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

Site 45635, Land off Rotherham Road, Killamarsh, should be retained as a housing allocation in the emerging Local Plan.

The Site is already allocated for housing in the adopted 2014–2034 Local Plan. Its continued allocation would therefore represent a logical and justified continuation of the current development strategy for Killamarsh.

The Site remains available and deliverable. A housebuilder is actively progressing proposals for residential development and pre-application discussions with the Council are already underway. The emerging scheme is therefore being actively advanced towards a planning application, with design and layout matters being considered through the pre-application process. This demonstrates a clear prospect of delivery within the plan period.

The Site is located at Killamarsh, which is identified as a Level 1 Settlement / Main Town in the proposed Settlement Hierarchy. Residential development on the Site would therefore align with the proposed spatial approach, which seeks to focus growth in the District’s most sustainable settlements with good access to services, facilities, employment and public transport.

The constraints identified in the site commentary are capable of mitigation. Highway access is being actively considered through the pre-application process and can be addressed through detailed design. Surface water flood risk can be addressed through a site-specific drainage strategy and SuDS. The Coal Authority Development High Risk Area designation is a common constraint in the locality and can be addressed through a Coal Mining Risk Assessment, ground investigation and appropriate mitigation. The provisional agricultural land classification does not represent a constraint that should prevent retention of an existing housing allocation.

The Site should therefore continue to be identified as a housing allocation in the emerging Local Plan. Any necessary mitigation requirements can be appropriately reflected in site-specific allocation policy wording and addressed through the planning application process.

The proposed approach to the location of development is broadly supported. It is appropriate for the emerging Local Plan to prioritise development in the most sustainable locations, including the edges of Chesterfield and Sheffield, new settlements / strategic sites, and Level 1 Settlements / Main Towns. This reflects the principle that growth should be directed to places with the strongest access to services, facilities, employment opportunities and public transport, or where the necessary infrastructure can be provided.

The use of a cascade approach is also supported in principle. However, the approach should be applied in a way that gives meaningful effect to the Priority 1 locations. In particular, Level 1 Settlements should not be treated as theoretically sustainable locations but then constrained to only limited growth because of existing Green Belt boundaries, if suitable, available and achievable sites are identified and if Green Belt release can be justified through the Local Plan process.

The statement that allocations outside the Green Belt should be maximised before considering Green Belt sites is understood. However, this should not result in an overly sequential approach which defers sustainable Green Belt sites at Priority 1 settlements in favour of less sustainable locations elsewhere. National policy allows Green Belt boundaries to be altered through plan-making where exceptional circumstances are demonstrated, and the current NPPF also requires consideration of grey belt land. The emerging Green Belt Review should therefore be used proactively to identify whether sustainable edge-of-settlement sites can be released without undermining the wider purposes of the Green Belt.

In this context, Site 45905, Land east of Upperthorpe Road, Killamarsh, aligns well with the proposed approach. Killamarsh is a Priority 1 location as a Level 1 Settlement / Main Town. The Site is available, achievable and capable of delivering a meaningful housing contribution as part of a wider coordinated growth opportunity with adjoining land. Its technical constraints are capable of mitigation, and its Green Belt position should be assessed through the emerging Green Belt Review and current grey belt policy context.

The approach should therefore be refined to make clear that sustainable Green Belt sites at Priority 1 locations should not be excluded simply because non-Green Belt options exist elsewhere, particularly where those alternatives may be less sustainable, less deliverable, or less capable of supporting the Local Plan’s spatial strategy.

The proposed Settlement Hierarchy is supported, particularly the identification of Killamarsh as a Level 1 Settlement / Main Town.

The Settlement Role and Function Study and Settlement Hierarchy Topic Paper provide an appropriate basis for identifying the District’s most sustainable settlements. The use of population, services and facilities, employment provision and public transport as assessment criteria is logical and reflects the factors that determine whether a settlement is capable of accommodating sustainable growth.

Killamarsh’s position in the hierarchy is especially important. It scores 10+ for population, 10+ for facilities and services, 10 for employment, and 10+ for public transport, giving it a total score of 40+. It is therefore one of the highest scoring settlements in the District, alongside Dronfield and Clay Cross. This confirms that Killamarsh is one of the most sustainable locations in North East Derbyshire.

The Local Plan should give practical effect to this evidence. If Killamarsh is identified as a Level 1 Settlement / Main Town, then it should be expected to accommodate a meaningful level of growth, subject to site-specific constraints and the outcome of the Green Belt Review. The hierarchy should not be treated merely as a theoretical exercise. It should guide the distribution of housing allocations towards settlements such as Killamarsh where residents can access services, facilities, employment and public transport.

It is acknowledged that the hierarchy does not override land availability, site suitability, Green Belt, Settlement Gaps or other constraints. However, those constraints should be assessed through the Local Plan process, rather than used to suppress growth at the District’s most sustainable settlements by default. In particular, the Green Belt Review should consider whether suitable edge-of-settlement sites at Level 1 settlements can be released, including grey belt land or land capable of forming a defensible long-term boundary.

Site 45905, Land east of Upperthorpe Road, is consistent with the proposed Settlement Hierarchy. It lies at Killamarsh, one of the District’s highest-order settlements. It is available, achievable and capable of delivering approximately 80–100 homes. The Site is supported by site-specific highways and ecology evidence demonstrating that the principal technical constraints are capable of mitigation. It should therefore be assessed positively as a new residential allocation and as part of a wider coordinated growth opportunity together with the neighbouring sites currently being promoted at Killamarsh.

The proposed Settlement Hierarchy is therefore supported, but the next stage of the Local Plan should ensure that the hierarchy is translated into an appropriate distribution of allocations, with meaningful housing growth directed to Level 1 Settlements, including Killamarsh.

Site 45905, Land east of Upperthorpe Road, Killamarsh, should be carried forward as a residential allocation.

The Council’s assessment confirms that the Site is capable of making a meaningful contribution to housing supply at Killamarsh, with an indicative capacity of approximately 110 dwellings before mitigation. We consider that a prudent working capacity of approximately 80–110 homes is appropriate, allowing for access design, green infrastructure, Biodiversity Net Gain, SuDS, Public Rights of Way, landscape treatment and an appropriate settlement edge. This remains a significant and deliverable contribution at one of the District’s most sustainable settlements.

The Site is available, achievable and well-related to the existing settlement edge of Killamarsh. Killamarsh is identified as a Level 1 Settlement / Main Town in the proposed Settlement Hierarchy and scores highly in relation to population, services and facilities, employment and public transport. The principle of directing growth to Killamarsh is therefore consistent with the Council’s proposed spatial approach.

The principal outstanding issue is Green Belt. The Site should be assessed through the new Green Belt Review in accordance with the current NPPF and Planning Practice Guidance, rather than being assessed on the basis of the 2016/17 assessment. That earlier assessment was prepared under a different national policy context and assessed the land by reference to older parcel boundaries. The new review should assess Site 45905 as a coherent site and should also consider its relationship with adjoining land forming part of a wider coordinated Killamarsh growth opportunity.

We consider that the Site has a credible basis for being treated as grey belt. It does not strongly contribute to Green Belt purposes (a), (b) or (d). The Site sits within a wider pocket of land influenced by the existing settlement edge, would not result in unrestricted sprawl beyond the broader physical envelope of development in this part of Killamarsh, would not materially reduce the separation between Killamarsh and Highmoor, and does not contribute to the setting or special character of a historic town.

The technical constraints identified by the Council are capable of mitigation and should not prevent the Site from being carried forward.

In relation to ecology, a Preliminary Ecological Appraisal has now been undertaken. No statutory designated sites are affected, no priority habitats were recorded within the redline boundary, and no direct or indirect impacts on designated sites are anticipated. The PEA identifies standard mitigation and enhancement measures. The PEA does not identify any overriding ecological constraint to allocation.

In relation to highways, a site-specific Highways Site Appraisal has also been prepared. This confirms that safe and suitable access can be achieved from Upperthorpe Road. The forecast vehicle trip generation from the site is modest and capable of being accommodated on the local highway network. The Site is also well-related to existing bus stops and local services, supporting sustainable travel.

Surface water flood risk affects less than 1% of the Site and can be addressed through detailed drainage design and SuDS. Public Rights of Way crossing the Site can be retained and enhanced as part of the green infrastructure and active travel network. The Coal Authority Development High Risk Area designation is acknowledged, but this is a common and manageable constraint in the locality and can be addressed through a Coal Mining Risk Assessment, ground investigation and appropriate mitigation at planning application stage.

The Site should therefore not be excluded on the basis of the constraints identified. Those matters are capable of being addressed through allocation policy wording and detailed planning application requirements.
Site 45905 should be identified as a new residential allocation and as part of a wider coordinated growth opportunity at Killamarsh. We have submitted a detailed representations report submitted alongside this response which provides further evidence in support of the Site’s suitability, availability and achievability.