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

We strongly support the LPA’s proposed approach to location of development, particularly the identification of “Edges of Chesterfield / Sheffield” as Priority 1 locations. This reflects the functional geography of the district, where both Chesterfield and Sheffield act as the principle economic, social and transport centres for a significant proportion of residents within North East Derbyshire.

Site 45190 (land west of Harehill Road) is located directly on the edge of Chesterfield and therefore falls within the highest-priority location for development, alongside strategic sites and the districts main towns.

We consider this designation entirely appropriate given the Site’s close proximity to Chesterfield’s services, infrastructure and public transport corridors, and allocation of this Site would be consistent with the principles of sustainable development, as outline in Paragraph 8 of the Framework, as it represents a logical and contained extension to the existing built-up area, capable of supporting planned growth in a sustainable manner.

We welcome the retention of a four-tier settlement hierarchy, which combined with the priority levels for growth, provides a robust framework for directing development.

The LPA acknowledges that a settlement’s position in the hierarchy indicates its theoretical potential to accommodate development and does not take account of land availability, land suitability, or other policy considerations such as Green Belt.

We welcome the update to the Settlement Hierarchy to support the LPA’s objective of ensuring that the new Local Plan is informed by an accurate understanding of settlement roles. We note that the hierarchy is intended to provide a strategic framework rather than an allocation tool and therefore must be read alongside site-specific evidence.

In this context, significant weight should be given to sites located on the edge of Chesterfield and Sheffield, where they exhibit clear spatial and functional relationships, are demonstrably deliverable, and will help reduce reliance on more dispersed patters of growth in smaller settlements. These characteristics apply to the Site at land west of Harehill Road.

We welcome the LPA’s publication of an updated Sustainability Appraisal [“SA”] which assesses the reasonable alternative sites for potential allocation in the Local Plan.

Site 45190, land west of Harehill Road, is identified as a reasonable alternative residential site, having passed the Council’s initial sieving process and been subject to full appraisal against the 13 Sustainability Appraisal Objectives.

We acknowledge the Council’s confirmation that the SA findings are based on a pre-mitigation assessment and that no site-specific design, mitigation, or policy measures have been applied at this stage.

Whilst the Site is directly adjacent to the built-up area of Chesterfield, the SA records minor negative effects in relation to ‘sustainable communities’ and ‘transport’. This is understood to arise from the methodology that applies district-wide distance thresholds, and the strategic, pre-mitigation nature of the SA assessment.

As with other Green Belt sites, the SA has a degree of uncertainty due to the absence of an updated Green Belt Review forming part of the evidence base at this stage.

It is considered that the Green Belt Review needs to be published before any allocations are confirmed, in order to ensure that decisions are based on a complete and robust evidence base. In the meantime, we reserve the right to comment further at Regulation 19 stage upon receipt of the updated evidence.

We note that the SA emphasises that pre-mitigation negative effects should not be treated as determinative. In this context and given the Site’s edge-of-settlement location and strong relationship with Chesterfield, the recorded minor adverse effects are considered to be reflective of the strategic methodology applied rather than any inherent constraint of the Site.

We would therefore welcome the preparation of an updated SA Addendum, taking into account further information being prepared in support of the allocation of Site 45190.

Site 45190 forms part of the refined list of potential housing allocations and has therefore been screened within the HRA alongside all other Sites.

The HRA confirms that the Site is not located within 400m of any European Site, and there is no direct land take, loss of habitat, or physical encroachment affecting any SAC or SPA. Overall, the HRA does not identify any site specific constraints associated with Site 45190 that would make it less suitable than other reasonable alternative sites at this stage of the process.

Having reviewed shortlisted edge of settlement sites, and in particular edge of Chesterfield sites, clear distinctions can be drawn between the shortlisted Sites, in terms of their suitability and deliverability.

The Site (ref. 45190), when compared with other options, directly adjoins the built-up area of Chesterfield and, when considered in the context of the surrounding development, represents a logical and coherent extension to the existing residential area.

In the context of edge-of-Chesterfield sites, the Site would deliver a valuable and proportionate contribution to meeting identified housing needs without giving rise to significant adverse impacts. Furthermore, given its separation from other potential allocation sites, it is unlikely to result in harmful cumulative effects.

Sites 45042 and 45043, which are also located on the edge of Chesterfield, would each make only a modest contribution to housing supply, with an estimated capacity of 10 dwellings per site. Whilst such sites may have a role to play, particularly given that the edge of Chesterfield is identified as a priority 1 location, it is important that sites capable of delivering more meaningful contributions to housing supply are given appropriate weight in the site selection process.

It is noted that site 45065, also located on the edge of Chesterfield, has the potential to deliver approximately 800 dwellings. We would note that sites of this scale are typically more complex to bring forward and are unlikely to contribute to housing delivery in the early years of the plan period due to the need for masterplans and design codes, infrastructure provision, phasing and the need to consider potential cumulative impacts. As such, reliance on larger strategic sites alone is unlikely to ensure consistent and deliverable supply of housing in the short term.

It is therefore concluded that Site 45190 represents the most appropriate edge of Chesterfield option, due to its strong relationship with the adjacent built-up area, the appropriate and deliverable scale of development proposed, and its clear potential to come forward in the short term. The Site is well placed to contribute to housing delivery in the early part of the plan period.

The LPA’s assessment of the Site indicates that the Site may be able to support approximately 210 dwellings, based on prevailing neighbouring densities, and a 20% density uplift for towns and cities. However, mitigation measures have not yet been applied to Site capacity.

We would note that the landowner has instructed additional ecology, flood risk and drainage assessments on the Site, and we are currently preparing an Indicative Layout which will take into account any required mitigation as a result of these initial assessments. This will give the LPA a more evidence-based assessment to indicate the appropriate capacity on this Site. This information will be submitted to the Local Plan team before the deadline of 1st June 2026.

In terms of the Site’s Green Belt designation, the LPA acknowledge that the 2016/17 Green Belt review performed weakly against Green Belt purposes a), b) and d).

We expect the outcome of the 2026 Green Belt Review to reach a similar conclusion and when considering the Site against the updated Planning Practice Guidance (February 2025) relating to assessing Green Belt and grey belt sites, we would make the following observations.

Purpose a is to check the unrestricted sprawl of large built-up areas. This purpose was considered as part of the 2017 Green Belt Review and the Site was confirmed to be contained by existing development on 3 sides: to the north, east and south. Each of these boundaries represent strong and defensible boundaries. While the Site is not bound by existing development to the west, a dense and continuous line of mature trees provide a strong and robust boundary to the west, which would assist in screening any future residential development on the Site. Consequently, development on this Site would result in an amended Green Belt boundary that is neither stronger nor weaker than the existing.

Purpose b is to prevent neighbouring towns merging into one another. As the 2017 Green Belt Review acknowledged, the closest neighbouring town to the site is Wingerworth, approximately 1km to the south. It is not considered that development of this Site would bring development any closer to the neighbouring settlement than the existing residential area to the south.

Purpose d is in place to preserve the setting and special character of historic towns. The Site is not located near any heritage assets or within a conservation area, therefore Green Belt purpose d is not considered relevant to this Site.

After considering the above criteria, the PPG states that any assessment area which is not judged to strongly contribute to any one of purposes a, b, or d can be identified as grey belt land, subject to the exclusion of land where the application of the policies relating to the areas or assets in footnote 7 to the NPPF (other than Green Belt) would provide a strong reason for refusing or restricting development. None of the footnote 7 policies apply to this Site.

When considering the impact on the remaining Green Belt in the plan area, the PPG states that a Green Belt assessment should also consider the extent to which release or development of Green Belt land (including but not limited to grey belt land) would fundamentally undermine the purposes (taken together) of the remaining Green Belt across the plan area as whole.

It is considered that the remaining Green Belt land across the District; which is a significant swathe in this location, would continue to fulfil its purposes and would not be compromised by the development of this Site as grey belt land. The Site is also contained by built form already on three sides, and the land to the west is used as a golf course by the landowner (Chesterfield Golf Club) who are committed to continuing this use and plan to invest any funds released from the development of the land back into the Golf Club to protect its future use. This is critical to the future of the Golf Club which is in severe need of renovation and will secure its viable use for years to come

It is therefore considered that the Site meets this appropriateness test.

The second appropriateness tests asks whether the development in the grey belt would be in a sustainable location. The Site is located on the edge of Chesterfield, which is a sustainable location with numerous facilities and amenities, including good public transport links. It is therefore considered that the Site meets this appropriateness test for development in the grey belt.

Overall, it is considered that the Representation Site makes little contribution to Green Belt purposes a), b) and d) and does not raise issues in relation to footnote 7 constraints. When assessed against the updated PPG guidance, the Site meets the criteria for identification as grey belt land and represents an appropriate location for release. Importantly, the release of this parcel would not undermine the overall integrity of the remaining Green Belt

We acknowledge that the Site is located within a Coal Authority high risk area. Any future planning application would be accompanied by a Coal Mining Risk Assessment and Site Investigation. The findings of these reports would of inform the layout of residential development.

For the reasons set out throughout this Representation, the Site is confirmed to be available, suitable and deliverable for residential development. The Site is situated on the western edge of Chesterfield, is strongly related to the existing built form, and benefits from a sustainable location with access to a range of services, facilities and public transport links.

Whilst designated as Green Belt, the Site makes a limited contribution to the purposes of the Green Belt, and when considered against updated PPG guidance, could fall under the definition of grey belt land. In addition, there are no insurmountable technical constraints which would prevent development.

As stated above, additional technical assessment is currently underway, alongside the preparation of an Indicative Masterplan. This work will refine understanding of site constraints and opportunities and will inform an appropriate development capacity and layout for the Site. The outputs of this work will be submitted to the Local Plan team prior to the relevant deadline in June 2026 and will assist in further demonstrating the Site’s suitability and deliverability.