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

1. SUMMARY

Moss Valley Wildlife Group herby formally objects to the inclusion of Site 45900 (White Lane Farm) on the following grounds:

1. The exceptional and irreplaceable ecological and landscape importance of the Moss
Valley as a cross-border whole.

2. The disproportionately and indefensibly high price in ecological and landscape
damage that inclusion of Site 45900 would wreak.

3. The gross inadequacies of NEDDC’s knowledge and assumptions about Site 45900
in relation to SCC’s wholly unsustainable and undeliverable Site SS19, which would render
the above-stated damage tragically pointless.

4. In these regards, the failure of NEDDC to comply with the aplicable requirements of the following:

a) The 2024 "National Planning Policy Framework"
b) The 2026 "Land Use Framework for England"
c) The 1955 "Green Belts"
d) NEDDC's own LLA designation of Site 45900 as lying almost entirely within its Moss Valley Conservation Area
e) MVWG's own evidence of the irreplaceable ecological diversity and connectivity of both Site 45900 and of the wider Moss Valley on which the Site 45900 species depend for longterm resilience, particularly in the face of climate change.

For evidence, MVWG quotes the relevant passages of S12 Green Belt’s objection submission, which we completely agree with and support, as follows.

SUPPORTING CASE AND EVIDENCE

Incompatibility with the 1955 "Green Belt"

Together, SS19 and 45900 create a single cross boundary expansion that magnifies every
constraint identified in the S12 Green Belt Action Group’s objections. Green Belt harm becomes
strategic, landscape effects spread across the full Moss Valley ridge, and flood risk and
ecological impacts compound along shared corridors. Both sites draw on the same limited
school places, GP capacity, road network and wastewater systems, meaning pressures
accumulate rather than disperse. In combination, the proposals function as an unplanned urban
extension that neither authority has assessed or mitigated.

General Site Assessment
As part of the 2026 Issues and Options Consultation, NEDDC has provided a Land Availability
Assessment (LLA). Within this, section 2 provides specific site assessment information.
Critically, 45900 is deemed RED for suitability. NEDDCs definition of RED RAG is “The site is
unlikely developable”. For this reason alone the site should be removed from consideration and
not included in any future local plan preparation.

However, it is important to make clear why we support this RED designation, both highlighting
elements of NEDDCs own assessment as well as other constraints that it does not cover:

1. Site position & role in Moss Valley

1.1 The site is of significant, irreplaceable, ecological importance and critical to the wider Moss
Valley landscape, which includes areas of high countryside heritage character, such as ancient
field boundaries, trackways, hedgerows and clean water streams and ponds. The Moss Valley
includes many areas designated SSSI status, which are protected by the Wildlife and
Countryside Act 1981 (section 28). The Moss Valley is further characterised by unusually rich
lowland-farmland mosaic of ancient woodlands, smallscale arable and dairy-farming meadow
and pasture grassland, dotted with large timber trees, of which there are few comparators in the
whole of England.

1.2 The area is home to many mammals, Red Data Book birds, reptiles, amphibians and insect
species which are in rapid decline. The nationally important wealth of wildlife depends on the
ecological strength of the Moss Valley, which in turn depends on maintaining the ecological
integrity of the Valley as a whole. It was accepted during the Sheffield Green Belt Inquiry in
1982 that the Moss Valley is a nationally important reservoir for many precious and threatened
species. The impact of climate change has seen the Moss Valley become an increasingly
important stepping-stone and longer term haven for an increased number of southern species,
which are wholly dependent on the plant and insect food sources provided by the valley.

1.2.1 The national importance of the Moss Valley in these regards was demonstrated by the way in which one of the Inspector's recommendations in her report following the 1982 Green Belt Inquiry was implemented in the form of the Moss Valley Countryside Management Project, the "Schedule of Projects" wall map (of which MVWG possess a copy):

This is clearly demonstrated by the information provided by an article in the local Mosborough “Leader” newspaper of 21st February 1985, written by Janet Lane, reporting on a public meeting to launch the Project’s work in that year:
– “Work will be tackled through schemes run by the Manpower Services Commission…
– "Half the cost of the project will be met by Derbyshire County Council, North East Derbyshire District Council, South Yorkshire County Council and Sheffield City Council.
– "The rest will come from the Countryside Commission and the Nature Conservancy
Council”.

In other words, this is serious money and involvement from all levels of government: not just a jointly-funded LEA/county-level scheme, but one that was 50% funded by the two top relevant national bodies of the time, and with the employment contracts in the hands of the UK Government's top job-creation office of the time.

1.3 We exhibit to this statement, marked “Exhibit 2”, from Emeritus Professor Ian Rotherham, a
leading environmental expert and former Ecologist and Head of Ecological Advisory services for
Sheffield City Council. The views of Professor Rotherham are unequivocal, and we submit that
they should be preferred over any of NEDDCs desk based Heritage Impact Assessment (HIA)
concerning the site.

1.3.1 Impact Risk Zones

The following warnings included in SSC’s PEA for Site SS19 may well apply to NEDDC’s
Site 45900 as well:

(Para. 3.2): “The Site falls within the SSSI Impact Risk Zone (IRZ) for Moss Valley Meadows
SSSI. The Site lies within an area that indicates that impacts to the SSSI could be present
for residential developments of 100 units or more, or rural residential developments of 50 or
more units outside existing settlements/urban areas. As the proposals are anticipated to
have in excess of 200 units, there is potential for the development to impact Moss
Valley SSSI”
.
(Paras. 3.3 & 3.4): "A total of 15 non-statutory designated sites were identified within 2 km of the
Site boundary, all of which were Local Wildlife Sites (LWS). Stoneley and Charnock Woods
LWS is the closest non-statutory designated site to the Site, located approximately 300m.
south of the Site…. Due to the proximity of Stoneley and Charnock Woods LWS, there is
potential for this designated site to be impacted from increased footfall in the
designated site from the development”.

1.4 The Council has failed to identify any mitigation or compensatory measures except from
outlining vague “buffers”. However, we submit emphatically that any measures adopted would
be insufficient. The Moss Valley’s ecological richness has been created by centuries of gradual
habitat-building and is of the highest green belt value, which cannot be replaced or relocated.
1.5 We submit that any proposed development is entirely inconsistent with the Framework duty
to ‘protect and enhance biodiversity and geodiversity’ and will constitute a failure to ‘safeguard
components of local wildlife-rich habitats and wider ecological networks’ including wildlife
corridors and the stepping stones that connect them (para 192(a)). The ‘wholly exceptional
circumstances’ required by paragraph 193 of the Framework to justify development do not exist
and the presumption in favour of sustainable development (para 195) is rebutted by the
evidence presented in this statement.

As stated above, any notion that BNG can be achieved at the site is, at best, fanciful.

2. The Moss & Robin Brooks

2.1 The Moss is a Brook which flows through the Moss Valley and ultimately supplies the River
Rother, which in turn has previously supported the three lakes within the Rother Valley Country
Park. The Robin Brook runs through the centre of the proposed 45900 site and is one of the
main tributaries (alongside Shire Brook) to the Moss. These waterways play a critical role in
supporting the ecosystem of the Moss Valley.

2.2 Research conducted by the Environment Agency conducted in 2019 and 2022 showed the
alarmingly poor health of The Moss, with its ecological status categorised as ‘bad’ and chemical
status categorised as ‘fail’.

2.3 The Group is concerned that the extensive development planned for the site will further
diminish the health of the Robin Brook and its connected waterways. We remind the Council of
its duties under para 187 of the Framework to enhance the natural and local environment and to
avoid adverse effects or unacceptable risk to the Robin Brook, which is unlikely to be ensured
by an overly simplistic buffer zone.

3. Buffers

3.1 As part of the Sheffield SS19 consultation, it was initially presented that an 8m buffer should
be put in place either side of the brook. After initial consultation feedback from S12 Green Belt
action group and Moss Valley Wildlife Group, this was increased to 15m either side as
confirmed in the latest main modifications documents in March 2026, note that this is 15m either
side from the canopy of the trees.

However, MVWG has carried out further site analysis for both the SS19 site and NEDDC 45900
site to ascertain the woodland on the banks of the brook, this has uncovered clear evidence that
there is strong indication that the woodland on the banks of the brook on both sites has
attributes of ancient woodland.

This is based upon but not limited to the findings of:
[A] Very good indicators:
1. Yellow Archangel
2. Bush Vetch
3. Wood Anemone

[B] Good indicators:
4. Bluebell
5. Dog’s Mercury
6. Field Maple
7. Greater Stitchwort
8. Pendulous Sedge
9. Sessile Oak
10. Wild Arum

[C] Perhaps confirmatory indicators:
11. Hart’s-tongue Fern
12. Herb Robert
13. Lesser Celandine.
Due to these factors, we believe this buffer should be 24m either side from the center of the
brook to allow for the appropriate buffering with respect to the canopy of the woodland.

3.2 We estimate that for NEDDC 45900 this will reduce the developable area by roughly 1.3ha
which will inevitably impact the viability and deliverability of the site.

3.3 In addition, site analysis indicates clearly that most of hedgerows within and bordering the
site date at least from 1796 (as shown in the Enclosure Award map of that date for the Manor and Parish of Eckington), which in themselves should be protected and adequate buffers (minimum 5m ideally 8m in
places) should be put in place, this itself reduces the developable area on the southern most
site by roughly 1-1.2ha further compounding the impact to buildable area viability.

3.3.1 The Enclosure Award map of that date for the Manor and Parish of Eckington shows the following hedgerows in the 45900 area, which still appear on the modern OS map of the same area:

a) From the footpath tip of White’s Wood:
– the hedgerow that runs NE. to just W. of the N. tip of the wood
– the hedgerow that curves W. to Carterhall Lane.

b) From Sunnybank:
– the hedgerow that runs SSW. from the W. Side of Sunny Bank.
– the first hedgerow W. from Sunny Bank, that runs from White Lane to Robin Brook. The well-wooded lower third of this hedgerow still currently includes at least one Ancient Woodland Indicator plant, Dog’s Mercury, in profusion.
– the hedgerow S. of Sunny Bank. that runs between these two.

c) From Eckington Leys:
– all the hedges that mark the field between EL and the hedge that the tram cuts through. The NE. hedgerow is the obviously very ancient N. boundary of Eckington Parish.

d) Obviously both hedgerows along the ancient White Lane, as well as those along the ancient Carterhall Lane.

11. Wastewater and sewerage

11.1. The sewerage system in S12 is already under unsustainable pressure, demonstrated by
frequent storm overflow discharges for the past 12 months 26. These include:
● Bridge Inn Ford: 37 times for a total of 81.50 hours in 2025 and 27 times for a total of 87 hours
in 2025 , discharging into The Moss.

12 Flood risk

12.1 The North East Derbyshire Housing Land Availability Assessment (2026) confirms that
Site 45900 contains land within Fluvial Flood Zone 3 and Flood Zone 2, alongside multiple
surface water flood risk layers and steep topography. Under NPPF paragraphs 170–182
(National Planning Policy Framework) development must be directed away from areas at
highest flood risk, and the Sequential Test must be applied at plan making stage to steer
allocations to safer land wherever possible. Paragraph 174 is explicit that development should
not be allocated if reasonably available sites exist in areas of lower flood risk, which is clearly
the case in North East Derbyshire.

12.2 The presence of Robin Brook along the southern boundary further constrains the
developable area and introduces ecological and drainage sensitivities that require buffers and
mitigation. Given the combination of Zone 3 land, surface water pathways, steep gradients, and
the site’s location within a high sensitivity landscape and Conservation Area, the site cannot
realistically demonstrate that development would be safe for its lifetime without increasing flood
risk elsewhere, as required by NPPF paragraphs 178–181. On this basis, Site 45900 fails the
Sequential Test and is unsuitable for allocation.

13. Green belt exceptions

13.1 Site 45900 does not meet the national policy exceptions for Green Belt release. The LAA
confirms that the site is 99.8% Green Belt and lies almost entirely within the Moss Valley
Conservation Area, with 98.43% Primary AMES sensitivity, meaning it strongly fulfils Green Belt
purposes by safeguarding the countryside from encroachment and preserving the setting,
character, and openness of the valley landscape .

13.2 Under the NPPF, Green Belt boundaries may only be altered in exceptional circumstances,
demonstrated through a fully evidenced plan making process & not through site by site
pressure or housing numbers alone. No such exceptional circumstances exist here: the district
has numerous lower harm alternatives, the site’s landscape harm is assessed as Major, and
development would represent a clear incursion into open countryside, directly conflicting with
Green Belt purposes.

14. Cross Boundary Impact

14.1 Site 45900 lies immediately adjacent to Sheffield’s SS19 allocation, meaning that
development here would form a single, continuous block of urban expansion across the district
boundary. The two sites share the same landowner, promoter, and developer, yet there has
been no transparent, cross boundary assessment of their combined effects.

14.2 Together, they would erode the Green Belt separation between Sheffield and
North East Derbyshire, undermine the Moss Valley Conservation Area, and intensify pressure on
shared infrastructure including school places, GP capacity, and the wastewater network already
identified as constrained.

14.3 The North East Derbyshire LAA 2026 itself records major landscape harm, high
environmental sensitivity, and Red suitability, confirming that the site is unsuitable even in
isolation. When considered cumulatively with SS19, the omission of a joint assessment
breaches the recognised “golden rules” of plan making, whereby there should be no surprises,
no duplication, and no gaps, leaving both authorities without a defensible evidence base for
Green Belt release or infrastructure mitigation.

15. Density and uplift

15.1 The LAA (Housing Land Availability Assessment 2026) assessment gives site 45900 space
for around 290 homes, then adds a 20 percent uplift, pushing this up to 348, because it sits near
Sheffield. However, the site is rural Green Belt agricultural land, not part of the city. It has
narrow lanes, B roads, limited public transport, and lies within a Conservation Area. The site
also faces flood risk, steep ground, and a watercourse requiring significant buffers and major
landscape harm, all of which reduce the land that could actually be built on. The number of
houses proposed is unrealistic and inflates capacity beyond what the site can safely or
sustainably deliver.