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

1. Introduction
1.1.
These representations are prepared by Fisher German on behalf of our client Richborough in respect of their land interests at Cross and Birch Farm, off Eckington Road, Coal Aston, Dronfield.
1.2.
The site was submitted to the Council during the 2025 Call for Sites exercise alongside an extensive evidence base engaging on landscape, ecology, transport, heritage and other matters. The site has since been the subject of Representations submitted to the initial Regulation 18 consultation carried out between June and August 2025.
1.3.
The Council are now consulting on its latest material as part of the Issues & Options stage of Local Plan production. Specifically, the current consultation is focussed on the strategic approach to the location of development and a refined schedule of sites all of which have passed through both the initial desktop screening, and further detailed stages of assessment. Notably, these sites also align with the emerging strategy. Included within this refined schedule is our client’s site identified as ‘45483 – Land off Eckington Road, Coal Aston, Dronfield’ within the consultation document.
1.4.
For context it’s important to note that the site was included as a draft allocation - DR2 - in the Submission version of the now-adopted Local Plan (adopted November 2021). This demonstrated the Council’s in principle agreement that the site could accommodate residential development. Following completion of the Examination Hearing Sessions, the Inspector in her initial findings report highlighted concerns around DR2, concluding that it was a prominent extension that changes the character of the area, harms the Moss Valley Conservation Area and erodes the function of the Green Belt. On this basis, the Inspector recommended deletion of the site. Ultimately, to secure adoption of the plan at that time, the Council conceded and removed the site through Main Modifications.
1.5.
It is acknowledged that the Council were previously unable to demonstrate exceptional circumstances that could outweigh perceived harm enough to warrant removal of the site from the Green Belt and as such it was removed as an allocation from the then-submission version Local Plan. However it is considered that the context within which plan making is being undertaken today – driven by central Government ambitions for enhanced housing delivery (1.5 million net additional homes in England by the next General Election), supported by a raft of changes to the National Planning Policy Framework (NPPF) – has fundamentally changed in favour of significantly boosting housing supply locally, including via the increased utilisation of Green Belt sites (as confirmed by Paragraph 146 of the Framework), but only where such sites meet the Golden Rules of Paragraph 156 and 157 of the Framework, providing enhanced public benefits. This site represents a viable option for helping North East Derbyshire to deliver on its (much increased) housing need whilst minimising Green Belt harm and is fully compatible with the current Framework and its approach to the utilisation of Green Belt to meet housing needs in full.
1.6.
The NPPF and Standard Method were published on 12th December 2024 and the updated Local Housing Need for the district has significantly increased from 224 dwellings per annum (dpa) to 605 dpa. The Council will be required to allocate sufficient residential sites to deliver the housing need and we believe this will need to include the use of currently designated Green Belt land to secure a pattern of deliverable and sustainable growth (NPPF 148).
2. Representations
45483 – Land off Eckington Road, Coal Aston, Dronfield
2.1.
The consultation invites specific comments on sites which have been the subject of further testing and been included within the refined schedule. This section seeks to provide site specific commentary to promote its onward selection as a future allocation and this includes a consideration of relevant evidence base work carried out by the client to inform site strategy.
2.2.
It should be noted that since submission of the representations to the June-August 2025 consultation, our client has commissioned updated evidence base and informative plans which are discussed here wherever possible. Otherwise, any additional documentation will be provided to the Council by 1 June as required by the Council and set out in direct correspondence in March 2026.
Site overview
2.3.
The site comprises five field parcels bounded by mature hedgerows, scattered trees and a woodland area to the north. It is located immediately north of the settlement boundary of Dronfield, recognised as a ‘Level 1’ settlement in the adopted Local Plan (the most sustainable of locations for growth). Scattered agricultural development associated with Birch Cross Farm is located in the southern half of the site.
2.4.
The Vision Document, submitted alongside these representations, includes an indicative masterplan (Figure 1) to accommodate around 200 dwellings, which we intend as a ‘starting point’ to form the basis of onward discussions with the Council. We are keen to address more focussed parameters -such as appropriate densities- proactively with the Council and as informed by emerging evidence, including outcomes from work commissioned by our client for submission by 1 June.
Site feasibility
2.5.
Access to the site would be achieved directly from Eckington Road (B6056) and the site would be well serviced by public transport; an initial transport assessment undertaken and submitted to the Call for Sites found its development for c.200 dwellings would not have an adverse impact on the local highway network.
2.6.
The site is entirely within Flood Zone 1 thus at low risk of flooding from rivers or sea and only small pockets of the site are subject to limited surface water flood risk. There are no listed heritage assets within the site or in particularly close proximity to it. The nearest site – Grade II listed ‘Range of Outbuildings to the East of Silkstone Farmhouse’ is located approximately 315m away in Coal Aston. The site is supported by a willing landowner and a well- developed evidence base established as a result of its allocation within the Submission version of the now-adopted Local Plan which is the subject of ongoing updates. The site could be available to deliver units within the first five year period post-adoption of the new Local Plan, helping to ensure a robust housing supply within the District.
2.7.
The site is within the Green Belt, extensive Moss Valey Conservation Area and the Impact Risk Zone for the Moss Valley Woods SSSI, located approximately 235m north east of the site. These constraints are surmountable and considered in more detail below.
2.8.
As part of the consultation, the Council has published a summary of key outstanding issues that they would need to see appropriately addressed for the site to be considered suitable for selection as a future allocation. The following sub-sections address each of the remaining issues highlighted by the Council through this consultation in turn. Where appropriate and as already addressed above, additional evidence currently being produced for our client will be provided by 1 June to provide additional support to the Council. Whilst some of the issues below have already been addressed through the Call for Sites submission and previous Regulation 18 representations of 2025, for reasons of completeness and clarity, these issues remain included within these representations.
Site issue – location within Moss Valley Conservation Area
2.9.
Section 69 of the Planning (Listed Buildings and Conservation Areas) Act 1990 makes provision for local planning authorities to designate Conservation Areas because of their “special architectural or historic interest the character or appearance of which it is desirable to preserve or enhance”. The Moss Valley Conservation Area was designated by North East Derbyshire District Council on 3rd May 1990. There is no character appraisal for this designated asset nor publicly accessible management plan. Reasons for its designation are only covered within the planning committee report supporting its original designation. The Heritage Statement undertaken by Humble Heritage in 2016 in support of the site’s original designation within the now-adopted Local Plan (also submitted to the Call for Sites exercise in 2025) summarises the reasons for its designation (extracted from the committee report) at paragraph 4.09 of that report. It includes mention of Moss Valley being a landscape of historic interest in its own right, there being a great range of natural and man-made elements which comprise its special character, and the presence of vernacular buildings, farmsteads and early industrial sites.
2.10.
The Moss Valley Conservation Area is a large designation covering an area of approximately 1,660 hectares. It includes a number of small to medium sized settlements containing a mix of types of character including modern dwellings such as Lightwood, Troway, Highlane, Ridgeway, Ridgeway Moor, Ford and part of Marsh Lane so is not exclusively rural. Development of the site would result in the loss of less than 0.3% of rural land from the conservation area. There are no industrial archaeology sites within the site or in close proximity of the site’s boundaries. Cross and Birches Farm is a modern farmhouse and farmstead erected in c.1960s and as such does not positively contribute to the historical significance or appearance of the conservation area in relation to the special character associated with man-made elements and building vernacular. No designated assets are in close proximity to the site and there would be no intervisibility between the site and the setting of heritage assets listed outside of the site.
2.11.
In terms of natural elements of the conservation area, there are no designations within the site and its development would not impact upon the Moss Valley Woodland or nearby SSSI (considered in further detail below). The site is active farmland and as such is highly unlikely to be rich in wildlife habitat. Hedgerows and trees within the site could be retained – notwithstanding the fact that none of them benefit from tree preservation orders – and aside from the ecological benefits, this would help to maintain the grain of the existing field layout. Views are not identified as being an important part of the character and appearance of the conservation area. In any case, the changing topography and belts of trees mean that residential scale development on the site is unlikely to be visible from multiple points within the conservation area, notwithstanding also the opportunity for suitable landscape mitigation to be incorporated with any future proposal for the site.
2.12.
In response to concerns highlighted by the Council, our clients have commissioned a new Heritage Statement which will be provided to the Council by 1 June. In the interim, and for the purpose of providing some additional clarity within these representations, an interim Historic Environment Technical Report was also commissioned. It does identify far-reaching views to the north and north-east that incorporate heritage assets, and potential impact on these assets will be a consideration of the forthcoming Heritage Statement. We can confirm however that early recommendations from our client’s heritage consultants is to ensure the retention of important views from the site across Moss Valley Conservation Area, in particular to Oakes Park and Norton Water Tower. It is also recommended that existing hedgerows are retained wherever possible. Ultimately early indications are that these matters can be addressed via appropriate masterplanning of the site and the Vision Document submitted with these representations provides some additional insight on this, and the Heritage Statement will more directly address the concerns. To note also is that the Historic Environment Technical Report finds no evidence to suggest the site contains archaeological remains relating to the medieval rural economy and post-medieval rural industries associated with the Moss Valley Conservation Area so as to preclude or constrain future development of the site.
2.13.
With the above in mind, and notwithstanding forthcoming evidence, we do not consider that the site’s location within the Moss Valley Conservation Area amounts to a strong reason for restricting development at this location as intended by Footnote 7 of the NPPF and reference to designated heritage assets.
Site issue – location within the Green Belt
2.14.
The site’s main constraint is that it is presently designated as Green Belt. Having regard for the recently published NPPF (December 2024), it is clear in paragraph 146 that Green Belt land can be utilised in ‘exceptional circumstances’ where development needs justify release. It states that “Exceptional circumstances, in this context include… instances where an authority cannot meet its identified need for homes, commercial or other development through other means. If that is the case, authorities should review Green Belt boundaries in accordance with the policies in this Framework and propose alterations to meet these needs in full, unless the review provides clear evidence that doing so would fundamentally undermine the purposes (taken together) of the remaining Green Belt, when considered across the area of the plan”.
2.15.
Given the significant uplift in housing need applicable to North East Derbyshire as a result of the revised standard method for calculating Local Housing Need, we cannot envisage a circumstance whereby North East Derbyshire will not need to review its Green Belt boundaries to accommodate its demonstrable growth needs, particularly given the need to ensure ‘sustainable patterns of development’ as advocated by Paragraph 148 of the NPPF. Exceptional circumstances therefore do exist. With this in mind, an assessment of whether the release of the site from the Green Belt would fundamentally undermine the five purposes of the Green Belt is set out in Table 1.
2.16.
This review has been informed by an assessment carried out by independent landscape consultants Tyler Grange as part of a wider updated Landscape Technical Note which formed part of the original evidence base supporting draft allocation DR2 of the now-adopted Local Plan. This work was completed in July 2025 to inform understanding of the recent NPPF and NPPG changes relating to Green Belt and Grey Belt in relation to this site. It considers the sites contribution to the purposes of Green Belt, also utilising the North East Derbyshire Green Belt Review (NEDGBR) produced by NLP in 2017 to support the then-emerging Local Plan. The site was assessed as part of the wider parcel 025 in that Review; the context of which is highlighted in Figure 2 below.
2.17.
It is acknowledged that the Council are committed to producing an updated Green Belt Review to be published alongside a Publication Draft Local Plan later this year. We cannot envisage a scenario where this land could justifiably be identified as making a strong contribution to the Green Belt since its assessment in 2017 (where it was found to perform moderately against purposes a and d and weaker against purpose b) given the national policy context referred to above and clarity provided by the 2025 updates to the PPG.
Five Purposes of the Green Belt Assessment
A - to check the unrestricted sprawl of large built-up areas;
The Site is bordered by the settlement edge of Coal Aston off Eckington Road to the west and south. Development extends along part of the western boundary of the site from Eckington Road. The site boundary then follows the edge of a designated open space, sports and recreation facility to its northern boundary which is marked by Whinacre Wood which provides a strong defensible boundary. The eastern boundary of the Site is bounded by mature hedgerow dividing the site and the adjacent field which to an extent also provides a defensible edge to ensure development would not sprawl any further eastwards. The NEDGBR review study of Parcel 025 (within which the site is located) considers that the parcel plays a role in preventing unrestricted sprawl: “The parcel is partially contained by the urban area. The southern boundary and the majority of the western boundary adjoin the urban area of Dronfield.” It also states that “The parcel has strong and defensible boundaries. The parcels northern boundary comprises a combination of hedgerow and mature tree coverage, whilst the eastern boundary consists of a hedgerow. The southern and western boundaries adjoin the urban area.” The review gave an overall score of ‘amber’ for purpose (a) – to check unrestricted sprawl, stating that “Development of the
Building lasting value, together 8
parcel would neither strengthen nor weaken the Green Belt boundary.” It is evident that all boundaries of the proposed site are currently contained by either a minimum of mature hedgerow and tree planting but also physical features including roads and housing. Masterplanning of the wider site can further ensure any containing features are reinforced with the siting of residential development also responding to the immediate context. The site represents a logical extension of Dronfield and does not strongly contribute to this Green Belt purpose. Specifically, its contribution in this regard is limited to ‘moderate’.
The PPG clarifies to achieve a Strong contribution, which would rule out Grey Belt designation, there needs to be a lack of “physical feature(s) in reasonable proximity that could restrict and contain development”. Furthermore, that the development would result in an “incongruous pattern of development (such as an extended “finger” of development into the Green Belt)”. Whilst only illustrative, it is clear that the development of the site would not amount to either example provided. Conversely, to achieve a moderate contribution, the PPG clarifies land which is “adjacent or near to a large built up area, but include one or more features that weaken the land’s contribution to this purpose a, such as (but not limited to):
•
having physical feature(s) in reasonable proximity that could restrict and contain development
•
be partially enclosed by existing development, such that new development would not result in an incongruous pattern of development
•
contain existing development
•
being subject to other urbanising influences”.
All of which apply to the site, indicating strongly that the previous
assessment remains robust under the new guidance and that at worst the site should be judged to make a moderate contribution to Purpose A of the Green Belt.
B - to prevent neighbouring towns merging into one another;
The City of Sheffield lies to the north of Dronfield and comprises many various suburbs, the closest of which to Dronfield include Batemoor and Jordanthorpe which are c.780m north of the Site. Development of the Site would not bring them into closer proximity with one another. As similarly pointed out in the 2017 NEDGBR in relation to the parcel containing the Site: “The parcel would leave a gap marginally above 1km to Sheffield urban area. In addition it is no closer than the existing adjoining development.” Removal of this Site from the Green Belt would not reduce the strategic gap between Dronfield and Sheffield. The next nearest town to the Site and the east of Dronfield is Eckington which is located c.4.4km from the easternmost extent of Dronfield. Development of the Site would not reduce this gap as the Site is located further west than the most eastern extent of Dronfield at Eckington Road. Chesterfield town is located c.5km south-east of the Site. Development south of Eckington Road (B6056) is located between the Site and Chesterfield. Development at the southern extents of Dronfield also fall in closer proximity to Chesterfield. The site does not make a strong contribution to this purpose. Specifically, the sites contribution in this regard is ‘weak’. This finding is contrary to the conclusion of the Inspector in Examining the now-adopted Local Plan who, in her letter dated 18 February 2019, highlighted the perceived impact of development on the strategic function of Green Belt at this location (in particular to maintain expansive vistas between urban areas and to define settlement extent) as reason for the site’s removal as a draft allocation. Its weak contribution to this Green Belt purpose as detailed here evidences that the site does not erode these features at this location.
Building lasting value, together 9
Again, the updated PPG provides helpful guidance as to how land should be considered against this purpose. Strong functioning land against this purpose is land which forms a substantial part of a gap between towns and would result in the loss of visual separation between towns, neither of which would be applicable. Land which serves a moderate purpose includes land which forms a small gap between towns, being able to be developed without the loss of visual separation. This could be due to the presence or the close proximity of structures, natural landscape elements or topography that preserve visual separation. Weak/no function is similar, where the land does form a gap between towns, but only a very small part of the gap, without making a contribution to visual separation. Having regard for the above, it is clear at worst the site would make a moderate contribution but given scale and lack of intervisibility, a weak contribution is considered more robust.
C - to assist in safeguarding the countryside from encroachment;
The 2017 NEDGBR acknowledged that the parcel already includes some development that accounts for approximately 10% of the parcel, giving it an ‘amber’ score. In terms of site specific development, Birch Cross Farm is currently situated on Site and includes an individual farmstead and associated buildings, vegetation and hardstanding. The field parcels within the Site are presently associated with the farmstead and used for agricultural purposes. Development of the Site would extend the existing built boundaries off Birches Lane and Eckington Road towards the north and Whinacre Wood. The NEDGBR set out that “development of the parcel would neither strengthen nor weaken the Green Belt boundary.” Whinacre Wood would become the boundary which could be supplemented by on-Site planting creating a softer edge between the Green Belt and Urban areas. This would allow any potential for further encroachment to be restricted, prevented and mitigated. The site does not make a strong contribution to this purpose. Specifically, its contribution in this regard is limited to ‘moderate’.
D - to preserve the setting and special character of historic towns; and
The Site is located within the Moss Valley Conservation Area however it does not form a significant part of the conservation area, making no specific contribution to its special character. Further, there is no character appraisal or management plan supporting the designation and the 2017 NEDGBR stated in regard to the parcel containing the site that “The parcel is located within the Moss Valley Conservation Area. It is however considered that the parcel has a limited role in preserving the setting of a historic village or town. The Moss Valley Conservation Area covers a large area of land, and it is not considered that this parcel serves a fundamental purpose of Green Belt land in this respect.” Further, the site is not considered to form part of the historic setting of Dronfield, nor does it have particular relationship with historic elements of the town, being visually screened from its conservation area and listed buildings by mostly post-war development. In accordance with the PPG a weak score is considered appropriate.
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The significant increase in the Local Housing Need for North East Derbyshire and strong evidence of enhanced demand within Dronfield means that multiple sites will be required at different scales to deliver this housing need and this cannot be delivered solely through brownfield allocations. The proposed site allocation would not therefore discourage the recycling of derelict and other urban land in North East Derbyshire and therefore its status as Green Belt land does not strongly contribute to this purpose.
Conclusion
Development of the site would not fundamentally undermine the five purposes (taken together) of the Green Belt. Furthermore, the site does not strongly contribute to purposes (a), (b) or (d) of paragraph 143, nor do the application of policies relating to Footnote 7 designations (excluding Green Belt) provide a strong reason for refusing or restricting development. As such, the site would meet the definition of Grey Belt set out in the NPPF.
2.18.
As set out above, we consider that Footnote 7 designations – specifically the Moss Valley Conservation Area designated heritage asset – do not provide strong reasons for restricting development. Additional context to this is the shift in recognition of Grey Belt designation from being perceived as resulting from a purely land-based assessment to one which should take account of a proposal (including any mitigation provided). In Wrotham Parish Council v SSHCLG (Ref: AC-2025-LON-000898), the High Court concluded that the Inspector had erred in their judgment in only assessing the land, rather than the proposal – which included mitigation – in concluding on impacts on Footnote 7 designations.
2.19.
Whilst this finding relates to decision making on a specific proposal with explicit mitigation measures proposed, the principle logically should be carried across when considering potential allocation, particularly as any site-specific policy can appropriately require mitigation measures as part of any future proposal. This is further underpinned by the Government’s clear intention to remove reference to Footnote 7 from the grey belt definition within the NPPF, which is a logical refinement given that decision makers have at their disposal the tools to refuse permission where a particular designation (such as a heritage asset) would genuinely provide strong reasons for refusal anyway. There is no need for grey belt designation to repeat such protections which results in the artificial narrowing of the scope of land that can fall within grey belt category.
2.20.
With the above in mind, the site would meet the definition of Grey Belt set out in the NPPF. Paragraph 155 of the NPPF (2024) confirms development in the Green Belt should not be regarded as inappropriate where:
•
the development would utilise grey belt land and would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan,
•
there is a demonstrable unmet need for the type of development proposed,
•
the development would be in a sustainable location and
•
where applicable the development proposed meets the ‘Golden Rules’ requirements set out in paragraphs 156-157.
2.21.
With regard to the ‘Golden Rules’ set out in paragraphs 156-157 of the NPPF, the affordable housing requirement to be accommodated on the site will be set at a higher level than that which would otherwise apply to land, subject to viability, to be established in this Plan as per Framework particularly Paragraph 67b. The development proposal on the site will include any necessary improvements to local or national infrastructure as well as provision of new, or improvements to existing, green spaces that are accessible to the public.
2.22.
Development of this site would meet all of the criteria of NPPF Paragraph 155 and therefore would not constitute inappropriate development in the Green Belt. Given its Grey Belt status, its release from the Green Belt should be prioritised.
Site issue – landscape impact
2.23.
Our client has commissioned Landscape and Visual Impact Assessment (LVIA) evidence following direct feedback from the Council received after completion of their site refinement process. Specifically, it has been requested that LVIA is carried out to address some specific landscape constraints identified by the Inspector appointed to examine the now adopted Local Plan who, at the time, removed the site from contention for allocation not least due to perceived localised landscape impacts such as in relation to Eckington Road and Footpath 37. This evidence will be submitted to the Council by the 1 June 2026 deadline afforded for additional evidence.
2.24.
The Vision Document submitted alongside these representations provides some early insight, which suggests the site is generally well contained with a limited visual connection with the wider landscape character and that the visual effects associated with future development would be contained to near context and would be capable of being managed through layout, scale and landscape mitigation.
2.25.
Notwithstanding the above, in support of representations submitted to the last round of consultation in 2025, our client separately commissioned a detailed Landscape Technical Note which provides useful insight in the interim, until completion of the LVIA. In summary, the report – which was carried out by landscape specialists Tyler Grange – found that the site had a very limited relationship with the wider Moss Valley Conservation Area and that development of the site has the potential to be accommodated with reference to the site-specific conditions. It made a number of observations and recommendations as follows:
•
Permeability across the site should be integrated into any emerging development layout and views across portions of the Site retained. Vehicular access should be limited to the south, off Eckington Road with pedestrian access in other locations, linking up with the wider Green Infrastructure network;
•
The Site is influenced by its visual connection to the surrounding settlement edge. This character and backdrop acts as a strong precedent, but built development will need consideration of appropriate materials, scale, height and density to respond to the context;
•
An existing overhead line runs north-south through the Site, this constraint could be utilised to create a green link connecting the Site from Eckington Road to the wider PRoW network. Further tree planting will further assist in softening building mass where the Site can be viewed (partially screened and heavily filtered) from elevated, distant locations to the north;
•
Where the Site is viewed from elevated topography to the north and east, it is where there are gaps in existing built form and boundary vegetation. However, these views are very limited due to the layering effect of scattered built form, changes in topography and vegetation associated with these dwellings, fields and roads. Layering of east-west vegetation strips and new Green Infrastructure corridors could be considered throughout the Site to break-up and soften any new built development;
•
The site is physically contained in all directions by mature boundaries. Boundaries should be retained and enhanced with development offsets and new native planting to soften the development edge linking into the existing Green Infrastructure network;
•
In terms of Green Belt, when assessed against Green Belt purposes, the Site does not perform a strong contribution in any purpose and is largely consistent with the findings of the previous NEDGBR 2017 undertaken by NEDC;
•
The site bears no listed heritage assets, nor has any known archaeology that provides cultural links to the past, nor does the site have any known cultural associations related to people or industry (such as mineral extraction and metalworking). Little is left of the historic field pattern, of which the current five fields on Site have occurred through agricultural intensification and field amalgamation. The farm complex is late 20th century and the Site as a whole is overlooked by late 20th and early 21st century housing.
Site issue – relationship with Moss Valley Woodlands SSSI and wider ecology
2.26.
Moss Valley Woods SSSI is designated on account of the presence of ancient woodland, located 0.2km north east of the site. It comprises two units of woodland – Whinacre Wood and Brownstorth Wood. It is contiguous with woodland in the north of the site and an ephemeral stream connects this woodland to the SSSI. The site falls within Natural England’s Impact Risk Zone where potential residential developments of 100 units or more would require further consultation with Natural England, consideration of potential impacts and appropriate mitigation.
2.27.
Potential adverse effects are limited by reason of there being no direct pedestrian links to the SSSI from the site and no known footpaths or access into Whinacre Wood (within the SSSI). The distance involved along with lack of parking and direct public access to Brownstorth Wood part of the SSSI means negligible potential impacts on this unit are anticipated.
2.28.
Principles of mitigation set out in the SSSI Technical Note submitted to the Call for Sites form the basis for mitigation that could be delivered to ensure the SSSI is not adversely affected by development of the site and these would be integrated with proposals through the planning application process. In summary the principles of such mitigation could include the implementation of pollution prevention measures during construction, implementation of an appropriately designed drainage strategy and implementation of a woodland management and access plan for the woodland in the north of the site. These principles would need to be built upon in consultation with Natural England.
2.29.
Notwithstanding the above considerations, in response to concerns raised by the Council, our client commissioned an Ecology Walkover Survey Report which was completed in April 2026 and will be submitted to the Council by 1 June. In this report, it is recommended that a habitat buffer between any potential development and the riparian corridor connected to the SSSI is retained. Otherwise, it finds the early indicative development footprint is largely devoid of priority habitats, but finds the stream and woodland to the northern boundary is high value and should be avoided, and the land between enhanced. All of these issues can be addressed directly through appropriate masterplanning of the site, and the Vision Document submitted alongside these representations and the indicative layout plan provides additional insight on this.
Site issue – presence of some risk of surface water flooding
2.30.
The site is wholly within Flood Zone 1. However with regards to surface water flooding and the presence of limited risk on some small sections of the site, onward site promotion and evidence to inform a planning application would include a Flood Risk Assessment and the site would be underpinned with a Sustainable Urban Drainage Strategy. It is important to note, much of the surface water flood risk is associated with an area of the site that would not be developed in any case – i.e. in relation to the woodland in the northern part of the site.
Site issue – location within the Coal Authority ‘High Risk’ area
2.31.
The coal mining ‘high risk’ zone is an extensive designation covering the entirety of multiple local planning authority areas. A Coal Mining Risk Assessment will be forthcoming as an important evidence base component to support a future planning application. Within this, any required mitigation would be identified.
Summary
2.32.
The site is included in the refined schedule of sites following initial assessment by the Council and the Land Availability Assessment categorises the site as ‘amber’, indicating ‘some constraints’. The key issues influencing the site’s current rating are addressed above and we consider are all resolvable through appropriate mitigation which will be forthcoming. Our approach to addressing any constraints will be the subject of further evidence base enquiry either for submission by 1 June or to inform onward promotion and an eventual planning application. This, as well as overall emerging strategic approach to the location of growth which favours Level 1 towns such as Dronfield, provides strong justification for allocating the site for residential development in the future Local Plan.
Development needs – Housing
Option 1 – Standard Method
2.33.
The NPPF is clear at Paragraph 62 that “to determine the 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”; effectively, the housing need informed by the standard method is the ‘policy-off’ assessment of the minimum number of homes needed in an area. Plugging this into a consideration of wider environmental, economic and social factors, policies and constraints then determines the housing requirement. The NPPF is clear that “the overall aim should be to meet an area’s identified housing need”. There has to be a well evidenced and compelling argument set out by a plan making authority to justify planning for a lower housing requirement than the housing need identified using the Standard Method. The NPPG makes clear there are some ‘specific circumstances’ whereby this might be justified. The specific circumstances set out at Paragraph 014 of the NPPG do not apply in the case of North East Derbyshire, and we do not consider that any insurmountable constraints exist within the District to justify the pursuit of a housing requirement which diverges negatively from the Standard Method informed housing need. Such an approach we consider would be found to be unsound.
2.34.
In view of the above, as an absolute minimum, Option 1 as set out within the current consultation document should be pursued. In fact, as considered in more detail below, there is evidence in favour of planning for above the Standard Method derived housing need figure.
Option 3 – above Standard Method
2.35.
Whilst the NPPF is clear that the overall aim of strategic policies relating to the delivery of a sufficient supply of homes should be to meet an area’s identified housing need, it is also clear that a Standard Method derived housing need will identify the minimum number of homes needed. The NPPF empowers local planning authorities to apply a ‘policy-on’ approach which should factor in local and strategic ambitions (including economic) as well as general affordability pressures to inform their housing requirement, which may justify pursuit of an increased requirement. Such an approach is closely aligned with the latest Government ambitions to significantly boost the supply of new homes nationally.
2.36.
North East Derbyshire is strategically well placed adjacent to Sheffield (the 4th largest city in England) and Chesterfield. Dronfield specifically benefits from access to the A61 corridor (the subject of a range of improvement projects), Northern Rail and local bus services which provide efficient access between all three. Both Sheffield and Chesterfield are the focus of significant growth ambitions set out in their respective Combined Authority economic plans and from this a growth in a wide range of employment sectors is targeted. Long term ambitions for these cities places North East Derbyshire and its main towns – including Dronfield – perfectly to benefit and, as part of this, react to likely further increase in demand for new homes. Given the spatial relationship between North East Derbyshire and the larger settlements, the housing requirement eventually promoted should take into account these regional ambitions which indicate a need to advance beyond the Standard Method derived minimum.
2.37.
As with the overall Standard Method derived housing need, affordable housing need has also significantly increased since adoption of the current Local Plan. The Housing Needs Assessment (2024) identifies an overall need of 356 affordable dwellings per annum – over 58% of the overall need – and makes clear that “provision of new affordable housing is an important and pressing issue in the area”. The new Local Plan could be proactive in addressing this, by planning to deliver more than the Standard Method derived housing need.
Mix of scale and type of housing sites should be sought
2.38.
The refined schedule of sites evidences that the Council intend to include within the new Local Plan a range of site sizes, also commensurate with the level of sustainability of the varied locations for growth also being supported. We support this approach in principle; the NPPF is clear at Paragraph 72 that “planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability”. The provision of a range of site allocations sizes will help to boost housing delivery by limiting the reliance on large strategic sites which in turn will support flexible and phased delivery from a range of providers. Critically, the provision of a range of site allocation sizes across multiple locations is a major factor in sustaining a robust and deliverable housing pipeline and five-year housing land supply. Our client’s site is at the lower end of the large sites scale and would be in a position as a result of this to contribute directly to the Council’s five-year housing land supply, as well as requirements of plan years beyond.
2.39.
Linked to this also, we continue to support an approach which seeks to allocate a range of types of sites. Although not a topic of this consultation, the 2025 consultation identified seven site type options which between them would provide a varied range of potential impacts (eg. sites within the Green Belt, sites with some landscape harm and higher density sites). Development in any location, by its very nature, will result in some level of impact on its immediate context. However the key, in our view, is to focus on delivering housing in the locations where it is most needed whilst minimising impacts and maximising potential benefits. We agree therefore with the findings of the Sustainability Appraisal which, at paragraph E20 summarises that “it is likely that a combination of different site type options will allow for the most sustainable development strategy, informed by a robust evidence base to determine the capacity of different locations in the district to accommodate proposed growth that is aligned with the relative scale and character of existing settlements”.
Development needs - employment
2.40.
As set out in our previous representations, the new Local Plan should be aspirational and a key component of this will be the district’s ability to accommodate ambitious employment growth. As such, the Council should plan for the district’s employment land requirements at the upper end of the 15-31 ha as recommended in the Employment Needs Assessment (Option 2 in the current consultation document). The upper end of the estimate quite rightly takes account of the ‘policy on’ scenario, recognising the district’s local economic growth aspirations and key growth sectors of the economy. Given the significantly increased Standard Method derived housing need for the district and the need for it to be met as a minimum, it is also correct that labour supply resulting from new housing is taken into account when identifying the quantity of employment land that will be required to service the district going forward. Not adopting this approach risks artificially constraining economic growth which would be in direct contravention of NPPF ambitions, particularly its call for the planning system to build a strong, responsive and competitive economy. We do not consider the district to be so constrained that the identified quantum of employment land within the upper estimate would be undeliverable, particularly when you consider its relationship with the economic growth ambitions of the wider area, including neighbouring Sheffield.
Spatial distribution of development
2.41.
In principle we support the Council’s proposed approach to the location of development. Specifically, that the level of priority of location for accommodating growth correlates with the level of sustainability and role of the type of settlement. We agree that ‘Priority 1 Locations’ should include as indicative locations those listed i.e. the edge of Chesterfield/ Sheffield, new settlement/ strategic sites and level 1 settlements – main towns. We also agree that Dronfield should continue to be recognised as a level 1 settlement – main town, which we explore in more detail below. It is notable that the Sustainability Appraisal does not envisage any major negative effects from accommodating development at the main towns. Indeed, providing growth to the main towns represents a sustainable growth strategy which would, critically, leverage existing infrastructure and services provided by the them, support the vitality and viability of their centres and facilitate access to enhanced sustainable transport options they provide.
2.42.
We also agree that allocations should be assigned using a ‘cascade’ approach. Through this approach, the higher priority locations are likely to receive higher levels of growth which is logical and supported in evidence, albeit the Council will need to remain cognisant of factors which may determine slight divergence from this if necessary, for example in providing for strongly evidenced localised need or responding to key constraints which, for example, may determine that lower priority locations, at least in some scenarios, represent the more suitable location for growth. We note that the consultation responses received are largely in favour of such an approach also.
2.43.
In our previous representations we highlighted that we considered options to focus growth around Sheffield and Chesterfield as not being the most sustainable approach. We considered that such a focus would fail to address the localised need evidenced across the district and undermine local opportunity within the district. We consider that the approach now put forward by the Council – specifically to dilute this focus into a broader ‘Priority 1 Locations’ level alongside, in particular, level 1 settlements – main towns (such as Dronfield) as a sustainable and well-balanced approach. Such an approach alleviates concerns we had that the future distribution of growth would be directed overwhelmingly toward Sheffield and Chesterfield at the expense of other settlements across the district, and this we consider would have been an unsound approach.
Settlement hierarchy
2.44.
We agree with the principle of the approach taken by the Council to identify and group together settlements with similar levels of sustainability which perform similar roles, amounting to a settlement hierarchy. We agree this should feed directly into deciding the spatial distribution of development discussed above.
2.45.
In particular, we concur with the findings of the Settlement Role and Function Study (March 2026) and discussion within the Settlement Hierarchy Topic Paper (March 2026) insofar as it relates to Dronfield and its containment within the ‘Level 1: Towns’ settlement level (scoring well above the required 32+ points (40+)). With concur with the findings that Dronfield includes a recognised town centre which contains an extensive range of services, and that it performs a prominent role in meeting the day to day needs of people across a wide geographic area. We also agree with its findings that Coal Aston forms part of Dronfield, being “closely related to Dronfield, with no obvious physical boundary between them” (paragraph 3.4).
Dronfield as a location for growth
2.46.
As the largest of the settlements in North East Derbyshire it is particularly important that Dronfield accommodates a proportionate level of growth. Its wide range of services, facilities and transport infrastructure as well as its role as a main town within the ‘north east economic zone’ of the Derbyshire Economic Strategy and close proximity to Sheffield and the wider South Yorkshire Mayoral Combined Authority – along with its significant economic growth ambitions – highlights Dronfield as a sustainable location for growth which should play a significant role in delivering North East Derbyshire’s Local Housing Need. Demand for housing around Dronfield is particularly strong as evidenced within the Local Housing Needs Assessment 2024 (LHNA) which finds that even the economic turbulence at the time – in particular its effect on mortgage rates – has had very little impact on buyer demand in the area. The assessment notes that Dronfield appears to have the strongest market demand within the District and notes that “the north and west of the district clearly sees higher prices than the south and east. Areas surrounding Dronfield in particular see high prices” (Paragraph 2.11).
2.47.
A divergence between demand and supply also appears around Dronfield in relation to affordable housing. The LHNA finds that the parish of Dronfield (attributed for this exercise to Dronfield, Coal Aston and Dron Woodhouse where parish statistics have not been collated) is amongst the most in-demand areas within the district with 207 applicants with local connection on the Council’s housing waiting list as at June 2024. Out of 25 Parishes, Dronfield is the third most in-demand within the District on these terms. Of the district’s wards, Dronfield South saw the most average bids per property in 2023 (80). The LHNA identifies an affordable housing need of 71 (net) affordable rented dwellings per annum within Dronfield Parish – the most of any Parish - and Dronfield is the only area identified as having a tangible net need for affordable home ownership products (30 per annum). The identified ‘standardised need for affordable housing’ finds that Dronfield Parish has a need per 1000 dwellings of 10.67 per annum. For comparison purposes, Clay Cross has a need of 5.48, Eckington has a need of 6.89 and Killamarsh has a need of 8.02 – all of these being significantly lower than that of Dronfield.
2.48.
The above represent significant indicators of a historically constrained supply of new dwellings within and around Dronfield specifically. Despite these circumstances, the adopted Local Plan apportions notably less new housing to Dronfield when compared with the smaller towns of Clay Cross and Killamarsh, an issue exacerbated by the Inspector’s decision to remove this site during the examination of the extant Local Plan. The new Local Plan provides the opportunity to re-balance this and ensure Dronfield accommodates a proportionate quantity of dwellings reflecting its existing size and offer. Whilst Dronfield’s place within the Green Belt and associated complexities around its expansion (specifically, the need to release land from the Green Belt) is acknowledged, our client’s site as considered above in more detail, represents an opportunity to contribute to resolving the demand issue in the area with limited Green Belt impact.
Strategic sites and new settlements
2.49.
With the above considerations in mind, whilst we do not object to the principle of identifying strategic sites and new settlements as part of ‘Priority 1 Locations’ for growth, we maintain reservations around the suitability of strategic site ‘Duckmanton Moor’ (now merged from previous sites 45227 and 45541) which is expected to be able to accommodate 2000-3000 dwellings.
2.50.
The southern element of the strategic site (45227) does not directly relate to any existing settlement form and as such would represent an illogical and significant intrusion into the open countryside at this location. The nearest settlement – Arkwright Town to the north – is distant from this element of the site without any sense of continuity. Similarly, whilst technically attached to Arkwright Town to its north west and Long Duckmanton to its north east, the northern element of the site (45541) would result in an illogical and incongruent built form exclusively to the south of A632, awkwardly conjoining both settlements with notable impacts on the countryside at this location including its openness and any landscape value.
2.51.
Both Arkwright Town and Long Duckmanton offer limited provision of services, facilities and employment as highlighted also by the previous Settlement Hierarchy Study and more recently the Settlement Hierarchy Topic Paper, with a significant number of settlements rated as being more sustainable locations for growth. Whilst settlements such as Arkwright Town and Long Duckmanton could accommodate some growth (and, indeed, a distribution of growth across the district we consider to be a sustainable approach), the scale of growth being considered through the delivery of this newly merged strategic site would be entirely at odds with their scale and offer and such an approach we consider to be unsustainable.
2.52.
A significant proportion of the site is occupied by established woodland and this represents a substantial development constraint. Given the likely ecological value of the woodland area, its inclusion within the site will establish a considerable BNG baseline to address which has the potential to undermine viability of the site as a whole. Retention of the asset would significantly reduce the actual developable area provided by the potential allocation and limits the extent to which the site could contribute to delivering the district’s housing needs. Reducing the extent of the site to exclude the woodland area would result in the same outcome, preventing the delivery of a critical mass of dwellings required to fund and maintain new service provision necessary to make new free-standing communities viable and sustainable, particularly in this location where existing infrastructure provision is so limited. Likewise, the exclusion of the woodland area may limit opportunities for mitigation and enhancement where needed.
Sustainability Appraisal (SA) Addendum March 2026
2.53.
The SA Addendum has been produced to assess 271 reasonable alternative sites for residential use which have been identified by the Council – following a comprehensive assessment and filtering process – as being genuinely capable of being selected as allocations within the emerging Local Plan. This assessment does not take into account any mitigation, which of course, as explored in more detail above for our client’s site, can and will be forthcoming where required.
2.54.
Whilst we have not carried out an exhaustive review of the SA Addendum, we do have some concerns which we think are important to raise now, relating to scores applied and, in some cases, what appears to be a mismatch between the stated method for arriving at appropriate scores and its application to this site.
2.55.
For example, we note that the site has been scored negatively for access to a bus stop, yet bus stops are available almost immediately adjacent to the site along Eckington Road. The SA links a negative rating to scenarios where bus stops are more than 400m away from a site, which is simply not the case for this site. Similarly, we are surprised to see a negative score in relation to access to a secondary school given the relatively close proximity to the site (1.75km away via Oakhill Road and Stonelow Green) of one of only three secondary schools in the whole of North East Derbyshire (Dronfield Henry Fanshawe School). It is not clear how this score is justified given the wider context. Further, Oakhill Medical Practice is located off Oakhill Road less than 1km from the site. Again, it is not clear how a negative score against this measure of site accessibility to services can be justified and overall these issues point to three separate scores which we consider to be excessively negative.
2.56.
We also consider that a negative score resulting from the site’s location within a Natural England SSSI Impact Risk Zone is excessive. At this stage, Natural England’s response and position is unknown and should be reflected as such within the SA. Natural England would be consulted as part of onward promotion and, ultimately, to inform a planning application and it is worth noting that the element which impacts on this site only requires consultation for developments of 100 dwellings or more.
Conclusion
2.57.
The site is included in the refined schedule of sites following initial assessment by the Council and the key issues highlighted by the Council are addressed within these representations and we consider are all surmountable alongside appropriate mitigation which will be forthcoming. Our approach to addressing any constraints will be the subject of further evidence base enquiry either for submission by 1 June or to inform onward promotion and an eventual planning application. This, as well as overall emerging strategic approach to the location of growth which favours Level 1 towns such as Dronfield, provides strong justification for allocating the site for residential development in the future Local Plan.

1. Introduction
1.1.
These representations are prepared by Fisher German on behalf of our client Richborough in respect of their land interests at Cross and Birch Farm, off Eckington Road, Coal Aston, Dronfield.
1.2.
The site was submitted to the Council during the 2025 Call for Sites exercise alongside an extensive evidence base engaging on landscape, ecology, transport, heritage and other matters. The site has since been the subject of Representations submitted to the initial Regulation 18 consultation carried out between June and August 2025.
1.3.
The Council are now consulting on its latest material as part of the Issues & Options stage of Local Plan production. Specifically, the current consultation is focussed on the strategic approach to the location of development and a refined schedule of sites all of which have passed through both the initial desktop screening, and further detailed stages of assessment. Notably, these sites also align with the emerging strategy. Included within this refined schedule is our client’s site identified as ‘45483 – Land off Eckington Road, Coal Aston, Dronfield’ within the consultation document.
1.4.
For context it’s important to note that the site was included as a draft allocation - DR2 - in the Submission version of the now-adopted Local Plan (adopted November 2021). This demonstrated the Council’s in principle agreement that the site could accommodate residential development. Following completion of the Examination Hearing Sessions, the Inspector in her initial findings report highlighted concerns around DR2, concluding that it was a prominent extension that changes the character of the area, harms the Moss Valley Conservation Area and erodes the function of the Green Belt. On this basis, the Inspector recommended deletion of the site. Ultimately, to secure adoption of the plan at that time, the Council conceded and removed the site through Main Modifications.
1.5.
It is acknowledged that the Council were previously unable to demonstrate exceptional circumstances that could outweigh perceived harm enough to warrant removal of the site from the Green Belt and as such it was removed as an allocation from the then-submission version Local Plan. However it is considered that the context within which plan making is being undertaken today – driven by central Government ambitions for enhanced housing delivery (1.5 million net additional homes in England by the next General Election), supported by a raft of changes to the National Planning Policy Framework (NPPF) – has fundamentally changed in favour of significantly boosting housing supply locally, including via the increased utilisation of Green Belt sites (as confirmed by Paragraph 146 of the Framework), but only where such sites meet the Golden Rules of Paragraph 156 and 157 of the Framework, providing enhanced public benefits. This site represents a viable option for helping North East Derbyshire to deliver on its (much increased) housing need whilst minimising Green Belt harm and is fully compatible with the current Framework and its approach to the utilisation of Green Belt to meet housing needs in full.
1.6.
The NPPF and Standard Method were published on 12th December 2024 and the updated Local Housing Need for the district has significantly increased from 224 dwellings per annum (dpa) to 605 dpa. The Council will be required to allocate sufficient residential sites to deliver the housing need and we believe this will need to include the use of currently designated Green Belt land to secure a pattern of deliverable and sustainable growth (NPPF 148).
2. Representations
45483 – Land off Eckington Road, Coal Aston, Dronfield
2.1.
The consultation invites specific comments on sites which have been the subject of further testing and been included within the refined schedule. This section seeks to provide site specific commentary to promote its onward selection as a future allocation and this includes a consideration of relevant evidence base work carried out by the client to inform site strategy.
2.2.
It should be noted that since submission of the representations to the June-August 2025 consultation, our client has commissioned updated evidence base and informative plans which are discussed here wherever possible. Otherwise, any additional documentation will be provided to the Council by 1 June as required by the Council and set out in direct correspondence in March 2026.
Site overview
2.3.
The site comprises five field parcels bounded by mature hedgerows, scattered trees and a woodland area to the north. It is located immediately north of the settlement boundary of Dronfield, recognised as a ‘Level 1’ settlement in the adopted Local Plan (the most sustainable of locations for growth). Scattered agricultural development associated with Birch Cross Farm is located in the southern half of the site.
2.4.
The Vision Document, submitted alongside these representations, includes an indicative masterplan (Figure 1) to accommodate around 200 dwellings, which we intend as a ‘starting point’ to form the basis of onward discussions with the Council. We are keen to address more focussed parameters -such as appropriate densities- proactively with the Council and as informed by emerging evidence, including outcomes from work commissioned by our client for submission by 1 June.
Site feasibility
2.5.
Access to the site would be achieved directly from Eckington Road (B6056) and the site would be well serviced by public transport; an initial transport assessment undertaken and submitted to the Call for Sites found its development for c.200 dwellings would not have an adverse impact on the local highway network.
2.6.
The site is entirely within Flood Zone 1 thus at low risk of flooding from rivers or sea and only small pockets of the site are subject to limited surface water flood risk. There are no listed heritage assets within the site or in particularly close proximity to it. The nearest site – Grade II listed ‘Range of Outbuildings to the East of Silkstone Farmhouse’ is located approximately 315m away in Coal Aston. The site is supported by a willing landowner and a well- developed evidence base established as a result of its allocation within the Submission version of the now-adopted Local Plan which is the subject of ongoing updates. The site could be available to deliver units within the first five year period post-adoption of the new Local Plan, helping to ensure a robust housing supply within the District.
2.7.
The site is within the Green Belt, extensive Moss Valey Conservation Area and the Impact Risk Zone for the Moss Valley Woods SSSI, located approximately 235m north east of the site. These constraints are surmountable and considered in more detail below.
2.8.
As part of the consultation, the Council has published a summary of key outstanding issues that they would need to see appropriately addressed for the site to be considered suitable for selection as a future allocation. The following sub-sections address each of the remaining issues highlighted by the Council through this consultation in turn. Where appropriate and as already addressed above, additional evidence currently being produced for our client will be provided by 1 June to provide additional support to the Council. Whilst some of the issues below have already been addressed through the Call for Sites submission and previous Regulation 18 representations of 2025, for reasons of completeness and clarity, these issues remain included within these representations.
Site issue – location within Moss Valley Conservation Area
2.9.
Section 69 of the Planning (Listed Buildings and Conservation Areas) Act 1990 makes provision for local planning authorities to designate Conservation Areas because of their “special architectural or historic interest the character or appearance of which it is desirable to preserve or enhance”. The Moss Valley Conservation Area was designated by North East Derbyshire District Council on 3rd May 1990. There is no character appraisal for this designated asset nor publicly accessible management plan. Reasons for its designation are only covered within the planning committee report supporting its original designation. The Heritage Statement undertaken by Humble Heritage in 2016 in support of the site’s original designation within the now-adopted Local Plan (also submitted to the Call for Sites exercise in 2025) summarises the reasons for its designation (extracted from the committee report) at paragraph 4.09 of that report. It includes mention of Moss Valley being a landscape of historic interest in its own right, there being a great range of natural and man-made elements which comprise its special character, and the presence of vernacular buildings, farmsteads and early industrial sites.
2.10.
The Moss Valley Conservation Area is a large designation covering an area of approximately 1,660 hectares. It includes a number of small to medium sized settlements containing a mix of types of character including modern dwellings such as Lightwood, Troway, Highlane, Ridgeway, Ridgeway Moor, Ford and part of Marsh Lane so is not exclusively rural. Development of the site would result in the loss of less than 0.3% of rural land from the conservation area. There are no industrial archaeology sites within the site or in close proximity of the site’s boundaries. Cross and Birches Farm is a modern farmhouse and farmstead erected in c.1960s and as such does not positively contribute to the historical significance or appearance of the conservation area in relation to the special character associated with man-made elements and building vernacular. No designated assets are in close proximity to the site and there would be no intervisibility between the site and the setting of heritage assets listed outside of the site.
2.11.
In terms of natural elements of the conservation area, there are no designations within the site and its development would not impact upon the Moss Valley Woodland or nearby SSSI (considered in further detail below). The site is active farmland and as such is highly unlikely to be rich in wildlife habitat. Hedgerows and trees within the site could be retained – notwithstanding the fact that none of them benefit from tree preservation orders – and aside from the ecological benefits, this would help to maintain the grain of the existing field layout. Views are not identified as being an important part of the character and appearance of the conservation area. In any case, the changing topography and belts of trees mean that residential scale development on the site is unlikely to be visible from multiple points within the conservation area, notwithstanding also the opportunity for suitable landscape mitigation to be incorporated with any future proposal for the site.
2.12.
In response to concerns highlighted by the Council, our clients have commissioned a new Heritage Statement which will be provided to the Council by 1 June. In the interim, and for the purpose of providing some additional clarity within these representations, an interim Historic Environment Technical Report was also commissioned. It does identify far-reaching views to the north and north-east that incorporate heritage assets, and potential impact on these assets will be a consideration of the forthcoming Heritage Statement. We can confirm however that early recommendations from our client’s heritage consultants is to ensure the retention of important views from the site across Moss Valley Conservation Area, in particular to Oakes Park and Norton Water Tower. It is also recommended that existing hedgerows are retained wherever possible. Ultimately early indications are that these matters can be addressed via appropriate masterplanning of the site and the Vision Document submitted with these representations provides some additional insight on this, and the Heritage Statement will more directly address the concerns. To note also is that the Historic Environment Technical Report finds no evidence to suggest the site contains archaeological remains relating to the medieval rural economy and post-medieval rural industries associated with the Moss Valley Conservation Area so as to preclude or constrain future development of the site.
2.13.
With the above in mind, and notwithstanding forthcoming evidence, we do not consider that the site’s location within the Moss Valley Conservation Area amounts to a strong reason for restricting development at this location as intended by Footnote 7 of the NPPF and reference to designated heritage assets.
Site issue – location within the Green Belt
2.14.
The site’s main constraint is that it is presently designated as Green Belt. Having regard for the recently published NPPF (December 2024), it is clear in paragraph 146 that Green Belt land can be utilised in ‘exceptional circumstances’ where development needs justify release. It states that “Exceptional circumstances, in this context include… instances where an authority cannot meet its identified need for homes, commercial or other development through other means. If that is the case, authorities should review Green Belt boundaries in accordance with the policies in this Framework and propose alterations to meet these needs in full, unless the review provides clear evidence that doing so would fundamentally undermine the purposes (taken together) of the remaining Green Belt, when considered across the area of the plan”.
2.15.
Given the significant uplift in housing need applicable to North East Derbyshire as a result of the revised standard method for calculating Local Housing Need, we cannot envisage a circumstance whereby North East Derbyshire will not need to review its Green Belt boundaries to accommodate its demonstrable growth needs, particularly given the need to ensure ‘sustainable patterns of development’ as advocated by Paragraph 148 of the NPPF. Exceptional circumstances therefore do exist. With this in mind, an assessment of whether the release of the site from the Green Belt would fundamentally undermine the five purposes of the Green Belt is set out in Table 1.
2.16.
This review has been informed by an assessment carried out by independent landscape consultants Tyler Grange as part of a wider updated Landscape Technical Note which formed part of the original evidence base supporting draft allocation DR2 of the now-adopted Local Plan. This work was completed in July 2025 to inform understanding of the recent NPPF and NPPG changes relating to Green Belt and Grey Belt in relation to this site. It considers the sites contribution to the purposes of Green Belt, also utilising the North East Derbyshire Green Belt Review (NEDGBR) produced by NLP in 2017 to support the then-emerging Local Plan. The site was assessed as part of the wider parcel 025 in that Review; the context of which is highlighted in Figure 2 below.
2.17.
It is acknowledged that the Council are committed to producing an updated Green Belt Review to be published alongside a Publication Draft Local Plan later this year. We cannot envisage a scenario where this land could justifiably be identified as making a strong contribution to the Green Belt since its assessment in 2017 (where it was found to perform moderately against purposes a and d and weaker against purpose b) given the national policy context referred to above and clarity provided by the 2025 updates to the PPG.
Five Purposes of the Green Belt Assessment
A - to check the unrestricted sprawl of large built-up areas;
The Site is bordered by the settlement edge of Coal Aston off Eckington Road to the west and south. Development extends along part of the western boundary of the site from Eckington Road. The site boundary then follows the edge of a designated open space, sports and recreation facility to its northern boundary which is marked by Whinacre Wood which provides a strong defensible boundary. The eastern boundary of the Site is bounded by mature hedgerow dividing the site and the adjacent field which to an extent also provides a defensible edge to ensure development would not sprawl any further eastwards. The NEDGBR review study of Parcel 025 (within which the site is located) considers that the parcel plays a role in preventing unrestricted sprawl: “The parcel is partially contained by the urban area. The southern boundary and the majority of the western boundary adjoin the urban area of Dronfield.” It also states that “The parcel has strong and defensible boundaries. The parcels northern boundary comprises a combination of hedgerow and mature tree coverage, whilst the eastern boundary consists of a hedgerow. The southern and western boundaries adjoin the urban area.” The review gave an overall score of ‘amber’ for purpose (a) – to check unrestricted sprawl, stating that “Development of the
Building lasting value, together 8
parcel would neither strengthen nor weaken the Green Belt boundary.” It is evident that all boundaries of the proposed site are currently contained by either a minimum of mature hedgerow and tree planting but also physical features including roads and housing. Masterplanning of the wider site can further ensure any containing features are reinforced with the siting of residential development also responding to the immediate context. The site represents a logical extension of Dronfield and does not strongly contribute to this Green Belt purpose. Specifically, its contribution in this regard is limited to ‘moderate’.
The PPG clarifies to achieve a Strong contribution, which would rule out Grey Belt designation, there needs to be a lack of “physical feature(s) in reasonable proximity that could restrict and contain development”. Furthermore, that the development would result in an “incongruous pattern of development (such as an extended “finger” of development into the Green Belt)”. Whilst only illustrative, it is clear that the development of the site would not amount to either example provided. Conversely, to achieve a moderate contribution, the PPG clarifies land which is “adjacent or near to a large built up area, but include one or more features that weaken the land’s contribution to this purpose a, such as (but not limited to):
•
having physical feature(s) in reasonable proximity that could restrict and contain development
•
be partially enclosed by existing development, such that new development would not result in an incongruous pattern of development
•
contain existing development
•
being subject to other urbanising influences”.
All of which apply to the site, indicating strongly that the previous
assessment remains robust under the new guidance and that at worst the site should be judged to make a moderate contribution to Purpose A of the Green Belt.
B - to prevent neighbouring towns merging into one another;
The City of Sheffield lies to the north of Dronfield and comprises many various suburbs, the closest of which to Dronfield include Batemoor and Jordanthorpe which are c.780m north of the Site. Development of the Site would not bring them into closer proximity with one another. As similarly pointed out in the 2017 NEDGBR in relation to the parcel containing the Site: “The parcel would leave a gap marginally above 1km to Sheffield urban area. In addition it is no closer than the existing adjoining development.” Removal of this Site from the Green Belt would not reduce the strategic gap between Dronfield and Sheffield. The next nearest town to the Site and the east of Dronfield is Eckington which is located c.4.4km from the easternmost extent of Dronfield. Development of the Site would not reduce this gap as the Site is located further west than the most eastern extent of Dronfield at Eckington Road. Chesterfield town is located c.5km south-east of the Site. Development south of Eckington Road (B6056) is located between the Site and Chesterfield. Development at the southern extents of Dronfield also fall in closer proximity to Chesterfield. The site does not make a strong contribution to this purpose. Specifically, the sites contribution in this regard is ‘weak’. This finding is contrary to the conclusion of the Inspector in Examining the now-adopted Local Plan who, in her letter dated 18 February 2019, highlighted the perceived impact of development on the strategic function of Green Belt at this location (in particular to maintain expansive vistas between urban areas and to define settlement extent) as reason for the site’s removal as a draft allocation. Its weak contribution to this Green Belt purpose as detailed here evidences that the site does not erode these features at this location.
Building lasting value, together 9
Again, the updated PPG provides helpful guidance as to how land should be considered against this purpose. Strong functioning land against this purpose is land which forms a substantial part of a gap between towns and would result in the loss of visual separation between towns, neither of which would be applicable. Land which serves a moderate purpose includes land which forms a small gap between towns, being able to be developed without the loss of visual separation. This could be due to the presence or the close proximity of structures, natural landscape elements or topography that preserve visual separation. Weak/no function is similar, where the land does form a gap between towns, but only a very small part of the gap, without making a contribution to visual separation. Having regard for the above, it is clear at worst the site would make a moderate contribution but given scale and lack of intervisibility, a weak contribution is considered more robust.
C - to assist in safeguarding the countryside from encroachment;
The 2017 NEDGBR acknowledged that the parcel already includes some development that accounts for approximately 10% of the parcel, giving it an ‘amber’ score. In terms of site specific development, Birch Cross Farm is currently situated on Site and includes an individual farmstead and associated buildings, vegetation and hardstanding. The field parcels within the Site are presently associated with the farmstead and used for agricultural purposes. Development of the Site would extend the existing built boundaries off Birches Lane and Eckington Road towards the north and Whinacre Wood. The NEDGBR set out that “development of the parcel would neither strengthen nor weaken the Green Belt boundary.” Whinacre Wood would become the boundary which could be supplemented by on-Site planting creating a softer edge between the Green Belt and Urban areas. This would allow any potential for further encroachment to be restricted, prevented and mitigated. The site does not make a strong contribution to this purpose. Specifically, its contribution in this regard is limited to ‘moderate’.
D - to preserve the setting and special character of historic towns; and
The Site is located within the Moss Valley Conservation Area however it does not form a significant part of the conservation area, making no specific contribution to its special character. Further, there is no character appraisal or management plan supporting the designation and the 2017 NEDGBR stated in regard to the parcel containing the site that “The parcel is located within the Moss Valley Conservation Area. It is however considered that the parcel has a limited role in preserving the setting of a historic village or town. The Moss Valley Conservation Area covers a large area of land, and it is not considered that this parcel serves a fundamental purpose of Green Belt land in this respect.” Further, the site is not considered to form part of the historic setting of Dronfield, nor does it have particular relationship with historic elements of the town, being visually screened from its conservation area and listed buildings by mostly post-war development. In accordance with the PPG a weak score is considered appropriate.
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The significant increase in the Local Housing Need for North East Derbyshire and strong evidence of enhanced demand within Dronfield means that multiple sites will be required at different scales to deliver this housing need and this cannot be delivered solely through brownfield allocations. The proposed site allocation would not therefore discourage the recycling of derelict and other urban land in North East Derbyshire and therefore its status as Green Belt land does not strongly contribute to this purpose.
Conclusion
Development of the site would not fundamentally undermine the five purposes (taken together) of the Green Belt. Furthermore, the site does not strongly contribute to purposes (a), (b) or (d) of paragraph 143, nor do the application of policies relating to Footnote 7 designations (excluding Green Belt) provide a strong reason for refusing or restricting development. As such, the site would meet the definition of Grey Belt set out in the NPPF.
2.18.
As set out above, we consider that Footnote 7 designations – specifically the Moss Valley Conservation Area designated heritage asset – do not provide strong reasons for restricting development. Additional context to this is the shift in recognition of Grey Belt designation from being perceived as resulting from a purely land-based assessment to one which should take account of a proposal (including any mitigation provided). In Wrotham Parish Council v SSHCLG (Ref: AC-2025-LON-000898), the High Court concluded that the Inspector had erred in their judgment in only assessing the land, rather than the proposal – which included mitigation – in concluding on impacts on Footnote 7 designations.
2.19.
Whilst this finding relates to decision making on a specific proposal with explicit mitigation measures proposed, the principle logically should be carried across when considering potential allocation, particularly as any site-specific policy can appropriately require mitigation measures as part of any future proposal. This is further underpinned by the Government’s clear intention to remove reference to Footnote 7 from the grey belt definition within the NPPF, which is a logical refinement given that decision makers have at their disposal the tools to refuse permission where a particular designation (such as a heritage asset) would genuinely provide strong reasons for refusal anyway. There is no need for grey belt designation to repeat such protections which results in the artificial narrowing of the scope of land that can fall within grey belt category.
2.20.
With the above in mind, the site would meet the definition of Grey Belt set out in the NPPF. Paragraph 155 of the NPPF (2024) confirms development in the Green Belt should not be regarded as inappropriate where:
•
the development would utilise grey belt land and would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan,
•
there is a demonstrable unmet need for the type of development proposed,
•
the development would be in a sustainable location and
•
where applicable the development proposed meets the ‘Golden Rules’ requirements set out in paragraphs 156-157.
2.21.
With regard to the ‘Golden Rules’ set out in paragraphs 156-157 of the NPPF, the affordable housing requirement to be accommodated on the site will be set at a higher level than that which would otherwise apply to land, subject to viability, to be established in this Plan as per Framework particularly Paragraph 67b. The development proposal on the site will include any necessary improvements to local or national infrastructure as well as provision of new, or improvements to existing, green spaces that are accessible to the public.
2.22.
Development of this site would meet all of the criteria of NPPF Paragraph 155 and therefore would not constitute inappropriate development in the Green Belt. Given its Grey Belt status, its release from the Green Belt should be prioritised.
Site issue – landscape impact
2.23.
Our client has commissioned Landscape and Visual Impact Assessment (LVIA) evidence following direct feedback from the Council received after completion of their site refinement process. Specifically, it has been requested that LVIA is carried out to address some specific landscape constraints identified by the Inspector appointed to examine the now adopted Local Plan who, at the time, removed the site from contention for allocation not least due to perceived localised landscape impacts such as in relation to Eckington Road and Footpath 37. This evidence will be submitted to the Council by the 1 June 2026 deadline afforded for additional evidence.
2.24.
The Vision Document submitted alongside these representations provides some early insight, which suggests the site is generally well contained with a limited visual connection with the wider landscape character and that the visual effects associated with future development would be contained to near context and would be capable of being managed through layout, scale and landscape mitigation.
2.25.
Notwithstanding the above, in support of representations submitted to the last round of consultation in 2025, our client separately commissioned a detailed Landscape Technical Note which provides useful insight in the interim, until completion of the LVIA. In summary, the report – which was carried out by landscape specialists Tyler Grange – found that the site had a very limited relationship with the wider Moss Valley Conservation Area and that development of the site has the potential to be accommodated with reference to the site-specific conditions. It made a number of observations and recommendations as follows:
•
Permeability across the site should be integrated into any emerging development layout and views across portions of the Site retained. Vehicular access should be limited to the south, off Eckington Road with pedestrian access in other locations, linking up with the wider Green Infrastructure network;
•
The Site is influenced by its visual connection to the surrounding settlement edge. This character and backdrop acts as a strong precedent, but built development will need consideration of appropriate materials, scale, height and density to respond to the context;
•
An existing overhead line runs north-south through the Site, this constraint could be utilised to create a green link connecting the Site from Eckington Road to the wider PRoW network. Further tree planting will further assist in softening building mass where the Site can be viewed (partially screened and heavily filtered) from elevated, distant locations to the north;
•
Where the Site is viewed from elevated topography to the north and east, it is where there are gaps in existing built form and boundary vegetation. However, these views are very limited due to the layering effect of scattered built form, changes in topography and vegetation associated with these dwellings, fields and roads. Layering of east-west vegetation strips and new Green Infrastructure corridors could be considered throughout the Site to break-up and soften any new built development;
•
The site is physically contained in all directions by mature boundaries. Boundaries should be retained and enhanced with development offsets and new native planting to soften the development edge linking into the existing Green Infrastructure network;
•
In terms of Green Belt, when assessed against Green Belt purposes, the Site does not perform a strong contribution in any purpose and is largely consistent with the findings of the previous NEDGBR 2017 undertaken by NEDC;
•
The site bears no listed heritage assets, nor has any known archaeology that provides cultural links to the past, nor does the site have any known cultural associations related to people or industry (such as mineral extraction and metalworking). Little is left of the historic field pattern, of which the current five fields on Site have occurred through agricultural intensification and field amalgamation. The farm complex is late 20th century and the Site as a whole is overlooked by late 20th and early 21st century housing.
Site issue – relationship with Moss Valley Woodlands SSSI and wider ecology
2.26.
Moss Valley Woods SSSI is designated on account of the presence of ancient woodland, located 0.2km north east of the site. It comprises two units of woodland – Whinacre Wood and Brownstorth Wood. It is contiguous with woodland in the north of the site and an ephemeral stream connects this woodland to the SSSI. The site falls within Natural England’s Impact Risk Zone where potential residential developments of 100 units or more would require further consultation with Natural England, consideration of potential impacts and appropriate mitigation.
2.27.
Potential adverse effects are limited by reason of there being no direct pedestrian links to the SSSI from the site and no known footpaths or access into Whinacre Wood (within the SSSI). The distance involved along with lack of parking and direct public access to Brownstorth Wood part of the SSSI means negligible potential impacts on this unit are anticipated.
2.28.
Principles of mitigation set out in the SSSI Technical Note submitted to the Call for Sites form the basis for mitigation that could be delivered to ensure the SSSI is not adversely affected by development of the site and these would be integrated with proposals through the planning application process. In summary the principles of such mitigation could include the implementation of pollution prevention measures during construction, implementation of an appropriately designed drainage strategy and implementation of a woodland management and access plan for the woodland in the north of the site. These principles would need to be built upon in consultation with Natural England.
2.29.
Notwithstanding the above considerations, in response to concerns raised by the Council, our client commissioned an Ecology Walkover Survey Report which was completed in April 2026 and will be submitted to the Council by 1 June. In this report, it is recommended that a habitat buffer between any potential development and the riparian corridor connected to the SSSI is retained. Otherwise, it finds the early indicative development footprint is largely devoid of priority habitats, but finds the stream and woodland to the northern boundary is high value and should be avoided, and the land between enhanced. All of these issues can be addressed directly through appropriate masterplanning of the site, and the Vision Document submitted alongside these representations and the indicative layout plan provides additional insight on this.
Site issue – presence of some risk of surface water flooding
2.30.
The site is wholly within Flood Zone 1. However with regards to surface water flooding and the presence of limited risk on some small sections of the site, onward site promotion and evidence to inform a planning application would include a Flood Risk Assessment and the site would be underpinned with a Sustainable Urban Drainage Strategy. It is important to note, much of the surface water flood risk is associated with an area of the site that would not be developed in any case – i.e. in relation to the woodland in the northern part of the site.
Site issue – location within the Coal Authority ‘High Risk’ area
2.31.
The coal mining ‘high risk’ zone is an extensive designation covering the entirety of multiple local planning authority areas. A Coal Mining Risk Assessment will be forthcoming as an important evidence base component to support a future planning application. Within this, any required mitigation would be identified.
Summary
2.32.
The site is included in the refined schedule of sites following initial assessment by the Council and the Land Availability Assessment categorises the site as ‘amber’, indicating ‘some constraints’. The key issues influencing the site’s current rating are addressed above and we consider are all resolvable through appropriate mitigation which will be forthcoming. Our approach to addressing any constraints will be the subject of further evidence base enquiry either for submission by 1 June or to inform onward promotion and an eventual planning application. This, as well as overall emerging strategic approach to the location of growth which favours Level 1 towns such as Dronfield, provides strong justification for allocating the site for residential development in the future Local Plan.
Development needs – Housing
Option 1 – Standard Method
2.33.
The NPPF is clear at Paragraph 62 that “to determine the 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”; effectively, the housing need informed by the standard method is the ‘policy-off’ assessment of the minimum number of homes needed in an area. Plugging this into a consideration of wider environmental, economic and social factors, policies and constraints then determines the housing requirement. The NPPF is clear that “the overall aim should be to meet an area’s identified housing need”. There has to be a well evidenced and compelling argument set out by a plan making authority to justify planning for a lower housing requirement than the housing need identified using the Standard Method. The NPPG makes clear there are some ‘specific circumstances’ whereby this might be justified. The specific circumstances set out at Paragraph 014 of the NPPG do not apply in the case of North East Derbyshire, and we do not consider that any insurmountable constraints exist within the District to justify the pursuit of a housing requirement which diverges negatively from the Standard Method informed housing need. Such an approach we consider would be found to be unsound.
2.34.
In view of the above, as an absolute minimum, Option 1 as set out within the current consultation document should be pursued. In fact, as considered in more detail below, there is evidence in favour of planning for above the Standard Method derived housing need figure.
Option 3 – above Standard Method
2.35.
Whilst the NPPF is clear that the overall aim of strategic policies relating to the delivery of a sufficient supply of homes should be to meet an area’s identified housing need, it is also clear that a Standard Method derived housing need will identify the minimum number of homes needed. The NPPF empowers local planning authorities to apply a ‘policy-on’ approach which should factor in local and strategic ambitions (including economic) as well as general affordability pressures to inform their housing requirement, which may justify pursuit of an increased requirement. Such an approach is closely aligned with the latest Government ambitions to significantly boost the supply of new homes nationally.
2.36.
North East Derbyshire is strategically well placed adjacent to Sheffield (the 4th largest city in England) and Chesterfield. Dronfield specifically benefits from access to the A61 corridor (the subject of a range of improvement projects), Northern Rail and local bus services which provide efficient access between all three. Both Sheffield and Chesterfield are the focus of significant growth ambitions set out in their respective Combined Authority economic plans and from this a growth in a wide range of employment sectors is targeted. Long term ambitions for these cities places North East Derbyshire and its main towns – including Dronfield – perfectly to benefit and, as part of this, react to likely further increase in demand for new homes. Given the spatial relationship between North East Derbyshire and the larger settlements, the housing requirement eventually promoted should take into account these regional ambitions which indicate a need to advance beyond the Standard Method derived minimum.
2.37.
As with the overall Standard Method derived housing need, affordable housing need has also significantly increased since adoption of the current Local Plan. The Housing Needs Assessment (2024) identifies an overall need of 356 affordable dwellings per annum – over 58% of the overall need – and makes clear that “provision of new affordable housing is an important and pressing issue in the area”. The new Local Plan could be proactive in addressing this, by planning to deliver more than the Standard Method derived housing need.
Mix of scale and type of housing sites should be sought
2.38.
The refined schedule of sites evidences that the Council intend to include within the new Local Plan a range of site sizes, also commensurate with the level of sustainability of the varied locations for growth also being supported. We support this approach in principle; the NPPF is clear at Paragraph 72 that “planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability”. The provision of a range of site allocations sizes will help to boost housing delivery by limiting the reliance on large strategic sites which in turn will support flexible and phased delivery from a range of providers. Critically, the provision of a range of site allocation sizes across multiple locations is a major factor in sustaining a robust and deliverable housing pipeline and five-year housing land supply. Our client’s site is at the lower end of the large sites scale and would be in a position as a result of this to contribute directly to the Council’s five-year housing land supply, as well as requirements of plan years beyond.
2.39.
Linked to this also, we continue to support an approach which seeks to allocate a range of types of sites. Although not a topic of this consultation, the 2025 consultation identified seven site type options which between them would provide a varied range of potential impacts (eg. sites within the Green Belt, sites with some landscape harm and higher density sites). Development in any location, by its very nature, will result in some level of impact on its immediate context. However the key, in our view, is to focus on delivering housing in the locations where it is most needed whilst minimising impacts and maximising potential benefits. We agree therefore with the findings of the Sustainability Appraisal which, at paragraph E20 summarises that “it is likely that a combination of different site type options will allow for the most sustainable development strategy, informed by a robust evidence base to determine the capacity of different locations in the district to accommodate proposed growth that is aligned with the relative scale and character of existing settlements”.
Development needs - employment
2.40.
As set out in our previous representations, the new Local Plan should be aspirational and a key component of this will be the district’s ability to accommodate ambitious employment growth. As such, the Council should plan for the district’s employment land requirements at the upper end of the 15-31 ha as recommended in the Employment Needs Assessment (Option 2 in the current consultation document). The upper end of the estimate quite rightly takes account of the ‘policy on’ scenario, recognising the district’s local economic growth aspirations and key growth sectors of the economy. Given the significantly increased Standard Method derived housing need for the district and the need for it to be met as a minimum, it is also correct that labour supply resulting from new housing is taken into account when identifying the quantity of employment land that will be required to service the district going forward. Not adopting this approach risks artificially constraining economic growth which would be in direct contravention of NPPF ambitions, particularly its call for the planning system to build a strong, responsive and competitive economy. We do not consider the district to be so constrained that the identified quantum of employment land within the upper estimate would be undeliverable, particularly when you consider its relationship with the economic growth ambitions of the wider area, including neighbouring Sheffield.
Spatial distribution of development
2.41.
In principle we support the Council’s proposed approach to the location of development. Specifically, that the level of priority of location for accommodating growth correlates with the level of sustainability and role of the type of settlement. We agree that ‘Priority 1 Locations’ should include as indicative locations those listed i.e. the edge of Chesterfield/ Sheffield, new settlement/ strategic sites and level 1 settlements – main towns. We also agree that Dronfield should continue to be recognised as a level 1 settlement – main town, which we explore in more detail below. It is notable that the Sustainability Appraisal does not envisage any major negative effects from accommodating development at the main towns. Indeed, providing growth to the main towns represents a sustainable growth strategy which would, critically, leverage existing infrastructure and services provided by the them, support the vitality and viability of their centres and facilitate access to enhanced sustainable transport options they provide.
2.42.
We also agree that allocations should be assigned using a ‘cascade’ approach. Through this approach, the higher priority locations are likely to receive higher levels of growth which is logical and supported in evidence, albeit the Council will need to remain cognisant of factors which may determine slight divergence from this if necessary, for example in providing for strongly evidenced localised need or responding to key constraints which, for example, may determine that lower priority locations, at least in some scenarios, represent the more suitable location for growth. We note that the consultation responses received are largely in favour of such an approach also.
2.43.
In our previous representations we highlighted that we considered options to focus growth around Sheffield and Chesterfield as not being the most sustainable approach. We considered that such a focus would fail to address the localised need evidenced across the district and undermine local opportunity within the district. We consider that the approach now put forward by the Council – specifically to dilute this focus into a broader ‘Priority 1 Locations’ level alongside, in particular, level 1 settlements – main towns (such as Dronfield) as a sustainable and well-balanced approach. Such an approach alleviates concerns we had that the future distribution of growth would be directed overwhelmingly toward Sheffield and Chesterfield at the expense of other settlements across the district, and this we consider would have been an unsound approach.
Settlement hierarchy
2.44.
We agree with the principle of the approach taken by the Council to identify and group together settlements with similar levels of sustainability which perform similar roles, amounting to a settlement hierarchy. We agree this should feed directly into deciding the spatial distribution of development discussed above.
2.45.
In particular, we concur with the findings of the Settlement Role and Function Study (March 2026) and discussion within the Settlement Hierarchy Topic Paper (March 2026) insofar as it relates to Dronfield and its containment within the ‘Level 1: Towns’ settlement level (scoring well above the required 32+ points (40+)). With concur with the findings that Dronfield includes a recognised town centre which contains an extensive range of services, and that it performs a prominent role in meeting the day to day needs of people across a wide geographic area. We also agree with its findings that Coal Aston forms part of Dronfield, being “closely related to Dronfield, with no obvious physical boundary between them” (paragraph 3.4).
Dronfield as a location for growth
2.46.
As the largest of the settlements in North East Derbyshire it is particularly important that Dronfield accommodates a proportionate level of growth. Its wide range of services, facilities and transport infrastructure as well as its role as a main town within the ‘north east economic zone’ of the Derbyshire Economic Strategy and close proximity to Sheffield and the wider South Yorkshire Mayoral Combined Authority – along with its significant economic growth ambitions – highlights Dronfield as a sustainable location for growth which should play a significant role in delivering North East Derbyshire’s Local Housing Need. Demand for housing around Dronfield is particularly strong as evidenced within the Local Housing Needs Assessment 2024 (LHNA) which finds that even the economic turbulence at the time – in particular its effect on mortgage rates – has had very little impact on buyer demand in the area. The assessment notes that Dronfield appears to have the strongest market demand within the District and notes that “the north and west of the district clearly sees higher prices than the south and east. Areas surrounding Dronfield in particular see high prices” (Paragraph 2.11).
2.47.
A divergence between demand and supply also appears around Dronfield in relation to affordable housing. The LHNA finds that the parish of Dronfield (attributed for this exercise to Dronfield, Coal Aston and Dron Woodhouse where parish statistics have not been collated) is amongst the most in-demand areas within the district with 207 applicants with local connection on the Council’s housing waiting list as at June 2024. Out of 25 Parishes, Dronfield is the third most in-demand within the District on these terms. Of the district’s wards, Dronfield South saw the most average bids per property in 2023 (80). The LHNA identifies an affordable housing need of 71 (net) affordable rented dwellings per annum within Dronfield Parish – the most of any Parish - and Dronfield is the only area identified as having a tangible net need for affordable home ownership products (30 per annum). The identified ‘standardised need for affordable housing’ finds that Dronfield Parish has a need per 1000 dwellings of 10.67 per annum. For comparison purposes, Clay Cross has a need of 5.48, Eckington has a need of 6.89 and Killamarsh has a need of 8.02 – all of these being significantly lower than that of Dronfield.
2.48.
The above represent significant indicators of a historically constrained supply of new dwellings within and around Dronfield specifically. Despite these circumstances, the adopted Local Plan apportions notably less new housing to Dronfield when compared with the smaller towns of Clay Cross and Killamarsh, an issue exacerbated by the Inspector’s decision to remove this site during the examination of the extant Local Plan. The new Local Plan provides the opportunity to re-balance this and ensure Dronfield accommodates a proportionate quantity of dwellings reflecting its existing size and offer. Whilst Dronfield’s place within the Green Belt and associated complexities around its expansion (specifically, the need to release land from the Green Belt) is acknowledged, our client’s site as considered above in more detail, represents an opportunity to contribute to resolving the demand issue in the area with limited Green Belt impact.
Strategic sites and new settlements
2.49.
With the above considerations in mind, whilst we do not object to the principle of identifying strategic sites and new settlements as part of ‘Priority 1 Locations’ for growth, we maintain reservations around the suitability of strategic site ‘Duckmanton Moor’ (now merged from previous sites 45227 and 45541) which is expected to be able to accommodate 2000-3000 dwellings.
2.50.
The southern element of the strategic site (45227) does not directly relate to any existing settlement form and as such would represent an illogical and significant intrusion into the open countryside at this location. The nearest settlement – Arkwright Town to the north – is distant from this element of the site without any sense of continuity. Similarly, whilst technically attached to Arkwright Town to its north west and Long Duckmanton to its north east, the northern element of the site (45541) would result in an illogical and incongruent built form exclusively to the south of A632, awkwardly conjoining both settlements with notable impacts on the countryside at this location including its openness and any landscape value.
2.51.
Both Arkwright Town and Long Duckmanton offer limited provision of services, facilities and employment as highlighted also by the previous Settlement Hierarchy Study and more recently the Settlement Hierarchy Topic Paper, with a significant number of settlements rated as being more sustainable locations for growth. Whilst settlements such as Arkwright Town and Long Duckmanton could accommodate some growth (and, indeed, a distribution of growth across the district we consider to be a sustainable approach), the scale of growth being considered through the delivery of this newly merged strategic site would be entirely at odds with their scale and offer and such an approach we consider to be unsustainable.
2.52.
A significant proportion of the site is occupied by established woodland and this represents a substantial development constraint. Given the likely ecological value of the woodland area, its inclusion within the site will establish a considerable BNG baseline to address which has the potential to undermine viability of the site as a whole. Retention of the asset would significantly reduce the actual developable area provided by the potential allocation and limits the extent to which the site could contribute to delivering the district’s housing needs. Reducing the extent of the site to exclude the woodland area would result in the same outcome, preventing the delivery of a critical mass of dwellings required to fund and maintain new service provision necessary to make new free-standing communities viable and sustainable, particularly in this location where existing infrastructure provision is so limited. Likewise, the exclusion of the woodland area may limit opportunities for mitigation and enhancement where needed.
Sustainability Appraisal (SA) Addendum March 2026
2.53.
The SA Addendum has been produced to assess 271 reasonable alternative sites for residential use which have been identified by the Council – following a comprehensive assessment and filtering process – as being genuinely capable of being selected as allocations within the emerging Local Plan. This assessment does not take into account any mitigation, which of course, as explored in more detail above for our client’s site, can and will be forthcoming where required.
2.54.
Whilst we have not carried out an exhaustive review of the SA Addendum, we do have some concerns which we think are important to raise now, relating to scores applied and, in some cases, what appears to be a mismatch between the stated method for arriving at appropriate scores and its application to this site.
2.55.
For example, we note that the site has been scored negatively for access to a bus stop, yet bus stops are available almost immediately adjacent to the site along Eckington Road. The SA links a negative rating to scenarios where bus stops are more than 400m away from a site, which is simply not the case for this site. Similarly, we are surprised to see a negative score in relation to access to a secondary school given the relatively close proximity to the site (1.75km away via Oakhill Road and Stonelow Green) of one of only three secondary schools in the whole of North East Derbyshire (Dronfield Henry Fanshawe School). It is not clear how this score is justified given the wider context. Further, Oakhill Medical Practice is located off Oakhill Road less than 1km from the site. Again, it is not clear how a negative score against this measure of site accessibility to services can be justified and overall these issues point to three separate scores which we consider to be excessively negative.
2.56.
We also consider that a negative score resulting from the site’s location within a Natural England SSSI Impact Risk Zone is excessive. At this stage, Natural England’s response and position is unknown and should be reflected as such within the SA. Natural England would be consulted as part of onward promotion and, ultimately, to inform a planning application and it is worth noting that the element which impacts on this site only requires consultation for developments of 100 dwellings or more.
Conclusion
2.57.
The site is included in the refined schedule of sites following initial assessment by the Council and the key issues highlighted by the Council are addressed within these representations and we consider are all surmountable alongside appropriate mitigation which will be forthcoming. Our approach to addressing any constraints will be the subject of further evidence base enquiry either for submission by 1 June or to inform onward promotion and an eventual planning application. This, as well as overall emerging strategic approach to the location of growth which favours Level 1 towns such as Dronfield, provides strong justification for allocating the site for residential development in the future Local Plan.

1. Introduction
1.1.
These representations are prepared by Fisher German on behalf of our client Richborough in respect of their land interests at Cross and Birch Farm, off Eckington Road, Coal Aston, Dronfield.
1.2.
The site was submitted to the Council during the 2025 Call for Sites exercise alongside an extensive evidence base engaging on landscape, ecology, transport, heritage and other matters. The site has since been the subject of Representations submitted to the initial Regulation 18 consultation carried out between June and August 2025.
1.3.
The Council are now consulting on its latest material as part of the Issues & Options stage of Local Plan production. Specifically, the current consultation is focussed on the strategic approach to the location of development and a refined schedule of sites all of which have passed through both the initial desktop screening, and further detailed stages of assessment. Notably, these sites also align with the emerging strategy. Included within this refined schedule is our client’s site identified as ‘45483 – Land off Eckington Road, Coal Aston, Dronfield’ within the consultation document.
1.4.
For context it’s important to note that the site was included as a draft allocation - DR2 - in the Submission version of the now-adopted Local Plan (adopted November 2021). This demonstrated the Council’s in principle agreement that the site could accommodate residential development. Following completion of the Examination Hearing Sessions, the Inspector in her initial findings report highlighted concerns around DR2, concluding that it was a prominent extension that changes the character of the area, harms the Moss Valley Conservation Area and erodes the function of the Green Belt. On this basis, the Inspector recommended deletion of the site. Ultimately, to secure adoption of the plan at that time, the Council conceded and removed the site through Main Modifications.
1.5.
It is acknowledged that the Council were previously unable to demonstrate exceptional circumstances that could outweigh perceived harm enough to warrant removal of the site from the Green Belt and as such it was removed as an allocation from the then-submission version Local Plan. However it is considered that the context within which plan making is being undertaken today – driven by central Government ambitions for enhanced housing delivery (1.5 million net additional homes in England by the next General Election), supported by a raft of changes to the National Planning Policy Framework (NPPF) – has fundamentally changed in favour of significantly boosting housing supply locally, including via the increased utilisation of Green Belt sites (as confirmed by Paragraph 146 of the Framework), but only where such sites meet the Golden Rules of Paragraph 156 and 157 of the Framework, providing enhanced public benefits. This site represents a viable option for helping North East Derbyshire to deliver on its (much increased) housing need whilst minimising Green Belt harm and is fully compatible with the current Framework and its approach to the utilisation of Green Belt to meet housing needs in full.
1.6.
The NPPF and Standard Method were published on 12th December 2024 and the updated Local Housing Need for the district has significantly increased from 224 dwellings per annum (dpa) to 605 dpa. The Council will be required to allocate sufficient residential sites to deliver the housing need and we believe this will need to include the use of currently designated Green Belt land to secure a pattern of deliverable and sustainable growth (NPPF 148).
2. Representations
45483 – Land off Eckington Road, Coal Aston, Dronfield
2.1.
The consultation invites specific comments on sites which have been the subject of further testing and been included within the refined schedule. This section seeks to provide site specific commentary to promote its onward selection as a future allocation and this includes a consideration of relevant evidence base work carried out by the client to inform site strategy.
2.2.
It should be noted that since submission of the representations to the June-August 2025 consultation, our client has commissioned updated evidence base and informative plans which are discussed here wherever possible. Otherwise, any additional documentation will be provided to the Council by 1 June as required by the Council and set out in direct correspondence in March 2026.
Site overview
2.3.
The site comprises five field parcels bounded by mature hedgerows, scattered trees and a woodland area to the north. It is located immediately north of the settlement boundary of Dronfield, recognised as a ‘Level 1’ settlement in the adopted Local Plan (the most sustainable of locations for growth). Scattered agricultural development associated with Birch Cross Farm is located in the southern half of the site.
2.4.
The Vision Document, submitted alongside these representations, includes an indicative masterplan (Figure 1) to accommodate around 200 dwellings, which we intend as a ‘starting point’ to form the basis of onward discussions with the Council. We are keen to address more focussed parameters -such as appropriate densities- proactively with the Council and as informed by emerging evidence, including outcomes from work commissioned by our client for submission by 1 June.
Site feasibility
2.5.
Access to the site would be achieved directly from Eckington Road (B6056) and the site would be well serviced by public transport; an initial transport assessment undertaken and submitted to the Call for Sites found its development for c.200 dwellings would not have an adverse impact on the local highway network.
2.6.
The site is entirely within Flood Zone 1 thus at low risk of flooding from rivers or sea and only small pockets of the site are subject to limited surface water flood risk. There are no listed heritage assets within the site or in particularly close proximity to it. The nearest site – Grade II listed ‘Range of Outbuildings to the East of Silkstone Farmhouse’ is located approximately 315m away in Coal Aston. The site is supported by a willing landowner and a well- developed evidence base established as a result of its allocation within the Submission version of the now-adopted Local Plan which is the subject of ongoing updates. The site could be available to deliver units within the first five year period post-adoption of the new Local Plan, helping to ensure a robust housing supply within the District.
2.7.
The site is within the Green Belt, extensive Moss Valey Conservation Area and the Impact Risk Zone for the Moss Valley Woods SSSI, located approximately 235m north east of the site. These constraints are surmountable and considered in more detail below.
2.8.
As part of the consultation, the Council has published a summary of key outstanding issues that they would need to see appropriately addressed for the site to be considered suitable for selection as a future allocation. The following sub-sections address each of the remaining issues highlighted by the Council through this consultation in turn. Where appropriate and as already addressed above, additional evidence currently being produced for our client will be provided by 1 June to provide additional support to the Council. Whilst some of the issues below have already been addressed through the Call for Sites submission and previous Regulation 18 representations of 2025, for reasons of completeness and clarity, these issues remain included within these representations.
Site issue – location within Moss Valley Conservation Area
2.9.
Section 69 of the Planning (Listed Buildings and Conservation Areas) Act 1990 makes provision for local planning authorities to designate Conservation Areas because of their “special architectural or historic interest the character or appearance of which it is desirable to preserve or enhance”. The Moss Valley Conservation Area was designated by North East Derbyshire District Council on 3rd May 1990. There is no character appraisal for this designated asset nor publicly accessible management plan. Reasons for its designation are only covered within the planning committee report supporting its original designation. The Heritage Statement undertaken by Humble Heritage in 2016 in support of the site’s original designation within the now-adopted Local Plan (also submitted to the Call for Sites exercise in 2025) summarises the reasons for its designation (extracted from the committee report) at paragraph 4.09 of that report. It includes mention of Moss Valley being a landscape of historic interest in its own right, there being a great range of natural and man-made elements which comprise its special character, and the presence of vernacular buildings, farmsteads and early industrial sites.
2.10.
The Moss Valley Conservation Area is a large designation covering an area of approximately 1,660 hectares. It includes a number of small to medium sized settlements containing a mix of types of character including modern dwellings such as Lightwood, Troway, Highlane, Ridgeway, Ridgeway Moor, Ford and part of Marsh Lane so is not exclusively rural. Development of the site would result in the loss of less than 0.3% of rural land from the conservation area. There are no industrial archaeology sites within the site or in close proximity of the site’s boundaries. Cross and Birches Farm is a modern farmhouse and farmstead erected in c.1960s and as such does not positively contribute to the historical significance or appearance of the conservation area in relation to the special character associated with man-made elements and building vernacular. No designated assets are in close proximity to the site and there would be no intervisibility between the site and the setting of heritage assets listed outside of the site.
2.11.
In terms of natural elements of the conservation area, there are no designations within the site and its development would not impact upon the Moss Valley Woodland or nearby SSSI (considered in further detail below). The site is active farmland and as such is highly unlikely to be rich in wildlife habitat. Hedgerows and trees within the site could be retained – notwithstanding the fact that none of them benefit from tree preservation orders – and aside from the ecological benefits, this would help to maintain the grain of the existing field layout. Views are not identified as being an important part of the character and appearance of the conservation area. In any case, the changing topography and belts of trees mean that residential scale development on the site is unlikely to be visible from multiple points within the conservation area, notwithstanding also the opportunity for suitable landscape mitigation to be incorporated with any future proposal for the site.
2.12.
In response to concerns highlighted by the Council, our clients have commissioned a new Heritage Statement which will be provided to the Council by 1 June. In the interim, and for the purpose of providing some additional clarity within these representations, an interim Historic Environment Technical Report was also commissioned. It does identify far-reaching views to the north and north-east that incorporate heritage assets, and potential impact on these assets will be a consideration of the forthcoming Heritage Statement. We can confirm however that early recommendations from our client’s heritage consultants is to ensure the retention of important views from the site across Moss Valley Conservation Area, in particular to Oakes Park and Norton Water Tower. It is also recommended that existing hedgerows are retained wherever possible. Ultimately early indications are that these matters can be addressed via appropriate masterplanning of the site and the Vision Document submitted with these representations provides some additional insight on this, and the Heritage Statement will more directly address the concerns. To note also is that the Historic Environment Technical Report finds no evidence to suggest the site contains archaeological remains relating to the medieval rural economy and post-medieval rural industries associated with the Moss Valley Conservation Area so as to preclude or constrain future development of the site.
2.13.
With the above in mind, and notwithstanding forthcoming evidence, we do not consider that the site’s location within the Moss Valley Conservation Area amounts to a strong reason for restricting development at this location as intended by Footnote 7 of the NPPF and reference to designated heritage assets.
Site issue – location within the Green Belt
2.14.
The site’s main constraint is that it is presently designated as Green Belt. Having regard for the recently published NPPF (December 2024), it is clear in paragraph 146 that Green Belt land can be utilised in ‘exceptional circumstances’ where development needs justify release. It states that “Exceptional circumstances, in this context include… instances where an authority cannot meet its identified need for homes, commercial or other development through other means. If that is the case, authorities should review Green Belt boundaries in accordance with the policies in this Framework and propose alterations to meet these needs in full, unless the review provides clear evidence that doing so would fundamentally undermine the purposes (taken together) of the remaining Green Belt, when considered across the area of the plan”.
2.15.
Given the significant uplift in housing need applicable to North East Derbyshire as a result of the revised standard method for calculating Local Housing Need, we cannot envisage a circumstance whereby North East Derbyshire will not need to review its Green Belt boundaries to accommodate its demonstrable growth needs, particularly given the need to ensure ‘sustainable patterns of development’ as advocated by Paragraph 148 of the NPPF. Exceptional circumstances therefore do exist. With this in mind, an assessment of whether the release of the site from the Green Belt would fundamentally undermine the five purposes of the Green Belt is set out in Table 1.
2.16.
This review has been informed by an assessment carried out by independent landscape consultants Tyler Grange as part of a wider updated Landscape Technical Note which formed part of the original evidence base supporting draft allocation DR2 of the now-adopted Local Plan. This work was completed in July 2025 to inform understanding of the recent NPPF and NPPG changes relating to Green Belt and Grey Belt in relation to this site. It considers the sites contribution to the purposes of Green Belt, also utilising the North East Derbyshire Green Belt Review (NEDGBR) produced by NLP in 2017 to support the then-emerging Local Plan. The site was assessed as part of the wider parcel 025 in that Review; the context of which is highlighted in Figure 2 below.
2.17.
It is acknowledged that the Council are committed to producing an updated Green Belt Review to be published alongside a Publication Draft Local Plan later this year. We cannot envisage a scenario where this land could justifiably be identified as making a strong contribution to the Green Belt since its assessment in 2017 (where it was found to perform moderately against purposes a and d and weaker against purpose b) given the national policy context referred to above and clarity provided by the 2025 updates to the PPG.
Five Purposes of the Green Belt Assessment
A - to check the unrestricted sprawl of large built-up areas;
The Site is bordered by the settlement edge of Coal Aston off Eckington Road to the west and south. Development extends along part of the western boundary of the site from Eckington Road. The site boundary then follows the edge of a designated open space, sports and recreation facility to its northern boundary which is marked by Whinacre Wood which provides a strong defensible boundary. The eastern boundary of the Site is bounded by mature hedgerow dividing the site and the adjacent field which to an extent also provides a defensible edge to ensure development would not sprawl any further eastwards. The NEDGBR review study of Parcel 025 (within which the site is located) considers that the parcel plays a role in preventing unrestricted sprawl: “The parcel is partially contained by the urban area. The southern boundary and the majority of the western boundary adjoin the urban area of Dronfield.” It also states that “The parcel has strong and defensible boundaries. The parcels northern boundary comprises a combination of hedgerow and mature tree coverage, whilst the eastern boundary consists of a hedgerow. The southern and western boundaries adjoin the urban area.” The review gave an overall score of ‘amber’ for purpose (a) – to check unrestricted sprawl, stating that “Development of the
Building lasting value, together 8
parcel would neither strengthen nor weaken the Green Belt boundary.” It is evident that all boundaries of the proposed site are currently contained by either a minimum of mature hedgerow and tree planting but also physical features including roads and housing. Masterplanning of the wider site can further ensure any containing features are reinforced with the siting of residential development also responding to the immediate context. The site represents a logical extension of Dronfield and does not strongly contribute to this Green Belt purpose. Specifically, its contribution in this regard is limited to ‘moderate’.
The PPG clarifies to achieve a Strong contribution, which would rule out Grey Belt designation, there needs to be a lack of “physical feature(s) in reasonable proximity that could restrict and contain development”. Furthermore, that the development would result in an “incongruous pattern of development (such as an extended “finger” of development into the Green Belt)”. Whilst only illustrative, it is clear that the development of the site would not amount to either example provided. Conversely, to achieve a moderate contribution, the PPG clarifies land which is “adjacent or near to a large built up area, but include one or more features that weaken the land’s contribution to this purpose a, such as (but not limited to):
•
having physical feature(s) in reasonable proximity that could restrict and contain development
•
be partially enclosed by existing development, such that new development would not result in an incongruous pattern of development
•
contain existing development
•
being subject to other urbanising influences”.
All of which apply to the site, indicating strongly that the previous
assessment remains robust under the new guidance and that at worst the site should be judged to make a moderate contribution to Purpose A of the Green Belt.
B - to prevent neighbouring towns merging into one another;
The City of Sheffield lies to the north of Dronfield and comprises many various suburbs, the closest of which to Dronfield include Batemoor and Jordanthorpe which are c.780m north of the Site. Development of the Site would not bring them into closer proximity with one another. As similarly pointed out in the 2017 NEDGBR in relation to the parcel containing the Site: “The parcel would leave a gap marginally above 1km to Sheffield urban area. In addition it is no closer than the existing adjoining development.” Removal of this Site from the Green Belt would not reduce the strategic gap between Dronfield and Sheffield. The next nearest town to the Site and the east of Dronfield is Eckington which is located c.4.4km from the easternmost extent of Dronfield. Development of the Site would not reduce this gap as the Site is located further west than the most eastern extent of Dronfield at Eckington Road. Chesterfield town is located c.5km south-east of the Site. Development south of Eckington Road (B6056) is located between the Site and Chesterfield. Development at the southern extents of Dronfield also fall in closer proximity to Chesterfield. The site does not make a strong contribution to this purpose. Specifically, the sites contribution in this regard is ‘weak’. This finding is contrary to the conclusion of the Inspector in Examining the now-adopted Local Plan who, in her letter dated 18 February 2019, highlighted the perceived impact of development on the strategic function of Green Belt at this location (in particular to maintain expansive vistas between urban areas and to define settlement extent) as reason for the site’s removal as a draft allocation. Its weak contribution to this Green Belt purpose as detailed here evidences that the site does not erode these features at this location.
Building lasting value, together 9
Again, the updated PPG provides helpful guidance as to how land should be considered against this purpose. Strong functioning land against this purpose is land which forms a substantial part of a gap between towns and would result in the loss of visual separation between towns, neither of which would be applicable. Land which serves a moderate purpose includes land which forms a small gap between towns, being able to be developed without the loss of visual separation. This could be due to the presence or the close proximity of structures, natural landscape elements or topography that preserve visual separation. Weak/no function is similar, where the land does form a gap between towns, but only a very small part of the gap, without making a contribution to visual separation. Having regard for the above, it is clear at worst the site would make a moderate contribution but given scale and lack of intervisibility, a weak contribution is considered more robust.
C - to assist in safeguarding the countryside from encroachment;
The 2017 NEDGBR acknowledged that the parcel already includes some development that accounts for approximately 10% of the parcel, giving it an ‘amber’ score. In terms of site specific development, Birch Cross Farm is currently situated on Site and includes an individual farmstead and associated buildings, vegetation and hardstanding. The field parcels within the Site are presently associated with the farmstead and used for agricultural purposes. Development of the Site would extend the existing built boundaries off Birches Lane and Eckington Road towards the north and Whinacre Wood. The NEDGBR set out that “development of the parcel would neither strengthen nor weaken the Green Belt boundary.” Whinacre Wood would become the boundary which could be supplemented by on-Site planting creating a softer edge between the Green Belt and Urban areas. This would allow any potential for further encroachment to be restricted, prevented and mitigated. The site does not make a strong contribution to this purpose. Specifically, its contribution in this regard is limited to ‘moderate’.
D - to preserve the setting and special character of historic towns; and
The Site is located within the Moss Valley Conservation Area however it does not form a significant part of the conservation area, making no specific contribution to its special character. Further, there is no character appraisal or management plan supporting the designation and the 2017 NEDGBR stated in regard to the parcel containing the site that “The parcel is located within the Moss Valley Conservation Area. It is however considered that the parcel has a limited role in preserving the setting of a historic village or town. The Moss Valley Conservation Area covers a large area of land, and it is not considered that this parcel serves a fundamental purpose of Green Belt land in this respect.” Further, the site is not considered to form part of the historic setting of Dronfield, nor does it have particular relationship with historic elements of the town, being visually screened from its conservation area and listed buildings by mostly post-war development. In accordance with the PPG a weak score is considered appropriate.
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The significant increase in the Local Housing Need for North East Derbyshire and strong evidence of enhanced demand within Dronfield means that multiple sites will be required at different scales to deliver this housing need and this cannot be delivered solely through brownfield allocations. The proposed site allocation would not therefore discourage the recycling of derelict and other urban land in North East Derbyshire and therefore its status as Green Belt land does not strongly contribute to this purpose.
Conclusion
Development of the site would not fundamentally undermine the five purposes (taken together) of the Green Belt. Furthermore, the site does not strongly contribute to purposes (a), (b) or (d) of paragraph 143, nor do the application of policies relating to Footnote 7 designations (excluding Green Belt) provide a strong reason for refusing or restricting development. As such, the site would meet the definition of Grey Belt set out in the NPPF.
2.18.
As set out above, we consider that Footnote 7 designations – specifically the Moss Valley Conservation Area designated heritage asset – do not provide strong reasons for restricting development. Additional context to this is the shift in recognition of Grey Belt designation from being perceived as resulting from a purely land-based assessment to one which should take account of a proposal (including any mitigation provided). In Wrotham Parish Council v SSHCLG (Ref: AC-2025-LON-000898), the High Court concluded that the Inspector had erred in their judgment in only assessing the land, rather than the proposal – which included mitigation – in concluding on impacts on Footnote 7 designations.
2.19.
Whilst this finding relates to decision making on a specific proposal with explicit mitigation measures proposed, the principle logically should be carried across when considering potential allocation, particularly as any site-specific policy can appropriately require mitigation measures as part of any future proposal. This is further underpinned by the Government’s clear intention to remove reference to Footnote 7 from the grey belt definition within the NPPF, which is a logical refinement given that decision makers have at their disposal the tools to refuse permission where a particular designation (such as a heritage asset) would genuinely provide strong reasons for refusal anyway. There is no need for grey belt designation to repeat such protections which results in the artificial narrowing of the scope of land that can fall within grey belt category.
2.20.
With the above in mind, the site would meet the definition of Grey Belt set out in the NPPF. Paragraph 155 of the NPPF (2024) confirms development in the Green Belt should not be regarded as inappropriate where:
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the development would utilise grey belt land and would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan,
•
there is a demonstrable unmet need for the type of development proposed,
•
the development would be in a sustainable location and
•
where applicable the development proposed meets the ‘Golden Rules’ requirements set out in paragraphs 156-157.
2.21.
With regard to the ‘Golden Rules’ set out in paragraphs 156-157 of the NPPF, the affordable housing requirement to be accommodated on the site will be set at a higher level than that which would otherwise apply to land, subject to viability, to be established in this Plan as per Framework particularly Paragraph 67b. The development proposal on the site will include any necessary improvements to local or national infrastructure as well as provision of new, or improvements to existing, green spaces that are accessible to the public.
2.22.
Development of this site would meet all of the criteria of NPPF Paragraph 155 and therefore would not constitute inappropriate development in the Green Belt. Given its Grey Belt status, its release from the Green Belt should be prioritised.
Site issue – landscape impact
2.23.
Our client has commissioned Landscape and Visual Impact Assessment (LVIA) evidence following direct feedback from the Council received after completion of their site refinement process. Specifically, it has been requested that LVIA is carried out to address some specific landscape constraints identified by the Inspector appointed to examine the now adopted Local Plan who, at the time, removed the site from contention for allocation not least due to perceived localised landscape impacts such as in relation to Eckington Road and Footpath 37. This evidence will be submitted to the Council by the 1 June 2026 deadline afforded for additional evidence.
2.24.
The Vision Document submitted alongside these representations provides some early insight, which suggests the site is generally well contained with a limited visual connection with the wider landscape character and that the visual effects associated with future development would be contained to near context and would be capable of being managed through layout, scale and landscape mitigation.
2.25.
Notwithstanding the above, in support of representations submitted to the last round of consultation in 2025, our client separately commissioned a detailed Landscape Technical Note which provides useful insight in the interim, until completion of the LVIA. In summary, the report – which was carried out by landscape specialists Tyler Grange – found that the site had a very limited relationship with the wider Moss Valley Conservation Area and that development of the site has the potential to be accommodated with reference to the site-specific conditions. It made a number of observations and recommendations as follows:
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Permeability across the site should be integrated into any emerging development layout and views across portions of the Site retained. Vehicular access should be limited to the south, off Eckington Road with pedestrian access in other locations, linking up with the wider Green Infrastructure network;
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The Site is influenced by its visual connection to the surrounding settlement edge. This character and backdrop acts as a strong precedent, but built development will need consideration of appropriate materials, scale, height and density to respond to the context;
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An existing overhead line runs north-south through the Site, this constraint could be utilised to create a green link connecting the Site from Eckington Road to the wider PRoW network. Further tree planting will further assist in softening building mass where the Site can be viewed (partially screened and heavily filtered) from elevated, distant locations to the north;
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Where the Site is viewed from elevated topography to the north and east, it is where there are gaps in existing built form and boundary vegetation. However, these views are very limited due to the layering effect of scattered built form, changes in topography and vegetation associated with these dwellings, fields and roads. Layering of east-west vegetation strips and new Green Infrastructure corridors could be considered throughout the Site to break-up and soften any new built development;
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The site is physically contained in all directions by mature boundaries. Boundaries should be retained and enhanced with development offsets and new native planting to soften the development edge linking into the existing Green Infrastructure network;
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In terms of Green Belt, when assessed against Green Belt purposes, the Site does not perform a strong contribution in any purpose and is largely consistent with the findings of the previous NEDGBR 2017 undertaken by NEDC;
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The site bears no listed heritage assets, nor has any known archaeology that provides cultural links to the past, nor does the site have any known cultural associations related to people or industry (such as mineral extraction and metalworking). Little is left of the historic field pattern, of which the current five fields on Site have occurred through agricultural intensification and field amalgamation. The farm complex is late 20th century and the Site as a whole is overlooked by late 20th and early 21st century housing.
Site issue – relationship with Moss Valley Woodlands SSSI and wider ecology
2.26.
Moss Valley Woods SSSI is designated on account of the presence of ancient woodland, located 0.2km north east of the site. It comprises two units of woodland – Whinacre Wood and Brownstorth Wood. It is contiguous with woodland in the north of the site and an ephemeral stream connects this woodland to the SSSI. The site falls within Natural England’s Impact Risk Zone where potential residential developments of 100 units or more would require further consultation with Natural England, consideration of potential impacts and appropriate mitigation.
2.27.
Potential adverse effects are limited by reason of there being no direct pedestrian links to the SSSI from the site and no known footpaths or access into Whinacre Wood (within the SSSI). The distance involved along with lack of parking and direct public access to Brownstorth Wood part of the SSSI means negligible potential impacts on this unit are anticipated.
2.28.
Principles of mitigation set out in the SSSI Technical Note submitted to the Call for Sites form the basis for mitigation that could be delivered to ensure the SSSI is not adversely affected by development of the site and these would be integrated with proposals through the planning application process. In summary the principles of such mitigation could include the implementation of pollution prevention measures during construction, implementation of an appropriately designed drainage strategy and implementation of a woodland management and access plan for the woodland in the north of the site. These principles would need to be built upon in consultation with Natural England.
2.29.
Notwithstanding the above considerations, in response to concerns raised by the Council, our client commissioned an Ecology Walkover Survey Report which was completed in April 2026 and will be submitted to the Council by 1 June. In this report, it is recommended that a habitat buffer between any potential development and the riparian corridor connected to the SSSI is retained. Otherwise, it finds the early indicative development footprint is largely devoid of priority habitats, but finds the stream and woodland to the northern boundary is high value and should be avoided, and the land between enhanced. All of these issues can be addressed directly through appropriate masterplanning of the site, and the Vision Document submitted alongside these representations and the indicative layout plan provides additional insight on this.
Site issue – presence of some risk of surface water flooding
2.30.
The site is wholly within Flood Zone 1. However with regards to surface water flooding and the presence of limited risk on some small sections of the site, onward site promotion and evidence to inform a planning application would include a Flood Risk Assessment and the site would be underpinned with a Sustainable Urban Drainage Strategy. It is important to note, much of the surface water flood risk is associated with an area of the site that would not be developed in any case – i.e. in relation to the woodland in the northern part of the site.
Site issue – location within the Coal Authority ‘High Risk’ area
2.31.
The coal mining ‘high risk’ zone is an extensive designation covering the entirety of multiple local planning authority areas. A Coal Mining Risk Assessment will be forthcoming as an important evidence base component to support a future planning application. Within this, any required mitigation would be identified.
Summary
2.32.
The site is included in the refined schedule of sites following initial assessment by the Council and the Land Availability Assessment categorises the site as ‘amber’, indicating ‘some constraints’. The key issues influencing the site’s current rating are addressed above and we consider are all resolvable through appropriate mitigation which will be forthcoming. Our approach to addressing any constraints will be the subject of further evidence base enquiry either for submission by 1 June or to inform onward promotion and an eventual planning application. This, as well as overall emerging strategic approach to the location of growth which favours Level 1 towns such as Dronfield, provides strong justification for allocating the site for residential development in the future Local Plan.
Development needs – Housing
Option 1 – Standard Method
2.33.
The NPPF is clear at Paragraph 62 that “to determine the 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”; effectively, the housing need informed by the standard method is the ‘policy-off’ assessment of the minimum number of homes needed in an area. Plugging this into a consideration of wider environmental, economic and social factors, policies and constraints then determines the housing requirement. The NPPF is clear that “the overall aim should be to meet an area’s identified housing need”. There has to be a well evidenced and compelling argument set out by a plan making authority to justify planning for a lower housing requirement than the housing need identified using the Standard Method. The NPPG makes clear there are some ‘specific circumstances’ whereby this might be justified. The specific circumstances set out at Paragraph 014 of the NPPG do not apply in the case of North East Derbyshire, and we do not consider that any insurmountable constraints exist within the District to justify the pursuit of a housing requirement which diverges negatively from the Standard Method informed housing need. Such an approach we consider would be found to be unsound.
2.34.
In view of the above, as an absolute minimum, Option 1 as set out within the current consultation document should be pursued. In fact, as considered in more detail below, there is evidence in favour of planning for above the Standard Method derived housing need figure.
Option 3 – above Standard Method
2.35.
Whilst the NPPF is clear that the overall aim of strategic policies relating to the delivery of a sufficient supply of homes should be to meet an area’s identified housing need, it is also clear that a Standard Method derived housing need will identify the minimum number of homes needed. The NPPF empowers local planning authorities to apply a ‘policy-on’ approach which should factor in local and strategic ambitions (including economic) as well as general affordability pressures to inform their housing requirement, which may justify pursuit of an increased requirement. Such an approach is closely aligned with the latest Government ambitions to significantly boost the supply of new homes nationally.
2.36.
North East Derbyshire is strategically well placed adjacent to Sheffield (the 4th largest city in England) and Chesterfield. Dronfield specifically benefits from access to the A61 corridor (the subject of a range of improvement projects), Northern Rail and local bus services which provide efficient access between all three. Both Sheffield and Chesterfield are the focus of significant growth ambitions set out in their respective Combined Authority economic plans and from this a growth in a wide range of employment sectors is targeted. Long term ambitions for these cities places North East Derbyshire and its main towns – including Dronfield – perfectly to benefit and, as part of this, react to likely further increase in demand for new homes. Given the spatial relationship between North East Derbyshire and the larger settlements, the housing requirement eventually promoted should take into account these regional ambitions which indicate a need to advance beyond the Standard Method derived minimum.
2.37.
As with the overall Standard Method derived housing need, affordable housing need has also significantly increased since adoption of the current Local Plan. The Housing Needs Assessment (2024) identifies an overall need of 356 affordable dwellings per annum – over 58% of the overall need – and makes clear that “provision of new affordable housing is an important and pressing issue in the area”. The new Local Plan could be proactive in addressing this, by planning to deliver more than the Standard Method derived housing need.
Mix of scale and type of housing sites should be sought
2.38.
The refined schedule of sites evidences that the Council intend to include within the new Local Plan a range of site sizes, also commensurate with the level of sustainability of the varied locations for growth also being supported. We support this approach in principle; the NPPF is clear at Paragraph 72 that “planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability”. The provision of a range of site allocations sizes will help to boost housing delivery by limiting the reliance on large strategic sites which in turn will support flexible and phased delivery from a range of providers. Critically, the provision of a range of site allocation sizes across multiple locations is a major factor in sustaining a robust and deliverable housing pipeline and five-year housing land supply. Our client’s site is at the lower end of the large sites scale and would be in a position as a result of this to contribute directly to the Council’s five-year housing land supply, as well as requirements of plan years beyond.
2.39.
Linked to this also, we continue to support an approach which seeks to allocate a range of types of sites. Although not a topic of this consultation, the 2025 consultation identified seven site type options which between them would provide a varied range of potential impacts (eg. sites within the Green Belt, sites with some landscape harm and higher density sites). Development in any location, by its very nature, will result in some level of impact on its immediate context. However the key, in our view, is to focus on delivering housing in the locations where it is most needed whilst minimising impacts and maximising potential benefits. We agree therefore with the findings of the Sustainability Appraisal which, at paragraph E20 summarises that “it is likely that a combination of different site type options will allow for the most sustainable development strategy, informed by a robust evidence base to determine the capacity of different locations in the district to accommodate proposed growth that is aligned with the relative scale and character of existing settlements”.
Development needs - employment
2.40.
As set out in our previous representations, the new Local Plan should be aspirational and a key component of this will be the district’s ability to accommodate ambitious employment growth. As such, the Council should plan for the district’s employment land requirements at the upper end of the 15-31 ha as recommended in the Employment Needs Assessment (Option 2 in the current consultation document). The upper end of the estimate quite rightly takes account of the ‘policy on’ scenario, recognising the district’s local economic growth aspirations and key growth sectors of the economy. Given the significantly increased Standard Method derived housing need for the district and the need for it to be met as a minimum, it is also correct that labour supply resulting from new housing is taken into account when identifying the quantity of employment land that will be required to service the district going forward. Not adopting this approach risks artificially constraining economic growth which would be in direct contravention of NPPF ambitions, particularly its call for the planning system to build a strong, responsive and competitive economy. We do not consider the district to be so constrained that the identified quantum of employment land within the upper estimate would be undeliverable, particularly when you consider its relationship with the economic growth ambitions of the wider area, including neighbouring Sheffield.
Spatial distribution of development
2.41.
In principle we support the Council’s proposed approach to the location of development. Specifically, that the level of priority of location for accommodating growth correlates with the level of sustainability and role of the type of settlement. We agree that ‘Priority 1 Locations’ should include as indicative locations those listed i.e. the edge of Chesterfield/ Sheffield, new settlement/ strategic sites and level 1 settlements – main towns. We also agree that Dronfield should continue to be recognised as a level 1 settlement – main town, which we explore in more detail below. It is notable that the Sustainability Appraisal does not envisage any major negative effects from accommodating development at the main towns. Indeed, providing growth to the main towns represents a sustainable growth strategy which would, critically, leverage existing infrastructure and services provided by the them, support the vitality and viability of their centres and facilitate access to enhanced sustainable transport options they provide.
2.42.
We also agree that allocations should be assigned using a ‘cascade’ approach. Through this approach, the higher priority locations are likely to receive higher levels of growth which is logical and supported in evidence, albeit the Council will need to remain cognisant of factors which may determine slight divergence from this if necessary, for example in providing for strongly evidenced localised need or responding to key constraints which, for example, may determine that lower priority locations, at least in some scenarios, represent the more suitable location for growth. We note that the consultation responses received are largely in favour of such an approach also.
2.43.
In our previous representations we highlighted that we considered options to focus growth around Sheffield and Chesterfield as not being the most sustainable approach. We considered that such a focus would fail to address the localised need evidenced across the district and undermine local opportunity within the district. We consider that the approach now put forward by the Council – specifically to dilute this focus into a broader ‘Priority 1 Locations’ level alongside, in particular, level 1 settlements – main towns (such as Dronfield) as a sustainable and well-balanced approach. Such an approach alleviates concerns we had that the future distribution of growth would be directed overwhelmingly toward Sheffield and Chesterfield at the expense of other settlements across the district, and this we consider would have been an unsound approach.
Settlement hierarchy
2.44.
We agree with the principle of the approach taken by the Council to identify and group together settlements with similar levels of sustainability which perform similar roles, amounting to a settlement hierarchy. We agree this should feed directly into deciding the spatial distribution of development discussed above.
2.45.
In particular, we concur with the findings of the Settlement Role and Function Study (March 2026) and discussion within the Settlement Hierarchy Topic Paper (March 2026) insofar as it relates to Dronfield and its containment within the ‘Level 1: Towns’ settlement level (scoring well above the required 32+ points (40+)). With concur with the findings that Dronfield includes a recognised town centre which contains an extensive range of services, and that it performs a prominent role in meeting the day to day needs of people across a wide geographic area. We also agree with its findings that Coal Aston forms part of Dronfield, being “closely related to Dronfield, with no obvious physical boundary between them” (paragraph 3.4).
Dronfield as a location for growth
2.46.
As the largest of the settlements in North East Derbyshire it is particularly important that Dronfield accommodates a proportionate level of growth. Its wide range of services, facilities and transport infrastructure as well as its role as a main town within the ‘north east economic zone’ of the Derbyshire Economic Strategy and close proximity to Sheffield and the wider South Yorkshire Mayoral Combined Authority – along with its significant economic growth ambitions – highlights Dronfield as a sustainable location for growth which should play a significant role in delivering North East Derbyshire’s Local Housing Need. Demand for housing around Dronfield is particularly strong as evidenced within the Local Housing Needs Assessment 2024 (LHNA) which finds that even the economic turbulence at the time – in particular its effect on mortgage rates – has had very little impact on buyer demand in the area. The assessment notes that Dronfield appears to have the strongest market demand within the District and notes that “the north and west of the district clearly sees higher prices than the south and east. Areas surrounding Dronfield in particular see high prices” (Paragraph 2.11).
2.47.
A divergence between demand and supply also appears around Dronfield in relation to affordable housing. The LHNA finds that the parish of Dronfield (attributed for this exercise to Dronfield, Coal Aston and Dron Woodhouse where parish statistics have not been collated) is amongst the most in-demand areas within the district with 207 applicants with local connection on the Council’s housing waiting list as at June 2024. Out of 25 Parishes, Dronfield is the third most in-demand within the District on these terms. Of the district’s wards, Dronfield South saw the most average bids per property in 2023 (80). The LHNA identifies an affordable housing need of 71 (net) affordable rented dwellings per annum within Dronfield Parish – the most of any Parish - and Dronfield is the only area identified as having a tangible net need for affordable home ownership products (30 per annum). The identified ‘standardised need for affordable housing’ finds that Dronfield Parish has a need per 1000 dwellings of 10.67 per annum. For comparison purposes, Clay Cross has a need of 5.48, Eckington has a need of 6.89 and Killamarsh has a need of 8.02 – all of these being significantly lower than that of Dronfield.
2.48.
The above represent significant indicators of a historically constrained supply of new dwellings within and around Dronfield specifically. Despite these circumstances, the adopted Local Plan apportions notably less new housing to Dronfield when compared with the smaller towns of Clay Cross and Killamarsh, an issue exacerbated by the Inspector’s decision to remove this site during the examination of the extant Local Plan. The new Local Plan provides the opportunity to re-balance this and ensure Dronfield accommodates a proportionate quantity of dwellings reflecting its existing size and offer. Whilst Dronfield’s place within the Green Belt and associated complexities around its expansion (specifically, the need to release land from the Green Belt) is acknowledged, our client’s site as considered above in more detail, represents an opportunity to contribute to resolving the demand issue in the area with limited Green Belt impact.
Strategic sites and new settlements
2.49.
With the above considerations in mind, whilst we do not object to the principle of identifying strategic sites and new settlements as part of ‘Priority 1 Locations’ for growth, we maintain reservations around the suitability of strategic site ‘Duckmanton Moor’ (now merged from previous sites 45227 and 45541) which is expected to be able to accommodate 2000-3000 dwellings.
2.50.
The southern element of the strategic site (45227) does not directly relate to any existing settlement form and as such would represent an illogical and significant intrusion into the open countryside at this location. The nearest settlement – Arkwright Town to the north – is distant from this element of the site without any sense of continuity. Similarly, whilst technically attached to Arkwright Town to its north west and Long Duckmanton to its north east, the northern element of the site (45541) would result in an illogical and incongruent built form exclusively to the south of A632, awkwardly conjoining both settlements with notable impacts on the countryside at this location including its openness and any landscape value.
2.51.
Both Arkwright Town and Long Duckmanton offer limited provision of services, facilities and employment as highlighted also by the previous Settlement Hierarchy Study and more recently the Settlement Hierarchy Topic Paper, with a significant number of settlements rated as being more sustainable locations for growth. Whilst settlements such as Arkwright Town and Long Duckmanton could accommodate some growth (and, indeed, a distribution of growth across the district we consider to be a sustainable approach), the scale of growth being considered through the delivery of this newly merged strategic site would be entirely at odds with their scale and offer and such an approach we consider to be unsustainable.
2.52.
A significant proportion of the site is occupied by established woodland and this represents a substantial development constraint. Given the likely ecological value of the woodland area, its inclusion within the site will establish a considerable BNG baseline to address which has the potential to undermine viability of the site as a whole. Retention of the asset would significantly reduce the actual developable area provided by the potential allocation and limits the extent to which the site could contribute to delivering the district’s housing needs. Reducing the extent of the site to exclude the woodland area would result in the same outcome, preventing the delivery of a critical mass of dwellings required to fund and maintain new service provision necessary to make new free-standing communities viable and sustainable, particularly in this location where existing infrastructure provision is so limited. Likewise, the exclusion of the woodland area may limit opportunities for mitigation and enhancement where needed.
Sustainability Appraisal (SA) Addendum March 2026
2.53.
The SA Addendum has been produced to assess 271 reasonable alternative sites for residential use which have been identified by the Council – following a comprehensive assessment and filtering process – as being genuinely capable of being selected as allocations within the emerging Local Plan. This assessment does not take into account any mitigation, which of course, as explored in more detail above for our client’s site, can and will be forthcoming where required.
2.54.
Whilst we have not carried out an exhaustive review of the SA Addendum, we do have some concerns which we think are important to raise now, relating to scores applied and, in some cases, what appears to be a mismatch between the stated method for arriving at appropriate scores and its application to this site.
2.55.
For example, we note that the site has been scored negatively for access to a bus stop, yet bus stops are available almost immediately adjacent to the site along Eckington Road. The SA links a negative rating to scenarios where bus stops are more than 400m away from a site, which is simply not the case for this site. Similarly, we are surprised to see a negative score in relation to access to a secondary school given the relatively close proximity to the site (1.75km away via Oakhill Road and Stonelow Green) of one of only three secondary schools in the whole of North East Derbyshire (Dronfield Henry Fanshawe School). It is not clear how this score is justified given the wider context. Further, Oakhill Medical Practice is located off Oakhill Road less than 1km from the site. Again, it is not clear how a negative score against this measure of site accessibility to services can be justified and overall these issues point to three separate scores which we consider to be excessively negative.
2.56.
We also consider that a negative score resulting from the site’s location within a Natural England SSSI Impact Risk Zone is excessive. At this stage, Natural England’s response and position is unknown and should be reflected as such within the SA. Natural England would be consulted as part of onward promotion and, ultimately, to inform a planning application and it is worth noting that the element which impacts on this site only requires consultation for developments of 100 dwellings or more.
Conclusion
2.57.
The site is included in the refined schedule of sites following initial assessment by the Council and the key issues highlighted by the Council are addressed within these representations and we consider are all surmountable alongside appropriate mitigation which will be forthcoming. Our approach to addressing any constraints will be the subject of further evidence base enquiry either for submission by 1 June or to inform onward promotion and an eventual planning application. This, as well as overall emerging strategic approach to the location of growth which favours Level 1 towns such as Dronfield, provides strong justification for allocating the site for residential development in the future Local Plan.

1. Introduction
1.1.
These representations are prepared by Fisher German on behalf of our client Richborough in respect of their land interests at Cross and Birch Farm, off Eckington Road, Coal Aston, Dronfield.
1.2.
The site was submitted to the Council during the 2025 Call for Sites exercise alongside an extensive evidence base engaging on landscape, ecology, transport, heritage and other matters. The site has since been the subject of Representations submitted to the initial Regulation 18 consultation carried out between June and August 2025.
1.3.
The Council are now consulting on its latest material as part of the Issues & Options stage of Local Plan production. Specifically, the current consultation is focussed on the strategic approach to the location of development and a refined schedule of sites all of which have passed through both the initial desktop screening, and further detailed stages of assessment. Notably, these sites also align with the emerging strategy. Included within this refined schedule is our client’s site identified as ‘45483 – Land off Eckington Road, Coal Aston, Dronfield’ within the consultation document.
1.4.
For context it’s important to note that the site was included as a draft allocation - DR2 - in the Submission version of the now-adopted Local Plan (adopted November 2021). This demonstrated the Council’s in principle agreement that the site could accommodate residential development. Following completion of the Examination Hearing Sessions, the Inspector in her initial findings report highlighted concerns around DR2, concluding that it was a prominent extension that changes the character of the area, harms the Moss Valley Conservation Area and erodes the function of the Green Belt. On this basis, the Inspector recommended deletion of the site. Ultimately, to secure adoption of the plan at that time, the Council conceded and removed the site through Main Modifications.
1.5.
It is acknowledged that the Council were previously unable to demonstrate exceptional circumstances that could outweigh perceived harm enough to warrant removal of the site from the Green Belt and as such it was removed as an allocation from the then-submission version Local Plan. However it is considered that the context within which plan making is being undertaken today – driven by central Government ambitions for enhanced housing delivery (1.5 million net additional homes in England by the next General Election), supported by a raft of changes to the National Planning Policy Framework (NPPF) – has fundamentally changed in favour of significantly boosting housing supply locally, including via the increased utilisation of Green Belt sites (as confirmed by Paragraph 146 of the Framework), but only where such sites meet the Golden Rules of Paragraph 156 and 157 of the Framework, providing enhanced public benefits. This site represents a viable option for helping North East Derbyshire to deliver on its (much increased) housing need whilst minimising Green Belt harm and is fully compatible with the current Framework and its approach to the utilisation of Green Belt to meet housing needs in full.
1.6.
The NPPF and Standard Method were published on 12th December 2024 and the updated Local Housing Need for the district has significantly increased from 224 dwellings per annum (dpa) to 605 dpa. The Council will be required to allocate sufficient residential sites to deliver the housing need and we believe this will need to include the use of currently designated Green Belt land to secure a pattern of deliverable and sustainable growth (NPPF 148).
2. Representations
45483 – Land off Eckington Road, Coal Aston, Dronfield
2.1.
The consultation invites specific comments on sites which have been the subject of further testing and been included within the refined schedule. This section seeks to provide site specific commentary to promote its onward selection as a future allocation and this includes a consideration of relevant evidence base work carried out by the client to inform site strategy.
2.2.
It should be noted that since submission of the representations to the June-August 2025 consultation, our client has commissioned updated evidence base and informative plans which are discussed here wherever possible. Otherwise, any additional documentation will be provided to the Council by 1 June as required by the Council and set out in direct correspondence in March 2026.
Site overview
2.3.
The site comprises five field parcels bounded by mature hedgerows, scattered trees and a woodland area to the north. It is located immediately north of the settlement boundary of Dronfield, recognised as a ‘Level 1’ settlement in the adopted Local Plan (the most sustainable of locations for growth). Scattered agricultural development associated with Birch Cross Farm is located in the southern half of the site.
2.4.
The Vision Document, submitted alongside these representations, includes an indicative masterplan (Figure 1) to accommodate around 200 dwellings, which we intend as a ‘starting point’ to form the basis of onward discussions with the Council. We are keen to address more focussed parameters -such as appropriate densities- proactively with the Council and as informed by emerging evidence, including outcomes from work commissioned by our client for submission by 1 June.
Site feasibility
2.5.
Access to the site would be achieved directly from Eckington Road (B6056) and the site would be well serviced by public transport; an initial transport assessment undertaken and submitted to the Call for Sites found its development for c.200 dwellings would not have an adverse impact on the local highway network.
2.6.
The site is entirely within Flood Zone 1 thus at low risk of flooding from rivers or sea and only small pockets of the site are subject to limited surface water flood risk. There are no listed heritage assets within the site or in particularly close proximity to it. The nearest site – Grade II listed ‘Range of Outbuildings to the East of Silkstone Farmhouse’ is located approximately 315m away in Coal Aston. The site is supported by a willing landowner and a well- developed evidence base established as a result of its allocation within the Submission version of the now-adopted Local Plan which is the subject of ongoing updates. The site could be available to deliver units within the first five year period post-adoption of the new Local Plan, helping to ensure a robust housing supply within the District.
2.7.
The site is within the Green Belt, extensive Moss Valey Conservation Area and the Impact Risk Zone for the Moss Valley Woods SSSI, located approximately 235m north east of the site. These constraints are surmountable and considered in more detail below.
2.8.
As part of the consultation, the Council has published a summary of key outstanding issues that they would need to see appropriately addressed for the site to be considered suitable for selection as a future allocation. The following sub-sections address each of the remaining issues highlighted by the Council through this consultation in turn. Where appropriate and as already addressed above, additional evidence currently being produced for our client will be provided by 1 June to provide additional support to the Council. Whilst some of the issues below have already been addressed through the Call for Sites submission and previous Regulation 18 representations of 2025, for reasons of completeness and clarity, these issues remain included within these representations.
Site issue – location within Moss Valley Conservation Area
2.9.
Section 69 of the Planning (Listed Buildings and Conservation Areas) Act 1990 makes provision for local planning authorities to designate Conservation Areas because of their “special architectural or historic interest the character or appearance of which it is desirable to preserve or enhance”. The Moss Valley Conservation Area was designated by North East Derbyshire District Council on 3rd May 1990. There is no character appraisal for this designated asset nor publicly accessible management plan. Reasons for its designation are only covered within the planning committee report supporting its original designation. The Heritage Statement undertaken by Humble Heritage in 2016 in support of the site’s original designation within the now-adopted Local Plan (also submitted to the Call for Sites exercise in 2025) summarises the reasons for its designation (extracted from the committee report) at paragraph 4.09 of that report. It includes mention of Moss Valley being a landscape of historic interest in its own right, there being a great range of natural and man-made elements which comprise its special character, and the presence of vernacular buildings, farmsteads and early industrial sites.
2.10.
The Moss Valley Conservation Area is a large designation covering an area of approximately 1,660 hectares. It includes a number of small to medium sized settlements containing a mix of types of character including modern dwellings such as Lightwood, Troway, Highlane, Ridgeway, Ridgeway Moor, Ford and part of Marsh Lane so is not exclusively rural. Development of the site would result in the loss of less than 0.3% of rural land from the conservation area. There are no industrial archaeology sites within the site or in close proximity of the site’s boundaries. Cross and Birches Farm is a modern farmhouse and farmstead erected in c.1960s and as such does not positively contribute to the historical significance or appearance of the conservation area in relation to the special character associated with man-made elements and building vernacular. No designated assets are in close proximity to the site and there would be no intervisibility between the site and the setting of heritage assets listed outside of the site.
2.11.
In terms of natural elements of the conservation area, there are no designations within the site and its development would not impact upon the Moss Valley Woodland or nearby SSSI (considered in further detail below). The site is active farmland and as such is highly unlikely to be rich in wildlife habitat. Hedgerows and trees within the site could be retained – notwithstanding the fact that none of them benefit from tree preservation orders – and aside from the ecological benefits, this would help to maintain the grain of the existing field layout. Views are not identified as being an important part of the character and appearance of the conservation area. In any case, the changing topography and belts of trees mean that residential scale development on the site is unlikely to be visible from multiple points within the conservation area, notwithstanding also the opportunity for suitable landscape mitigation to be incorporated with any future proposal for the site.
2.12.
In response to concerns highlighted by the Council, our clients have commissioned a new Heritage Statement which will be provided to the Council by 1 June. In the interim, and for the purpose of providing some additional clarity within these representations, an interim Historic Environment Technical Report was also commissioned. It does identify far-reaching views to the north and north-east that incorporate heritage assets, and potential impact on these assets will be a consideration of the forthcoming Heritage Statement. We can confirm however that early recommendations from our client’s heritage consultants is to ensure the retention of important views from the site across Moss Valley Conservation Area, in particular to Oakes Park and Norton Water Tower. It is also recommended that existing hedgerows are retained wherever possible. Ultimately early indications are that these matters can be addressed via appropriate masterplanning of the site and the Vision Document submitted with these representations provides some additional insight on this, and the Heritage Statement will more directly address the concerns. To note also is that the Historic Environment Technical Report finds no evidence to suggest the site contains archaeological remains relating to the medieval rural economy and post-medieval rural industries associated with the Moss Valley Conservation Area so as to preclude or constrain future development of the site.
2.13.
With the above in mind, and notwithstanding forthcoming evidence, we do not consider that the site’s location within the Moss Valley Conservation Area amounts to a strong reason for restricting development at this location as intended by Footnote 7 of the NPPF and reference to designated heritage assets.
Site issue – location within the Green Belt
2.14.
The site’s main constraint is that it is presently designated as Green Belt. Having regard for the recently published NPPF (December 2024), it is clear in paragraph 146 that Green Belt land can be utilised in ‘exceptional circumstances’ where development needs justify release. It states that “Exceptional circumstances, in this context include… instances where an authority cannot meet its identified need for homes, commercial or other development through other means. If that is the case, authorities should review Green Belt boundaries in accordance with the policies in this Framework and propose alterations to meet these needs in full, unless the review provides clear evidence that doing so would fundamentally undermine the purposes (taken together) of the remaining Green Belt, when considered across the area of the plan”.
2.15.
Given the significant uplift in housing need applicable to North East Derbyshire as a result of the revised standard method for calculating Local Housing Need, we cannot envisage a circumstance whereby North East Derbyshire will not need to review its Green Belt boundaries to accommodate its demonstrable growth needs, particularly given the need to ensure ‘sustainable patterns of development’ as advocated by Paragraph 148 of the NPPF. Exceptional circumstances therefore do exist. With this in mind, an assessment of whether the release of the site from the Green Belt would fundamentally undermine the five purposes of the Green Belt is set out in Table 1.
2.16.
This review has been informed by an assessment carried out by independent landscape consultants Tyler Grange as part of a wider updated Landscape Technical Note which formed part of the original evidence base supporting draft allocation DR2 of the now-adopted Local Plan. This work was completed in July 2025 to inform understanding of the recent NPPF and NPPG changes relating to Green Belt and Grey Belt in relation to this site. It considers the sites contribution to the purposes of Green Belt, also utilising the North East Derbyshire Green Belt Review (NEDGBR) produced by NLP in 2017 to support the then-emerging Local Plan. The site was assessed as part of the wider parcel 025 in that Review; the context of which is highlighted in Figure 2 below.
2.17.
It is acknowledged that the Council are committed to producing an updated Green Belt Review to be published alongside a Publication Draft Local Plan later this year. We cannot envisage a scenario where this land could justifiably be identified as making a strong contribution to the Green Belt since its assessment in 2017 (where it was found to perform moderately against purposes a and d and weaker against purpose b) given the national policy context referred to above and clarity provided by the 2025 updates to the PPG.
Five Purposes of the Green Belt Assessment
A - to check the unrestricted sprawl of large built-up areas;
The Site is bordered by the settlement edge of Coal Aston off Eckington Road to the west and south. Development extends along part of the western boundary of the site from Eckington Road. The site boundary then follows the edge of a designated open space, sports and recreation facility to its northern boundary which is marked by Whinacre Wood which provides a strong defensible boundary. The eastern boundary of the Site is bounded by mature hedgerow dividing the site and the adjacent field which to an extent also provides a defensible edge to ensure development would not sprawl any further eastwards. The NEDGBR review study of Parcel 025 (within which the site is located) considers that the parcel plays a role in preventing unrestricted sprawl: “The parcel is partially contained by the urban area. The southern boundary and the majority of the western boundary adjoin the urban area of Dronfield.” It also states that “The parcel has strong and defensible boundaries. The parcels northern boundary comprises a combination of hedgerow and mature tree coverage, whilst the eastern boundary consists of a hedgerow. The southern and western boundaries adjoin the urban area.” The review gave an overall score of ‘amber’ for purpose (a) – to check unrestricted sprawl, stating that “Development of the
Building lasting value, together 8
parcel would neither strengthen nor weaken the Green Belt boundary.” It is evident that all boundaries of the proposed site are currently contained by either a minimum of mature hedgerow and tree planting but also physical features including roads and housing. Masterplanning of the wider site can further ensure any containing features are reinforced with the siting of residential development also responding to the immediate context. The site represents a logical extension of Dronfield and does not strongly contribute to this Green Belt purpose. Specifically, its contribution in this regard is limited to ‘moderate’.
The PPG clarifies to achieve a Strong contribution, which would rule out Grey Belt designation, there needs to be a lack of “physical feature(s) in reasonable proximity that could restrict and contain development”. Furthermore, that the development would result in an “incongruous pattern of development (such as an extended “finger” of development into the Green Belt)”. Whilst only illustrative, it is clear that the development of the site would not amount to either example provided. Conversely, to achieve a moderate contribution, the PPG clarifies land which is “adjacent or near to a large built up area, but include one or more features that weaken the land’s contribution to this purpose a, such as (but not limited to):
•
having physical feature(s) in reasonable proximity that could restrict and contain development
•
be partially enclosed by existing development, such that new development would not result in an incongruous pattern of development
•
contain existing development
•
being subject to other urbanising influences”.
All of which apply to the site, indicating strongly that the previous
assessment remains robust under the new guidance and that at worst the site should be judged to make a moderate contribution to Purpose A of the Green Belt.
B - to prevent neighbouring towns merging into one another;
The City of Sheffield lies to the north of Dronfield and comprises many various suburbs, the closest of which to Dronfield include Batemoor and Jordanthorpe which are c.780m north of the Site. Development of the Site would not bring them into closer proximity with one another. As similarly pointed out in the 2017 NEDGBR in relation to the parcel containing the Site: “The parcel would leave a gap marginally above 1km to Sheffield urban area. In addition it is no closer than the existing adjoining development.” Removal of this Site from the Green Belt would not reduce the strategic gap between Dronfield and Sheffield. The next nearest town to the Site and the east of Dronfield is Eckington which is located c.4.4km from the easternmost extent of Dronfield. Development of the Site would not reduce this gap as the Site is located further west than the most eastern extent of Dronfield at Eckington Road. Chesterfield town is located c.5km south-east of the Site. Development south of Eckington Road (B6056) is located between the Site and Chesterfield. Development at the southern extents of Dronfield also fall in closer proximity to Chesterfield. The site does not make a strong contribution to this purpose. Specifically, the sites contribution in this regard is ‘weak’. This finding is contrary to the conclusion of the Inspector in Examining the now-adopted Local Plan who, in her letter dated 18 February 2019, highlighted the perceived impact of development on the strategic function of Green Belt at this location (in particular to maintain expansive vistas between urban areas and to define settlement extent) as reason for the site’s removal as a draft allocation. Its weak contribution to this Green Belt purpose as detailed here evidences that the site does not erode these features at this location.
Building lasting value, together 9
Again, the updated PPG provides helpful guidance as to how land should be considered against this purpose. Strong functioning land against this purpose is land which forms a substantial part of a gap between towns and would result in the loss of visual separation between towns, neither of which would be applicable. Land which serves a moderate purpose includes land which forms a small gap between towns, being able to be developed without the loss of visual separation. This could be due to the presence or the close proximity of structures, natural landscape elements or topography that preserve visual separation. Weak/no function is similar, where the land does form a gap between towns, but only a very small part of the gap, without making a contribution to visual separation. Having regard for the above, it is clear at worst the site would make a moderate contribution but given scale and lack of intervisibility, a weak contribution is considered more robust.
C - to assist in safeguarding the countryside from encroachment;
The 2017 NEDGBR acknowledged that the parcel already includes some development that accounts for approximately 10% of the parcel, giving it an ‘amber’ score. In terms of site specific development, Birch Cross Farm is currently situated on Site and includes an individual farmstead and associated buildings, vegetation and hardstanding. The field parcels within the Site are presently associated with the farmstead and used for agricultural purposes. Development of the Site would extend the existing built boundaries off Birches Lane and Eckington Road towards the north and Whinacre Wood. The NEDGBR set out that “development of the parcel would neither strengthen nor weaken the Green Belt boundary.” Whinacre Wood would become the boundary which could be supplemented by on-Site planting creating a softer edge between the Green Belt and Urban areas. This would allow any potential for further encroachment to be restricted, prevented and mitigated. The site does not make a strong contribution to this purpose. Specifically, its contribution in this regard is limited to ‘moderate’.
D - to preserve the setting and special character of historic towns; and
The Site is located within the Moss Valley Conservation Area however it does not form a significant part of the conservation area, making no specific contribution to its special character. Further, there is no character appraisal or management plan supporting the designation and the 2017 NEDGBR stated in regard to the parcel containing the site that “The parcel is located within the Moss Valley Conservation Area. It is however considered that the parcel has a limited role in preserving the setting of a historic village or town. The Moss Valley Conservation Area covers a large area of land, and it is not considered that this parcel serves a fundamental purpose of Green Belt land in this respect.” Further, the site is not considered to form part of the historic setting of Dronfield, nor does it have particular relationship with historic elements of the town, being visually screened from its conservation area and listed buildings by mostly post-war development. In accordance with the PPG a weak score is considered appropriate.
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The significant increase in the Local Housing Need for North East Derbyshire and strong evidence of enhanced demand within Dronfield means that multiple sites will be required at different scales to deliver this housing need and this cannot be delivered solely through brownfield allocations. The proposed site allocation would not therefore discourage the recycling of derelict and other urban land in North East Derbyshire and therefore its status as Green Belt land does not strongly contribute to this purpose.
Conclusion
Development of the site would not fundamentally undermine the five purposes (taken together) of the Green Belt. Furthermore, the site does not strongly contribute to purposes (a), (b) or (d) of paragraph 143, nor do the application of policies relating to Footnote 7 designations (excluding Green Belt) provide a strong reason for refusing or restricting development. As such, the site would meet the definition of Grey Belt set out in the NPPF.
2.18.
As set out above, we consider that Footnote 7 designations – specifically the Moss Valley Conservation Area designated heritage asset – do not provide strong reasons for restricting development. Additional context to this is the shift in recognition of Grey Belt designation from being perceived as resulting from a purely land-based assessment to one which should take account of a proposal (including any mitigation provided). In Wrotham Parish Council v SSHCLG (Ref: AC-2025-LON-000898), the High Court concluded that the Inspector had erred in their judgment in only assessing the land, rather than the proposal – which included mitigation – in concluding on impacts on Footnote 7 designations.
2.19.
Whilst this finding relates to decision making on a specific proposal with explicit mitigation measures proposed, the principle logically should be carried across when considering potential allocation, particularly as any site-specific policy can appropriately require mitigation measures as part of any future proposal. This is further underpinned by the Government’s clear intention to remove reference to Footnote 7 from the grey belt definition within the NPPF, which is a logical refinement given that decision makers have at their disposal the tools to refuse permission where a particular designation (such as a heritage asset) would genuinely provide strong reasons for refusal anyway. There is no need for grey belt designation to repeat such protections which results in the artificial narrowing of the scope of land that can fall within grey belt category.
2.20.
With the above in mind, the site would meet the definition of Grey Belt set out in the NPPF. Paragraph 155 of the NPPF (2024) confirms development in the Green Belt should not be regarded as inappropriate where:
•
the development would utilise grey belt land and would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan,
•
there is a demonstrable unmet need for the type of development proposed,
•
the development would be in a sustainable location and
•
where applicable the development proposed meets the ‘Golden Rules’ requirements set out in paragraphs 156-157.
2.21.
With regard to the ‘Golden Rules’ set out in paragraphs 156-157 of the NPPF, the affordable housing requirement to be accommodated on the site will be set at a higher level than that which would otherwise apply to land, subject to viability, to be established in this Plan as per Framework particularly Paragraph 67b. The development proposal on the site will include any necessary improvements to local or national infrastructure as well as provision of new, or improvements to existing, green spaces that are accessible to the public.
2.22.
Development of this site would meet all of the criteria of NPPF Paragraph 155 and therefore would not constitute inappropriate development in the Green Belt. Given its Grey Belt status, its release from the Green Belt should be prioritised.
Site issue – landscape impact
2.23.
Our client has commissioned Landscape and Visual Impact Assessment (LVIA) evidence following direct feedback from the Council received after completion of their site refinement process. Specifically, it has been requested that LVIA is carried out to address some specific landscape constraints identified by the Inspector appointed to examine the now adopted Local Plan who, at the time, removed the site from contention for allocation not least due to perceived localised landscape impacts such as in relation to Eckington Road and Footpath 37. This evidence will be submitted to the Council by the 1 June 2026 deadline afforded for additional evidence.
2.24.
The Vision Document submitted alongside these representations provides some early insight, which suggests the site is generally well contained with a limited visual connection with the wider landscape character and that the visual effects associated with future development would be contained to near context and would be capable of being managed through layout, scale and landscape mitigation.
2.25.
Notwithstanding the above, in support of representations submitted to the last round of consultation in 2025, our client separately commissioned a detailed Landscape Technical Note which provides useful insight in the interim, until completion of the LVIA. In summary, the report – which was carried out by landscape specialists Tyler Grange – found that the site had a very limited relationship with the wider Moss Valley Conservation Area and that development of the site has the potential to be accommodated with reference to the site-specific conditions. It made a number of observations and recommendations as follows:
•
Permeability across the site should be integrated into any emerging development layout and views across portions of the Site retained. Vehicular access should be limited to the south, off Eckington Road with pedestrian access in other locations, linking up with the wider Green Infrastructure network;
•
The Site is influenced by its visual connection to the surrounding settlement edge. This character and backdrop acts as a strong precedent, but built development will need consideration of appropriate materials, scale, height and density to respond to the context;
•
An existing overhead line runs north-south through the Site, this constraint could be utilised to create a green link connecting the Site from Eckington Road to the wider PRoW network. Further tree planting will further assist in softening building mass where the Site can be viewed (partially screened and heavily filtered) from elevated, distant locations to the north;
•
Where the Site is viewed from elevated topography to the north and east, it is where there are gaps in existing built form and boundary vegetation. However, these views are very limited due to the layering effect of scattered built form, changes in topography and vegetation associated with these dwellings, fields and roads. Layering of east-west vegetation strips and new Green Infrastructure corridors could be considered throughout the Site to break-up and soften any new built development;
•
The site is physically contained in all directions by mature boundaries. Boundaries should be retained and enhanced with development offsets and new native planting to soften the development edge linking into the existing Green Infrastructure network;
•
In terms of Green Belt, when assessed against Green Belt purposes, the Site does not perform a strong contribution in any purpose and is largely consistent with the findings of the previous NEDGBR 2017 undertaken by NEDC;
•
The site bears no listed heritage assets, nor has any known archaeology that provides cultural links to the past, nor does the site have any known cultural associations related to people or industry (such as mineral extraction and metalworking). Little is left of the historic field pattern, of which the current five fields on Site have occurred through agricultural intensification and field amalgamation. The farm complex is late 20th century and the Site as a whole is overlooked by late 20th and early 21st century housing.
Site issue – relationship with Moss Valley Woodlands SSSI and wider ecology
2.26.
Moss Valley Woods SSSI is designated on account of the presence of ancient woodland, located 0.2km north east of the site. It comprises two units of woodland – Whinacre Wood and Brownstorth Wood. It is contiguous with woodland in the north of the site and an ephemeral stream connects this woodland to the SSSI. The site falls within Natural England’s Impact Risk Zone where potential residential developments of 100 units or more would require further consultation with Natural England, consideration of potential impacts and appropriate mitigation.
2.27.
Potential adverse effects are limited by reason of there being no direct pedestrian links to the SSSI from the site and no known footpaths or access into Whinacre Wood (within the SSSI). The distance involved along with lack of parking and direct public access to Brownstorth Wood part of the SSSI means negligible potential impacts on this unit are anticipated.
2.28.
Principles of mitigation set out in the SSSI Technical Note submitted to the Call for Sites form the basis for mitigation that could be delivered to ensure the SSSI is not adversely affected by development of the site and these would be integrated with proposals through the planning application process. In summary the principles of such mitigation could include the implementation of pollution prevention measures during construction, implementation of an appropriately designed drainage strategy and implementation of a woodland management and access plan for the woodland in the north of the site. These principles would need to be built upon in consultation with Natural England.
2.29.
Notwithstanding the above considerations, in response to concerns raised by the Council, our client commissioned an Ecology Walkover Survey Report which was completed in April 2026 and will be submitted to the Council by 1 June. In this report, it is recommended that a habitat buffer between any potential development and the riparian corridor connected to the SSSI is retained. Otherwise, it finds the early indicative development footprint is largely devoid of priority habitats, but finds the stream and woodland to the northern boundary is high value and should be avoided, and the land between enhanced. All of these issues can be addressed directly through appropriate masterplanning of the site, and the Vision Document submitted alongside these representations and the indicative layout plan provides additional insight on this.
Site issue – presence of some risk of surface water flooding
2.30.
The site is wholly within Flood Zone 1. However with regards to surface water flooding and the presence of limited risk on some small sections of the site, onward site promotion and evidence to inform a planning application would include a Flood Risk Assessment and the site would be underpinned with a Sustainable Urban Drainage Strategy. It is important to note, much of the surface water flood risk is associated with an area of the site that would not be developed in any case – i.e. in relation to the woodland in the northern part of the site.
Site issue – location within the Coal Authority ‘High Risk’ area
2.31.
The coal mining ‘high risk’ zone is an extensive designation covering the entirety of multiple local planning authority areas. A Coal Mining Risk Assessment will be forthcoming as an important evidence base component to support a future planning application. Within this, any required mitigation would be identified.
Summary
2.32.
The site is included in the refined schedule of sites following initial assessment by the Council and the Land Availability Assessment categorises the site as ‘amber’, indicating ‘some constraints’. The key issues influencing the site’s current rating are addressed above and we consider are all resolvable through appropriate mitigation which will be forthcoming. Our approach to addressing any constraints will be the subject of further evidence base enquiry either for submission by 1 June or to inform onward promotion and an eventual planning application. This, as well as overall emerging strategic approach to the location of growth which favours Level 1 towns such as Dronfield, provides strong justification for allocating the site for residential development in the future Local Plan.
Development needs – Housing
Option 1 – Standard Method
2.33.
The NPPF is clear at Paragraph 62 that “to determine the 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”; effectively, the housing need informed by the standard method is the ‘policy-off’ assessment of the minimum number of homes needed in an area. Plugging this into a consideration of wider environmental, economic and social factors, policies and constraints then determines the housing requirement. The NPPF is clear that “the overall aim should be to meet an area’s identified housing need”. There has to be a well evidenced and compelling argument set out by a plan making authority to justify planning for a lower housing requirement than the housing need identified using the Standard Method. The NPPG makes clear there are some ‘specific circumstances’ whereby this might be justified. The specific circumstances set out at Paragraph 014 of the NPPG do not apply in the case of North East Derbyshire, and we do not consider that any insurmountable constraints exist within the District to justify the pursuit of a housing requirement which diverges negatively from the Standard Method informed housing need. Such an approach we consider would be found to be unsound.
2.34.
In view of the above, as an absolute minimum, Option 1 as set out within the current consultation document should be pursued. In fact, as considered in more detail below, there is evidence in favour of planning for above the Standard Method derived housing need figure.
Option 3 – above Standard Method
2.35.
Whilst the NPPF is clear that the overall aim of strategic policies relating to the delivery of a sufficient supply of homes should be to meet an area’s identified housing need, it is also clear that a Standard Method derived housing need will identify the minimum number of homes needed. The NPPF empowers local planning authorities to apply a ‘policy-on’ approach which should factor in local and strategic ambitions (including economic) as well as general affordability pressures to inform their housing requirement, which may justify pursuit of an increased requirement. Such an approach is closely aligned with the latest Government ambitions to significantly boost the supply of new homes nationally.
2.36.
North East Derbyshire is strategically well placed adjacent to Sheffield (the 4th largest city in England) and Chesterfield. Dronfield specifically benefits from access to the A61 corridor (the subject of a range of improvement projects), Northern Rail and local bus services which provide efficient access between all three. Both Sheffield and Chesterfield are the focus of significant growth ambitions set out in their respective Combined Authority economic plans and from this a growth in a wide range of employment sectors is targeted. Long term ambitions for these cities places North East Derbyshire and its main towns – including Dronfield – perfectly to benefit and, as part of this, react to likely further increase in demand for new homes. Given the spatial relationship between North East Derbyshire and the larger settlements, the housing requirement eventually promoted should take into account these regional ambitions which indicate a need to advance beyond the Standard Method derived minimum.
2.37.
As with the overall Standard Method derived housing need, affordable housing need has also significantly increased since adoption of the current Local Plan. The Housing Needs Assessment (2024) identifies an overall need of 356 affordable dwellings per annum – over 58% of the overall need – and makes clear that “provision of new affordable housing is an important and pressing issue in the area”. The new Local Plan could be proactive in addressing this, by planning to deliver more than the Standard Method derived housing need.
Mix of scale and type of housing sites should be sought
2.38.
The refined schedule of sites evidences that the Council intend to include within the new Local Plan a range of site sizes, also commensurate with the level of sustainability of the varied locations for growth also being supported. We support this approach in principle; the NPPF is clear at Paragraph 72 that “planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability”. The provision of a range of site allocations sizes will help to boost housing delivery by limiting the reliance on large strategic sites which in turn will support flexible and phased delivery from a range of providers. Critically, the provision of a range of site allocation sizes across multiple locations is a major factor in sustaining a robust and deliverable housing pipeline and five-year housing land supply. Our client’s site is at the lower end of the large sites scale and would be in a position as a result of this to contribute directly to the Council’s five-year housing land supply, as well as requirements of plan years beyond.
2.39.
Linked to this also, we continue to support an approach which seeks to allocate a range of types of sites. Although not a topic of this consultation, the 2025 consultation identified seven site type options which between them would provide a varied range of potential impacts (eg. sites within the Green Belt, sites with some landscape harm and higher density sites). Development in any location, by its very nature, will result in some level of impact on its immediate context. However the key, in our view, is to focus on delivering housing in the locations where it is most needed whilst minimising impacts and maximising potential benefits. We agree therefore with the findings of the Sustainability Appraisal which, at paragraph E20 summarises that “it is likely that a combination of different site type options will allow for the most sustainable development strategy, informed by a robust evidence base to determine the capacity of different locations in the district to accommodate proposed growth that is aligned with the relative scale and character of existing settlements”.
Development needs - employment
2.40.
As set out in our previous representations, the new Local Plan should be aspirational and a key component of this will be the district’s ability to accommodate ambitious employment growth. As such, the Council should plan for the district’s employment land requirements at the upper end of the 15-31 ha as recommended in the Employment Needs Assessment (Option 2 in the current consultation document). The upper end of the estimate quite rightly takes account of the ‘policy on’ scenario, recognising the district’s local economic growth aspirations and key growth sectors of the economy. Given the significantly increased Standard Method derived housing need for the district and the need for it to be met as a minimum, it is also correct that labour supply resulting from new housing is taken into account when identifying the quantity of employment land that will be required to service the district going forward. Not adopting this approach risks artificially constraining economic growth which would be in direct contravention of NPPF ambitions, particularly its call for the planning system to build a strong, responsive and competitive economy. We do not consider the district to be so constrained that the identified quantum of employment land within the upper estimate would be undeliverable, particularly when you consider its relationship with the economic growth ambitions of the wider area, including neighbouring Sheffield.
Spatial distribution of development
2.41.
In principle we support the Council’s proposed approach to the location of development. Specifically, that the level of priority of location for accommodating growth correlates with the level of sustainability and role of the type of settlement. We agree that ‘Priority 1 Locations’ should include as indicative locations those listed i.e. the edge of Chesterfield/ Sheffield, new settlement/ strategic sites and level 1 settlements – main towns. We also agree that Dronfield should continue to be recognised as a level 1 settlement – main town, which we explore in more detail below. It is notable that the Sustainability Appraisal does not envisage any major negative effects from accommodating development at the main towns. Indeed, providing growth to the main towns represents a sustainable growth strategy which would, critically, leverage existing infrastructure and services provided by the them, support the vitality and viability of their centres and facilitate access to enhanced sustainable transport options they provide.
2.42.
We also agree that allocations should be assigned using a ‘cascade’ approach. Through this approach, the higher priority locations are likely to receive higher levels of growth which is logical and supported in evidence, albeit the Council will need to remain cognisant of factors which may determine slight divergence from this if necessary, for example in providing for strongly evidenced localised need or responding to key constraints which, for example, may determine that lower priority locations, at least in some scenarios, represent the more suitable location for growth. We note that the consultation responses received are largely in favour of such an approach also.
2.43.
In our previous representations we highlighted that we considered options to focus growth around Sheffield and Chesterfield as not being the most sustainable approach. We considered that such a focus would fail to address the localised need evidenced across the district and undermine local opportunity within the district. We consider that the approach now put forward by the Council – specifically to dilute this focus into a broader ‘Priority 1 Locations’ level alongside, in particular, level 1 settlements – main towns (such as Dronfield) as a sustainable and well-balanced approach. Such an approach alleviates concerns we had that the future distribution of growth would be directed overwhelmingly toward Sheffield and Chesterfield at the expense of other settlements across the district, and this we consider would have been an unsound approach.
Settlement hierarchy
2.44.
We agree with the principle of the approach taken by the Council to identify and group together settlements with similar levels of sustainability which perform similar roles, amounting to a settlement hierarchy. We agree this should feed directly into deciding the spatial distribution of development discussed above.
2.45.
In particular, we concur with the findings of the Settlement Role and Function Study (March 2026) and discussion within the Settlement Hierarchy Topic Paper (March 2026) insofar as it relates to Dronfield and its containment within the ‘Level 1: Towns’ settlement level (scoring well above the required 32+ points (40+)). With concur with the findings that Dronfield includes a recognised town centre which contains an extensive range of services, and that it performs a prominent role in meeting the day to day needs of people across a wide geographic area. We also agree with its findings that Coal Aston forms part of Dronfield, being “closely related to Dronfield, with no obvious physical boundary between them” (paragraph 3.4).
Dronfield as a location for growth
2.46.
As the largest of the settlements in North East Derbyshire it is particularly important that Dronfield accommodates a proportionate level of growth. Its wide range of services, facilities and transport infrastructure as well as its role as a main town within the ‘north east economic zone’ of the Derbyshire Economic Strategy and close proximity to Sheffield and the wider South Yorkshire Mayoral Combined Authority – along with its significant economic growth ambitions – highlights Dronfield as a sustainable location for growth which should play a significant role in delivering North East Derbyshire’s Local Housing Need. Demand for housing around Dronfield is particularly strong as evidenced within the Local Housing Needs Assessment 2024 (LHNA) which finds that even the economic turbulence at the time – in particular its effect on mortgage rates – has had very little impact on buyer demand in the area. The assessment notes that Dronfield appears to have the strongest market demand within the District and notes that “the north and west of the district clearly sees higher prices than the south and east. Areas surrounding Dronfield in particular see high prices” (Paragraph 2.11).
2.47.
A divergence between demand and supply also appears around Dronfield in relation to affordable housing. The LHNA finds that the parish of Dronfield (attributed for this exercise to Dronfield, Coal Aston and Dron Woodhouse where parish statistics have not been collated) is amongst the most in-demand areas within the district with 207 applicants with local connection on the Council’s housing waiting list as at June 2024. Out of 25 Parishes, Dronfield is the third most in-demand within the District on these terms. Of the district’s wards, Dronfield South saw the most average bids per property in 2023 (80). The LHNA identifies an affordable housing need of 71 (net) affordable rented dwellings per annum within Dronfield Parish – the most of any Parish - and Dronfield is the only area identified as having a tangible net need for affordable home ownership products (30 per annum). The identified ‘standardised need for affordable housing’ finds that Dronfield Parish has a need per 1000 dwellings of 10.67 per annum. For comparison purposes, Clay Cross has a need of 5.48, Eckington has a need of 6.89 and Killamarsh has a need of 8.02 – all of these being significantly lower than that of Dronfield.
2.48.
The above represent significant indicators of a historically constrained supply of new dwellings within and around Dronfield specifically. Despite these circumstances, the adopted Local Plan apportions notably less new housing to Dronfield when compared with the smaller towns of Clay Cross and Killamarsh, an issue exacerbated by the Inspector’s decision to remove this site during the examination of the extant Local Plan. The new Local Plan provides the opportunity to re-balance this and ensure Dronfield accommodates a proportionate quantity of dwellings reflecting its existing size and offer. Whilst Dronfield’s place within the Green Belt and associated complexities around its expansion (specifically, the need to release land from the Green Belt) is acknowledged, our client’s site as considered above in more detail, represents an opportunity to contribute to resolving the demand issue in the area with limited Green Belt impact.
Strategic sites and new settlements
2.49.
With the above considerations in mind, whilst we do not object to the principle of identifying strategic sites and new settlements as part of ‘Priority 1 Locations’ for growth, we maintain reservations around the suitability of strategic site ‘Duckmanton Moor’ (now merged from previous sites 45227 and 45541) which is expected to be able to accommodate 2000-3000 dwellings.
2.50.
The southern element of the strategic site (45227) does not directly relate to any existing settlement form and as such would represent an illogical and significant intrusion into the open countryside at this location. The nearest settlement – Arkwright Town to the north – is distant from this element of the site without any sense of continuity. Similarly, whilst technically attached to Arkwright Town to its north west and Long Duckmanton to its north east, the northern element of the site (45541) would result in an illogical and incongruent built form exclusively to the south of A632, awkwardly conjoining both settlements with notable impacts on the countryside at this location including its openness and any landscape value.
2.51.
Both Arkwright Town and Long Duckmanton offer limited provision of services, facilities and employment as highlighted also by the previous Settlement Hierarchy Study and more recently the Settlement Hierarchy Topic Paper, with a significant number of settlements rated as being more sustainable locations for growth. Whilst settlements such as Arkwright Town and Long Duckmanton could accommodate some growth (and, indeed, a distribution of growth across the district we consider to be a sustainable approach), the scale of growth being considered through the delivery of this newly merged strategic site would be entirely at odds with their scale and offer and such an approach we consider to be unsustainable.
2.52.
A significant proportion of the site is occupied by established woodland and this represents a substantial development constraint. Given the likely ecological value of the woodland area, its inclusion within the site will establish a considerable BNG baseline to address which has the potential to undermine viability of the site as a whole. Retention of the asset would significantly reduce the actual developable area provided by the potential allocation and limits the extent to which the site could contribute to delivering the district’s housing needs. Reducing the extent of the site to exclude the woodland area would result in the same outcome, preventing the delivery of a critical mass of dwellings required to fund and maintain new service provision necessary to make new free-standing communities viable and sustainable, particularly in this location where existing infrastructure provision is so limited. Likewise, the exclusion of the woodland area may limit opportunities for mitigation and enhancement where needed.
Sustainability Appraisal (SA) Addendum March 2026
2.53.
The SA Addendum has been produced to assess 271 reasonable alternative sites for residential use which have been identified by the Council – following a comprehensive assessment and filtering process – as being genuinely capable of being selected as allocations within the emerging Local Plan. This assessment does not take into account any mitigation, which of course, as explored in more detail above for our client’s site, can and will be forthcoming where required.
2.54.
Whilst we have not carried out an exhaustive review of the SA Addendum, we do have some concerns which we think are important to raise now, relating to scores applied and, in some cases, what appears to be a mismatch between the stated method for arriving at appropriate scores and its application to this site.
2.55.
For example, we note that the site has been scored negatively for access to a bus stop, yet bus stops are available almost immediately adjacent to the site along Eckington Road. The SA links a negative rating to scenarios where bus stops are more than 400m away from a site, which is simply not the case for this site. Similarly, we are surprised to see a negative score in relation to access to a secondary school given the relatively close proximity to the site (1.75km away via Oakhill Road and Stonelow Green) of one of only three secondary schools in the whole of North East Derbyshire (Dronfield Henry Fanshawe School). It is not clear how this score is justified given the wider context. Further, Oakhill Medical Practice is located off Oakhill Road less than 1km from the site. Again, it is not clear how a negative score against this measure of site accessibility to services can be justified and overall these issues point to three separate scores which we consider to be excessively negative.
2.56.
We also consider that a negative score resulting from the site’s location within a Natural England SSSI Impact Risk Zone is excessive. At this stage, Natural England’s response and position is unknown and should be reflected as such within the SA. Natural England would be consulted as part of onward promotion and, ultimately, to inform a planning application and it is worth noting that the element which impacts on this site only requires consultation for developments of 100 dwellings or more.
Conclusion
2.57.
The site is included in the refined schedule of sites following initial assessment by the Council and the key issues highlighted by the Council are addressed within these representations and we consider are all surmountable alongside appropriate mitigation which will be forthcoming. Our approach to addressing any constraints will be the subject of further evidence base enquiry either for submission by 1 June or to inform onward promotion and an eventual planning application. This, as well as overall emerging strategic approach to the location of growth which favours Level 1 towns such as Dronfield, provides strong justification for allocating the site for residential development in the future Local Plan.

1. Introduction
1.1.
These representations are prepared by Fisher German on behalf of our client Richborough in respect of their land interests at Cross and Birch Farm, off Eckington Road, Coal Aston, Dronfield.
1.2.
The site was submitted to the Council during the 2025 Call for Sites exercise alongside an extensive evidence base engaging on landscape, ecology, transport, heritage and other matters. The site has since been the subject of Representations submitted to the initial Regulation 18 consultation carried out between June and August 2025.
1.3.
The Council are now consulting on its latest material as part of the Issues & Options stage of Local Plan production. Specifically, the current consultation is focussed on the strategic approach to the location of development and a refined schedule of sites all of which have passed through both the initial desktop screening, and further detailed stages of assessment. Notably, these sites also align with the emerging strategy. Included within this refined schedule is our client’s site identified as ‘45483 – Land off Eckington Road, Coal Aston, Dronfield’ within the consultation document.
1.4.
For context it’s important to note that the site was included as a draft allocation - DR2 - in the Submission version of the now-adopted Local Plan (adopted November 2021). This demonstrated the Council’s in principle agreement that the site could accommodate residential development. Following completion of the Examination Hearing Sessions, the Inspector in her initial findings report highlighted concerns around DR2, concluding that it was a prominent extension that changes the character of the area, harms the Moss Valley Conservation Area and erodes the function of the Green Belt. On this basis, the Inspector recommended deletion of the site. Ultimately, to secure adoption of the plan at that time, the Council conceded and removed the site through Main Modifications.
1.5.
It is acknowledged that the Council were previously unable to demonstrate exceptional circumstances that could outweigh perceived harm enough to warrant removal of the site from the Green Belt and as such it was removed as an allocation from the then-submission version Local Plan. However it is considered that the context within which plan making is being undertaken today – driven by central Government ambitions for enhanced housing delivery (1.5 million net additional homes in England by the next General Election), supported by a raft of changes to the National Planning Policy Framework (NPPF) – has fundamentally changed in favour of significantly boosting housing supply locally, including via the increased utilisation of Green Belt sites (as confirmed by Paragraph 146 of the Framework), but only where such sites meet the Golden Rules of Paragraph 156 and 157 of the Framework, providing enhanced public benefits. This site represents a viable option for helping North East Derbyshire to deliver on its (much increased) housing need whilst minimising Green Belt harm and is fully compatible with the current Framework and its approach to the utilisation of Green Belt to meet housing needs in full.
1.6.
The NPPF and Standard Method were published on 12th December 2024 and the updated Local Housing Need for the district has significantly increased from 224 dwellings per annum (dpa) to 605 dpa. The Council will be required to allocate sufficient residential sites to deliver the housing need and we believe this will need to include the use of currently designated Green Belt land to secure a pattern of deliverable and sustainable growth (NPPF 148).
2. Representations
45483 – Land off Eckington Road, Coal Aston, Dronfield
2.1.
The consultation invites specific comments on sites which have been the subject of further testing and been included within the refined schedule. This section seeks to provide site specific commentary to promote its onward selection as a future allocation and this includes a consideration of relevant evidence base work carried out by the client to inform site strategy.
2.2.
It should be noted that since submission of the representations to the June-August 2025 consultation, our client has commissioned updated evidence base and informative plans which are discussed here wherever possible. Otherwise, any additional documentation will be provided to the Council by 1 June as required by the Council and set out in direct correspondence in March 2026.
Site overview
2.3.
The site comprises five field parcels bounded by mature hedgerows, scattered trees and a woodland area to the north. It is located immediately north of the settlement boundary of Dronfield, recognised as a ‘Level 1’ settlement in the adopted Local Plan (the most sustainable of locations for growth). Scattered agricultural development associated with Birch Cross Farm is located in the southern half of the site.
2.4.
The Vision Document, submitted alongside these representations, includes an indicative masterplan (Figure 1) to accommodate around 200 dwellings, which we intend as a ‘starting point’ to form the basis of onward discussions with the Council. We are keen to address more focussed parameters -such as appropriate densities- proactively with the Council and as informed by emerging evidence, including outcomes from work commissioned by our client for submission by 1 June.
Site feasibility
2.5.
Access to the site would be achieved directly from Eckington Road (B6056) and the site would be well serviced by public transport; an initial transport assessment undertaken and submitted to the Call for Sites found its development for c.200 dwellings would not have an adverse impact on the local highway network.
2.6.
The site is entirely within Flood Zone 1 thus at low risk of flooding from rivers or sea and only small pockets of the site are subject to limited surface water flood risk. There are no listed heritage assets within the site or in particularly close proximity to it. The nearest site – Grade II listed ‘Range of Outbuildings to the East of Silkstone Farmhouse’ is located approximately 315m away in Coal Aston. The site is supported by a willing landowner and a well- developed evidence base established as a result of its allocation within the Submission version of the now-adopted Local Plan which is the subject of ongoing updates. The site could be available to deliver units within the first five year period post-adoption of the new Local Plan, helping to ensure a robust housing supply within the District.
2.7.
The site is within the Green Belt, extensive Moss Valey Conservation Area and the Impact Risk Zone for the Moss Valley Woods SSSI, located approximately 235m north east of the site. These constraints are surmountable and considered in more detail below.
2.8.
As part of the consultation, the Council has published a summary of key outstanding issues that they would need to see appropriately addressed for the site to be considered suitable for selection as a future allocation. The following sub-sections address each of the remaining issues highlighted by the Council through this consultation in turn. Where appropriate and as already addressed above, additional evidence currently being produced for our client will be provided by 1 June to provide additional support to the Council. Whilst some of the issues below have already been addressed through the Call for Sites submission and previous Regulation 18 representations of 2025, for reasons of completeness and clarity, these issues remain included within these representations.
Site issue – location within Moss Valley Conservation Area
2.9.
Section 69 of the Planning (Listed Buildings and Conservation Areas) Act 1990 makes provision for local planning authorities to designate Conservation Areas because of their “special architectural or historic interest the character or appearance of which it is desirable to preserve or enhance”. The Moss Valley Conservation Area was designated by North East Derbyshire District Council on 3rd May 1990. There is no character appraisal for this designated asset nor publicly accessible management plan. Reasons for its designation are only covered within the planning committee report supporting its original designation. The Heritage Statement undertaken by Humble Heritage in 2016 in support of the site’s original designation within the now-adopted Local Plan (also submitted to the Call for Sites exercise in 2025) summarises the reasons for its designation (extracted from the committee report) at paragraph 4.09 of that report. It includes mention of Moss Valley being a landscape of historic interest in its own right, there being a great range of natural and man-made elements which comprise its special character, and the presence of vernacular buildings, farmsteads and early industrial sites.
2.10.
The Moss Valley Conservation Area is a large designation covering an area of approximately 1,660 hectares. It includes a number of small to medium sized settlements containing a mix of types of character including modern dwellings such as Lightwood, Troway, Highlane, Ridgeway, Ridgeway Moor, Ford and part of Marsh Lane so is not exclusively rural. Development of the site would result in the loss of less than 0.3% of rural land from the conservation area. There are no industrial archaeology sites within the site or in close proximity of the site’s boundaries. Cross and Birches Farm is a modern farmhouse and farmstead erected in c.1960s and as such does not positively contribute to the historical significance or appearance of the conservation area in relation to the special character associated with man-made elements and building vernacular. No designated assets are in close proximity to the site and there would be no intervisibility between the site and the setting of heritage assets listed outside of the site.
2.11.
In terms of natural elements of the conservation area, there are no designations within the site and its development would not impact upon the Moss Valley Woodland or nearby SSSI (considered in further detail below). The site is active farmland and as such is highly unlikely to be rich in wildlife habitat. Hedgerows and trees within the site could be retained – notwithstanding the fact that none of them benefit from tree preservation orders – and aside from the ecological benefits, this would help to maintain the grain of the existing field layout. Views are not identified as being an important part of the character and appearance of the conservation area. In any case, the changing topography and belts of trees mean that residential scale development on the site is unlikely to be visible from multiple points within the conservation area, notwithstanding also the opportunity for suitable landscape mitigation to be incorporated with any future proposal for the site.
2.12.
In response to concerns highlighted by the Council, our clients have commissioned a new Heritage Statement which will be provided to the Council by 1 June. In the interim, and for the purpose of providing some additional clarity within these representations, an interim Historic Environment Technical Report was also commissioned. It does identify far-reaching views to the north and north-east that incorporate heritage assets, and potential impact on these assets will be a consideration of the forthcoming Heritage Statement. We can confirm however that early recommendations from our client’s heritage consultants is to ensure the retention of important views from the site across Moss Valley Conservation Area, in particular to Oakes Park and Norton Water Tower. It is also recommended that existing hedgerows are retained wherever possible. Ultimately early indications are that these matters can be addressed via appropriate masterplanning of the site and the Vision Document submitted with these representations provides some additional insight on this, and the Heritage Statement will more directly address the concerns. To note also is that the Historic Environment Technical Report finds no evidence to suggest the site contains archaeological remains relating to the medieval rural economy and post-medieval rural industries associated with the Moss Valley Conservation Area so as to preclude or constrain future development of the site.
2.13.
With the above in mind, and notwithstanding forthcoming evidence, we do not consider that the site’s location within the Moss Valley Conservation Area amounts to a strong reason for restricting development at this location as intended by Footnote 7 of the NPPF and reference to designated heritage assets.
Site issue – location within the Green Belt
2.14.
The site’s main constraint is that it is presently designated as Green Belt. Having regard for the recently published NPPF (December 2024), it is clear in paragraph 146 that Green Belt land can be utilised in ‘exceptional circumstances’ where development needs justify release. It states that “Exceptional circumstances, in this context include… instances where an authority cannot meet its identified need for homes, commercial or other development through other means. If that is the case, authorities should review Green Belt boundaries in accordance with the policies in this Framework and propose alterations to meet these needs in full, unless the review provides clear evidence that doing so would fundamentally undermine the purposes (taken together) of the remaining Green Belt, when considered across the area of the plan”.
2.15.
Given the significant uplift in housing need applicable to North East Derbyshire as a result of the revised standard method for calculating Local Housing Need, we cannot envisage a circumstance whereby North East Derbyshire will not need to review its Green Belt boundaries to accommodate its demonstrable growth needs, particularly given the need to ensure ‘sustainable patterns of development’ as advocated by Paragraph 148 of the NPPF. Exceptional circumstances therefore do exist. With this in mind, an assessment of whether the release of the site from the Green Belt would fundamentally undermine the five purposes of the Green Belt is set out in Table 1.
2.16.
This review has been informed by an assessment carried out by independent landscape consultants Tyler Grange as part of a wider updated Landscape Technical Note which formed part of the original evidence base supporting draft allocation DR2 of the now-adopted Local Plan. This work was completed in July 2025 to inform understanding of the recent NPPF and NPPG changes relating to Green Belt and Grey Belt in relation to this site. It considers the sites contribution to the purposes of Green Belt, also utilising the North East Derbyshire Green Belt Review (NEDGBR) produced by NLP in 2017 to support the then-emerging Local Plan. The site was assessed as part of the wider parcel 025 in that Review; the context of which is highlighted in Figure 2 below.
2.17.
It is acknowledged that the Council are committed to producing an updated Green Belt Review to be published alongside a Publication Draft Local Plan later this year. We cannot envisage a scenario where this land could justifiably be identified as making a strong contribution to the Green Belt since its assessment in 2017 (where it was found to perform moderately against purposes a and d and weaker against purpose b) given the national policy context referred to above and clarity provided by the 2025 updates to the PPG.
Five Purposes of the Green Belt Assessment
A - to check the unrestricted sprawl of large built-up areas;
The Site is bordered by the settlement edge of Coal Aston off Eckington Road to the west and south. Development extends along part of the western boundary of the site from Eckington Road. The site boundary then follows the edge of a designated open space, sports and recreation facility to its northern boundary which is marked by Whinacre Wood which provides a strong defensible boundary. The eastern boundary of the Site is bounded by mature hedgerow dividing the site and the adjacent field which to an extent also provides a defensible edge to ensure development would not sprawl any further eastwards. The NEDGBR review study of Parcel 025 (within which the site is located) considers that the parcel plays a role in preventing unrestricted sprawl: “The parcel is partially contained by the urban area. The southern boundary and the majority of the western boundary adjoin the urban area of Dronfield.” It also states that “The parcel has strong and defensible boundaries. The parcels northern boundary comprises a combination of hedgerow and mature tree coverage, whilst the eastern boundary consists of a hedgerow. The southern and western boundaries adjoin the urban area.” The review gave an overall score of ‘amber’ for purpose (a) – to check unrestricted sprawl, stating that “Development of the
Building lasting value, together 8
parcel would neither strengthen nor weaken the Green Belt boundary.” It is evident that all boundaries of the proposed site are currently contained by either a minimum of mature hedgerow and tree planting but also physical features including roads and housing. Masterplanning of the wider site can further ensure any containing features are reinforced with the siting of residential development also responding to the immediate context. The site represents a logical extension of Dronfield and does not strongly contribute to this Green Belt purpose. Specifically, its contribution in this regard is limited to ‘moderate’.
The PPG clarifies to achieve a Strong contribution, which would rule out Grey Belt designation, there needs to be a lack of “physical feature(s) in reasonable proximity that could restrict and contain development”. Furthermore, that the development would result in an “incongruous pattern of development (such as an extended “finger” of development into the Green Belt)”. Whilst only illustrative, it is clear that the development of the site would not amount to either example provided. Conversely, to achieve a moderate contribution, the PPG clarifies land which is “adjacent or near to a large built up area, but include one or more features that weaken the land’s contribution to this purpose a, such as (but not limited to):
•
having physical feature(s) in reasonable proximity that could restrict and contain development
•
be partially enclosed by existing development, such that new development would not result in an incongruous pattern of development
•
contain existing development
•
being subject to other urbanising influences”.
All of which apply to the site, indicating strongly that the previous
assessment remains robust under the new guidance and that at worst the site should be judged to make a moderate contribution to Purpose A of the Green Belt.
B - to prevent neighbouring towns merging into one another;
The City of Sheffield lies to the north of Dronfield and comprises many various suburbs, the closest of which to Dronfield include Batemoor and Jordanthorpe which are c.780m north of the Site. Development of the Site would not bring them into closer proximity with one another. As similarly pointed out in the 2017 NEDGBR in relation to the parcel containing the Site: “The parcel would leave a gap marginally above 1km to Sheffield urban area. In addition it is no closer than the existing adjoining development.” Removal of this Site from the Green Belt would not reduce the strategic gap between Dronfield and Sheffield. The next nearest town to the Site and the east of Dronfield is Eckington which is located c.4.4km from the easternmost extent of Dronfield. Development of the Site would not reduce this gap as the Site is located further west than the most eastern extent of Dronfield at Eckington Road. Chesterfield town is located c.5km south-east of the Site. Development south of Eckington Road (B6056) is located between the Site and Chesterfield. Development at the southern extents of Dronfield also fall in closer proximity to Chesterfield. The site does not make a strong contribution to this purpose. Specifically, the sites contribution in this regard is ‘weak’. This finding is contrary to the conclusion of the Inspector in Examining the now-adopted Local Plan who, in her letter dated 18 February 2019, highlighted the perceived impact of development on the strategic function of Green Belt at this location (in particular to maintain expansive vistas between urban areas and to define settlement extent) as reason for the site’s removal as a draft allocation. Its weak contribution to this Green Belt purpose as detailed here evidences that the site does not erode these features at this location.
Building lasting value, together 9
Again, the updated PPG provides helpful guidance as to how land should be considered against this purpose. Strong functioning land against this purpose is land which forms a substantial part of a gap between towns and would result in the loss of visual separation between towns, neither of which would be applicable. Land which serves a moderate purpose includes land which forms a small gap between towns, being able to be developed without the loss of visual separation. This could be due to the presence or the close proximity of structures, natural landscape elements or topography that preserve visual separation. Weak/no function is similar, where the land does form a gap between towns, but only a very small part of the gap, without making a contribution to visual separation. Having regard for the above, it is clear at worst the site would make a moderate contribution but given scale and lack of intervisibility, a weak contribution is considered more robust.
C - to assist in safeguarding the countryside from encroachment;
The 2017 NEDGBR acknowledged that the parcel already includes some development that accounts for approximately 10% of the parcel, giving it an ‘amber’ score. In terms of site specific development, Birch Cross Farm is currently situated on Site and includes an individual farmstead and associated buildings, vegetation and hardstanding. The field parcels within the Site are presently associated with the farmstead and used for agricultural purposes. Development of the Site would extend the existing built boundaries off Birches Lane and Eckington Road towards the north and Whinacre Wood. The NEDGBR set out that “development of the parcel would neither strengthen nor weaken the Green Belt boundary.” Whinacre Wood would become the boundary which could be supplemented by on-Site planting creating a softer edge between the Green Belt and Urban areas. This would allow any potential for further encroachment to be restricted, prevented and mitigated. The site does not make a strong contribution to this purpose. Specifically, its contribution in this regard is limited to ‘moderate’.
D - to preserve the setting and special character of historic towns; and
The Site is located within the Moss Valley Conservation Area however it does not form a significant part of the conservation area, making no specific contribution to its special character. Further, there is no character appraisal or management plan supporting the designation and the 2017 NEDGBR stated in regard to the parcel containing the site that “The parcel is located within the Moss Valley Conservation Area. It is however considered that the parcel has a limited role in preserving the setting of a historic village or town. The Moss Valley Conservation Area covers a large area of land, and it is not considered that this parcel serves a fundamental purpose of Green Belt land in this respect.” Further, the site is not considered to form part of the historic setting of Dronfield, nor does it have particular relationship with historic elements of the town, being visually screened from its conservation area and listed buildings by mostly post-war development. In accordance with the PPG a weak score is considered appropriate.
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The significant increase in the Local Housing Need for North East Derbyshire and strong evidence of enhanced demand within Dronfield means that multiple sites will be required at different scales to deliver this housing need and this cannot be delivered solely through brownfield allocations. The proposed site allocation would not therefore discourage the recycling of derelict and other urban land in North East Derbyshire and therefore its status as Green Belt land does not strongly contribute to this purpose.
Conclusion
Development of the site would not fundamentally undermine the five purposes (taken together) of the Green Belt. Furthermore, the site does not strongly contribute to purposes (a), (b) or (d) of paragraph 143, nor do the application of policies relating to Footnote 7 designations (excluding Green Belt) provide a strong reason for refusing or restricting development. As such, the site would meet the definition of Grey Belt set out in the NPPF.
2.18.
As set out above, we consider that Footnote 7 designations – specifically the Moss Valley Conservation Area designated heritage asset – do not provide strong reasons for restricting development. Additional context to this is the shift in recognition of Grey Belt designation from being perceived as resulting from a purely land-based assessment to one which should take account of a proposal (including any mitigation provided). In Wrotham Parish Council v SSHCLG (Ref: AC-2025-LON-000898), the High Court concluded that the Inspector had erred in their judgment in only assessing the land, rather than the proposal – which included mitigation – in concluding on impacts on Footnote 7 designations.
2.19.
Whilst this finding relates to decision making on a specific proposal with explicit mitigation measures proposed, the principle logically should be carried across when considering potential allocation, particularly as any site-specific policy can appropriately require mitigation measures as part of any future proposal. This is further underpinned by the Government’s clear intention to remove reference to Footnote 7 from the grey belt definition within the NPPF, which is a logical refinement given that decision makers have at their disposal the tools to refuse permission where a particular designation (such as a heritage asset) would genuinely provide strong reasons for refusal anyway. There is no need for grey belt designation to repeat such protections which results in the artificial narrowing of the scope of land that can fall within grey belt category.
2.20.
With the above in mind, the site would meet the definition of Grey Belt set out in the NPPF. Paragraph 155 of the NPPF (2024) confirms development in the Green Belt should not be regarded as inappropriate where:
•
the development would utilise grey belt land and would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan,
•
there is a demonstrable unmet need for the type of development proposed,
•
the development would be in a sustainable location and
•
where applicable the development proposed meets the ‘Golden Rules’ requirements set out in paragraphs 156-157.
2.21.
With regard to the ‘Golden Rules’ set out in paragraphs 156-157 of the NPPF, the affordable housing requirement to be accommodated on the site will be set at a higher level than that which would otherwise apply to land, subject to viability, to be established in this Plan as per Framework particularly Paragraph 67b. The development proposal on the site will include any necessary improvements to local or national infrastructure as well as provision of new, or improvements to existing, green spaces that are accessible to the public.
2.22.
Development of this site would meet all of the criteria of NPPF Paragraph 155 and therefore would not constitute inappropriate development in the Green Belt. Given its Grey Belt status, its release from the Green Belt should be prioritised.
Site issue – landscape impact
2.23.
Our client has commissioned Landscape and Visual Impact Assessment (LVIA) evidence following direct feedback from the Council received after completion of their site refinement process. Specifically, it has been requested that LVIA is carried out to address some specific landscape constraints identified by the Inspector appointed to examine the now adopted Local Plan who, at the time, removed the site from contention for allocation not least due to perceived localised landscape impacts such as in relation to Eckington Road and Footpath 37. This evidence will be submitted to the Council by the 1 June 2026 deadline afforded for additional evidence.
2.24.
The Vision Document submitted alongside these representations provides some early insight, which suggests the site is generally well contained with a limited visual connection with the wider landscape character and that the visual effects associated with future development would be contained to near context and would be capable of being managed through layout, scale and landscape mitigation.
2.25.
Notwithstanding the above, in support of representations submitted to the last round of consultation in 2025, our client separately commissioned a detailed Landscape Technical Note which provides useful insight in the interim, until completion of the LVIA. In summary, the report – which was carried out by landscape specialists Tyler Grange – found that the site had a very limited relationship with the wider Moss Valley Conservation Area and that development of the site has the potential to be accommodated with reference to the site-specific conditions. It made a number of observations and recommendations as follows:
•
Permeability across the site should be integrated into any emerging development layout and views across portions of the Site retained. Vehicular access should be limited to the south, off Eckington Road with pedestrian access in other locations, linking up with the wider Green Infrastructure network;
•
The Site is influenced by its visual connection to the surrounding settlement edge. This character and backdrop acts as a strong precedent, but built development will need consideration of appropriate materials, scale, height and density to respond to the context;
•
An existing overhead line runs north-south through the Site, this constraint could be utilised to create a green link connecting the Site from Eckington Road to the wider PRoW network. Further tree planting will further assist in softening building mass where the Site can be viewed (partially screened and heavily filtered) from elevated, distant locations to the north;
•
Where the Site is viewed from elevated topography to the north and east, it is where there are gaps in existing built form and boundary vegetation. However, these views are very limited due to the layering effect of scattered built form, changes in topography and vegetation associated with these dwellings, fields and roads. Layering of east-west vegetation strips and new Green Infrastructure corridors could be considered throughout the Site to break-up and soften any new built development;
•
The site is physically contained in all directions by mature boundaries. Boundaries should be retained and enhanced with development offsets and new native planting to soften the development edge linking into the existing Green Infrastructure network;
•
In terms of Green Belt, when assessed against Green Belt purposes, the Site does not perform a strong contribution in any purpose and is largely consistent with the findings of the previous NEDGBR 2017 undertaken by NEDC;
•
The site bears no listed heritage assets, nor has any known archaeology that provides cultural links to the past, nor does the site have any known cultural associations related to people or industry (such as mineral extraction and metalworking). Little is left of the historic field pattern, of which the current five fields on Site have occurred through agricultural intensification and field amalgamation. The farm complex is late 20th century and the Site as a whole is overlooked by late 20th and early 21st century housing.
Site issue – relationship with Moss Valley Woodlands SSSI and wider ecology
2.26.
Moss Valley Woods SSSI is designated on account of the presence of ancient woodland, located 0.2km north east of the site. It comprises two units of woodland – Whinacre Wood and Brownstorth Wood. It is contiguous with woodland in the north of the site and an ephemeral stream connects this woodland to the SSSI. The site falls within Natural England’s Impact Risk Zone where potential residential developments of 100 units or more would require further consultation with Natural England, consideration of potential impacts and appropriate mitigation.
2.27.
Potential adverse effects are limited by reason of there being no direct pedestrian links to the SSSI from the site and no known footpaths or access into Whinacre Wood (within the SSSI). The distance involved along with lack of parking and direct public access to Brownstorth Wood part of the SSSI means negligible potential impacts on this unit are anticipated.
2.28.
Principles of mitigation set out in the SSSI Technical Note submitted to the Call for Sites form the basis for mitigation that could be delivered to ensure the SSSI is not adversely affected by development of the site and these would be integrated with proposals through the planning application process. In summary the principles of such mitigation could include the implementation of pollution prevention measures during construction, implementation of an appropriately designed drainage strategy and implementation of a woodland management and access plan for the woodland in the north of the site. These principles would need to be built upon in consultation with Natural England.
2.29.
Notwithstanding the above considerations, in response to concerns raised by the Council, our client commissioned an Ecology Walkover Survey Report which was completed in April 2026 and will be submitted to the Council by 1 June. In this report, it is recommended that a habitat buffer between any potential development and the riparian corridor connected to the SSSI is retained. Otherwise, it finds the early indicative development footprint is largely devoid of priority habitats, but finds the stream and woodland to the northern boundary is high value and should be avoided, and the land between enhanced. All of these issues can be addressed directly through appropriate masterplanning of the site, and the Vision Document submitted alongside these representations and the indicative layout plan provides additional insight on this.
Site issue – presence of some risk of surface water flooding
2.30.
The site is wholly within Flood Zone 1. However with regards to surface water flooding and the presence of limited risk on some small sections of the site, onward site promotion and evidence to inform a planning application would include a Flood Risk Assessment and the site would be underpinned with a Sustainable Urban Drainage Strategy. It is important to note, much of the surface water flood risk is associated with an area of the site that would not be developed in any case – i.e. in relation to the woodland in the northern part of the site.
Site issue – location within the Coal Authority ‘High Risk’ area
2.31.
The coal mining ‘high risk’ zone is an extensive designation covering the entirety of multiple local planning authority areas. A Coal Mining Risk Assessment will be forthcoming as an important evidence base component to support a future planning application. Within this, any required mitigation would be identified.
Summary
2.32.
The site is included in the refined schedule of sites following initial assessment by the Council and the Land Availability Assessment categorises the site as ‘amber’, indicating ‘some constraints’. The key issues influencing the site’s current rating are addressed above and we consider are all resolvable through appropriate mitigation which will be forthcoming. Our approach to addressing any constraints will be the subject of further evidence base enquiry either for submission by 1 June or to inform onward promotion and an eventual planning application. This, as well as overall emerging strategic approach to the location of growth which favours Level 1 towns such as Dronfield, provides strong justification for allocating the site for residential development in the future Local Plan.
Development needs – Housing
Option 1 – Standard Method
2.33.
The NPPF is clear at Paragraph 62 that “to determine the 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”; effectively, the housing need informed by the standard method is the ‘policy-off’ assessment of the minimum number of homes needed in an area. Plugging this into a consideration of wider environmental, economic and social factors, policies and constraints then determines the housing requirement. The NPPF is clear that “the overall aim should be to meet an area’s identified housing need”. There has to be a well evidenced and compelling argument set out by a plan making authority to justify planning for a lower housing requirement than the housing need identified using the Standard Method. The NPPG makes clear there are some ‘specific circumstances’ whereby this might be justified. The specific circumstances set out at Paragraph 014 of the NPPG do not apply in the case of North East Derbyshire, and we do not consider that any insurmountable constraints exist within the District to justify the pursuit of a housing requirement which diverges negatively from the Standard Method informed housing need. Such an approach we consider would be found to be unsound.
2.34.
In view of the above, as an absolute minimum, Option 1 as set out within the current consultation document should be pursued. In fact, as considered in more detail below, there is evidence in favour of planning for above the Standard Method derived housing need figure.
Option 3 – above Standard Method
2.35.
Whilst the NPPF is clear that the overall aim of strategic policies relating to the delivery of a sufficient supply of homes should be to meet an area’s identified housing need, it is also clear that a Standard Method derived housing need will identify the minimum number of homes needed. The NPPF empowers local planning authorities to apply a ‘policy-on’ approach which should factor in local and strategic ambitions (including economic) as well as general affordability pressures to inform their housing requirement, which may justify pursuit of an increased requirement. Such an approach is closely aligned with the latest Government ambitions to significantly boost the supply of new homes nationally.
2.36.
North East Derbyshire is strategically well placed adjacent to Sheffield (the 4th largest city in England) and Chesterfield. Dronfield specifically benefits from access to the A61 corridor (the subject of a range of improvement projects), Northern Rail and local bus services which provide efficient access between all three. Both Sheffield and Chesterfield are the focus of significant growth ambitions set out in their respective Combined Authority economic plans and from this a growth in a wide range of employment sectors is targeted. Long term ambitions for these cities places North East Derbyshire and its main towns – including Dronfield – perfectly to benefit and, as part of this, react to likely further increase in demand for new homes. Given the spatial relationship between North East Derbyshire and the larger settlements, the housing requirement eventually promoted should take into account these regional ambitions which indicate a need to advance beyond the Standard Method derived minimum.
2.37.
As with the overall Standard Method derived housing need, affordable housing need has also significantly increased since adoption of the current Local Plan. The Housing Needs Assessment (2024) identifies an overall need of 356 affordable dwellings per annum – over 58% of the overall need – and makes clear that “provision of new affordable housing is an important and pressing issue in the area”. The new Local Plan could be proactive in addressing this, by planning to deliver more than the Standard Method derived housing need.
Mix of scale and type of housing sites should be sought
2.38.
The refined schedule of sites evidences that the Council intend to include within the new Local Plan a range of site sizes, also commensurate with the level of sustainability of the varied locations for growth also being supported. We support this approach in principle; the NPPF is clear at Paragraph 72 that “planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability”. The provision of a range of site allocations sizes will help to boost housing delivery by limiting the reliance on large strategic sites which in turn will support flexible and phased delivery from a range of providers. Critically, the provision of a range of site allocation sizes across multiple locations is a major factor in sustaining a robust and deliverable housing pipeline and five-year housing land supply. Our client’s site is at the lower end of the large sites scale and would be in a position as a result of this to contribute directly to the Council’s five-year housing land supply, as well as requirements of plan years beyond.
2.39.
Linked to this also, we continue to support an approach which seeks to allocate a range of types of sites. Although not a topic of this consultation, the 2025 consultation identified seven site type options which between them would provide a varied range of potential impacts (eg. sites within the Green Belt, sites with some landscape harm and higher density sites). Development in any location, by its very nature, will result in some level of impact on its immediate context. However the key, in our view, is to focus on delivering housing in the locations where it is most needed whilst minimising impacts and maximising potential benefits. We agree therefore with the findings of the Sustainability Appraisal which, at paragraph E20 summarises that “it is likely that a combination of different site type options will allow for the most sustainable development strategy, informed by a robust evidence base to determine the capacity of different locations in the district to accommodate proposed growth that is aligned with the relative scale and character of existing settlements”.
Development needs - employment
2.40.
As set out in our previous representations, the new Local Plan should be aspirational and a key component of this will be the district’s ability to accommodate ambitious employment growth. As such, the Council should plan for the district’s employment land requirements at the upper end of the 15-31 ha as recommended in the Employment Needs Assessment (Option 2 in the current consultation document). The upper end of the estimate quite rightly takes account of the ‘policy on’ scenario, recognising the district’s local economic growth aspirations and key growth sectors of the economy. Given the significantly increased Standard Method derived housing need for the district and the need for it to be met as a minimum, it is also correct that labour supply resulting from new housing is taken into account when identifying the quantity of employment land that will be required to service the district going forward. Not adopting this approach risks artificially constraining economic growth which would be in direct contravention of NPPF ambitions, particularly its call for the planning system to build a strong, responsive and competitive economy. We do not consider the district to be so constrained that the identified quantum of employment land within the upper estimate would be undeliverable, particularly when you consider its relationship with the economic growth ambitions of the wider area, including neighbouring Sheffield.
Spatial distribution of development
2.41.
In principle we support the Council’s proposed approach to the location of development. Specifically, that the level of priority of location for accommodating growth correlates with the level of sustainability and role of the type of settlement. We agree that ‘Priority 1 Locations’ should include as indicative locations those listed i.e. the edge of Chesterfield/ Sheffield, new settlement/ strategic sites and level 1 settlements – main towns. We also agree that Dronfield should continue to be recognised as a level 1 settlement – main town, which we explore in more detail below. It is notable that the Sustainability Appraisal does not envisage any major negative effects from accommodating development at the main towns. Indeed, providing growth to the main towns represents a sustainable growth strategy which would, critically, leverage existing infrastructure and services provided by the them, support the vitality and viability of their centres and facilitate access to enhanced sustainable transport options they provide.
2.42.
We also agree that allocations should be assigned using a ‘cascade’ approach. Through this approach, the higher priority locations are likely to receive higher levels of growth which is logical and supported in evidence, albeit the Council will need to remain cognisant of factors which may determine slight divergence from this if necessary, for example in providing for strongly evidenced localised need or responding to key constraints which, for example, may determine that lower priority locations, at least in some scenarios, represent the more suitable location for growth. We note that the consultation responses received are largely in favour of such an approach also.
2.43.
In our previous representations we highlighted that we considered options to focus growth around Sheffield and Chesterfield as not being the most sustainable approach. We considered that such a focus would fail to address the localised need evidenced across the district and undermine local opportunity within the district. We consider that the approach now put forward by the Council – specifically to dilute this focus into a broader ‘Priority 1 Locations’ level alongside, in particular, level 1 settlements – main towns (such as Dronfield) as a sustainable and well-balanced approach. Such an approach alleviates concerns we had that the future distribution of growth would be directed overwhelmingly toward Sheffield and Chesterfield at the expense of other settlements across the district, and this we consider would have been an unsound approach.
Settlement hierarchy
2.44.
We agree with the principle of the approach taken by the Council to identify and group together settlements with similar levels of sustainability which perform similar roles, amounting to a settlement hierarchy. We agree this should feed directly into deciding the spatial distribution of development discussed above.
2.45.
In particular, we concur with the findings of the Settlement Role and Function Study (March 2026) and discussion within the Settlement Hierarchy Topic Paper (March 2026) insofar as it relates to Dronfield and its containment within the ‘Level 1: Towns’ settlement level (scoring well above the required 32+ points (40+)). With concur with the findings that Dronfield includes a recognised town centre which contains an extensive range of services, and that it performs a prominent role in meeting the day to day needs of people across a wide geographic area. We also agree with its findings that Coal Aston forms part of Dronfield, being “closely related to Dronfield, with no obvious physical boundary between them” (paragraph 3.4).
Dronfield as a location for growth
2.46.
As the largest of the settlements in North East Derbyshire it is particularly important that Dronfield accommodates a proportionate level of growth. Its wide range of services, facilities and transport infrastructure as well as its role as a main town within the ‘north east economic zone’ of the Derbyshire Economic Strategy and close proximity to Sheffield and the wider South Yorkshire Mayoral Combined Authority – along with its significant economic growth ambitions – highlights Dronfield as a sustainable location for growth which should play a significant role in delivering North East Derbyshire’s Local Housing Need. Demand for housing around Dronfield is particularly strong as evidenced within the Local Housing Needs Assessment 2024 (LHNA) which finds that even the economic turbulence at the time – in particular its effect on mortgage rates – has had very little impact on buyer demand in the area. The assessment notes that Dronfield appears to have the strongest market demand within the District and notes that “the north and west of the district clearly sees higher prices than the south and east. Areas surrounding Dronfield in particular see high prices” (Paragraph 2.11).
2.47.
A divergence between demand and supply also appears around Dronfield in relation to affordable housing. The LHNA finds that the parish of Dronfield (attributed for this exercise to Dronfield, Coal Aston and Dron Woodhouse where parish statistics have not been collated) is amongst the most in-demand areas within the district with 207 applicants with local connection on the Council’s housing waiting list as at June 2024. Out of 25 Parishes, Dronfield is the third most in-demand within the District on these terms. Of the district’s wards, Dronfield South saw the most average bids per property in 2023 (80). The LHNA identifies an affordable housing need of 71 (net) affordable rented dwellings per annum within Dronfield Parish – the most of any Parish - and Dronfield is the only area identified as having a tangible net need for affordable home ownership products (30 per annum). The identified ‘standardised need for affordable housing’ finds that Dronfield Parish has a need per 1000 dwellings of 10.67 per annum. For comparison purposes, Clay Cross has a need of 5.48, Eckington has a need of 6.89 and Killamarsh has a need of 8.02 – all of these being significantly lower than that of Dronfield.
2.48.
The above represent significant indicators of a historically constrained supply of new dwellings within and around Dronfield specifically. Despite these circumstances, the adopted Local Plan apportions notably less new housing to Dronfield when compared with the smaller towns of Clay Cross and Killamarsh, an issue exacerbated by the Inspector’s decision to remove this site during the examination of the extant Local Plan. The new Local Plan provides the opportunity to re-balance this and ensure Dronfield accommodates a proportionate quantity of dwellings reflecting its existing size and offer. Whilst Dronfield’s place within the Green Belt and associated complexities around its expansion (specifically, the need to release land from the Green Belt) is acknowledged, our client’s site as considered above in more detail, represents an opportunity to contribute to resolving the demand issue in the area with limited Green Belt impact.
Strategic sites and new settlements
2.49.
With the above considerations in mind, whilst we do not object to the principle of identifying strategic sites and new settlements as part of ‘Priority 1 Locations’ for growth, we maintain reservations around the suitability of strategic site ‘Duckmanton Moor’ (now merged from previous sites 45227 and 45541) which is expected to be able to accommodate 2000-3000 dwellings.
2.50.
The southern element of the strategic site (45227) does not directly relate to any existing settlement form and as such would represent an illogical and significant intrusion into the open countryside at this location. The nearest settlement – Arkwright Town to the north – is distant from this element of the site without any sense of continuity. Similarly, whilst technically attached to Arkwright Town to its north west and Long Duckmanton to its north east, the northern element of the site (45541) would result in an illogical and incongruent built form exclusively to the south of A632, awkwardly conjoining both settlements with notable impacts on the countryside at this location including its openness and any landscape value.
2.51.
Both Arkwright Town and Long Duckmanton offer limited provision of services, facilities and employment as highlighted also by the previous Settlement Hierarchy Study and more recently the Settlement Hierarchy Topic Paper, with a significant number of settlements rated as being more sustainable locations for growth. Whilst settlements such as Arkwright Town and Long Duckmanton could accommodate some growth (and, indeed, a distribution of growth across the district we consider to be a sustainable approach), the scale of growth being considered through the delivery of this newly merged strategic site would be entirely at odds with their scale and offer and such an approach we consider to be unsustainable.
2.52.
A significant proportion of the site is occupied by established woodland and this represents a substantial development constraint. Given the likely ecological value of the woodland area, its inclusion within the site will establish a considerable BNG baseline to address which has the potential to undermine viability of the site as a whole. Retention of the asset would significantly reduce the actual developable area provided by the potential allocation and limits the extent to which the site could contribute to delivering the district’s housing needs. Reducing the extent of the site to exclude the woodland area would result in the same outcome, preventing the delivery of a critical mass of dwellings required to fund and maintain new service provision necessary to make new free-standing communities viable and sustainable, particularly in this location where existing infrastructure provision is so limited. Likewise, the exclusion of the woodland area may limit opportunities for mitigation and enhancement where needed.
Sustainability Appraisal (SA) Addendum March 2026
2.53.
The SA Addendum has been produced to assess 271 reasonable alternative sites for residential use which have been identified by the Council – following a comprehensive assessment and filtering process – as being genuinely capable of being selected as allocations within the emerging Local Plan. This assessment does not take into account any mitigation, which of course, as explored in more detail above for our client’s site, can and will be forthcoming where required.
2.54.
Whilst we have not carried out an exhaustive review of the SA Addendum, we do have some concerns which we think are important to raise now, relating to scores applied and, in some cases, what appears to be a mismatch between the stated method for arriving at appropriate scores and its application to this site.
2.55.
For example, we note that the site has been scored negatively for access to a bus stop, yet bus stops are available almost immediately adjacent to the site along Eckington Road. The SA links a negative rating to scenarios where bus stops are more than 400m away from a site, which is simply not the case for this site. Similarly, we are surprised to see a negative score in relation to access to a secondary school given the relatively close proximity to the site (1.75km away via Oakhill Road and Stonelow Green) of one of only three secondary schools in the whole of North East Derbyshire (Dronfield Henry Fanshawe School). It is not clear how this score is justified given the wider context. Further, Oakhill Medical Practice is located off Oakhill Road less than 1km from the site. Again, it is not clear how a negative score against this measure of site accessibility to services can be justified and overall these issues point to three separate scores which we consider to be excessively negative.
2.56.
We also consider that a negative score resulting from the site’s location within a Natural England SSSI Impact Risk Zone is excessive. At this stage, Natural England’s response and position is unknown and should be reflected as such within the SA. Natural England would be consulted as part of onward promotion and, ultimately, to inform a planning application and it is worth noting that the element which impacts on this site only requires consultation for developments of 100 dwellings or more.
Conclusion
2.57.
The site is included in the refined schedule of sites following initial assessment by the Council and the key issues highlighted by the Council are addressed within these representations and we consider are all surmountable alongside appropriate mitigation which will be forthcoming. Our approach to addressing any constraints will be the subject of further evidence base enquiry either for submission by 1 June or to inform onward promotion and an eventual planning application. This, as well as overall emerging strategic approach to the location of growth which favours Level 1 towns such as Dronfield, provides strong justification for allocating the site for residential development in the future Local Plan.