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This representation provides Gladman Development Ltd.’s (Gladman) response to the North East
Derbyshire Local Plan Issues and Options Consultation on the Strategic Approach to the Location of
Development and Refined Sites (March 2026).
Gladman responded to North East Derbyshire District Council (the Council) Local Plan Issues and
Options Consultation which took place in Summer 2025. Information contained within our previous
representation is not repeated here except in cases where it’s required for context.
Development Needs and the Spatial Strategy
It is confirmed in the Development Needs section that the Council is meeting its Local Housing Needs
(LHN) in full by planning for a housing requirement of 12,000 dwellings over the plan period of 2024-
2044. Gladman welcome the Council confirming that it’s the Councils intention to accommodate its
housing need requirement in full. The PPG is clear, however, that the standard method identifies a
minimum annual housing need figure, and that local planning authorities can plan for growth above
this minimum where justified.
Gladman consider it important for the Council to be mindful of the delivery risks associated with
relying heavily on a small number of large Sustainable Urban Extensions (SUE), namely Duckmanton
Moor Village, Duckmanton Moor Extension and Eckington South. While such strategic sites are
capable of making a significant contribution to housing supply, they are often complex to deliver and
can be susceptible to delays due to infrastructure provision, lead‑in times, land ownership and
phasing.
The emerging Local Plan is aligned to meeting the LHN, leaving limited flexibility should delivery not
come forward as anticipated from any of these large allocations. In that context, the
over‑concentration of growth on a limited number of SUEs increases the risk of under delivery across
the plan period.
To ensure a robust and resilient spatial strategy, Gladman encourage the Council to consider planning
positively beyond the LHN figure, in line with national policy and guidance. This could include
incorporating an appropriate buffer such as a 10% uplift to the housing requirement. Such an
approach would provide greater flexibility, improve choice and competition in the land market, and
help ensure delivery is maintained should one or more strategic sites not deliver as expected. This
flexibility is also particularly important in the context of ongoing cross‑boundary matters
Effective Cooperation and Potential Unmet Needs from Neighbouring Authorities
Gladman consider that the emerging spatial strategy should retain sufficient flexibility to respond to
potential unmet development needs arising from neighbouring authorities, including Sheffield City
Council and Chesterfield Borough Council. While the Government has removed formal Duty to
Cooperate under the new plan‑making system, the requirement for effective cooperation remains
firmly embedded in national policy.
Paragraphs 24–28 of the National Planning Policy Framework (NPPF) continue to emphasise that local
planning authorities should maintain effective cooperation throughout the plan‑making process, and
that joint working is integral to producing a plan that is positively prepared and underpinned by a
justified strategy for supporting growth and meeting identified development needs. The NPPF makes
clear that such cooperation should assist in identifying strategic priorities, including the provision of
infrastructure, and in considering whether development needs that cannot be met wholly within one
plan area could be accommodated elsewhere.
Given the constrained nature of some adjoining authorities, there remains the potential for unmet
housing needs to arise over the plan period. At the time of writing, there is no confirmation that the
Council has agreed to accommodate unmet needs from neighbouring authorities. However, it is
important that the Local Plan is sufficiently flexible to respond to such matters should they arise as
discussions progress.
In this context, Gladman reiterate that planning only to meet the minimum LHN leaves limited scope
to respond to any future requests for assistance from neighbouring authorities without triggering an
early plan review. The inclusion of an additional buffer within the housing requirement would provide
valuable headroom, enabling the Council to engage constructively in cross‑boundary discussions and
support sustainable growth where appropriate, in accordance with national policy. Such an approach
would help ensure the Local Plan remains resilient, adaptable, and capable of addressing strategic
housing matters over its full plan period.
Green Belt Review and the Identification of Grey Belt Land
Gladman welcome the Council’s decision to undertake a new Green Belt Review to inform the
emerging Local Plan. This is an important piece of evidence which will assist the Council in fully
understanding the role and function of Green Belt land within the district and in identifying
opportunities to meet development needs in a sustainable manner.
In particular, the assessment and identification of land which may appropriately be categorised as
“grey belt” has the potential to play a meaningful role in meeting the Council’s LHN in full. The
outcomes of the Green Belt Review will therefore have direct implications for the Council’s ability to
deliver its housing strategy and maintain flexibility over the plan period.
At this stage, it remains unclear how the findings of the Green Belt Review and the identification of
potential grey belt sites will translate into the overall housing requirement and spatial distribution of
growth. However, given the reliance on large strategic sites, Gladman consider it essential that the
Council allows the results of the Review to meaningfully influence the scale and spread of allocations,
where this would contribute to a more resilient and deliverable strategy.
In this context, the incorporation of an additional buffer above the minimum LHN would provide the
Council with greater scope to respond positively to the findings of the Green Belt Review, bring
forward suitable grey belt sites where appropriate, and ensure that housing needs can be met in full.
Such an approach would support a flexible, plan‑led release of land and help avoid the need for early
review of the Local Plan.
Summary
Gladman support the Council’s commitment to meeting its LHN in full and welcome the progress being
made through the emerging Local Plan. However, the current approach is closely aligned to the
minimum housing need figure and relies heavily on a limited number of large strategic allocations,
which introduces delivery risk and limits flexibility over the plan period.
To ensure a robust and resilient spatial strategy, Gladman encourage the Council to plan positively
beyond the minimum LHN by incorporating an appropriate buffer within the overall housing
requirement. This would provide greater flexibility to respond to delivery delays, potential unmet
housing needs from neighbouring authorities, and the outcomes of the Council’s ongoing Green Belt
Review, including the identification of suitable grey belt sites.
Embedding flexibility at this Regulation 18 stage will help safeguard housing delivery, support effective
cross‑boundary engagement, and ensure the Local Plan remains adaptable and capable of meeting
identified development needs in full over the period to 2044.
