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

1.1 North East Derbyshire District Council (hereafter referred to as ‘the Council’) are reviewing the current local plan to ensure that it reflects changes to the district’s housing requirements along with new legislation and guidance introduced by the government. The Council is seeking to engage with key stakeholders, including individuals and organisations who have an interest in the district (in accordance with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012).
1.2 Spawforths have been instructed by Stratland to submit representations to the North East Derbyshire District Council Local Plan Review Regulation 18 Consultation on the Strategic Approach to the Location of Development and Refined Sites.
1.3 Stratland have significant interest within North East Derbyshire, which can positively contribute to the housing and economic growth agenda, and therefore welcome the opportunity to engage with the Council in the preparation of an updated Local Plan. Stratland’s site is Land off Primrose Lane, Killamarsh (Site 45221) and a Vision Report has been previously submitted.
1.4 Stratland would like to make comments on the following topics and sections of the North East Derbyshire District Local Plan Review:
• General Comments
• Strategic Approach
• Refined Schedule of Sites: Site 45221 - Land off Primrose Lane, Killamarsh
1.5 In each case, observations are set out with reference to the provisions of the National Planning Policy Framework (hereafter referred to as “the Framework”) and where necessary, amendments are suggested to ensure that the Local Plan Update is found sound.
1.6 Stratland welcomes the opportunity for further engagement and the opportunity to appear at Examination in Public.
1.7 We trust that you will confirm that these representations are duly made and will give due consideration to these comments. Please do not hesitate to contact us to discuss any issues raised in this Representation further.
1.8 The Governments core objectives as established through the 2024 National Planning Policy Framework are sustainable development and growth. Paragraph 11 of the 2024 Framework stresses the need for Local Plans to meet, as a minimum, the objectively assessed needs of an area. The 2024 Framework sets out to boost significantly the supply of homes and ensure that a sufficient amount and variety of land can come forward where it is needed. The Local Housing Need identified through the standard method in the National Planning Practice Guidance should be met as a minimum. In terms of building a strong and competitive economy the 2024 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2024 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes and well-designed places.
1.9 In relation to Local Plan formulation, paragraphs 15 to 38 of the 2024 Framework state that Local Plans are the key to delivering sustainable development which reflect the vision and aspirations of the local community. The 2024 Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where. Paragraph 22 is clear that the Strategic policies should look ahead over a minimum period of 15 year period, and where larger scale development such as new settlements or significant extensions to existing villages and towns form part of the areas strategy, then policies should look ahead over a period of at least 30 years.
1.10 In relation to the examination of Local Plans, paragraph 36 of the 2024 Framework sets out the tests of soundness and establishes that:
Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
• Positively prepared – providing a strategy which as a minimum, seeks to meet the area’s objectively assessed need; and is informed by agreements with other authorities, so that unmet needs from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with policies in this Framework and other statements of national planning policy, where relevant.
1.11 The Local Planning Authority must demonstrate that the Local Plan Update complies with the legal and regulatory framework, including the legal requirements in ss19 and 24(1) of the Planning and Compulsory Purchase Act 2004 (PCPA 2004), Regulations under s.17 and any regulations under s. 36 relating to the preparation of DPD’s, and that the Local Plan Update is ‘Sound’, and that it complies with the Duty to Cooperate.
1.12 The PCPA 2004 requires the LPA to demonstrate that regard has been given to national policies and advice, development plan documents, and must undertake a sustainability appraisal. Plan making authorities are also required to have regard to the resources that are likely to be available for implementing the proposals1. As confirmed with legal judgements “resources” includes resources in the private sector “thus the viability and deliverability of the proposals are considerations to which the authority should have regard when preparing its policies” 2.
1.13 This document therefore considers the content of the consultation on behalf of Stratland in the light of this legal and planning policy context.
General Comments
2.1 Stratland consider that the Council needs to fully reflect the new 2024 Framework in relation to ambition and growth.
Justification
Housing and Economic Growth
2.2 Stratland welcomes a further opportunity to engage on the spatial strategy and locations for development.
2.3 The North East Derbyshire Local Plan was adopted in November 2021 and covered the period 2014-2034, which is now approaching 5 years ago. National planning policy and guidance has changed significantly in that time, with latest National Planning Policy Framework published in December 2024. This includes a refreshed approach to the standard methodology for calculating housing need.
2.4 The Framework establishes a more positive and pro-development policy framework to address the concern that the planning system is a major constraint to growth. The July 2024 Written Ministerial Statement (30th July 2024) confirms the Government’s position on restoring and raising housing targets; focussing new development into the ‘right places’ including within the Green Belt; moving towards strategic planning; building infrastructure to grow the economy; and supporting local planning.
2.5 The Framework is the immediate tool to unlock the planning system and reflects the new Labour Government’s aspirations for growth. Rachel Reeves gave a speech soon after the election to emphasise that “sustained growth is the only route to improving prosperity of our country”; that “nowhere is decisive reform needed more urgently than in our planning system”; and importantly “economic benefits of development will be a central consideration”.
2.6 Chapter 5 is all about ‘Delivering a sufficient supply of homes’ and the changes to the Framework reinforce and emphasise that local authorities should meet the identified housing need as a minimum and the baseline is the standard method. Para 62 of the NPPF states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.”
2.7 Under the standard method for calculating housing need, North East Derbyshire District Council’s local housing need requirement is set at a minimum of 605 new homes per year.
2.8 The proposed changes to the NPPF were published for consultation on 16th December 2025. The Ministerial Statement that accompanied the proposed changes states that the overhaul of the NPPF is designed “to facilitate the delivery of high and sustainable rates of housebuilding” and to “boost the housing supply and unlock economic growth”. The proposed changes create a “permanent presumption in favour of sustainable development”, secure a diverse mix of homes and streamline local standards to speed up decision making. It is appreciated that the proposed changes are out for consultation, but they are a direction of travel contained in an accompanying Written Ministerial Statement.
2.9 Therefore, there is a need for the emerging Local Plan to address the updated national planning position and provide for the housing and employment needs for the area.
Plan period
2.10 Stratland welcomes the extension of the Plan period from the consultation undertaken in August 2025. The consultation material now suggests the emerging Local Plan will cover a Plan period from 2024-2044. The Framework is clear that all strategic policies should look ahead for a minimum of 15 years from the date of adoption. However, if there are large scale urban extensions / new towns then this should be over a 30 year period. Therefore, Stratland considers that there is potential for the Local Plan to cover a longer period and plan accordingly to drive economic and housing growth that the area needs
Ambition
2.11 The Government’s ambition is to deliver sustained economic growth, improve prospective and enhance living standards. To deliver this ambition growth needs to be created throughout the country. The Local Plan Review needs to reflect the Government’s ambition and recognise the housing crisis.
2.12 Furthermore, the Local Plan Update needs to reflect the ambitions both nationally, and for the sub-region. The East Midlands Vision for Growth (May 2025) sets out the region’s bold plan which will transform the region. Delivery of the vision will create 100,000 new jobs, deliver and add £4 billion to the East Midlands economy.
2.13 This vision sets out a clear direction for the region and establishes long-term objectives that will make the East Midlands an even greater place to live, work, and visit. The plan focuses on seven key locations where there are opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
2.14 This approach needs to be reflected and enshrined within the Local Plan Update for North East Derbyshire.
Proposed Approach
2.15 To address the comments, the following approach is proposed:
• Reflect the new National Planning Policy Framework.
• With the economic ambitions and affordable housing need, the housing requirement should be set above the standard method Local Housing Need.
• Reflect the region’s ambitions and growth strategies.
Strategic Approach to the Location of Development
3.1 Stratland consider that the Council’s approach to the emerging Local Plan needs to reflect national policy and guidance and deliver the ambitions for housing and economic growth. The emerging Local Plan should not just be trying to achieve the minimum number of homes required.
3.2 The emerging Local Plan needs to address the big strategic issues of providing for new homes and businesses and supporting infrastructure.
Justification
Development Needs
3.3 The Vision needs to reflect national and regional policy ambitions. Nationally, the Government is seeking to deliver 1.5 million new homes and the housing crisis is a key policy issue to address over this parliamentary period. This flows through Written Ministerial Statements and the new Framework, which includes updated guidance and minimum housing targets, which the Vision should set out to achieve.
3.4 Furthermore, the Government seeks to increase economic growth, which is important to address prosperity and living standards, consistently highlighting that “sustained growth is the only route to improving prosperity of our country”.
3.5 Stratland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.6 Stratland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.7 The standard method calculates for North East Derbyshire that the housing need is 605 new homes per annum, or 12,100 over the 20 years of the Local Plan period. Furthermore, national policy and guidance states that Councils can choose to plan for more homes if they want to support things like economic growth or help meet housing needs in nearby areas.
3.8 The standard method represents a baseline for calculating housing need, and should not be seen as a ceiling for delivering housing. Whilst the standard method provides a minimum starting point for housing need, using household projections and affordability. It also fails to account for local economic growth, job creation, infrastructure changes, or specific demographic shifts.
3.9 Providing ambitious housing targets above the standard methodology also supports economic growth. This would match the East Midlands Vision for Growth (May 2025) which sets out the vision for transformative and ambitious growth within the region. Where significant employment growth is planned, housing supply must match job creation to avoid commuting issues and labour shortages.
3.10 At Examination, the Planning Inspectors may find the Loca Plan unsound if it fails adequately address all sources of housing need. A higher target for housing will demonstrate that the Local Plan is positively prepared, justified, and effective, which are key NPPF soundness tests.
3.11 The Local Plan should therefore establish a housing requirement above the standard method to reflect the economic ambitions for the area and affordable housing needs.
Spatial Distribution of Development
3.12 The location of development is a critical aspect of achieving sustainable development. As a general principal development should be located in areas that are accessible, sustainable, and benefit the local community.
3.13 The feedback from the August 2025 consultation shows preference towards the identification of sites that are sustainable, located in higher order settlements and that are accessible to jobs and services. Killamarsh is a Level 1 Main Settlement and is eminently sustainable.
3.14 Therefore, through engagement and dialogue appropriate sustainable opportunities should be identified within Killamarsh, such as Stratland’s site at Land off Primrose Lane, Killamarsh (Site Ref 45221).
Proposed Approach to the Location of Development
3.15 Stratland support the proposed approach which identifies Priority Locations with Priority 1 including Level 1 Settlements – Main Town locations.
3.16 Stratland consider that this is an appropriate option in identifying land required to deliver sustainable growth within the district. Development on appropriate sites within Killamarsh should be prioritised as the most appropriate and sustainable option.
3.17 Stratland consider that focusing development in Killamarsh is appropriate in delivering growth in one of the most sustainable settlements within the District, and also within close proximity to the largest settlement and City within South Yorkshire. Locating development within Killamarsh will ensure that new development has access to services, facilities, employment opportunities and access to public transport.
Settlement Hierarchy
3.18 The Settlement Hierarchy Study 2025 provides up to date information about settlements in North East Derbyshire District and the services and facilities they provide. One of the primary aims of establishing a settlement hierarchy is to promote sustainable communities by bringing housing, jobs and services closer together in an attempt to maintain and promote the viability of local facilities and reduce the need to travel to services and facilities elsewhere.
3.19 Stratland consider that the Council’s approach to the emerging Local Plan and Settlement Hierarchy is appropriate, with Clay Cross, Dronfield, Eckington and Killamarsh appropriately identified as being the four main towns within the District.
3.20 Killamarsh is situated in the north east corner of the District, immediately adjacent to the boundary with Rotherham and Sheffield. Killamarsh isa one of the larger settlements with access to services, employment opportunities across the region and public transport facilities, including Sheffield’s Supertram .
3.21 Within this context, Stratland feel that the Local Plan could strengthen the settlement hierarchy by addressing the relationship between Killamarsh and Sheffield, recognising its close proximity to the largest settlement within the South Yorkshire region.
Sustainability Appraisal
3.22 It is welcomed that the Sustainability Appraisal has been published. However, the methodology and approach appears confused and it is unclear how the scoring, ranking and assessment has been applied.
3.23 For example, it is implied that Table 3.2 is summary of the Sustainability Appraisal for each site, however it portrays an inaccurate picture. Stratland’s site at Land off Primrose Lane, Killamarsh (Site Ref 45221) is considered to have a negative score on transport. However, in the individual table it has a positive for buses and negative for railway station.
3.24 Nevertheless, the Sustainability Appraisal has not reflected the DfT connectivity tool which assesses the area to be extremely accessible and therefore the negative score is confusing.
3.25 The overall approach of the Sustainability Appraisal is confused and the methodology should be reviewed.
3.26 To address the comments, the following approach is proposed:
• Reflect national and regional policy ambitions.
• Set housing targets which are above the standard method baseline, and exceed for affordable housing and economic growth.
• Amend approach to site identification that focusses on the most appropriate and sustainable locations first.
• Review the methodology and approach of the Sustainability Appraisal.
Site 45221 – Land off Primrose Lane, Killamarsh
4.1 Stratland supports Site 45221 being short listed as a potential future housing allocation.
4.2 Stratland controls the site at Primrose Lane, Killamarsh, which is available, suitable and achievable and therefore deliverable in accordance with national planning policy and guidance.
4.3 A Vision Report has been previously submitted, which explains the deliverability of the site. With the urban context of the site a pre-application enquiry has also been submitted and a planning application is being prepared.
4.4 Stratland considers the site can come forward in the short term and make a valuable contribution to the housing land supply.
Justification
4.5 Stratland considers that their Site at Primrose Lane should be allocated for housing use within the local plan review.
4.6 The site’s location, surrounded by existing development, with no immediate technical challenges, highlights its suitability for development. The site’s proximity to local services, access to wider transport infrastructure and access to the Rother Valley Country Park mean the site offers the opportunity to extend the existing community.
4.7 Furthermore, the ‘Bolsover, Chesterfield and North East Derbyshire Economic Needs Assessment Study (March 2025)’, recognises within table 6.9 that the ‘Land Adjacent to Norwood Industrial Estate, Killamarsh’ (NED31) should no longer be identified for employment. The Study states that “ the site largely comprises undeveloped greenfield land but is contained by built development on three of the boundaries”. The Study indicates that “existing residential uses are located adjacent to two boundaries with planning permission to bring forward 50 dwellings located to the site’s western boundary”. Given the proximity of residential development it is recommend that the site’s designation as General Employment Area is removed and that residential is a more suited use.
4.8 A Vision Report has previously been prepared and submitted to the Council to support the allocation of the site within the Local Plan. The Vision Report demonstrates that the site is available, suitable and achievable and therefore deliverable in accordance with the Framework and PPG.
4.9 Given the site is within the urban area of Killamarsh, a pre-application enquiry has also been prepared and submitted and a planning application is currently being prepared, which will be submitted shortly.
4.10 Stratland’s vision for the site is to create a well-designed residential area that complements the existing community and enhances local character. The development of the site will support the Council’s and the East Midlands Region’s ambition to promote opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
4.11 The site presents an opportunity to provide housing in a sustainable location. The site is contained on all sides, bounded by residential development to the south and west, and established landscaping and employment to the east.
4.12 The ambition for the site is to prioritise the retention of key natural features, including existing trees, hedgerows along the site’s boundaries, and drainage features. Areas will be dedicated to creation of high quality public open space for the benefit of future residents, including an area of open space at the northern end of the site adjacent to the canal. The masterplan shows that the southern section of the site would be reserved for a senior living scheme, potentially a care home (C2 use class).
4.13 The principal highway access for the scheme would be achieved via Primrose Lane, entering into the south-westernmost point of the site. The development would relate well to the approved development to the west (21/00976/FL), which is currently under construction. The approval of this application has set a precedent for the principle of developing to the north of Killamarsh and establishing that this area is both sustainable and suitable for housing.
4.14 In response to the bulleted list in the consultation document relating to Site 45221 the Vision Report, pre-application enquiry and forthcoming planning application have been informed by technical assessments, which are briefly summarised below and further on in this representation:
• The proposed scheme is for circa 100 dwellings and a care home.
• The proposed scheme and illustrative masterplan reflects the Chesterfield Canal and provides open space at the northern end of the site adjacent to the canal.
• Heritage: Heritage assessment has been undertaken and there are no archaeological or heritage constraints to the scheme.
• Ecology: Preliminary Ecological Appraisal and BNG assessment and there are no ecological or constraints to the scheme.
• Highways: AMA has undertaken a Transport Assessment and there are no highways constraints to the scheme.
• Flood Risk and Drainage: Flood Risk and Drainage Appraisal has been undertaken and there are no flood risk or drainage constraints to the scheme.
• Employment: The site is an employment allocation in the adopted Local Plan, however the Council’s Economic Needs Study considers the site is not an appropriate employment site given its residential neighbours and therefore suggests the site be reallocated for residential use.
• Health and Safety Executive Zone: The HSE zone is at the far northern end of the site and within the illustrative masterplan is shown for open space.
• Geo-Environmental: Preliminary ground investigation has been undertaken and there are no geo-environmental constraints
• Agricultural Land: The site is not Best and Most Versatile agricultural land.
4.15 Overall, this is a scheme that has strong potential to balance connectivity, sustainability, and community well-being. It will create a vibrant, healthy, and resilient place for people to live, work, and thrive, while preserving the distinct identity of Killamarsh.
Availability
4.16 Stratland has a legal agreement with the landowners to promote and develop the land for housing. Stratland is proud of their reputation for working with local and national builders to deliver high-quality desirable homes in sustainable locations. The Site is currently available for residential development which can be brought forward early within the local plan period, representing a short term opportunity.
4.17 The masterplan and constraints plan demonstrate that appropriate access point can be achieved for the Site. The scheme will also be able to deliver off-site highways contributions for any further works required. This would therefore not represent a constraint in the Site being available.
4.18 It is demonstrated that significant BNG uplift can be delivered on the Site, and that these matters would not represent constraints in the site being available.
4.19 The land is therefore “available” in accordance with the Framework and the Planning Practice Guidance.
Suitability
4.20 Stratland believe that the site is suitable for residential development, with no constraints that cannot be appropriately mitigated or that would represent the site being unsuitable.
4.21 The proposed development can make an efficient and attractive use of the land. Although greenfield land, the Site represents an excellent opportunity for future housing and development. This site would allow housing to be delivered within an appropriate and sustainable location at Killamarsh. The development of this site would assist in creating a logical extension to the built up urban area.
4.22 The site is located within a highly sustainable location, within one of the principal towns and most sustainable settlements within the district, as identified within the Statutory Development Plan and Settlement Hierarchy.
4.23 The site is 850m from Killamarsh Local Centre, which includes Aldi, Fulton Foods, Co-op Food, a Medical Clinic, a library and several local services like hair salons, a bakery, and a café. Killamarsh Infant and Junior School is very close to the site, accessible off Primrose Lane on Sheffield Road. Other schools, including St Giles CE Primary and Killamarsh Bears Pre School, are also within walking distance.
4.24 Rother Valley Country Park is within walking distance, offering 750 acres of trails, a nature reserve, and leisure attractions like Sheffield Cable Waterski & Aqua Park. Nearby, Rother Valley Golf Centre and Gulliver’s Valley Theme Park offer additional recreational opportunities
4.25 The site offers excellent connectivity, located within 2.5km of the Halfway Park & Ride, benefiting from frequent tram and bus services to Sheffield City Centre. Furthermore, bus stops within close proximity link to Crystal Peaks shopping centre and Sheffield. Kiveton Park train station is approximately 3km away, however the proposed reopening of the Barrow Hill Line will significantly improve regional connections. The proposed Killamarsh station will further enhance access to key employment and education hubs in Sheffield and Chesterfield and support strategic housing developments along the Staveley Growth Corridor.
4.26 The site is almost entirely within Flood Zone 1 and is of low risk in terms of fluvial and surface water flooding, with some small areas situated in Flood Zone 2/3. The site generally falls from the southern boundary down to the northern and eastern/ western boundaries. Remaining elements of the Chesterfield Canal is to the north east of the site. It is considered that any areas within the higher flood zone risk areas can be easily excluded from the developable area, and utilised for either landscaping, public open space and/or drainage attenuation.
4.27 A small portion of the perimeter of the site falls within a Hazardous Installation Inner Zone and would therefore be precluded from housing development, but is suitable for ecology, habitat and open space.
4.28 The site is not located within or adjacent to a Conversation Area and there are no listed buildings within close proximity. As a result, it is considered that development of the Site will not affect any national or local heritage features.
4.29 There are no statutory ecological designations or known priority habitats on the Site. Any development would utilise existing tree belts and features, with reinforced landscaping and planting. The Ste is currently made up of arable fields, which therefore have a monoculture of limited specifies diversity, and limited ecological value or importance.
4.30 There is a clear need for new sites to come forward for housing to support the growth ambitions for the East Midlands region. The Site provides an important opportunity to meet local housing needs. The proposed residential development would be developed to a high-quality design standard that respects the nature of the surrounding area. The development of the site for housing presents an ideal opportunity to address local housing needs by providing a diverse range of affordable and aspirational homes for families, older adults, and young professionals.
4.31 The site provides a unique opportunity that will benefit the area and wider district with economic, environmental and social benefits. The technical work that underpins the masterplan confirms that there are no known constraints to development. It is therefore considered that the proposed allocation of the site is suitable, in accordance with national guidance and PPG
4.32 The land is therefore “suitable” in accordance with the Framework and the Planning Practice Guidance.
Deliverability
4.33 Stratland consider that the site can come forward immediately and be delivered in the short term (1-5 years) of the Local Plan Period. The masterplan and constraints plan provided show that there are no significant issues preventing the site coming forward, with solutions on site to address availability and suitability concerns.
4.34 The proposed development is located within close proximity to existing services and facilities. The indicative masterplan represents an efficient use of the land available. The scheme is therefore making an efficient and effective use of land and infrastructure.
4.35 The site provides a development opportunity that is available, suitable and achievable and therefore it is considered that the site is deliverable, in accordance with national planning policy and guidance. It is promoted by Stratland and is deliverable within the plan period.
Achievable
4.36 A range of technical work has been undertaken and is ongoing. From these initial assessments there are no technical issues that would prevent the delivery of the site for residential purposes. The technical reports will show how a mix of housing can be accommodated within the site, alongside connectivity, landscaping and drainage features.
4.37 The Framework requires Local Planning Authorities to meet their full objectively assessed housing need. Stratland considers that the site is deliverable in the short term (1-5 years) and will reinforce the housing supply and address the Council’s housing needs in the Local Plan period. Development of this Site will support the delivery of a range of housing types and contribute towards meeting identified needs
4.38 It will be evidenced that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
A Positive Response to the Key Objectives of the Framework
4.39 The Framework sets out that the Governments key housing policy goal of significantly boosting the supply of housing and proactively driving and supporting sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs. The Framework explains that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as extensions to towns, and creating mixed and sustainable communities with good access to jobs, key services and infrastructure. Sites should also make effective use of land and existing infrastructure.
4.40 In relation to the Framework:
• The proposal responds positively towards national guidance.
• The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.
• The proposed site is accessible to existing employment, local community facilities, infrastructure and services, including public transport.
• The site has been assessed as being is available, suitable and achievable for development.
Benefits of Site Reference 45221 – Land off Primrose Lane, Killamarsh
4.41 The development of the site would provide significant economic, social and environmental benefits. The site would provide housing that would meet the needs of the North-East Derbyshire District Council’s housing market in a sustainable location.
4.42 In accordance with the Framework this representation has shown that:
• The site is suitable for housing and can deliver circa 100 new homes and a care home.
• The proposal can provide a good mix of housing commensurate to the demand and need in the area and diversify the housing stock
• The site is within a sustainable location situated in close proximity to facilities and services and also to bus stops for local bus routes.
• The scheme uses land efficiently and effectively.
• The proposal is in line with planning for housing objectives.
• The scheme will create direct and indirect job opportunities both during and after construction, as well as employment opportunities through an C2 use on the Site.
• The site can deliver new areas of public open space.
4.43 The proposal is an appropriate site to provide for the housing needs of Killamarsh and the wider East Midlands region during the Local Plan period. Confirmation of the allocation will contribute positively to a balanced housing supply in the area in sustainable locations. The site can deliver a full range and mix of housing as part of a sustainable community. Development of the site would deliver affordable housing. North-East Derbyshire District Council needs to have a robust housing trajectory with a sufficient supply of deliverable sites. The site will assist with this delivery in the medium term. The site is situated within a prime location suitable for residential development and as such would facilitate the development of land in an effective and efficient manner. Development of the site would not harm or undermine the area’s wider policy objectives but seeks to reinforce the need to develop sites within sustainable locations as a priority.
4.44 The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.
4.45 To address the comments, the following approach is proposed:
• Allocate the site at Primrose Lane, Killamarsh for housing purposes.

1.1 North East Derbyshire District Council (hereafter referred to as ‘the Council’) are reviewing the current local plan to ensure that it reflects changes to the district’s housing requirements along with new legislation and guidance introduced by the government. The Council is seeking to engage with key stakeholders, including individuals and organisations who have an interest in the district (in accordance with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012).
1.2 Spawforths have been instructed by Stratland to submit representations to the North East Derbyshire District Council Local Plan Review Regulation 18 Consultation on the Strategic Approach to the Location of Development and Refined Sites.
1.3 Stratland have significant interest within North East Derbyshire, which can positively contribute to the housing and economic growth agenda, and therefore welcome the opportunity to engage with the Council in the preparation of an updated Local Plan. Stratland’s site is Land off Primrose Lane, Killamarsh (Site 45221) and a Vision Report has been previously submitted.
1.4 Stratland would like to make comments on the following topics and sections of the North East Derbyshire District Local Plan Review:
• General Comments
• Strategic Approach
• Refined Schedule of Sites: Site 45221 - Land off Primrose Lane, Killamarsh
1.5 In each case, observations are set out with reference to the provisions of the National Planning Policy Framework (hereafter referred to as “the Framework”) and where necessary, amendments are suggested to ensure that the Local Plan Update is found sound.
1.6 Stratland welcomes the opportunity for further engagement and the opportunity to appear at Examination in Public.
1.7 We trust that you will confirm that these representations are duly made and will give due consideration to these comments. Please do not hesitate to contact us to discuss any issues raised in this Representation further.
1.8 The Governments core objectives as established through the 2024 National Planning Policy Framework are sustainable development and growth. Paragraph 11 of the 2024 Framework stresses the need for Local Plans to meet, as a minimum, the objectively assessed needs of an area. The 2024 Framework sets out to boost significantly the supply of homes and ensure that a sufficient amount and variety of land can come forward where it is needed. The Local Housing Need identified through the standard method in the National Planning Practice Guidance should be met as a minimum. In terms of building a strong and competitive economy the 2024 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2024 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes and well-designed places.
1.9 In relation to Local Plan formulation, paragraphs 15 to 38 of the 2024 Framework state that Local Plans are the key to delivering sustainable development which reflect the vision and aspirations of the local community. The 2024 Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where. Paragraph 22 is clear that the Strategic policies should look ahead over a minimum period of 15 year period, and where larger scale development such as new settlements or significant extensions to existing villages and towns form part of the areas strategy, then policies should look ahead over a period of at least 30 years.
1.10 In relation to the examination of Local Plans, paragraph 36 of the 2024 Framework sets out the tests of soundness and establishes that:
Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
• Positively prepared – providing a strategy which as a minimum, seeks to meet the area’s objectively assessed need; and is informed by agreements with other authorities, so that unmet needs from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with policies in this Framework and other statements of national planning policy, where relevant.
1.11 The Local Planning Authority must demonstrate that the Local Plan Update complies with the legal and regulatory framework, including the legal requirements in ss19 and 24(1) of the Planning and Compulsory Purchase Act 2004 (PCPA 2004), Regulations under s.17 and any regulations under s. 36 relating to the preparation of DPD’s, and that the Local Plan Update is ‘Sound’, and that it complies with the Duty to Cooperate.
1.12 The PCPA 2004 requires the LPA to demonstrate that regard has been given to national policies and advice, development plan documents, and must undertake a sustainability appraisal. Plan making authorities are also required to have regard to the resources that are likely to be available for implementing the proposals1. As confirmed with legal judgements “resources” includes resources in the private sector “thus the viability and deliverability of the proposals are considerations to which the authority should have regard when preparing its policies” 2.
1.13 This document therefore considers the content of the consultation on behalf of Stratland in the light of this legal and planning policy context.
General Comments
2.1 Stratland consider that the Council needs to fully reflect the new 2024 Framework in relation to ambition and growth.
Justification
Housing and Economic Growth
2.2 Stratland welcomes a further opportunity to engage on the spatial strategy and locations for development.
2.3 The North East Derbyshire Local Plan was adopted in November 2021 and covered the period 2014-2034, which is now approaching 5 years ago. National planning policy and guidance has changed significantly in that time, with latest National Planning Policy Framework published in December 2024. This includes a refreshed approach to the standard methodology for calculating housing need.
2.4 The Framework establishes a more positive and pro-development policy framework to address the concern that the planning system is a major constraint to growth. The July 2024 Written Ministerial Statement (30th July 2024) confirms the Government’s position on restoring and raising housing targets; focussing new development into the ‘right places’ including within the Green Belt; moving towards strategic planning; building infrastructure to grow the economy; and supporting local planning.
2.5 The Framework is the immediate tool to unlock the planning system and reflects the new Labour Government’s aspirations for growth. Rachel Reeves gave a speech soon after the election to emphasise that “sustained growth is the only route to improving prosperity of our country”; that “nowhere is decisive reform needed more urgently than in our planning system”; and importantly “economic benefits of development will be a central consideration”.
2.6 Chapter 5 is all about ‘Delivering a sufficient supply of homes’ and the changes to the Framework reinforce and emphasise that local authorities should meet the identified housing need as a minimum and the baseline is the standard method. Para 62 of the NPPF states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.”
2.7 Under the standard method for calculating housing need, North East Derbyshire District Council’s local housing need requirement is set at a minimum of 605 new homes per year.
2.8 The proposed changes to the NPPF were published for consultation on 16th December 2025. The Ministerial Statement that accompanied the proposed changes states that the overhaul of the NPPF is designed “to facilitate the delivery of high and sustainable rates of housebuilding” and to “boost the housing supply and unlock economic growth”. The proposed changes create a “permanent presumption in favour of sustainable development”, secure a diverse mix of homes and streamline local standards to speed up decision making. It is appreciated that the proposed changes are out for consultation, but they are a direction of travel contained in an accompanying Written Ministerial Statement.
2.9 Therefore, there is a need for the emerging Local Plan to address the updated national planning position and provide for the housing and employment needs for the area.
Plan period
2.10 Stratland welcomes the extension of the Plan period from the consultation undertaken in August 2025. The consultation material now suggests the emerging Local Plan will cover a Plan period from 2024-2044. The Framework is clear that all strategic policies should look ahead for a minimum of 15 years from the date of adoption. However, if there are large scale urban extensions / new towns then this should be over a 30 year period. Therefore, Stratland considers that there is potential for the Local Plan to cover a longer period and plan accordingly to drive economic and housing growth that the area needs
Ambition
2.11 The Government’s ambition is to deliver sustained economic growth, improve prospective and enhance living standards. To deliver this ambition growth needs to be created throughout the country. The Local Plan Review needs to reflect the Government’s ambition and recognise the housing crisis.
2.12 Furthermore, the Local Plan Update needs to reflect the ambitions both nationally, and for the sub-region. The East Midlands Vision for Growth (May 2025) sets out the region’s bold plan which will transform the region. Delivery of the vision will create 100,000 new jobs, deliver and add £4 billion to the East Midlands economy.
2.13 This vision sets out a clear direction for the region and establishes long-term objectives that will make the East Midlands an even greater place to live, work, and visit. The plan focuses on seven key locations where there are opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
2.14 This approach needs to be reflected and enshrined within the Local Plan Update for North East Derbyshire.
Proposed Approach
2.15 To address the comments, the following approach is proposed:
• Reflect the new National Planning Policy Framework.
• With the economic ambitions and affordable housing need, the housing requirement should be set above the standard method Local Housing Need.
• Reflect the region’s ambitions and growth strategies.
Strategic Approach to the Location of Development
3.1 Stratland consider that the Council’s approach to the emerging Local Plan needs to reflect national policy and guidance and deliver the ambitions for housing and economic growth. The emerging Local Plan should not just be trying to achieve the minimum number of homes required.
3.2 The emerging Local Plan needs to address the big strategic issues of providing for new homes and businesses and supporting infrastructure.
Justification
Development Needs
3.3 The Vision needs to reflect national and regional policy ambitions. Nationally, the Government is seeking to deliver 1.5 million new homes and the housing crisis is a key policy issue to address over this parliamentary period. This flows through Written Ministerial Statements and the new Framework, which includes updated guidance and minimum housing targets, which the Vision should set out to achieve.
3.4 Furthermore, the Government seeks to increase economic growth, which is important to address prosperity and living standards, consistently highlighting that “sustained growth is the only route to improving prosperity of our country”.
3.5 Stratland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.6 Stratland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.7 The standard method calculates for North East Derbyshire that the housing need is 605 new homes per annum, or 12,100 over the 20 years of the Local Plan period. Furthermore, national policy and guidance states that Councils can choose to plan for more homes if they want to support things like economic growth or help meet housing needs in nearby areas.
3.8 The standard method represents a baseline for calculating housing need, and should not be seen as a ceiling for delivering housing. Whilst the standard method provides a minimum starting point for housing need, using household projections and affordability. It also fails to account for local economic growth, job creation, infrastructure changes, or specific demographic shifts.
3.9 Providing ambitious housing targets above the standard methodology also supports economic growth. This would match the East Midlands Vision for Growth (May 2025) which sets out the vision for transformative and ambitious growth within the region. Where significant employment growth is planned, housing supply must match job creation to avoid commuting issues and labour shortages.
3.10 At Examination, the Planning Inspectors may find the Loca Plan unsound if it fails adequately address all sources of housing need. A higher target for housing will demonstrate that the Local Plan is positively prepared, justified, and effective, which are key NPPF soundness tests.
3.11 The Local Plan should therefore establish a housing requirement above the standard method to reflect the economic ambitions for the area and affordable housing needs.
Spatial Distribution of Development
3.12 The location of development is a critical aspect of achieving sustainable development. As a general principal development should be located in areas that are accessible, sustainable, and benefit the local community.
3.13 The feedback from the August 2025 consultation shows preference towards the identification of sites that are sustainable, located in higher order settlements and that are accessible to jobs and services. Killamarsh is a Level 1 Main Settlement and is eminently sustainable.
3.14 Therefore, through engagement and dialogue appropriate sustainable opportunities should be identified within Killamarsh, such as Stratland’s site at Land off Primrose Lane, Killamarsh (Site Ref 45221).
Proposed Approach to the Location of Development
3.15 Stratland support the proposed approach which identifies Priority Locations with Priority 1 including Level 1 Settlements – Main Town locations.
3.16 Stratland consider that this is an appropriate option in identifying land required to deliver sustainable growth within the district. Development on appropriate sites within Killamarsh should be prioritised as the most appropriate and sustainable option.
3.17 Stratland consider that focusing development in Killamarsh is appropriate in delivering growth in one of the most sustainable settlements within the District, and also within close proximity to the largest settlement and City within South Yorkshire. Locating development within Killamarsh will ensure that new development has access to services, facilities, employment opportunities and access to public transport.
Settlement Hierarchy
3.18 The Settlement Hierarchy Study 2025 provides up to date information about settlements in North East Derbyshire District and the services and facilities they provide. One of the primary aims of establishing a settlement hierarchy is to promote sustainable communities by bringing housing, jobs and services closer together in an attempt to maintain and promote the viability of local facilities and reduce the need to travel to services and facilities elsewhere.
3.19 Stratland consider that the Council’s approach to the emerging Local Plan and Settlement Hierarchy is appropriate, with Clay Cross, Dronfield, Eckington and Killamarsh appropriately identified as being the four main towns within the District.
3.20 Killamarsh is situated in the north east corner of the District, immediately adjacent to the boundary with Rotherham and Sheffield. Killamarsh isa one of the larger settlements with access to services, employment opportunities across the region and public transport facilities, including Sheffield’s Supertram .
3.21 Within this context, Stratland feel that the Local Plan could strengthen the settlement hierarchy by addressing the relationship between Killamarsh and Sheffield, recognising its close proximity to the largest settlement within the South Yorkshire region.
Sustainability Appraisal
3.22 It is welcomed that the Sustainability Appraisal has been published. However, the methodology and approach appears confused and it is unclear how the scoring, ranking and assessment has been applied.
3.23 For example, it is implied that Table 3.2 is summary of the Sustainability Appraisal for each site, however it portrays an inaccurate picture. Stratland’s site at Land off Primrose Lane, Killamarsh (Site Ref 45221) is considered to have a negative score on transport. However, in the individual table it has a positive for buses and negative for railway station.
3.24 Nevertheless, the Sustainability Appraisal has not reflected the DfT connectivity tool which assesses the area to be extremely accessible and therefore the negative score is confusing.
3.25 The overall approach of the Sustainability Appraisal is confused and the methodology should be reviewed.
3.26 To address the comments, the following approach is proposed:
• Reflect national and regional policy ambitions.
• Set housing targets which are above the standard method baseline, and exceed for affordable housing and economic growth.
• Amend approach to site identification that focusses on the most appropriate and sustainable locations first.
• Review the methodology and approach of the Sustainability Appraisal.
Site 45221 – Land off Primrose Lane, Killamarsh
4.1 Stratland supports Site 45221 being short listed as a potential future housing allocation.
4.2 Stratland controls the site at Primrose Lane, Killamarsh, which is available, suitable and achievable and therefore deliverable in accordance with national planning policy and guidance.
4.3 A Vision Report has been previously submitted, which explains the deliverability of the site. With the urban context of the site a pre-application enquiry has also been submitted and a planning application is being prepared.
4.4 Stratland considers the site can come forward in the short term and make a valuable contribution to the housing land supply.
Justification
4.5 Stratland considers that their Site at Primrose Lane should be allocated for housing use within the local plan review.
4.6 The site’s location, surrounded by existing development, with no immediate technical challenges, highlights its suitability for development. The site’s proximity to local services, access to wider transport infrastructure and access to the Rother Valley Country Park mean the site offers the opportunity to extend the existing community.
4.7 Furthermore, the ‘Bolsover, Chesterfield and North East Derbyshire Economic Needs Assessment Study (March 2025)’, recognises within table 6.9 that the ‘Land Adjacent to Norwood Industrial Estate, Killamarsh’ (NED31) should no longer be identified for employment. The Study states that “ the site largely comprises undeveloped greenfield land but is contained by built development on three of the boundaries”. The Study indicates that “existing residential uses are located adjacent to two boundaries with planning permission to bring forward 50 dwellings located to the site’s western boundary”. Given the proximity of residential development it is recommend that the site’s designation as General Employment Area is removed and that residential is a more suited use.
4.8 A Vision Report has previously been prepared and submitted to the Council to support the allocation of the site within the Local Plan. The Vision Report demonstrates that the site is available, suitable and achievable and therefore deliverable in accordance with the Framework and PPG.
4.9 Given the site is within the urban area of Killamarsh, a pre-application enquiry has also been prepared and submitted and a planning application is currently being prepared, which will be submitted shortly.
4.10 Stratland’s vision for the site is to create a well-designed residential area that complements the existing community and enhances local character. The development of the site will support the Council’s and the East Midlands Region’s ambition to promote opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
4.11 The site presents an opportunity to provide housing in a sustainable location. The site is contained on all sides, bounded by residential development to the south and west, and established landscaping and employment to the east.
4.12 The ambition for the site is to prioritise the retention of key natural features, including existing trees, hedgerows along the site’s boundaries, and drainage features. Areas will be dedicated to creation of high quality public open space for the benefit of future residents, including an area of open space at the northern end of the site adjacent to the canal. The masterplan shows that the southern section of the site would be reserved for a senior living scheme, potentially a care home (C2 use class).
4.13 The principal highway access for the scheme would be achieved via Primrose Lane, entering into the south-westernmost point of the site. The development would relate well to the approved development to the west (21/00976/FL), which is currently under construction. The approval of this application has set a precedent for the principle of developing to the north of Killamarsh and establishing that this area is both sustainable and suitable for housing.
4.14 In response to the bulleted list in the consultation document relating to Site 45221 the Vision Report, pre-application enquiry and forthcoming planning application have been informed by technical assessments, which are briefly summarised below and further on in this representation:
• The proposed scheme is for circa 100 dwellings and a care home.
• The proposed scheme and illustrative masterplan reflects the Chesterfield Canal and provides open space at the northern end of the site adjacent to the canal.
• Heritage: Heritage assessment has been undertaken and there are no archaeological or heritage constraints to the scheme.
• Ecology: Preliminary Ecological Appraisal and BNG assessment and there are no ecological or constraints to the scheme.
• Highways: AMA has undertaken a Transport Assessment and there are no highways constraints to the scheme.
• Flood Risk and Drainage: Flood Risk and Drainage Appraisal has been undertaken and there are no flood risk or drainage constraints to the scheme.
• Employment: The site is an employment allocation in the adopted Local Plan, however the Council’s Economic Needs Study considers the site is not an appropriate employment site given its residential neighbours and therefore suggests the site be reallocated for residential use.
• Health and Safety Executive Zone: The HSE zone is at the far northern end of the site and within the illustrative masterplan is shown for open space.
• Geo-Environmental: Preliminary ground investigation has been undertaken and there are no geo-environmental constraints
• Agricultural Land: The site is not Best and Most Versatile agricultural land.
4.15 Overall, this is a scheme that has strong potential to balance connectivity, sustainability, and community well-being. It will create a vibrant, healthy, and resilient place for people to live, work, and thrive, while preserving the distinct identity of Killamarsh.
Availability
4.16 Stratland has a legal agreement with the landowners to promote and develop the land for housing. Stratland is proud of their reputation for working with local and national builders to deliver high-quality desirable homes in sustainable locations. The Site is currently available for residential development which can be brought forward early within the local plan period, representing a short term opportunity.
4.17 The masterplan and constraints plan demonstrate that appropriate access point can be achieved for the Site. The scheme will also be able to deliver off-site highways contributions for any further works required. This would therefore not represent a constraint in the Site being available.
4.18 It is demonstrated that significant BNG uplift can be delivered on the Site, and that these matters would not represent constraints in the site being available.
4.19 The land is therefore “available” in accordance with the Framework and the Planning Practice Guidance.
Suitability
4.20 Stratland believe that the site is suitable for residential development, with no constraints that cannot be appropriately mitigated or that would represent the site being unsuitable.
4.21 The proposed development can make an efficient and attractive use of the land. Although greenfield land, the Site represents an excellent opportunity for future housing and development. This site would allow housing to be delivered within an appropriate and sustainable location at Killamarsh. The development of this site would assist in creating a logical extension to the built up urban area.
4.22 The site is located within a highly sustainable location, within one of the principal towns and most sustainable settlements within the district, as identified within the Statutory Development Plan and Settlement Hierarchy.
4.23 The site is 850m from Killamarsh Local Centre, which includes Aldi, Fulton Foods, Co-op Food, a Medical Clinic, a library and several local services like hair salons, a bakery, and a café. Killamarsh Infant and Junior School is very close to the site, accessible off Primrose Lane on Sheffield Road. Other schools, including St Giles CE Primary and Killamarsh Bears Pre School, are also within walking distance.
4.24 Rother Valley Country Park is within walking distance, offering 750 acres of trails, a nature reserve, and leisure attractions like Sheffield Cable Waterski & Aqua Park. Nearby, Rother Valley Golf Centre and Gulliver’s Valley Theme Park offer additional recreational opportunities
4.25 The site offers excellent connectivity, located within 2.5km of the Halfway Park & Ride, benefiting from frequent tram and bus services to Sheffield City Centre. Furthermore, bus stops within close proximity link to Crystal Peaks shopping centre and Sheffield. Kiveton Park train station is approximately 3km away, however the proposed reopening of the Barrow Hill Line will significantly improve regional connections. The proposed Killamarsh station will further enhance access to key employment and education hubs in Sheffield and Chesterfield and support strategic housing developments along the Staveley Growth Corridor.
4.26 The site is almost entirely within Flood Zone 1 and is of low risk in terms of fluvial and surface water flooding, with some small areas situated in Flood Zone 2/3. The site generally falls from the southern boundary down to the northern and eastern/ western boundaries. Remaining elements of the Chesterfield Canal is to the north east of the site. It is considered that any areas within the higher flood zone risk areas can be easily excluded from the developable area, and utilised for either landscaping, public open space and/or drainage attenuation.
4.27 A small portion of the perimeter of the site falls within a Hazardous Installation Inner Zone and would therefore be precluded from housing development, but is suitable for ecology, habitat and open space.
4.28 The site is not located within or adjacent to a Conversation Area and there are no listed buildings within close proximity. As a result, it is considered that development of the Site will not affect any national or local heritage features.
4.29 There are no statutory ecological designations or known priority habitats on the Site. Any development would utilise existing tree belts and features, with reinforced landscaping and planting. The Ste is currently made up of arable fields, which therefore have a monoculture of limited specifies diversity, and limited ecological value or importance.
4.30 There is a clear need for new sites to come forward for housing to support the growth ambitions for the East Midlands region. The Site provides an important opportunity to meet local housing needs. The proposed residential development would be developed to a high-quality design standard that respects the nature of the surrounding area. The development of the site for housing presents an ideal opportunity to address local housing needs by providing a diverse range of affordable and aspirational homes for families, older adults, and young professionals.
4.31 The site provides a unique opportunity that will benefit the area and wider district with economic, environmental and social benefits. The technical work that underpins the masterplan confirms that there are no known constraints to development. It is therefore considered that the proposed allocation of the site is suitable, in accordance with national guidance and PPG
4.32 The land is therefore “suitable” in accordance with the Framework and the Planning Practice Guidance.
Deliverability
4.33 Stratland consider that the site can come forward immediately and be delivered in the short term (1-5 years) of the Local Plan Period. The masterplan and constraints plan provided show that there are no significant issues preventing the site coming forward, with solutions on site to address availability and suitability concerns.
4.34 The proposed development is located within close proximity to existing services and facilities. The indicative masterplan represents an efficient use of the land available. The scheme is therefore making an efficient and effective use of land and infrastructure.
4.35 The site provides a development opportunity that is available, suitable and achievable and therefore it is considered that the site is deliverable, in accordance with national planning policy and guidance. It is promoted by Stratland and is deliverable within the plan period.
Achievable
4.36 A range of technical work has been undertaken and is ongoing. From these initial assessments there are no technical issues that would prevent the delivery of the site for residential purposes. The technical reports will show how a mix of housing can be accommodated within the site, alongside connectivity, landscaping and drainage features.
4.37 The Framework requires Local Planning Authorities to meet their full objectively assessed housing need. Stratland considers that the site is deliverable in the short term (1-5 years) and will reinforce the housing supply and address the Council’s housing needs in the Local Plan period. Development of this Site will support the delivery of a range of housing types and contribute towards meeting identified needs
4.38 It will be evidenced that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
A Positive Response to the Key Objectives of the Framework
4.39 The Framework sets out that the Governments key housing policy goal of significantly boosting the supply of housing and proactively driving and supporting sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs. The Framework explains that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as extensions to towns, and creating mixed and sustainable communities with good access to jobs, key services and infrastructure. Sites should also make effective use of land and existing infrastructure.
4.40 In relation to the Framework:
• The proposal responds positively towards national guidance.
• The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.
• The proposed site is accessible to existing employment, local community facilities, infrastructure and services, including public transport.
• The site has been assessed as being is available, suitable and achievable for development.
Benefits of Site Reference 45221 – Land off Primrose Lane, Killamarsh
4.41 The development of the site would provide significant economic, social and environmental benefits. The site would provide housing that would meet the needs of the North-East Derbyshire District Council’s housing market in a sustainable location.
4.42 In accordance with the Framework this representation has shown that:
• The site is suitable for housing and can deliver circa 100 new homes and a care home.
• The proposal can provide a good mix of housing commensurate to the demand and need in the area and diversify the housing stock
• The site is within a sustainable location situated in close proximity to facilities and services and also to bus stops for local bus routes.
• The scheme uses land efficiently and effectively.
• The proposal is in line with planning for housing objectives.
• The scheme will create direct and indirect job opportunities both during and after construction, as well as employment opportunities through an C2 use on the Site.
• The site can deliver new areas of public open space.
4.43 The proposal is an appropriate site to provide for the housing needs of Killamarsh and the wider East Midlands region during the Local Plan period. Confirmation of the allocation will contribute positively to a balanced housing supply in the area in sustainable locations. The site can deliver a full range and mix of housing as part of a sustainable community. Development of the site would deliver affordable housing. North-East Derbyshire District Council needs to have a robust housing trajectory with a sufficient supply of deliverable sites. The site will assist with this delivery in the medium term. The site is situated within a prime location suitable for residential development and as such would facilitate the development of land in an effective and efficient manner. Development of the site would not harm or undermine the area’s wider policy objectives but seeks to reinforce the need to develop sites within sustainable locations as a priority.
4.44 The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.
4.45 To address the comments, the following approach is proposed:
• Allocate the site at Primrose Lane, Killamarsh for housing purposes.

1.1 North East Derbyshire District Council (hereafter referred to as ‘the Council’) are reviewing the current local plan to ensure that it reflects changes to the district’s housing requirements along with new legislation and guidance introduced by the government. The Council is seeking to engage with key stakeholders, including individuals and organisations who have an interest in the district (in accordance with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012).
1.2 Spawforths have been instructed by Stratland to submit representations to the North East Derbyshire District Council Local Plan Review Regulation 18 Consultation on the Strategic Approach to the Location of Development and Refined Sites.
1.3 Stratland have significant interest within North East Derbyshire, which can positively contribute to the housing and economic growth agenda, and therefore welcome the opportunity to engage with the Council in the preparation of an updated Local Plan. Stratland’s site is Land off Primrose Lane, Killamarsh (Site 45221) and a Vision Report has been previously submitted.
1.4 Stratland would like to make comments on the following topics and sections of the North East Derbyshire District Local Plan Review:
• General Comments
• Strategic Approach
• Refined Schedule of Sites: Site 45221 - Land off Primrose Lane, Killamarsh
1.5 In each case, observations are set out with reference to the provisions of the National Planning Policy Framework (hereafter referred to as “the Framework”) and where necessary, amendments are suggested to ensure that the Local Plan Update is found sound.
1.6 Stratland welcomes the opportunity for further engagement and the opportunity to appear at Examination in Public.
1.7 We trust that you will confirm that these representations are duly made and will give due consideration to these comments. Please do not hesitate to contact us to discuss any issues raised in this Representation further.
1.8 The Governments core objectives as established through the 2024 National Planning Policy Framework are sustainable development and growth. Paragraph 11 of the 2024 Framework stresses the need for Local Plans to meet, as a minimum, the objectively assessed needs of an area. The 2024 Framework sets out to boost significantly the supply of homes and ensure that a sufficient amount and variety of land can come forward where it is needed. The Local Housing Need identified through the standard method in the National Planning Practice Guidance should be met as a minimum. In terms of building a strong and competitive economy the 2024 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2024 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes and well-designed places.
1.9 In relation to Local Plan formulation, paragraphs 15 to 38 of the 2024 Framework state that Local Plans are the key to delivering sustainable development which reflect the vision and aspirations of the local community. The 2024 Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where. Paragraph 22 is clear that the Strategic policies should look ahead over a minimum period of 15 year period, and where larger scale development such as new settlements or significant extensions to existing villages and towns form part of the areas strategy, then policies should look ahead over a period of at least 30 years.
1.10 In relation to the examination of Local Plans, paragraph 36 of the 2024 Framework sets out the tests of soundness and establishes that:
Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
• Positively prepared – providing a strategy which as a minimum, seeks to meet the area’s objectively assessed need; and is informed by agreements with other authorities, so that unmet needs from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with policies in this Framework and other statements of national planning policy, where relevant.
1.11 The Local Planning Authority must demonstrate that the Local Plan Update complies with the legal and regulatory framework, including the legal requirements in ss19 and 24(1) of the Planning and Compulsory Purchase Act 2004 (PCPA 2004), Regulations under s.17 and any regulations under s. 36 relating to the preparation of DPD’s, and that the Local Plan Update is ‘Sound’, and that it complies with the Duty to Cooperate.
1.12 The PCPA 2004 requires the LPA to demonstrate that regard has been given to national policies and advice, development plan documents, and must undertake a sustainability appraisal. Plan making authorities are also required to have regard to the resources that are likely to be available for implementing the proposals1. As confirmed with legal judgements “resources” includes resources in the private sector “thus the viability and deliverability of the proposals are considerations to which the authority should have regard when preparing its policies” 2.
1.13 This document therefore considers the content of the consultation on behalf of Stratland in the light of this legal and planning policy context.
General Comments
2.1 Stratland consider that the Council needs to fully reflect the new 2024 Framework in relation to ambition and growth.
Justification
Housing and Economic Growth
2.2 Stratland welcomes a further opportunity to engage on the spatial strategy and locations for development.
2.3 The North East Derbyshire Local Plan was adopted in November 2021 and covered the period 2014-2034, which is now approaching 5 years ago. National planning policy and guidance has changed significantly in that time, with latest National Planning Policy Framework published in December 2024. This includes a refreshed approach to the standard methodology for calculating housing need.
2.4 The Framework establishes a more positive and pro-development policy framework to address the concern that the planning system is a major constraint to growth. The July 2024 Written Ministerial Statement (30th July 2024) confirms the Government’s position on restoring and raising housing targets; focussing new development into the ‘right places’ including within the Green Belt; moving towards strategic planning; building infrastructure to grow the economy; and supporting local planning.
2.5 The Framework is the immediate tool to unlock the planning system and reflects the new Labour Government’s aspirations for growth. Rachel Reeves gave a speech soon after the election to emphasise that “sustained growth is the only route to improving prosperity of our country”; that “nowhere is decisive reform needed more urgently than in our planning system”; and importantly “economic benefits of development will be a central consideration”.
2.6 Chapter 5 is all about ‘Delivering a sufficient supply of homes’ and the changes to the Framework reinforce and emphasise that local authorities should meet the identified housing need as a minimum and the baseline is the standard method. Para 62 of the NPPF states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.”
2.7 Under the standard method for calculating housing need, North East Derbyshire District Council’s local housing need requirement is set at a minimum of 605 new homes per year.
2.8 The proposed changes to the NPPF were published for consultation on 16th December 2025. The Ministerial Statement that accompanied the proposed changes states that the overhaul of the NPPF is designed “to facilitate the delivery of high and sustainable rates of housebuilding” and to “boost the housing supply and unlock economic growth”. The proposed changes create a “permanent presumption in favour of sustainable development”, secure a diverse mix of homes and streamline local standards to speed up decision making. It is appreciated that the proposed changes are out for consultation, but they are a direction of travel contained in an accompanying Written Ministerial Statement.
2.9 Therefore, there is a need for the emerging Local Plan to address the updated national planning position and provide for the housing and employment needs for the area.
Plan period
2.10 Stratland welcomes the extension of the Plan period from the consultation undertaken in August 2025. The consultation material now suggests the emerging Local Plan will cover a Plan period from 2024-2044. The Framework is clear that all strategic policies should look ahead for a minimum of 15 years from the date of adoption. However, if there are large scale urban extensions / new towns then this should be over a 30 year period. Therefore, Stratland considers that there is potential for the Local Plan to cover a longer period and plan accordingly to drive economic and housing growth that the area needs
Ambition
2.11 The Government’s ambition is to deliver sustained economic growth, improve prospective and enhance living standards. To deliver this ambition growth needs to be created throughout the country. The Local Plan Review needs to reflect the Government’s ambition and recognise the housing crisis.
2.12 Furthermore, the Local Plan Update needs to reflect the ambitions both nationally, and for the sub-region. The East Midlands Vision for Growth (May 2025) sets out the region’s bold plan which will transform the region. Delivery of the vision will create 100,000 new jobs, deliver and add £4 billion to the East Midlands economy.
2.13 This vision sets out a clear direction for the region and establishes long-term objectives that will make the East Midlands an even greater place to live, work, and visit. The plan focuses on seven key locations where there are opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
2.14 This approach needs to be reflected and enshrined within the Local Plan Update for North East Derbyshire.
Proposed Approach
2.15 To address the comments, the following approach is proposed:
• Reflect the new National Planning Policy Framework.
• With the economic ambitions and affordable housing need, the housing requirement should be set above the standard method Local Housing Need.
• Reflect the region’s ambitions and growth strategies.
Strategic Approach to the Location of Development
3.1 Stratland consider that the Council’s approach to the emerging Local Plan needs to reflect national policy and guidance and deliver the ambitions for housing and economic growth. The emerging Local Plan should not just be trying to achieve the minimum number of homes required.
3.2 The emerging Local Plan needs to address the big strategic issues of providing for new homes and businesses and supporting infrastructure.
Justification
Development Needs
3.3 The Vision needs to reflect national and regional policy ambitions. Nationally, the Government is seeking to deliver 1.5 million new homes and the housing crisis is a key policy issue to address over this parliamentary period. This flows through Written Ministerial Statements and the new Framework, which includes updated guidance and minimum housing targets, which the Vision should set out to achieve.
3.4 Furthermore, the Government seeks to increase economic growth, which is important to address prosperity and living standards, consistently highlighting that “sustained growth is the only route to improving prosperity of our country”.
3.5 Stratland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.6 Stratland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.7 The standard method calculates for North East Derbyshire that the housing need is 605 new homes per annum, or 12,100 over the 20 years of the Local Plan period. Furthermore, national policy and guidance states that Councils can choose to plan for more homes if they want to support things like economic growth or help meet housing needs in nearby areas.
3.8 The standard method represents a baseline for calculating housing need, and should not be seen as a ceiling for delivering housing. Whilst the standard method provides a minimum starting point for housing need, using household projections and affordability. It also fails to account for local economic growth, job creation, infrastructure changes, or specific demographic shifts.
3.9 Providing ambitious housing targets above the standard methodology also supports economic growth. This would match the East Midlands Vision for Growth (May 2025) which sets out the vision for transformative and ambitious growth within the region. Where significant employment growth is planned, housing supply must match job creation to avoid commuting issues and labour shortages.
3.10 At Examination, the Planning Inspectors may find the Loca Plan unsound if it fails adequately address all sources of housing need. A higher target for housing will demonstrate that the Local Plan is positively prepared, justified, and effective, which are key NPPF soundness tests.
3.11 The Local Plan should therefore establish a housing requirement above the standard method to reflect the economic ambitions for the area and affordable housing needs.
Spatial Distribution of Development
3.12 The location of development is a critical aspect of achieving sustainable development. As a general principal development should be located in areas that are accessible, sustainable, and benefit the local community.
3.13 The feedback from the August 2025 consultation shows preference towards the identification of sites that are sustainable, located in higher order settlements and that are accessible to jobs and services. Killamarsh is a Level 1 Main Settlement and is eminently sustainable.
3.14 Therefore, through engagement and dialogue appropriate sustainable opportunities should be identified within Killamarsh, such as Stratland’s site at Land off Primrose Lane, Killamarsh (Site Ref 45221).
Proposed Approach to the Location of Development
3.15 Stratland support the proposed approach which identifies Priority Locations with Priority 1 including Level 1 Settlements – Main Town locations.
3.16 Stratland consider that this is an appropriate option in identifying land required to deliver sustainable growth within the district. Development on appropriate sites within Killamarsh should be prioritised as the most appropriate and sustainable option.
3.17 Stratland consider that focusing development in Killamarsh is appropriate in delivering growth in one of the most sustainable settlements within the District, and also within close proximity to the largest settlement and City within South Yorkshire. Locating development within Killamarsh will ensure that new development has access to services, facilities, employment opportunities and access to public transport.
Settlement Hierarchy
3.18 The Settlement Hierarchy Study 2025 provides up to date information about settlements in North East Derbyshire District and the services and facilities they provide. One of the primary aims of establishing a settlement hierarchy is to promote sustainable communities by bringing housing, jobs and services closer together in an attempt to maintain and promote the viability of local facilities and reduce the need to travel to services and facilities elsewhere.
3.19 Stratland consider that the Council’s approach to the emerging Local Plan and Settlement Hierarchy is appropriate, with Clay Cross, Dronfield, Eckington and Killamarsh appropriately identified as being the four main towns within the District.
3.20 Killamarsh is situated in the north east corner of the District, immediately adjacent to the boundary with Rotherham and Sheffield. Killamarsh isa one of the larger settlements with access to services, employment opportunities across the region and public transport facilities, including Sheffield’s Supertram .
3.21 Within this context, Stratland feel that the Local Plan could strengthen the settlement hierarchy by addressing the relationship between Killamarsh and Sheffield, recognising its close proximity to the largest settlement within the South Yorkshire region.
Sustainability Appraisal
3.22 It is welcomed that the Sustainability Appraisal has been published. However, the methodology and approach appears confused and it is unclear how the scoring, ranking and assessment has been applied.
3.23 For example, it is implied that Table 3.2 is summary of the Sustainability Appraisal for each site, however it portrays an inaccurate picture. Stratland’s site at Land off Primrose Lane, Killamarsh (Site Ref 45221) is considered to have a negative score on transport. However, in the individual table it has a positive for buses and negative for railway station.
3.24 Nevertheless, the Sustainability Appraisal has not reflected the DfT connectivity tool which assesses the area to be extremely accessible and therefore the negative score is confusing.
3.25 The overall approach of the Sustainability Appraisal is confused and the methodology should be reviewed.
3.26 To address the comments, the following approach is proposed:
• Reflect national and regional policy ambitions.
• Set housing targets which are above the standard method baseline, and exceed for affordable housing and economic growth.
• Amend approach to site identification that focusses on the most appropriate and sustainable locations first.
• Review the methodology and approach of the Sustainability Appraisal.
Site 45221 – Land off Primrose Lane, Killamarsh
4.1 Stratland supports Site 45221 being short listed as a potential future housing allocation.
4.2 Stratland controls the site at Primrose Lane, Killamarsh, which is available, suitable and achievable and therefore deliverable in accordance with national planning policy and guidance.
4.3 A Vision Report has been previously submitted, which explains the deliverability of the site. With the urban context of the site a pre-application enquiry has also been submitted and a planning application is being prepared.
4.4 Stratland considers the site can come forward in the short term and make a valuable contribution to the housing land supply.
Justification
4.5 Stratland considers that their Site at Primrose Lane should be allocated for housing use within the local plan review.
4.6 The site’s location, surrounded by existing development, with no immediate technical challenges, highlights its suitability for development. The site’s proximity to local services, access to wider transport infrastructure and access to the Rother Valley Country Park mean the site offers the opportunity to extend the existing community.
4.7 Furthermore, the ‘Bolsover, Chesterfield and North East Derbyshire Economic Needs Assessment Study (March 2025)’, recognises within table 6.9 that the ‘Land Adjacent to Norwood Industrial Estate, Killamarsh’ (NED31) should no longer be identified for employment. The Study states that “ the site largely comprises undeveloped greenfield land but is contained by built development on three of the boundaries”. The Study indicates that “existing residential uses are located adjacent to two boundaries with planning permission to bring forward 50 dwellings located to the site’s western boundary”. Given the proximity of residential development it is recommend that the site’s designation as General Employment Area is removed and that residential is a more suited use.
4.8 A Vision Report has previously been prepared and submitted to the Council to support the allocation of the site within the Local Plan. The Vision Report demonstrates that the site is available, suitable and achievable and therefore deliverable in accordance with the Framework and PPG.
4.9 Given the site is within the urban area of Killamarsh, a pre-application enquiry has also been prepared and submitted and a planning application is currently being prepared, which will be submitted shortly.
4.10 Stratland’s vision for the site is to create a well-designed residential area that complements the existing community and enhances local character. The development of the site will support the Council’s and the East Midlands Region’s ambition to promote opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
4.11 The site presents an opportunity to provide housing in a sustainable location. The site is contained on all sides, bounded by residential development to the south and west, and established landscaping and employment to the east.
4.12 The ambition for the site is to prioritise the retention of key natural features, including existing trees, hedgerows along the site’s boundaries, and drainage features. Areas will be dedicated to creation of high quality public open space for the benefit of future residents, including an area of open space at the northern end of the site adjacent to the canal. The masterplan shows that the southern section of the site would be reserved for a senior living scheme, potentially a care home (C2 use class).
4.13 The principal highway access for the scheme would be achieved via Primrose Lane, entering into the south-westernmost point of the site. The development would relate well to the approved development to the west (21/00976/FL), which is currently under construction. The approval of this application has set a precedent for the principle of developing to the north of Killamarsh and establishing that this area is both sustainable and suitable for housing.
4.14 In response to the bulleted list in the consultation document relating to Site 45221 the Vision Report, pre-application enquiry and forthcoming planning application have been informed by technical assessments, which are briefly summarised below and further on in this representation:
• The proposed scheme is for circa 100 dwellings and a care home.
• The proposed scheme and illustrative masterplan reflects the Chesterfield Canal and provides open space at the northern end of the site adjacent to the canal.
• Heritage: Heritage assessment has been undertaken and there are no archaeological or heritage constraints to the scheme.
• Ecology: Preliminary Ecological Appraisal and BNG assessment and there are no ecological or constraints to the scheme.
• Highways: AMA has undertaken a Transport Assessment and there are no highways constraints to the scheme.
• Flood Risk and Drainage: Flood Risk and Drainage Appraisal has been undertaken and there are no flood risk or drainage constraints to the scheme.
• Employment: The site is an employment allocation in the adopted Local Plan, however the Council’s Economic Needs Study considers the site is not an appropriate employment site given its residential neighbours and therefore suggests the site be reallocated for residential use.
• Health and Safety Executive Zone: The HSE zone is at the far northern end of the site and within the illustrative masterplan is shown for open space.
• Geo-Environmental: Preliminary ground investigation has been undertaken and there are no geo-environmental constraints
• Agricultural Land: The site is not Best and Most Versatile agricultural land.
4.15 Overall, this is a scheme that has strong potential to balance connectivity, sustainability, and community well-being. It will create a vibrant, healthy, and resilient place for people to live, work, and thrive, while preserving the distinct identity of Killamarsh.
Availability
4.16 Stratland has a legal agreement with the landowners to promote and develop the land for housing. Stratland is proud of their reputation for working with local and national builders to deliver high-quality desirable homes in sustainable locations. The Site is currently available for residential development which can be brought forward early within the local plan period, representing a short term opportunity.
4.17 The masterplan and constraints plan demonstrate that appropriate access point can be achieved for the Site. The scheme will also be able to deliver off-site highways contributions for any further works required. This would therefore not represent a constraint in the Site being available.
4.18 It is demonstrated that significant BNG uplift can be delivered on the Site, and that these matters would not represent constraints in the site being available.
4.19 The land is therefore “available” in accordance with the Framework and the Planning Practice Guidance.
Suitability
4.20 Stratland believe that the site is suitable for residential development, with no constraints that cannot be appropriately mitigated or that would represent the site being unsuitable.
4.21 The proposed development can make an efficient and attractive use of the land. Although greenfield land, the Site represents an excellent opportunity for future housing and development. This site would allow housing to be delivered within an appropriate and sustainable location at Killamarsh. The development of this site would assist in creating a logical extension to the built up urban area.
4.22 The site is located within a highly sustainable location, within one of the principal towns and most sustainable settlements within the district, as identified within the Statutory Development Plan and Settlement Hierarchy.
4.23 The site is 850m from Killamarsh Local Centre, which includes Aldi, Fulton Foods, Co-op Food, a Medical Clinic, a library and several local services like hair salons, a bakery, and a café. Killamarsh Infant and Junior School is very close to the site, accessible off Primrose Lane on Sheffield Road. Other schools, including St Giles CE Primary and Killamarsh Bears Pre School, are also within walking distance.
4.24 Rother Valley Country Park is within walking distance, offering 750 acres of trails, a nature reserve, and leisure attractions like Sheffield Cable Waterski & Aqua Park. Nearby, Rother Valley Golf Centre and Gulliver’s Valley Theme Park offer additional recreational opportunities
4.25 The site offers excellent connectivity, located within 2.5km of the Halfway Park & Ride, benefiting from frequent tram and bus services to Sheffield City Centre. Furthermore, bus stops within close proximity link to Crystal Peaks shopping centre and Sheffield. Kiveton Park train station is approximately 3km away, however the proposed reopening of the Barrow Hill Line will significantly improve regional connections. The proposed Killamarsh station will further enhance access to key employment and education hubs in Sheffield and Chesterfield and support strategic housing developments along the Staveley Growth Corridor.
4.26 The site is almost entirely within Flood Zone 1 and is of low risk in terms of fluvial and surface water flooding, with some small areas situated in Flood Zone 2/3. The site generally falls from the southern boundary down to the northern and eastern/ western boundaries. Remaining elements of the Chesterfield Canal is to the north east of the site. It is considered that any areas within the higher flood zone risk areas can be easily excluded from the developable area, and utilised for either landscaping, public open space and/or drainage attenuation.
4.27 A small portion of the perimeter of the site falls within a Hazardous Installation Inner Zone and would therefore be precluded from housing development, but is suitable for ecology, habitat and open space.
4.28 The site is not located within or adjacent to a Conversation Area and there are no listed buildings within close proximity. As a result, it is considered that development of the Site will not affect any national or local heritage features.
4.29 There are no statutory ecological designations or known priority habitats on the Site. Any development would utilise existing tree belts and features, with reinforced landscaping and planting. The Ste is currently made up of arable fields, which therefore have a monoculture of limited specifies diversity, and limited ecological value or importance.
4.30 There is a clear need for new sites to come forward for housing to support the growth ambitions for the East Midlands region. The Site provides an important opportunity to meet local housing needs. The proposed residential development would be developed to a high-quality design standard that respects the nature of the surrounding area. The development of the site for housing presents an ideal opportunity to address local housing needs by providing a diverse range of affordable and aspirational homes for families, older adults, and young professionals.
4.31 The site provides a unique opportunity that will benefit the area and wider district with economic, environmental and social benefits. The technical work that underpins the masterplan confirms that there are no known constraints to development. It is therefore considered that the proposed allocation of the site is suitable, in accordance with national guidance and PPG
4.32 The land is therefore “suitable” in accordance with the Framework and the Planning Practice Guidance.
Deliverability
4.33 Stratland consider that the site can come forward immediately and be delivered in the short term (1-5 years) of the Local Plan Period. The masterplan and constraints plan provided show that there are no significant issues preventing the site coming forward, with solutions on site to address availability and suitability concerns.
4.34 The proposed development is located within close proximity to existing services and facilities. The indicative masterplan represents an efficient use of the land available. The scheme is therefore making an efficient and effective use of land and infrastructure.
4.35 The site provides a development opportunity that is available, suitable and achievable and therefore it is considered that the site is deliverable, in accordance with national planning policy and guidance. It is promoted by Stratland and is deliverable within the plan period.
Achievable
4.36 A range of technical work has been undertaken and is ongoing. From these initial assessments there are no technical issues that would prevent the delivery of the site for residential purposes. The technical reports will show how a mix of housing can be accommodated within the site, alongside connectivity, landscaping and drainage features.
4.37 The Framework requires Local Planning Authorities to meet their full objectively assessed housing need. Stratland considers that the site is deliverable in the short term (1-5 years) and will reinforce the housing supply and address the Council’s housing needs in the Local Plan period. Development of this Site will support the delivery of a range of housing types and contribute towards meeting identified needs
4.38 It will be evidenced that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
A Positive Response to the Key Objectives of the Framework
4.39 The Framework sets out that the Governments key housing policy goal of significantly boosting the supply of housing and proactively driving and supporting sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs. The Framework explains that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as extensions to towns, and creating mixed and sustainable communities with good access to jobs, key services and infrastructure. Sites should also make effective use of land and existing infrastructure.
4.40 In relation to the Framework:
• The proposal responds positively towards national guidance.
• The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.
• The proposed site is accessible to existing employment, local community facilities, infrastructure and services, including public transport.
• The site has been assessed as being is available, suitable and achievable for development.
Benefits of Site Reference 45221 – Land off Primrose Lane, Killamarsh
4.41 The development of the site would provide significant economic, social and environmental benefits. The site would provide housing that would meet the needs of the North-East Derbyshire District Council’s housing market in a sustainable location.
4.42 In accordance with the Framework this representation has shown that:
• The site is suitable for housing and can deliver circa 100 new homes and a care home.
• The proposal can provide a good mix of housing commensurate to the demand and need in the area and diversify the housing stock
• The site is within a sustainable location situated in close proximity to facilities and services and also to bus stops for local bus routes.
• The scheme uses land efficiently and effectively.
• The proposal is in line with planning for housing objectives.
• The scheme will create direct and indirect job opportunities both during and after construction, as well as employment opportunities through an C2 use on the Site.
• The site can deliver new areas of public open space.
4.43 The proposal is an appropriate site to provide for the housing needs of Killamarsh and the wider East Midlands region during the Local Plan period. Confirmation of the allocation will contribute positively to a balanced housing supply in the area in sustainable locations. The site can deliver a full range and mix of housing as part of a sustainable community. Development of the site would deliver affordable housing. North-East Derbyshire District Council needs to have a robust housing trajectory with a sufficient supply of deliverable sites. The site will assist with this delivery in the medium term. The site is situated within a prime location suitable for residential development and as such would facilitate the development of land in an effective and efficient manner. Development of the site would not harm or undermine the area’s wider policy objectives but seeks to reinforce the need to develop sites within sustainable locations as a priority.
4.44 The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.
4.45 To address the comments, the following approach is proposed:
• Allocate the site at Primrose Lane, Killamarsh for housing purposes.

1.1 North East Derbyshire District Council (hereafter referred to as ‘the Council’) are reviewing the current local plan to ensure that it reflects changes to the district’s housing requirements along with new legislation and guidance introduced by the government. The Council is seeking to engage with key stakeholders, including individuals and organisations who have an interest in the district (in accordance with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012).
1.2 Spawforths have been instructed by Stratland to submit representations to the North East Derbyshire District Council Local Plan Review Regulation 18 Consultation on the Strategic Approach to the Location of Development and Refined Sites.
1.3 Stratland have significant interest within North East Derbyshire, which can positively contribute to the housing and economic growth agenda, and therefore welcome the opportunity to engage with the Council in the preparation of an updated Local Plan. Stratland’s site is Land off Primrose Lane, Killamarsh (Site 45221) and a Vision Report has been previously submitted.
1.4 Stratland would like to make comments on the following topics and sections of the North East Derbyshire District Local Plan Review:
• General Comments
• Strategic Approach
• Refined Schedule of Sites: Site 45221 - Land off Primrose Lane, Killamarsh
1.5 In each case, observations are set out with reference to the provisions of the National Planning Policy Framework (hereafter referred to as “the Framework”) and where necessary, amendments are suggested to ensure that the Local Plan Update is found sound.
1.6 Stratland welcomes the opportunity for further engagement and the opportunity to appear at Examination in Public.
1.7 We trust that you will confirm that these representations are duly made and will give due consideration to these comments. Please do not hesitate to contact us to discuss any issues raised in this Representation further.
1.8 The Governments core objectives as established through the 2024 National Planning Policy Framework are sustainable development and growth. Paragraph 11 of the 2024 Framework stresses the need for Local Plans to meet, as a minimum, the objectively assessed needs of an area. The 2024 Framework sets out to boost significantly the supply of homes and ensure that a sufficient amount and variety of land can come forward where it is needed. The Local Housing Need identified through the standard method in the National Planning Practice Guidance should be met as a minimum. In terms of building a strong and competitive economy the 2024 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2024 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes and well-designed places.
1.9 In relation to Local Plan formulation, paragraphs 15 to 38 of the 2024 Framework state that Local Plans are the key to delivering sustainable development which reflect the vision and aspirations of the local community. The 2024 Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where. Paragraph 22 is clear that the Strategic policies should look ahead over a minimum period of 15 year period, and where larger scale development such as new settlements or significant extensions to existing villages and towns form part of the areas strategy, then policies should look ahead over a period of at least 30 years.
1.10 In relation to the examination of Local Plans, paragraph 36 of the 2024 Framework sets out the tests of soundness and establishes that:
Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
• Positively prepared – providing a strategy which as a minimum, seeks to meet the area’s objectively assessed need; and is informed by agreements with other authorities, so that unmet needs from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with policies in this Framework and other statements of national planning policy, where relevant.
1.11 The Local Planning Authority must demonstrate that the Local Plan Update complies with the legal and regulatory framework, including the legal requirements in ss19 and 24(1) of the Planning and Compulsory Purchase Act 2004 (PCPA 2004), Regulations under s.17 and any regulations under s. 36 relating to the preparation of DPD’s, and that the Local Plan Update is ‘Sound’, and that it complies with the Duty to Cooperate.
1.12 The PCPA 2004 requires the LPA to demonstrate that regard has been given to national policies and advice, development plan documents, and must undertake a sustainability appraisal. Plan making authorities are also required to have regard to the resources that are likely to be available for implementing the proposals1. As confirmed with legal judgements “resources” includes resources in the private sector “thus the viability and deliverability of the proposals are considerations to which the authority should have regard when preparing its policies” 2.
1.13 This document therefore considers the content of the consultation on behalf of Stratland in the light of this legal and planning policy context.
General Comments
2.1 Stratland consider that the Council needs to fully reflect the new 2024 Framework in relation to ambition and growth.
Justification
Housing and Economic Growth
2.2 Stratland welcomes a further opportunity to engage on the spatial strategy and locations for development.
2.3 The North East Derbyshire Local Plan was adopted in November 2021 and covered the period 2014-2034, which is now approaching 5 years ago. National planning policy and guidance has changed significantly in that time, with latest National Planning Policy Framework published in December 2024. This includes a refreshed approach to the standard methodology for calculating housing need.
2.4 The Framework establishes a more positive and pro-development policy framework to address the concern that the planning system is a major constraint to growth. The July 2024 Written Ministerial Statement (30th July 2024) confirms the Government’s position on restoring and raising housing targets; focussing new development into the ‘right places’ including within the Green Belt; moving towards strategic planning; building infrastructure to grow the economy; and supporting local planning.
2.5 The Framework is the immediate tool to unlock the planning system and reflects the new Labour Government’s aspirations for growth. Rachel Reeves gave a speech soon after the election to emphasise that “sustained growth is the only route to improving prosperity of our country”; that “nowhere is decisive reform needed more urgently than in our planning system”; and importantly “economic benefits of development will be a central consideration”.
2.6 Chapter 5 is all about ‘Delivering a sufficient supply of homes’ and the changes to the Framework reinforce and emphasise that local authorities should meet the identified housing need as a minimum and the baseline is the standard method. Para 62 of the NPPF states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.”
2.7 Under the standard method for calculating housing need, North East Derbyshire District Council’s local housing need requirement is set at a minimum of 605 new homes per year.
2.8 The proposed changes to the NPPF were published for consultation on 16th December 2025. The Ministerial Statement that accompanied the proposed changes states that the overhaul of the NPPF is designed “to facilitate the delivery of high and sustainable rates of housebuilding” and to “boost the housing supply and unlock economic growth”. The proposed changes create a “permanent presumption in favour of sustainable development”, secure a diverse mix of homes and streamline local standards to speed up decision making. It is appreciated that the proposed changes are out for consultation, but they are a direction of travel contained in an accompanying Written Ministerial Statement.
2.9 Therefore, there is a need for the emerging Local Plan to address the updated national planning position and provide for the housing and employment needs for the area.
Plan period
2.10 Stratland welcomes the extension of the Plan period from the consultation undertaken in August 2025. The consultation material now suggests the emerging Local Plan will cover a Plan period from 2024-2044. The Framework is clear that all strategic policies should look ahead for a minimum of 15 years from the date of adoption. However, if there are large scale urban extensions / new towns then this should be over a 30 year period. Therefore, Stratland considers that there is potential for the Local Plan to cover a longer period and plan accordingly to drive economic and housing growth that the area needs
Ambition
2.11 The Government’s ambition is to deliver sustained economic growth, improve prospective and enhance living standards. To deliver this ambition growth needs to be created throughout the country. The Local Plan Review needs to reflect the Government’s ambition and recognise the housing crisis.
2.12 Furthermore, the Local Plan Update needs to reflect the ambitions both nationally, and for the sub-region. The East Midlands Vision for Growth (May 2025) sets out the region’s bold plan which will transform the region. Delivery of the vision will create 100,000 new jobs, deliver and add £4 billion to the East Midlands economy.
2.13 This vision sets out a clear direction for the region and establishes long-term objectives that will make the East Midlands an even greater place to live, work, and visit. The plan focuses on seven key locations where there are opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
2.14 This approach needs to be reflected and enshrined within the Local Plan Update for North East Derbyshire.
Proposed Approach
2.15 To address the comments, the following approach is proposed:
• Reflect the new National Planning Policy Framework.
• With the economic ambitions and affordable housing need, the housing requirement should be set above the standard method Local Housing Need.
• Reflect the region’s ambitions and growth strategies.
Strategic Approach to the Location of Development
3.1 Stratland consider that the Council’s approach to the emerging Local Plan needs to reflect national policy and guidance and deliver the ambitions for housing and economic growth. The emerging Local Plan should not just be trying to achieve the minimum number of homes required.
3.2 The emerging Local Plan needs to address the big strategic issues of providing for new homes and businesses and supporting infrastructure.
Justification
Development Needs
3.3 The Vision needs to reflect national and regional policy ambitions. Nationally, the Government is seeking to deliver 1.5 million new homes and the housing crisis is a key policy issue to address over this parliamentary period. This flows through Written Ministerial Statements and the new Framework, which includes updated guidance and minimum housing targets, which the Vision should set out to achieve.
3.4 Furthermore, the Government seeks to increase economic growth, which is important to address prosperity and living standards, consistently highlighting that “sustained growth is the only route to improving prosperity of our country”.
3.5 Stratland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.6 Stratland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.7 The standard method calculates for North East Derbyshire that the housing need is 605 new homes per annum, or 12,100 over the 20 years of the Local Plan period. Furthermore, national policy and guidance states that Councils can choose to plan for more homes if they want to support things like economic growth or help meet housing needs in nearby areas.
3.8 The standard method represents a baseline for calculating housing need, and should not be seen as a ceiling for delivering housing. Whilst the standard method provides a minimum starting point for housing need, using household projections and affordability. It also fails to account for local economic growth, job creation, infrastructure changes, or specific demographic shifts.
3.9 Providing ambitious housing targets above the standard methodology also supports economic growth. This would match the East Midlands Vision for Growth (May 2025) which sets out the vision for transformative and ambitious growth within the region. Where significant employment growth is planned, housing supply must match job creation to avoid commuting issues and labour shortages.
3.10 At Examination, the Planning Inspectors may find the Loca Plan unsound if it fails adequately address all sources of housing need. A higher target for housing will demonstrate that the Local Plan is positively prepared, justified, and effective, which are key NPPF soundness tests.
3.11 The Local Plan should therefore establish a housing requirement above the standard method to reflect the economic ambitions for the area and affordable housing needs.
Spatial Distribution of Development
3.12 The location of development is a critical aspect of achieving sustainable development. As a general principal development should be located in areas that are accessible, sustainable, and benefit the local community.
3.13 The feedback from the August 2025 consultation shows preference towards the identification of sites that are sustainable, located in higher order settlements and that are accessible to jobs and services. Killamarsh is a Level 1 Main Settlement and is eminently sustainable.
3.14 Therefore, through engagement and dialogue appropriate sustainable opportunities should be identified within Killamarsh, such as Stratland’s site at Land off Primrose Lane, Killamarsh (Site Ref 45221).
Proposed Approach to the Location of Development
3.15 Stratland support the proposed approach which identifies Priority Locations with Priority 1 including Level 1 Settlements – Main Town locations.
3.16 Stratland consider that this is an appropriate option in identifying land required to deliver sustainable growth within the district. Development on appropriate sites within Killamarsh should be prioritised as the most appropriate and sustainable option.
3.17 Stratland consider that focusing development in Killamarsh is appropriate in delivering growth in one of the most sustainable settlements within the District, and also within close proximity to the largest settlement and City within South Yorkshire. Locating development within Killamarsh will ensure that new development has access to services, facilities, employment opportunities and access to public transport.
Settlement Hierarchy
3.18 The Settlement Hierarchy Study 2025 provides up to date information about settlements in North East Derbyshire District and the services and facilities they provide. One of the primary aims of establishing a settlement hierarchy is to promote sustainable communities by bringing housing, jobs and services closer together in an attempt to maintain and promote the viability of local facilities and reduce the need to travel to services and facilities elsewhere.
3.19 Stratland consider that the Council’s approach to the emerging Local Plan and Settlement Hierarchy is appropriate, with Clay Cross, Dronfield, Eckington and Killamarsh appropriately identified as being the four main towns within the District.
3.20 Killamarsh is situated in the north east corner of the District, immediately adjacent to the boundary with Rotherham and Sheffield. Killamarsh isa one of the larger settlements with access to services, employment opportunities across the region and public transport facilities, including Sheffield’s Supertram .
3.21 Within this context, Stratland feel that the Local Plan could strengthen the settlement hierarchy by addressing the relationship between Killamarsh and Sheffield, recognising its close proximity to the largest settlement within the South Yorkshire region.
Sustainability Appraisal
3.22 It is welcomed that the Sustainability Appraisal has been published. However, the methodology and approach appears confused and it is unclear how the scoring, ranking and assessment has been applied.
3.23 For example, it is implied that Table 3.2 is summary of the Sustainability Appraisal for each site, however it portrays an inaccurate picture. Stratland’s site at Land off Primrose Lane, Killamarsh (Site Ref 45221) is considered to have a negative score on transport. However, in the individual table it has a positive for buses and negative for railway station.
3.24 Nevertheless, the Sustainability Appraisal has not reflected the DfT connectivity tool which assesses the area to be extremely accessible and therefore the negative score is confusing.
3.25 The overall approach of the Sustainability Appraisal is confused and the methodology should be reviewed.
3.26 To address the comments, the following approach is proposed:
• Reflect national and regional policy ambitions.
• Set housing targets which are above the standard method baseline, and exceed for affordable housing and economic growth.
• Amend approach to site identification that focusses on the most appropriate and sustainable locations first.
• Review the methodology and approach of the Sustainability Appraisal.
Site 45221 – Land off Primrose Lane, Killamarsh
4.1 Stratland supports Site 45221 being short listed as a potential future housing allocation.
4.2 Stratland controls the site at Primrose Lane, Killamarsh, which is available, suitable and achievable and therefore deliverable in accordance with national planning policy and guidance.
4.3 A Vision Report has been previously submitted, which explains the deliverability of the site. With the urban context of the site a pre-application enquiry has also been submitted and a planning application is being prepared.
4.4 Stratland considers the site can come forward in the short term and make a valuable contribution to the housing land supply.
Justification
4.5 Stratland considers that their Site at Primrose Lane should be allocated for housing use within the local plan review.
4.6 The site’s location, surrounded by existing development, with no immediate technical challenges, highlights its suitability for development. The site’s proximity to local services, access to wider transport infrastructure and access to the Rother Valley Country Park mean the site offers the opportunity to extend the existing community.
4.7 Furthermore, the ‘Bolsover, Chesterfield and North East Derbyshire Economic Needs Assessment Study (March 2025)’, recognises within table 6.9 that the ‘Land Adjacent to Norwood Industrial Estate, Killamarsh’ (NED31) should no longer be identified for employment. The Study states that “ the site largely comprises undeveloped greenfield land but is contained by built development on three of the boundaries”. The Study indicates that “existing residential uses are located adjacent to two boundaries with planning permission to bring forward 50 dwellings located to the site’s western boundary”. Given the proximity of residential development it is recommend that the site’s designation as General Employment Area is removed and that residential is a more suited use.
4.8 A Vision Report has previously been prepared and submitted to the Council to support the allocation of the site within the Local Plan. The Vision Report demonstrates that the site is available, suitable and achievable and therefore deliverable in accordance with the Framework and PPG.
4.9 Given the site is within the urban area of Killamarsh, a pre-application enquiry has also been prepared and submitted and a planning application is currently being prepared, which will be submitted shortly.
4.10 Stratland’s vision for the site is to create a well-designed residential area that complements the existing community and enhances local character. The development of the site will support the Council’s and the East Midlands Region’s ambition to promote opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
4.11 The site presents an opportunity to provide housing in a sustainable location. The site is contained on all sides, bounded by residential development to the south and west, and established landscaping and employment to the east.
4.12 The ambition for the site is to prioritise the retention of key natural features, including existing trees, hedgerows along the site’s boundaries, and drainage features. Areas will be dedicated to creation of high quality public open space for the benefit of future residents, including an area of open space at the northern end of the site adjacent to the canal. The masterplan shows that the southern section of the site would be reserved for a senior living scheme, potentially a care home (C2 use class).
4.13 The principal highway access for the scheme would be achieved via Primrose Lane, entering into the south-westernmost point of the site. The development would relate well to the approved development to the west (21/00976/FL), which is currently under construction. The approval of this application has set a precedent for the principle of developing to the north of Killamarsh and establishing that this area is both sustainable and suitable for housing.
4.14 In response to the bulleted list in the consultation document relating to Site 45221 the Vision Report, pre-application enquiry and forthcoming planning application have been informed by technical assessments, which are briefly summarised below and further on in this representation:
• The proposed scheme is for circa 100 dwellings and a care home.
• The proposed scheme and illustrative masterplan reflects the Chesterfield Canal and provides open space at the northern end of the site adjacent to the canal.
• Heritage: Heritage assessment has been undertaken and there are no archaeological or heritage constraints to the scheme.
• Ecology: Preliminary Ecological Appraisal and BNG assessment and there are no ecological or constraints to the scheme.
• Highways: AMA has undertaken a Transport Assessment and there are no highways constraints to the scheme.
• Flood Risk and Drainage: Flood Risk and Drainage Appraisal has been undertaken and there are no flood risk or drainage constraints to the scheme.
• Employment: The site is an employment allocation in the adopted Local Plan, however the Council’s Economic Needs Study considers the site is not an appropriate employment site given its residential neighbours and therefore suggests the site be reallocated for residential use.
• Health and Safety Executive Zone: The HSE zone is at the far northern end of the site and within the illustrative masterplan is shown for open space.
• Geo-Environmental: Preliminary ground investigation has been undertaken and there are no geo-environmental constraints
• Agricultural Land: The site is not Best and Most Versatile agricultural land.
4.15 Overall, this is a scheme that has strong potential to balance connectivity, sustainability, and community well-being. It will create a vibrant, healthy, and resilient place for people to live, work, and thrive, while preserving the distinct identity of Killamarsh.
Availability
4.16 Stratland has a legal agreement with the landowners to promote and develop the land for housing. Stratland is proud of their reputation for working with local and national builders to deliver high-quality desirable homes in sustainable locations. The Site is currently available for residential development which can be brought forward early within the local plan period, representing a short term opportunity.
4.17 The masterplan and constraints plan demonstrate that appropriate access point can be achieved for the Site. The scheme will also be able to deliver off-site highways contributions for any further works required. This would therefore not represent a constraint in the Site being available.
4.18 It is demonstrated that significant BNG uplift can be delivered on the Site, and that these matters would not represent constraints in the site being available.
4.19 The land is therefore “available” in accordance with the Framework and the Planning Practice Guidance.
Suitability
4.20 Stratland believe that the site is suitable for residential development, with no constraints that cannot be appropriately mitigated or that would represent the site being unsuitable.
4.21 The proposed development can make an efficient and attractive use of the land. Although greenfield land, the Site represents an excellent opportunity for future housing and development. This site would allow housing to be delivered within an appropriate and sustainable location at Killamarsh. The development of this site would assist in creating a logical extension to the built up urban area.
4.22 The site is located within a highly sustainable location, within one of the principal towns and most sustainable settlements within the district, as identified within the Statutory Development Plan and Settlement Hierarchy.
4.23 The site is 850m from Killamarsh Local Centre, which includes Aldi, Fulton Foods, Co-op Food, a Medical Clinic, a library and several local services like hair salons, a bakery, and a café. Killamarsh Infant and Junior School is very close to the site, accessible off Primrose Lane on Sheffield Road. Other schools, including St Giles CE Primary and Killamarsh Bears Pre School, are also within walking distance.
4.24 Rother Valley Country Park is within walking distance, offering 750 acres of trails, a nature reserve, and leisure attractions like Sheffield Cable Waterski & Aqua Park. Nearby, Rother Valley Golf Centre and Gulliver’s Valley Theme Park offer additional recreational opportunities
4.25 The site offers excellent connectivity, located within 2.5km of the Halfway Park & Ride, benefiting from frequent tram and bus services to Sheffield City Centre. Furthermore, bus stops within close proximity link to Crystal Peaks shopping centre and Sheffield. Kiveton Park train station is approximately 3km away, however the proposed reopening of the Barrow Hill Line will significantly improve regional connections. The proposed Killamarsh station will further enhance access to key employment and education hubs in Sheffield and Chesterfield and support strategic housing developments along the Staveley Growth Corridor.
4.26 The site is almost entirely within Flood Zone 1 and is of low risk in terms of fluvial and surface water flooding, with some small areas situated in Flood Zone 2/3. The site generally falls from the southern boundary down to the northern and eastern/ western boundaries. Remaining elements of the Chesterfield Canal is to the north east of the site. It is considered that any areas within the higher flood zone risk areas can be easily excluded from the developable area, and utilised for either landscaping, public open space and/or drainage attenuation.
4.27 A small portion of the perimeter of the site falls within a Hazardous Installation Inner Zone and would therefore be precluded from housing development, but is suitable for ecology, habitat and open space.
4.28 The site is not located within or adjacent to a Conversation Area and there are no listed buildings within close proximity. As a result, it is considered that development of the Site will not affect any national or local heritage features.
4.29 There are no statutory ecological designations or known priority habitats on the Site. Any development would utilise existing tree belts and features, with reinforced landscaping and planting. The Ste is currently made up of arable fields, which therefore have a monoculture of limited specifies diversity, and limited ecological value or importance.
4.30 There is a clear need for new sites to come forward for housing to support the growth ambitions for the East Midlands region. The Site provides an important opportunity to meet local housing needs. The proposed residential development would be developed to a high-quality design standard that respects the nature of the surrounding area. The development of the site for housing presents an ideal opportunity to address local housing needs by providing a diverse range of affordable and aspirational homes for families, older adults, and young professionals.
4.31 The site provides a unique opportunity that will benefit the area and wider district with economic, environmental and social benefits. The technical work that underpins the masterplan confirms that there are no known constraints to development. It is therefore considered that the proposed allocation of the site is suitable, in accordance with national guidance and PPG
4.32 The land is therefore “suitable” in accordance with the Framework and the Planning Practice Guidance.
Deliverability
4.33 Stratland consider that the site can come forward immediately and be delivered in the short term (1-5 years) of the Local Plan Period. The masterplan and constraints plan provided show that there are no significant issues preventing the site coming forward, with solutions on site to address availability and suitability concerns.
4.34 The proposed development is located within close proximity to existing services and facilities. The indicative masterplan represents an efficient use of the land available. The scheme is therefore making an efficient and effective use of land and infrastructure.
4.35 The site provides a development opportunity that is available, suitable and achievable and therefore it is considered that the site is deliverable, in accordance with national planning policy and guidance. It is promoted by Stratland and is deliverable within the plan period.
Achievable
4.36 A range of technical work has been undertaken and is ongoing. From these initial assessments there are no technical issues that would prevent the delivery of the site for residential purposes. The technical reports will show how a mix of housing can be accommodated within the site, alongside connectivity, landscaping and drainage features.
4.37 The Framework requires Local Planning Authorities to meet their full objectively assessed housing need. Stratland considers that the site is deliverable in the short term (1-5 years) and will reinforce the housing supply and address the Council’s housing needs in the Local Plan period. Development of this Site will support the delivery of a range of housing types and contribute towards meeting identified needs
4.38 It will be evidenced that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
A Positive Response to the Key Objectives of the Framework
4.39 The Framework sets out that the Governments key housing policy goal of significantly boosting the supply of housing and proactively driving and supporting sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs. The Framework explains that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as extensions to towns, and creating mixed and sustainable communities with good access to jobs, key services and infrastructure. Sites should also make effective use of land and existing infrastructure.
4.40 In relation to the Framework:
• The proposal responds positively towards national guidance.
• The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.
• The proposed site is accessible to existing employment, local community facilities, infrastructure and services, including public transport.
• The site has been assessed as being is available, suitable and achievable for development.
Benefits of Site Reference 45221 – Land off Primrose Lane, Killamarsh
4.41 The development of the site would provide significant economic, social and environmental benefits. The site would provide housing that would meet the needs of the North-East Derbyshire District Council’s housing market in a sustainable location.
4.42 In accordance with the Framework this representation has shown that:
• The site is suitable for housing and can deliver circa 100 new homes and a care home.
• The proposal can provide a good mix of housing commensurate to the demand and need in the area and diversify the housing stock
• The site is within a sustainable location situated in close proximity to facilities and services and also to bus stops for local bus routes.
• The scheme uses land efficiently and effectively.
• The proposal is in line with planning for housing objectives.
• The scheme will create direct and indirect job opportunities both during and after construction, as well as employment opportunities through an C2 use on the Site.
• The site can deliver new areas of public open space.
4.43 The proposal is an appropriate site to provide for the housing needs of Killamarsh and the wider East Midlands region during the Local Plan period. Confirmation of the allocation will contribute positively to a balanced housing supply in the area in sustainable locations. The site can deliver a full range and mix of housing as part of a sustainable community. Development of the site would deliver affordable housing. North-East Derbyshire District Council needs to have a robust housing trajectory with a sufficient supply of deliverable sites. The site will assist with this delivery in the medium term. The site is situated within a prime location suitable for residential development and as such would facilitate the development of land in an effective and efficient manner. Development of the site would not harm or undermine the area’s wider policy objectives but seeks to reinforce the need to develop sites within sustainable locations as a priority.
4.44 The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.
4.45 To address the comments, the following approach is proposed:
• Allocate the site at Primrose Lane, Killamarsh for housing purposes.

1.1 North East Derbyshire District Council (hereafter referred to as ‘the Council’) are reviewing the current local plan to ensure that it reflects changes to the district’s housing requirements along with new legislation and guidance introduced by the government. The Council is seeking to engage with key stakeholders, including individuals and organisations who have an interest in the district (in accordance with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012).
1.2 Spawforths have been instructed by Stratland to submit representations to the North East Derbyshire District Council Local Plan Review Regulation 18 Consultation on the Strategic Approach to the Location of Development and Refined Sites.
1.3 Stratland have significant interest within North East Derbyshire, which can positively contribute to the housing and economic growth agenda, and therefore welcome the opportunity to engage with the Council in the preparation of an updated Local Plan. Stratland’s site is Land off Primrose Lane, Killamarsh (Site 45221) and a Vision Report has been previously submitted.
1.4 Stratland would like to make comments on the following topics and sections of the North East Derbyshire District Local Plan Review:
• General Comments
• Strategic Approach
• Refined Schedule of Sites: Site 45221 - Land off Primrose Lane, Killamarsh
1.5 In each case, observations are set out with reference to the provisions of the National Planning Policy Framework (hereafter referred to as “the Framework”) and where necessary, amendments are suggested to ensure that the Local Plan Update is found sound.
1.6 Stratland welcomes the opportunity for further engagement and the opportunity to appear at Examination in Public.
1.7 We trust that you will confirm that these representations are duly made and will give due consideration to these comments. Please do not hesitate to contact us to discuss any issues raised in this Representation further.
1.8 The Governments core objectives as established through the 2024 National Planning Policy Framework are sustainable development and growth. Paragraph 11 of the 2024 Framework stresses the need for Local Plans to meet, as a minimum, the objectively assessed needs of an area. The 2024 Framework sets out to boost significantly the supply of homes and ensure that a sufficient amount and variety of land can come forward where it is needed. The Local Housing Need identified through the standard method in the National Planning Practice Guidance should be met as a minimum. In terms of building a strong and competitive economy the 2024 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2024 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes and well-designed places.
1.9 In relation to Local Plan formulation, paragraphs 15 to 38 of the 2024 Framework state that Local Plans are the key to delivering sustainable development which reflect the vision and aspirations of the local community. The 2024 Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where. Paragraph 22 is clear that the Strategic policies should look ahead over a minimum period of 15 year period, and where larger scale development such as new settlements or significant extensions to existing villages and towns form part of the areas strategy, then policies should look ahead over a period of at least 30 years.
1.10 In relation to the examination of Local Plans, paragraph 36 of the 2024 Framework sets out the tests of soundness and establishes that:
Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
• Positively prepared – providing a strategy which as a minimum, seeks to meet the area’s objectively assessed need; and is informed by agreements with other authorities, so that unmet needs from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with policies in this Framework and other statements of national planning policy, where relevant.
1.11 The Local Planning Authority must demonstrate that the Local Plan Update complies with the legal and regulatory framework, including the legal requirements in ss19 and 24(1) of the Planning and Compulsory Purchase Act 2004 (PCPA 2004), Regulations under s.17 and any regulations under s. 36 relating to the preparation of DPD’s, and that the Local Plan Update is ‘Sound’, and that it complies with the Duty to Cooperate.
1.12 The PCPA 2004 requires the LPA to demonstrate that regard has been given to national policies and advice, development plan documents, and must undertake a sustainability appraisal. Plan making authorities are also required to have regard to the resources that are likely to be available for implementing the proposals1. As confirmed with legal judgements “resources” includes resources in the private sector “thus the viability and deliverability of the proposals are considerations to which the authority should have regard when preparing its policies” 2.
1.13 This document therefore considers the content of the consultation on behalf of Stratland in the light of this legal and planning policy context.
General Comments
2.1 Stratland consider that the Council needs to fully reflect the new 2024 Framework in relation to ambition and growth.
Justification
Housing and Economic Growth
2.2 Stratland welcomes a further opportunity to engage on the spatial strategy and locations for development.
2.3 The North East Derbyshire Local Plan was adopted in November 2021 and covered the period 2014-2034, which is now approaching 5 years ago. National planning policy and guidance has changed significantly in that time, with latest National Planning Policy Framework published in December 2024. This includes a refreshed approach to the standard methodology for calculating housing need.
2.4 The Framework establishes a more positive and pro-development policy framework to address the concern that the planning system is a major constraint to growth. The July 2024 Written Ministerial Statement (30th July 2024) confirms the Government’s position on restoring and raising housing targets; focussing new development into the ‘right places’ including within the Green Belt; moving towards strategic planning; building infrastructure to grow the economy; and supporting local planning.
2.5 The Framework is the immediate tool to unlock the planning system and reflects the new Labour Government’s aspirations for growth. Rachel Reeves gave a speech soon after the election to emphasise that “sustained growth is the only route to improving prosperity of our country”; that “nowhere is decisive reform needed more urgently than in our planning system”; and importantly “economic benefits of development will be a central consideration”.
2.6 Chapter 5 is all about ‘Delivering a sufficient supply of homes’ and the changes to the Framework reinforce and emphasise that local authorities should meet the identified housing need as a minimum and the baseline is the standard method. Para 62 of the NPPF states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.”
2.7 Under the standard method for calculating housing need, North East Derbyshire District Council’s local housing need requirement is set at a minimum of 605 new homes per year.
2.8 The proposed changes to the NPPF were published for consultation on 16th December 2025. The Ministerial Statement that accompanied the proposed changes states that the overhaul of the NPPF is designed “to facilitate the delivery of high and sustainable rates of housebuilding” and to “boost the housing supply and unlock economic growth”. The proposed changes create a “permanent presumption in favour of sustainable development”, secure a diverse mix of homes and streamline local standards to speed up decision making. It is appreciated that the proposed changes are out for consultation, but they are a direction of travel contained in an accompanying Written Ministerial Statement.
2.9 Therefore, there is a need for the emerging Local Plan to address the updated national planning position and provide for the housing and employment needs for the area.
Plan period
2.10 Stratland welcomes the extension of the Plan period from the consultation undertaken in August 2025. The consultation material now suggests the emerging Local Plan will cover a Plan period from 2024-2044. The Framework is clear that all strategic policies should look ahead for a minimum of 15 years from the date of adoption. However, if there are large scale urban extensions / new towns then this should be over a 30 year period. Therefore, Stratland considers that there is potential for the Local Plan to cover a longer period and plan accordingly to drive economic and housing growth that the area needs
Ambition
2.11 The Government’s ambition is to deliver sustained economic growth, improve prospective and enhance living standards. To deliver this ambition growth needs to be created throughout the country. The Local Plan Review needs to reflect the Government’s ambition and recognise the housing crisis.
2.12 Furthermore, the Local Plan Update needs to reflect the ambitions both nationally, and for the sub-region. The East Midlands Vision for Growth (May 2025) sets out the region’s bold plan which will transform the region. Delivery of the vision will create 100,000 new jobs, deliver and add £4 billion to the East Midlands economy.
2.13 This vision sets out a clear direction for the region and establishes long-term objectives that will make the East Midlands an even greater place to live, work, and visit. The plan focuses on seven key locations where there are opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
2.14 This approach needs to be reflected and enshrined within the Local Plan Update for North East Derbyshire.
Proposed Approach
2.15 To address the comments, the following approach is proposed:
• Reflect the new National Planning Policy Framework.
• With the economic ambitions and affordable housing need, the housing requirement should be set above the standard method Local Housing Need.
• Reflect the region’s ambitions and growth strategies.
Strategic Approach to the Location of Development
3.1 Stratland consider that the Council’s approach to the emerging Local Plan needs to reflect national policy and guidance and deliver the ambitions for housing and economic growth. The emerging Local Plan should not just be trying to achieve the minimum number of homes required.
3.2 The emerging Local Plan needs to address the big strategic issues of providing for new homes and businesses and supporting infrastructure.
Justification
Development Needs
3.3 The Vision needs to reflect national and regional policy ambitions. Nationally, the Government is seeking to deliver 1.5 million new homes and the housing crisis is a key policy issue to address over this parliamentary period. This flows through Written Ministerial Statements and the new Framework, which includes updated guidance and minimum housing targets, which the Vision should set out to achieve.
3.4 Furthermore, the Government seeks to increase economic growth, which is important to address prosperity and living standards, consistently highlighting that “sustained growth is the only route to improving prosperity of our country”.
3.5 Stratland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.6 Stratland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.7 The standard method calculates for North East Derbyshire that the housing need is 605 new homes per annum, or 12,100 over the 20 years of the Local Plan period. Furthermore, national policy and guidance states that Councils can choose to plan for more homes if they want to support things like economic growth or help meet housing needs in nearby areas.
3.8 The standard method represents a baseline for calculating housing need, and should not be seen as a ceiling for delivering housing. Whilst the standard method provides a minimum starting point for housing need, using household projections and affordability. It also fails to account for local economic growth, job creation, infrastructure changes, or specific demographic shifts.
3.9 Providing ambitious housing targets above the standard methodology also supports economic growth. This would match the East Midlands Vision for Growth (May 2025) which sets out the vision for transformative and ambitious growth within the region. Where significant employment growth is planned, housing supply must match job creation to avoid commuting issues and labour shortages.
3.10 At Examination, the Planning Inspectors may find the Loca Plan unsound if it fails adequately address all sources of housing need. A higher target for housing will demonstrate that the Local Plan is positively prepared, justified, and effective, which are key NPPF soundness tests.
3.11 The Local Plan should therefore establish a housing requirement above the standard method to reflect the economic ambitions for the area and affordable housing needs.
Spatial Distribution of Development
3.12 The location of development is a critical aspect of achieving sustainable development. As a general principal development should be located in areas that are accessible, sustainable, and benefit the local community.
3.13 The feedback from the August 2025 consultation shows preference towards the identification of sites that are sustainable, located in higher order settlements and that are accessible to jobs and services. Killamarsh is a Level 1 Main Settlement and is eminently sustainable.
3.14 Therefore, through engagement and dialogue appropriate sustainable opportunities should be identified within Killamarsh, such as Stratland’s site at Land off Primrose Lane, Killamarsh (Site Ref 45221).
Proposed Approach to the Location of Development
3.15 Stratland support the proposed approach which identifies Priority Locations with Priority 1 including Level 1 Settlements – Main Town locations.
3.16 Stratland consider that this is an appropriate option in identifying land required to deliver sustainable growth within the district. Development on appropriate sites within Killamarsh should be prioritised as the most appropriate and sustainable option.
3.17 Stratland consider that focusing development in Killamarsh is appropriate in delivering growth in one of the most sustainable settlements within the District, and also within close proximity to the largest settlement and City within South Yorkshire. Locating development within Killamarsh will ensure that new development has access to services, facilities, employment opportunities and access to public transport.
Settlement Hierarchy
3.18 The Settlement Hierarchy Study 2025 provides up to date information about settlements in North East Derbyshire District and the services and facilities they provide. One of the primary aims of establishing a settlement hierarchy is to promote sustainable communities by bringing housing, jobs and services closer together in an attempt to maintain and promote the viability of local facilities and reduce the need to travel to services and facilities elsewhere.
3.19 Stratland consider that the Council’s approach to the emerging Local Plan and Settlement Hierarchy is appropriate, with Clay Cross, Dronfield, Eckington and Killamarsh appropriately identified as being the four main towns within the District.
3.20 Killamarsh is situated in the north east corner of the District, immediately adjacent to the boundary with Rotherham and Sheffield. Killamarsh isa one of the larger settlements with access to services, employment opportunities across the region and public transport facilities, including Sheffield’s Supertram .
3.21 Within this context, Stratland feel that the Local Plan could strengthen the settlement hierarchy by addressing the relationship between Killamarsh and Sheffield, recognising its close proximity to the largest settlement within the South Yorkshire region.
Sustainability Appraisal
3.22 It is welcomed that the Sustainability Appraisal has been published. However, the methodology and approach appears confused and it is unclear how the scoring, ranking and assessment has been applied.
3.23 For example, it is implied that Table 3.2 is summary of the Sustainability Appraisal for each site, however it portrays an inaccurate picture. Stratland’s site at Land off Primrose Lane, Killamarsh (Site Ref 45221) is considered to have a negative score on transport. However, in the individual table it has a positive for buses and negative for railway station.
3.24 Nevertheless, the Sustainability Appraisal has not reflected the DfT connectivity tool which assesses the area to be extremely accessible and therefore the negative score is confusing.
3.25 The overall approach of the Sustainability Appraisal is confused and the methodology should be reviewed.
3.26 To address the comments, the following approach is proposed:
• Reflect national and regional policy ambitions.
• Set housing targets which are above the standard method baseline, and exceed for affordable housing and economic growth.
• Amend approach to site identification that focusses on the most appropriate and sustainable locations first.
• Review the methodology and approach of the Sustainability Appraisal.
Site 45221 – Land off Primrose Lane, Killamarsh
4.1 Stratland supports Site 45221 being short listed as a potential future housing allocation.
4.2 Stratland controls the site at Primrose Lane, Killamarsh, which is available, suitable and achievable and therefore deliverable in accordance with national planning policy and guidance.
4.3 A Vision Report has been previously submitted, which explains the deliverability of the site. With the urban context of the site a pre-application enquiry has also been submitted and a planning application is being prepared.
4.4 Stratland considers the site can come forward in the short term and make a valuable contribution to the housing land supply.
Justification
4.5 Stratland considers that their Site at Primrose Lane should be allocated for housing use within the local plan review.
4.6 The site’s location, surrounded by existing development, with no immediate technical challenges, highlights its suitability for development. The site’s proximity to local services, access to wider transport infrastructure and access to the Rother Valley Country Park mean the site offers the opportunity to extend the existing community.
4.7 Furthermore, the ‘Bolsover, Chesterfield and North East Derbyshire Economic Needs Assessment Study (March 2025)’, recognises within table 6.9 that the ‘Land Adjacent to Norwood Industrial Estate, Killamarsh’ (NED31) should no longer be identified for employment. The Study states that “ the site largely comprises undeveloped greenfield land but is contained by built development on three of the boundaries”. The Study indicates that “existing residential uses are located adjacent to two boundaries with planning permission to bring forward 50 dwellings located to the site’s western boundary”. Given the proximity of residential development it is recommend that the site’s designation as General Employment Area is removed and that residential is a more suited use.
4.8 A Vision Report has previously been prepared and submitted to the Council to support the allocation of the site within the Local Plan. The Vision Report demonstrates that the site is available, suitable and achievable and therefore deliverable in accordance with the Framework and PPG.
4.9 Given the site is within the urban area of Killamarsh, a pre-application enquiry has also been prepared and submitted and a planning application is currently being prepared, which will be submitted shortly.
4.10 Stratland’s vision for the site is to create a well-designed residential area that complements the existing community and enhances local character. The development of the site will support the Council’s and the East Midlands Region’s ambition to promote opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
4.11 The site presents an opportunity to provide housing in a sustainable location. The site is contained on all sides, bounded by residential development to the south and west, and established landscaping and employment to the east.
4.12 The ambition for the site is to prioritise the retention of key natural features, including existing trees, hedgerows along the site’s boundaries, and drainage features. Areas will be dedicated to creation of high quality public open space for the benefit of future residents, including an area of open space at the northern end of the site adjacent to the canal. The masterplan shows that the southern section of the site would be reserved for a senior living scheme, potentially a care home (C2 use class).
4.13 The principal highway access for the scheme would be achieved via Primrose Lane, entering into the south-westernmost point of the site. The development would relate well to the approved development to the west (21/00976/FL), which is currently under construction. The approval of this application has set a precedent for the principle of developing to the north of Killamarsh and establishing that this area is both sustainable and suitable for housing.
4.14 In response to the bulleted list in the consultation document relating to Site 45221 the Vision Report, pre-application enquiry and forthcoming planning application have been informed by technical assessments, which are briefly summarised below and further on in this representation:
• The proposed scheme is for circa 100 dwellings and a care home.
• The proposed scheme and illustrative masterplan reflects the Chesterfield Canal and provides open space at the northern end of the site adjacent to the canal.
• Heritage: Heritage assessment has been undertaken and there are no archaeological or heritage constraints to the scheme.
• Ecology: Preliminary Ecological Appraisal and BNG assessment and there are no ecological or constraints to the scheme.
• Highways: AMA has undertaken a Transport Assessment and there are no highways constraints to the scheme.
• Flood Risk and Drainage: Flood Risk and Drainage Appraisal has been undertaken and there are no flood risk or drainage constraints to the scheme.
• Employment: The site is an employment allocation in the adopted Local Plan, however the Council’s Economic Needs Study considers the site is not an appropriate employment site given its residential neighbours and therefore suggests the site be reallocated for residential use.
• Health and Safety Executive Zone: The HSE zone is at the far northern end of the site and within the illustrative masterplan is shown for open space.
• Geo-Environmental: Preliminary ground investigation has been undertaken and there are no geo-environmental constraints
• Agricultural Land: The site is not Best and Most Versatile agricultural land.
4.15 Overall, this is a scheme that has strong potential to balance connectivity, sustainability, and community well-being. It will create a vibrant, healthy, and resilient place for people to live, work, and thrive, while preserving the distinct identity of Killamarsh.
Availability
4.16 Stratland has a legal agreement with the landowners to promote and develop the land for housing. Stratland is proud of their reputation for working with local and national builders to deliver high-quality desirable homes in sustainable locations. The Site is currently available for residential development which can be brought forward early within the local plan period, representing a short term opportunity.
4.17 The masterplan and constraints plan demonstrate that appropriate access point can be achieved for the Site. The scheme will also be able to deliver off-site highways contributions for any further works required. This would therefore not represent a constraint in the Site being available.
4.18 It is demonstrated that significant BNG uplift can be delivered on the Site, and that these matters would not represent constraints in the site being available.
4.19 The land is therefore “available” in accordance with the Framework and the Planning Practice Guidance.
Suitability
4.20 Stratland believe that the site is suitable for residential development, with no constraints that cannot be appropriately mitigated or that would represent the site being unsuitable.
4.21 The proposed development can make an efficient and attractive use of the land. Although greenfield land, the Site represents an excellent opportunity for future housing and development. This site would allow housing to be delivered within an appropriate and sustainable location at Killamarsh. The development of this site would assist in creating a logical extension to the built up urban area.
4.22 The site is located within a highly sustainable location, within one of the principal towns and most sustainable settlements within the district, as identified within the Statutory Development Plan and Settlement Hierarchy.
4.23 The site is 850m from Killamarsh Local Centre, which includes Aldi, Fulton Foods, Co-op Food, a Medical Clinic, a library and several local services like hair salons, a bakery, and a café. Killamarsh Infant and Junior School is very close to the site, accessible off Primrose Lane on Sheffield Road. Other schools, including St Giles CE Primary and Killamarsh Bears Pre School, are also within walking distance.
4.24 Rother Valley Country Park is within walking distance, offering 750 acres of trails, a nature reserve, and leisure attractions like Sheffield Cable Waterski & Aqua Park. Nearby, Rother Valley Golf Centre and Gulliver’s Valley Theme Park offer additional recreational opportunities
4.25 The site offers excellent connectivity, located within 2.5km of the Halfway Park & Ride, benefiting from frequent tram and bus services to Sheffield City Centre. Furthermore, bus stops within close proximity link to Crystal Peaks shopping centre and Sheffield. Kiveton Park train station is approximately 3km away, however the proposed reopening of the Barrow Hill Line will significantly improve regional connections. The proposed Killamarsh station will further enhance access to key employment and education hubs in Sheffield and Chesterfield and support strategic housing developments along the Staveley Growth Corridor.
4.26 The site is almost entirely within Flood Zone 1 and is of low risk in terms of fluvial and surface water flooding, with some small areas situated in Flood Zone 2/3. The site generally falls from the southern boundary down to the northern and eastern/ western boundaries. Remaining elements of the Chesterfield Canal is to the north east of the site. It is considered that any areas within the higher flood zone risk areas can be easily excluded from the developable area, and utilised for either landscaping, public open space and/or drainage attenuation.
4.27 A small portion of the perimeter of the site falls within a Hazardous Installation Inner Zone and would therefore be precluded from housing development, but is suitable for ecology, habitat and open space.
4.28 The site is not located within or adjacent to a Conversation Area and there are no listed buildings within close proximity. As a result, it is considered that development of the Site will not affect any national or local heritage features.
4.29 There are no statutory ecological designations or known priority habitats on the Site. Any development would utilise existing tree belts and features, with reinforced landscaping and planting. The Ste is currently made up of arable fields, which therefore have a monoculture of limited specifies diversity, and limited ecological value or importance.
4.30 There is a clear need for new sites to come forward for housing to support the growth ambitions for the East Midlands region. The Site provides an important opportunity to meet local housing needs. The proposed residential development would be developed to a high-quality design standard that respects the nature of the surrounding area. The development of the site for housing presents an ideal opportunity to address local housing needs by providing a diverse range of affordable and aspirational homes for families, older adults, and young professionals.
4.31 The site provides a unique opportunity that will benefit the area and wider district with economic, environmental and social benefits. The technical work that underpins the masterplan confirms that there are no known constraints to development. It is therefore considered that the proposed allocation of the site is suitable, in accordance with national guidance and PPG
4.32 The land is therefore “suitable” in accordance with the Framework and the Planning Practice Guidance.
Deliverability
4.33 Stratland consider that the site can come forward immediately and be delivered in the short term (1-5 years) of the Local Plan Period. The masterplan and constraints plan provided show that there are no significant issues preventing the site coming forward, with solutions on site to address availability and suitability concerns.
4.34 The proposed development is located within close proximity to existing services and facilities. The indicative masterplan represents an efficient use of the land available. The scheme is therefore making an efficient and effective use of land and infrastructure.
4.35 The site provides a development opportunity that is available, suitable and achievable and therefore it is considered that the site is deliverable, in accordance with national planning policy and guidance. It is promoted by Stratland and is deliverable within the plan period.
Achievable
4.36 A range of technical work has been undertaken and is ongoing. From these initial assessments there are no technical issues that would prevent the delivery of the site for residential purposes. The technical reports will show how a mix of housing can be accommodated within the site, alongside connectivity, landscaping and drainage features.
4.37 The Framework requires Local Planning Authorities to meet their full objectively assessed housing need. Stratland considers that the site is deliverable in the short term (1-5 years) and will reinforce the housing supply and address the Council’s housing needs in the Local Plan period. Development of this Site will support the delivery of a range of housing types and contribute towards meeting identified needs
4.38 It will be evidenced that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
A Positive Response to the Key Objectives of the Framework
4.39 The Framework sets out that the Governments key housing policy goal of significantly boosting the supply of housing and proactively driving and supporting sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs. The Framework explains that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as extensions to towns, and creating mixed and sustainable communities with good access to jobs, key services and infrastructure. Sites should also make effective use of land and existing infrastructure.
4.40 In relation to the Framework:
• The proposal responds positively towards national guidance.
• The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.
• The proposed site is accessible to existing employment, local community facilities, infrastructure and services, including public transport.
• The site has been assessed as being is available, suitable and achievable for development.
Benefits of Site Reference 45221 – Land off Primrose Lane, Killamarsh
4.41 The development of the site would provide significant economic, social and environmental benefits. The site would provide housing that would meet the needs of the North-East Derbyshire District Council’s housing market in a sustainable location.
4.42 In accordance with the Framework this representation has shown that:
• The site is suitable for housing and can deliver circa 100 new homes and a care home.
• The proposal can provide a good mix of housing commensurate to the demand and need in the area and diversify the housing stock
• The site is within a sustainable location situated in close proximity to facilities and services and also to bus stops for local bus routes.
• The scheme uses land efficiently and effectively.
• The proposal is in line with planning for housing objectives.
• The scheme will create direct and indirect job opportunities both during and after construction, as well as employment opportunities through an C2 use on the Site.
• The site can deliver new areas of public open space.
4.43 The proposal is an appropriate site to provide for the housing needs of Killamarsh and the wider East Midlands region during the Local Plan period. Confirmation of the allocation will contribute positively to a balanced housing supply in the area in sustainable locations. The site can deliver a full range and mix of housing as part of a sustainable community. Development of the site would deliver affordable housing. North-East Derbyshire District Council needs to have a robust housing trajectory with a sufficient supply of deliverable sites. The site will assist with this delivery in the medium term. The site is situated within a prime location suitable for residential development and as such would facilitate the development of land in an effective and efficient manner. Development of the site would not harm or undermine the area’s wider policy objectives but seeks to reinforce the need to develop sites within sustainable locations as a priority.
4.44 The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.
4.45 To address the comments, the following approach is proposed:
• Allocate the site at Primrose Lane, Killamarsh for housing purposes.