of masterplanning options for the Site, the red line has been reduced to include only the land
which WBD is feasibly able to develop, and therefore promote.

The Site is located to the south of the existing Markham Vale employment area and the former Coalite mixed
use development site which is currently being developed as ‘Horizon 29’. Both Markham Vale and Horizon 29
provide I&L development (Use Class B2/B8). Land south of Markham Vale would provide a new strategic scale
I&L opportunity which would form a logical extension of Horizon 29 and would be attractive to inward investors,
as well as providing good supply chain opportunities for nearby businesses. It is envisaged that the Site could
provide c.700,000 sqft (c.65,000 sqm) of I&L floorspace across a number of units, as shown indicatively on the
submitted parameter plan (Appendix 1).

The Site is in single ownership and is relatively free of constraints. We also understand that, importantly, there
is available electricity capacity to serve the development. The Site therefore represents a deliverable and
achievable option for meeting the strategic employment needs of the FEMA, and can be developed within 3-5
years. As part of this submission an Economic Benefits Infographic (Appendix 6) has been provided to set out
how the development of the Site could boost the local and sub-regional economy.

National planning policy is supportive of planning policies helping to create the conditions in which businesses
can invest, expand and adapt, stating that significant weight should be placed on the need to support economic
growth and productivity, taking into account both local business needs and wider opportunities for development.
Additionally, the December 2025 consultation draft NPPF, which provides a clear indication of the direction of
travel of national policy, includes a proposed presumption in favour of I&L development where a need can be
evidenced. This is set out in detail at Policy S5 (1)(j)(ii) of the draft NPPF. Therefore, we consider that national
planning policy provides a clear basis for land south of Markham Vale to come forward and that this could
attract both local, regional and potentially foreign investment in the District.

Response to Regulation 18 Issues and Options Representations
We note that our representations to the 2025 Issues and Options consultation are recorded as representation
ref: PE146. Having reviewed the Consultation Statement issued in March 2026, we note that Appendix 2.4
(Focus Group Findings) states at paragraph 3.4 that “councillors emphasised that housing growth must be
aligned with employment opportunities. They stressed the need to consider where people actually work—
whether that is Sheffield, Chesterfield, or locations with strong motorway links—to ensure new communities
are well-connected and sustainable. They noted that an understanding of commuting patterns, including routes
through places like Dronfield and Killamarsh, should inform the spatial strategy.” (Savills emphasis)

WBD agrees with the above comments and considers that it is appropriate to ensure that housing and economic
growth are aligned. In light of North East Derbyshire’s relatively small settlements which sit in close proximity
to larger settlements outside of the borough such as Chesterfield, Sheffield and Bolsover, we also consider that
proximity to these labour forces should be taken into account when determining the most appropriate location
for strategic I&L growth in the region. Following the success of relatively recent developments at Markham Vale and Horizon 29, we consider that it is appropriate to situate such development around J29A of the M1 motorway at land south of Markham Vale.

Strategic Approach to the Location of Development
WBD objects to the Strategic Approach to the Location of Development set out in the consultation document.
Large and strategic-scale I&L schemes have a specific locational requirement to be located on key junctions
of the Strategic Road Network (‘SRN’), and should therefore be assessed separately to the four priority
locations set out in Figure 7 of the consultation document, which are more relevant to housing growth than to
strategic I&L.

It is important for strategic I&L development to be located in close proximity to the SRN for a number of reasons,
not least to provide easy access to the SRN for HGV vehicles which consequently keeps vehicle emissions
and amenity impacts on residential areas to a minimum. Locating I&L development near to strategic road
networks is also the most efficient way to ensure that wider supply chains can serve / be served by I&L sites.
This is significantly different from that of residential development, which naturally needs to be located close to
key services and facilities such as schools, GP surgeries and supermarkets. The same cannot be said for I&L
uses and therefore, we consider that a different methodology should be utilised for this type of development.

It is noted that the Council’s Settlement Role and Function Study (March 2026) considers the sustainability of
existing settlements within the District, providing information about the level of services and facilities each
settlement currently provides. This information has directly influenced the proposed settlement hierarchy within
the Local Plan consultation document, which has culminated in a hierarchy ranging from ‘Level 1’ (i.e.
largest/most sustainable) settlements down to ‘Level 4’ settlements. The Local Plan consultation proposes to
distribute development using a cascade approach, with Level 1 settlements prioritised for the most development
and Level 4 settlements accommodating significantly less development. Whilst WBD recognises that this study
enables the Council to build a picture as to which settlements are the most sustainable places to locate
residential development, this is not necessarily the case for strategic-scale I&L development, which benefits
from being located on key SRN junctions. These do not always correlate with the largest settlements with the
most services and facilities, and it is not necessarily the case that I&L development needs to be located close
to these facilities to be sustainable, for example in the case of schools. Therefore, an alternative spatial strategy
should be developed for employment uses, to provide a specific focus on the key SRN locations for the
allocation of I&L sites.

Paragraph 10.47 of the Bolsover, Chesterfield and North East Derbyshire Economic Needs Assessment Study
(‘ENA’) (Lichfields, March 2025) sets out nine SRN junctions which are considered to represent “areas of
opportunity” for strategic I&L development (Use Class B2 / B8). Paragraph 10.44 of the ENA explains the
reasoning behind this, stating that “the analysis involved identifying existing clusters of logistics parks across
the study area, and then defined broad areas of search, based primarily on proximity to the strategic road
network, which is generally one of the core motivations behind land searches for road-based logistics
operators”.

Of the 9 opportunity junctions, 3 fall within the North East Derbyshire LPA area, as identified by red circles on
the map below:
Figure 1: Plan showing the three “areas of opportunity” (circled red) within North East Derbyshire District (Bold black line)
See attachment

Savills has prepared an Alternative Sites Note, which is provided as Appendix 7 to these representations. This
note sets out a review of potential alternative locations to meet the strategic need identified in the ENA, both in
North East Derbyshire District and also in neighbouring Chesterfield / Bolsover. This review concludes that land
south of Markham Vale represents the only available and suitable site. Whilst the identified strategic
employment need is a sub-regional one, we consider that the Council should take a positive and proactive
approach to plan-making and act now to allocate land to contribute towards this significant economic need.
This would represent positive plan-making and would assist the emerging Local Plan in meeting the tests of
soundness, as set out at paragraph 36 of the NPPF, as well as attracting significant inward investment and
growth for this strategically important part of the district.

NPPF paragraph 87 further emphasises the need for planning policies to take account of specific locational
requirements of different sectors, including making provision for “storage and distribution operations at a variety of scales and in suitably accessible locations that allow for the efficient and reliable handling of goods,
especially where this is needed to support the supply chain, transport innovation and decarbonisation” (Savills
emphasis).

Paragraphs 3.24 – 3.29 of the Settlement Role and Function Study also set out how the number of local
employment opportunities within/adjacent to each settlement has been taken into account in assessing the
sustainability of the District’s existing settlements. Applying this approach when assessing the sustainability of settlements to accommodate residential development is considered to be an acceptable approach. However,
we object to the use of this methodology to assess the sustainability (and consequent settlement hierarchy) as
it relates to the provision of new employment development. Using this methodology will result in new
employment development being focused on market facing areas which already have significant levels of jobs,
which is backward-looking and ignores the current locational requirements of specific employment sectors such as strategic-scale I&L.

WBD considers that it would be unsound to apply the current proposed strategy to site allocations for
employment uses, as this would not take into account the relevant evidence as set out in the ENA and would
not fulfil the requirements of paragraph 87 of the NPPF. We consider that it would be more appropriate to
prepare a separate strategic approach and spatial strategy Local Plan policies for employment development
given its fundamental differences to residential development, particularly at the strategic scale, and to recognise that the identified settlement hierarchy is not relevant to employment development.

It should be recognised that a consultation on a revised draft NPPF has recently concluded (10 March 2026).
Whilst the final revised NPPF has yet to be published, the consultation draft provides an indication of the
direction of travel of national planning policy going forward. Draft Policy S5 (‘Principle of development outside
settlements’) provides details of a clear presumption in favour of sustainable development outside of
settlements at paragraph 1. Paragraph 1(j)(ii) confirms that this includes proposals comprising major
development for storage and distribution purposes, where the development would address an evidenced unmet
need. It is therefore considered that national planning policy is likely to be amended significantly to encourage
additional logistics development outside of settlements, and we therefore consider that the Council should seek
to plan positively for this type of development, which has distinctly different locational requirements when
compared with residential development.

Comments on the Refined Schedule of Sites
The consultation document also includes a Refined Schedule of Sites which are being consulted on for potential allocation. This includes sites which have passed the initial site assessment undertaken by the Council.
WBD welcomes the inclusion of text within the consultation document stating that “further evidence that may
be forthcoming from the site promoter and responses to this consultation will inform the Preferred List of Sites
that will be included in the Publication Draft Local Plan”. We consider that this represents a positive approach
to plan-making, which should be evidence-led to ensure that the most appropriate sites are selected. With this in mind, WBD has prepared a suite of technical work to respond to the initial comments on the Site which are
included in the consultation document. A summary of this work is included in Table 1 below:

Table 1: WBD response to NEDDC comments on land south of Markham Vale (ref: 45041)
See attachment

In summary, it is considered that the potential technical constraints highlighted in the consultation document
can be addressed through suitable mitigation which would come forward at the planning application stage.
Therefore, the Site is suitable for allocation in the Local Plan.

Sustainability Appraisal: Regulation 18 Addendum to the Issues and Options SA (March 2026)
It is noted that an addendum to the Issues and Options Sustainability Appraisal (‘SA’) Scoping Report has been
published to support this consultation. The SA Addendum assesses a total of 351 reasonable alternative sites
which NEDDC has put forward for consideration. This includes 272 sites for residential uses, 4 sites for strategic
mixed-use development, 54 employment sites and 21 gypsy and traveller sites.

The Site has been assessed as site reference 45041 (Land south of Markham Vale, Long Duckmanton). We
have provided a detailed review and response to any areas of the SA where the Site has scored negatively and
this is set out at Appendix 2 of these representations. In summary, it is considered that with appropriate
mitigation and amendments to the red line boundary for the Site, there are no reasons why the Site should not
score favourably in the SA and be considered for allocation in the upcoming Regulation 19 plan. We request
that any further iteration of the SA takes account of the revised red line boundary for Site 45041,
alongside the technical work provided as part of this submission.

Summary and Conclusions
In summary, WBD considers that land south of Markham Vale represents a unique opportunity to deliver largescale
I&L development within the NEDDC area: an opportunity which none of the other promoted sites are able
to accommodate. The Site should therefore be allocated for Strategic I&L development to contribute towards
the clearly identified need set out in the ENA. As set out in the accompanying Economic Benefits Infographic
(Appendix 6), the development of the Site is estimated to generate £39 million annual economic output and
971 full-time equivalent jobs, with c.£1.2 million in business rates paid per annum. This is in addition to the
significant (c.£65 million) estimated construction investment during the build programme, with £67 million GVA and 102 on-site jobs supported during the construction period.

I trust these representations are useful and look forward to receiving confirmation of safe receipt. We would
welcome the opportunity for continued positive dialogue with officers.