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

1.1 North East Derbyshire District Council (hereafter referred to as ‘the Council’) are reviewing the current local plan to ensure that it reflects changes to the district’s housing requirements along with new legislation and guidance introduced by the government. The Council is seeking to engage with key stakeholders, including individuals and organisations who have an interest in the district (in accordance with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012).
1.2 Spawforths have been instructed by Keyland Developments Ltd (Keyland) to submit representations to the North East Derbyshire District Council Local Plan Review Regulation 18 Consultation on the Strategic Approach to the Location of Development and Refined Sites.
1.3 Keyland have significant interest within North East Derbyshire, which can positively contribute to the housing and economic growth agenda, and therefore welcome the opportunity to engage with the Council in the preparation of an updated Local Plan. Keyland’s site is at Furnace Hillock Way, Hasland, Chesterfield (Site 45065):
1.4 Keyland would like to make comments on the following topics and sections of the North East Derbyshire District Local Plan Review:
• General Comments
• Strategic Approach
• Refined Schedule of Sites: Site 45065 – Land around Furnace Hillock Way, Hasland
1.5 In each case, observations are set out with reference to the provisions of the National Planning Policy Framework (hereafter referred to as “the Framework”) and where necessary, amendments are suggested to ensure that the Local Plan Update is found sound.
1.6 Keyland welcomes the opportunity for further engagement and the opportunity to appear at Examination in Public.
1.7 We trust that you will confirm that these representations are duly made and will give due consideration to these comments. Please do not hesitate to contact us to discuss any issues raised in this Representation further.
National Planning Policy context and Tests of Soundness
1.8 The Governments core objectives as established through the 2024 National Planning Policy Framework are sustainable development and growth. Paragraph 11 of the 2024 Framework stresses the need for Local Plans to meet, as a minimum, the objectively assessed needs of an area. The 2024 Framework sets out to boost significantly the supply of homes and ensure that a sufficient amount and variety of land can come forward where it is needed. The Local Housing Need identified through the standard method in the National Planning Practice Guidance should be met as a minimum. In terms of building a strong and competitive economy the 2024 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2024 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes and well-designed places.
1.9 In relation to Local Plan formulation, paragraphs 15 to 38 of the 2024 Framework state that Local Plans are the key to delivering sustainable development which reflect the vision and aspirations of the local community. The 2024 Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where. Paragraph 22 is clear that the Strategic policies should look ahead over a minimum period of 15 year period, andwhere larger scale development such as new settlements or significant extensions to existing villages and towns form part of the areas strategy, then policies should look ahead over a period of at least 30 years.
1.10 In relation to the examination of Local Plans, paragraph 36 of the 2024 Framework sets out the tests of soundness and establishes that:
Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
• Positively prepared – providing a strategy which as a minimum, seeks to meet the area’s objectively assessed need; and is informed by agreements with other authorities, so that unmet needs from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with policies in this Framework and other statements of national planning policy, where relevant.
1.11 The Local Planning Authority must demonstrate that the Local Plan Update complies with the legal and regulatory framework, including the legal requirements in ss19 and 24(1) of the Planning and Compulsory Purchase Act 2004 (PCPA 2004), Regulations under s.17 and any regulations under s. 36 relating to the preparation of DPD’s, and that the Local Plan Update is ‘Sound’, and that it complies with the Duty to Cooperate.
1.12 The PCPA 2004 requires the LPA to demonstrate that regard has been given to national policies and advice, development plan documents, and must undertake a sustainability appraisal. Plan making authorities are also required to have regard to the resources that are likely to be available for implementing the proposals1. As confirmed with legal judgements “resources” includes resources in the private sector “thus the viability and deliverability of the proposals are considerations to which the authority should have regard when preparing its policies” 2.
1.13 This document therefore considers the content of the consultation on behalf of Keyland in the light of this legal and planning policy context.
General Comments
2.1 Keyland consider that the Council needs to fully reflect the new 2024 Framework in relation to ambition and growth.
Justification
Housing and Economic Growth
2.2 Keyland welcomes a further opportunity to engage on the spatial strategy and locations for development.
2.3 The North East Derbyshire Local Plan was adopted in November 2021 and covered the period 2014-2034, which is now approaching 5 years ago. National planning policy and guidance has changed significantly in that time, with latest National Planning Policy Framework published in December 2024. This includes a refreshed approach to the standard methodology for calculating housing need.
2.4 The Framework establishes a more positive and pro-development policy framework to address the concern that the planning system is a major constraint to growth. The July 2024 Written Ministerial Statement (30th July 2024) confirms the Government’s position on restoring and raising housing targets; focussing new development into the ‘right places’ including within the Green Belt; moving towards strategic planning; building infrastructure to grow the economy; and supporting local planning.
2.5 The Framework is the immediate tool to unlock the planning system and reflects the new Labour Government’s aspirations for growth. Rachel Reeves gave a speech soon after the election to emphasise that “sustained growth is the only route to improving prosperity of our country”; that “nowhere is decisive reform needed more urgently than in our planning system”; and importantly “economic benefits of development will be a central consideration”.
2.6 Chapter 5 is all about ‘Delivering a sufficient supply of homes’ and the changes to the Framework reinforce and emphasise that local authorities should meet the identified housing need as a minimum and the baseline is the standard method. Para 62 of the NPPF states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” 2.7 Under the standard method for calculating housing need, North East Derbyshire District Council’s local housing need requirement is set at a minimum of 605 new homes per year.
2.8 The proposed changes to the NPPF were published for consultation on 16th December 2025. The Ministerial Statement that accompanied the proposed changes states that the overhaul of the NPPF is designed “to facilitate the delivery of high and sustainable rates of housebuilding” and to “boost the housing supply and unlock economic growth”. The proposed changes create a “permanent presumption in favour of sustainable development”, secure a diverse mix of homes and streamline local standards to speed up decision making. It is appreciated that the proposed changes are out for consultation, but they are a direction of travel contained in an accompanying Written Ministerial Statement.
2.9 Therefore, there is a need for the emerging Local Plan to address the updated national planning position and provide for the housing and employment needs for the area.
Plan period
2.10 Keyland welcomes the extension of the Plan period from the consultation undertaken in August 2025. The consultation material now suggests the emerging Local Plan will cover a Plan period from 2024-2044. The Framework is clear that all strategic policies should look ahead for a minimum of 15 years from the date of adoption. However, if there are large scale urban extensions / new towns then this should be over a 30 year period. Therefore, Keyland considers that there is potential for the Local Plan to cover a longer period and plan accordingly to drive economic and housing growth that the area needs.
Ambition
2.11 The Government’s ambition is to deliver sustained economic growth, improve prospective and enhance living standards. To deliver this ambition growth needs to be created throughout the country. The emerging Local Plan needs to reflect the Government’s ambition and recognise the housing crisis.
2.12 Furthermore, the Local Plan Update needs to reflect the ambitions both nationally, and for the sub-region. The East Midlands Vision for Growth (May 2025) sets out the region’s bold plan which will transform the region. Delivery of the vision will create 100,000 new jobs, deliver and add £4 billion to the East Midlands economy.
2.13 This vision sets out a clear direction for the region and establishes long-term objectives that will make the East Midlands an even greater place to live, work, and visit. The plan focuses on seven key locations where there are opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
2.14 This approach needs to be reflected and enshrined within the emerging Local Plan for North East Derbyshire.
Proposed Approach
2.15 To address the comments, the following approach is proposed:
• Reflect the new National Planning Policy Framework.
• With the economic ambitions and affordable housing need, the housing requirement should be set above the standard method Local Housing Need.
• Reflect the region’s ambitions and growth strategies.
Strategic Approach to the Location of Development
3.1 Keyland consider that the Council’s approach to the emerging Local Plan needs to reflect national policy and guidance and deliver the ambitions for housing and economic growth. The emerging Local Plan should not just be trying to achieve the minimum number of homes required.
3.2 The emerging Local Plan needs to address the big strategic issues of providing for new homes and businesses and supporting infrastructure.
Justification
Development Needs
3.3 The Vision needs to reflect national and regional policy ambitions. Nationally, the Government is seeking to deliver 1.5 million new homes and the housing crisis is a key policy issue to address over this parliamentary period. This flows through Written Ministerial Statements and the new Framework, which includes updated guidance and minimum housing targets, which the Vision should set out to achieve.
3.4 Furthermore, the Government seeks to increase economic growth, which is important to address prosperity and living standards, consistently highlighting that “sustained growth is the only route to improving prosperity of our country”.
3.5 Keyland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.6 Keyland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.7 The standard method calculates for North East Derbyshire that the housing need is 605 new homes per annum, or 12,100 over the 20 years of the Local Plan period. Furthermore, national policy and guidance states that Councils can choose to plan for more homes if they want to support things like economic growth or help meet housing needs in nearby areas.
3.8 The standard method represents a baseline for calculating housing need, and should not be seen as a ceiling for delivering housing. Whilst the standard method provides a minimum starting point for housing need, using household projections and affordability. It also fails to account for local economic growth, job creation, infrastructure changes, or specific demographic shifts.
3.9 Providing ambitious housing targets above the standard methodology also supports economic growth. This would match the East Midlands Vision for Growth (May 2025) which sets out the vision for transformative and ambitious growth within the region. Where significant employment growth is planned, housing supply must match job creation to avoid commuting issues and labour shortages.
3.10 At Examination, the Planning Inspectors may find the Loca Plan unsound if it fails adequately address all sources of housing need. A higher target for housing will demonstrate that the Local Plan is positively prepared, justified, and effective, which are key NPPF soundness tests.
3.11 The Local Plan should therefore establish a housing requirement above the standard method to reflect the economic ambitions for the area and affordable housing needs.
Spatial Distribution of Development
3.12 The location of development is a critical aspect of achieving sustainable development. As a general principal development should be located in areas that are accessible, sustainable, and benefit the local community.
3.13 The feedback from the August 2025 consultation shows the largest proportion of support (24%) was towards sites around the edge of Chesterfield. Keyland supports this approach. Chesterfield is the largest and most sustainable settlement in the area, which is surrounded by North East Derbyshire on three sides.
3.14 Furthermore, local government reorganisation is proceeding which is likely to merge Chesterfield with North East Derbyshire in the near future.
3.15 Therefore, through engagement and dialogue appropriate sustainable opportunities should be identified on the edge of Chesterfield, such as Keyland’s site at Furnace Hollock Way, Hasland (Site Ref 45065).
Proposed Approach to the Location of Development
3.16 Keyland support the proposed approach which identifies Priority Locations with Priority 1 including Edge of Chesterfield/Sheffield locations.
3.17 Keyland consider that this is an appropriate option in identifying land required to deliver sustainable growth within the district. Development around Chesterfield should be prioritised. Chesterfield is the most sustainable settlement in the area, which is surrounded by North East Derbyshire on three sides. Locating development on the edge of Chesterfield will ensure that new development has access to services, facilities, employment opportunities and access to public transport.
3.18 It is welcomed that higher positions in the spatial locations will be prioritised. However, it is slightly concerning that the consultation document states that “this does not override Green Belt or other desirable policy restrictions such as Local Settlement Gaps, provided that sufficient suitable sites can be found elsewhere in appropriate locations”. The consultation then states that the broad strategy is to “involve maximising allocations in areas outside of the Green Belt before considering sites within it; and then only where it can be shown to be necessary”. Given Chesterfield is surrounded by Green Belt, the Priority Locations and the spatial strategy are contrary.
3.19 The Council needs to recognise and accept that a Green Belt Review needs to occur and that the exceptional circumstances for releasing Green Belt is to meet housing needs in the most sustainable locations in accordance with the Priority Locations for development.
Settlement Hierarchy
3.20 The Settlement Hierarchy Study 2025 provides up to date information about settlements in North East Derbyshire District and the services and facilities they provide. One of the primary aims of establishing a settlement hierarchy is to promote sustainable communities by bringing housing, jobs and services closer together in an attempt to maintain and promote the viability of local facilities and reduce the need to travel to services and facilities elsewhere.
Sustainability Appraisal
3.21 It is welcomed that the Sustainability Appraisal has been published. However, the methodology and approach appears confused and it is unclear how the scoring, ranking and assessment has been applied.
3.22 For example, it is implied that Table 3.2 is summary of the Sustainability Appraisal for each site, however it portrays an inaccurate picture. Keyland’s site at Furnace Hillock Way, Hasland (Site 45065) is considered to have a negative score on transport. However, in the individual table it has a positive for buses and negative for railway station.
3.23 Nevertheless, the Sustainability Appraisal has not reflected the DfT connectivity tool which assesses the area to be extremely accessible and therefore the negative score is confusing.
3.24 The overall approach of the Sustainability Appraisal is confused and the methodology should be reviewed.
Proposed Approach
3.25 To address the comments, the following approach is proposed:
• Reflect national and regional policy ambitions.
• Set housing targets which are above the standard method baseline, and exceed for affordable housing and economic growth.
• Undertake a Green Belt Review that identifies grey belt.
• Amend approach to site identification that focusses on the most appropriate and sustainable locations first.
• Review the methodology and approach of the Sustainability Appraisal.
Site 45065 – Land around Furnace Hillock Way, Hasland
4.1 Keyland supports Site 45065 being short listed as a potential future housing allocation.
4.2 Keyland controls the site at Furnace Hillock Way, Hasland, which is available, suitable and achievable and therefore deliverable in accordance with national planning policy and guidance.
4.3 A Vision Report is attached to these representations, which explains the deliverability of the site.
4.4 Keyland considers the site can come forward in the short term and make a valuable contribution to the housing land supply.
Justification
4.1 Keyland considers that their Site at Furnace Hillock Way, Hasland should be allocated for housing use within the emerging Local Plan.
4.2 A Vision Report has been prepared and is attached at Appendix 1 to support the allocation of the site within the Local Plan. The Vision Report demonstrates that the site is available, suitable and achievable and therefore deliverable in accordance with the Framework and PPG. The Vision Report includes an illustrative masterplan and shows the vision for the site and how it could be delivered.
4.3 Keyland’s vision for the site is to create a logical extension to Chesterfield, creating a well-designed residential area that complements the existing community and enhances local character. The development of the site will support the Council’s and the East Midlands Region’s ambition to promote opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
4.4 Furnace Hillock Way, Hasland, presents an opportunity to make a significant contribution to the housing need in North East Derbyshire. The site creates an opportunity with Keyland’s Six Capitals philosophy to bring forward an exemplar residential scheme to meet a diverse range of occupiers and stakeholders.
4.5 The Six Capitals approach has therefore shaped the illustrative masterplan. As the starting point of the proposed scheme is different this leads to a different outcome. The development has been designed from the outset to meet the differing housing needs in the area. Furthermore, to meet the social, human and environmental ambitions a significant proportion of the site has been identified for a range of environmental, recreational and water management activities.
4.6 The site presents an opportunity to provide housing in a sustainable location. The site is contained on all sides, bounded by roads, residential development and a golf course.
4.7 Overall, this is a scheme that has strong potential to balance connectivity, sustainability, and community well-being. It will create a vibrant, healthy, and resilient place for people to live, work and thrive.
4.8 In response to the bulleted list in the consultation document relating to Site 45065 the Vision Report has been informed by technical assessments:
• Green Belt: Spawforths has undertaken a High Level Grey Belt Assessment which Assessment shows that against all five purposes of the Green Belt concludes that the site performs a WEAK/MODERATE role against the five purposes of the Green Belt. The site at Furnace Hillock Way, Hasland has the potential to be Grey Belt as it does not perform strongly against purposes (a), (b) and (d) and it does not contain any Footnote 7 matters. In addition the Assessment has shown to a high level that the boundary to the site is formed by recognisable features and is effectively contained, has urban influences on character with urban form on three sides and a golf course to the south. • Heritage: Adept has undertaken a Heritage Appraisal and there are no archaeological or heritage constraints to the scheme.
• Ecology and Trees: Brooks has undertaken a Preliminary Ecological Appraisal and BNG assessment and there are no ecological or arboricultural constraints to the scheme.
• Public Rights of Way and Green Space: the illustrative masterplan within the Vision Report demonstrates that the PROW’s and green spaces can be accommodated within the proposed scheme.
• Flood Risk and Drainage: OEC has undertaken a preliminary Flood Risk and Drainage Assessment and there are no flood risk or drainage constraints.
• Geo-Environmental: Lithos has undertaken a preliminary ground investigation and there are no geo-environmental constraints.
4.9 The technical reports and Vision Report demonstrate that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
Availability
4.10 Keyland has a legal agreement with the landowners to promote and develop the land for housing. Keyland is proud of their reputation for working with local and national builders to deliver high-quality desirable homes in sustainable locations. The site is currently available for residential development which can be brought forward early within the local plan period, representing a short term opportunity.
4.11 The land is therefore “available” in accordance with the Framework and the Planning Practice Guidance.
Suitability
4.12 Keyland believe that the site is suitable for residential development, with no constraints that cannot be appropriately mitigated or that would represent the site being unsuitable.
4.13 The proposed development can make an efficient and attractive use of the land. Although greenfield land, the site represents an excellent opportunity for future housing and development. This site would allow housing to be delivered within an appropriate and sustainable location at Hasland, Chesterfield. The development of this site would assist in creating a logical extension to the built up urban area.
4.14 The site occupies a highly sustainable location on the edge of Hasland, adjoining the existing built-up area and forming a logical extension to Chesterfield. It benefits from strong access to local services, education, and transport infrastructure, including proximity to Chesterfield and its wider employment opportunities.
4.15 Furnace Hillock Way provides direct connectivity through the site, linking key routes and supporting accessibility. The surrounding context, including residential areas, green spaces, and community facilities, reinforces its suitability for residential development.
4.1 While the site lies within the Green Belt, it is well contained and relates closely to the existing urban edge. It makes a limited contribution to Green Belt purposes and should be considered through the emerging Local Plan Review as a ‘grey belt’ opportunity.
4.2 Spawforths has undertaken a High Level Grey Belt Assessment (Appendix 2) and considers the site is capable of being ‘grey belt’. The site is bound by Chesterfield, B6039 Mansfield Road, B6038 Churchside, residential properties, a golf course, woodland, and tree belts. These existing conditions provide containment to the site, and provide significant urban influence on the character of the site. Partial enclosure leads to an assessment of weak to moderate contribution to the purposes of the Green Belt, and therefore presents a positive opportunity for residential growth as a grey belt site.
4.3 There is a clear need for new sites to come forward for housing to support the growth ambitions for the East Midlands region. The site provides an important opportunity to meet local housing needs. The proposed residential development would be developed to a high-quality design standard that respects the nature of the surrounding area. The development of the site for housing presents an ideal opportunity to address local housing needs by providing a diverse range of affordable and aspirational homes for families, older adults, and young professionals.
4.4 The site provides a unique opportunity that will benefit the area and wider district with economic, environmental and social benefits. The technical work that underpins the masterplan confirms that there are no known constraints to development. It is therefore considered that the proposed allocation of the site is suitable, in accordance with national guidance and PPG
4.5 The land is therefore “suitable” in accordance with the Framework and the Planning Practice Guidance.
Deliverability
4.6 Keyland consider that the Site can come forward immediately and be delivered within the Plan period. The Vision Report shows that there are no significant issues preventing the site coming forward.
4.7 The proposed development is located within close proximity to existing services and facilities. The indicative masterplan represents an efficient use of the land available. The scheme is therefore making an efficient and effective use of land and infrastructure.
4.8 The site provides a development opportunity that is available, suitable and achievable and therefore it is considered that the site is deliverable, in accordance with national planning policy and guidance. It is promoted by Keyland and is deliverable within the Plan period.
Achievable
4.9 A range of technical work has been undertaken and is ongoing. From these initial assessments there are no technical issues that would prevent the delivery of the site for residential purposes. The technical reports have informed the illustrative masterplan within the Vision Report and shows how a mix of housing can be accommodated within the site, alongside connectivity, landscaping and drainage features.
4.10 The Framework requires Local Planning Authorities to meet their full objectively assessed housing need. Keyland considers that the site is deliverable and will reinforce the housing supply and address the Council’s housing needs in the Local Plan period. Development of this site will support the delivery of a range of housing types and contribute towards meeting identified needs.
4.11 The Vision Report demonstrates that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
A Positive Response to the Key Objectives of the Framework
4.12 The Framework sets out that the Governments key housing policy goal of significantly boosting the supply of housing and proactively driving and supporting sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs. The Framework explains that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as extensions to towns, and creating mixed and sustainable communities with good access to jobs, key services and infrastructure. Sites should also make effective use of land and existing infrastructure.
4.13 In relation to the Framework:
• The proposal responds positively towards national guidance.
• The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.
• The proposed site is accessible to existing employment, local community facilities, infrastructure and services, including public transport.
• The site has been assessed as being is available, suitable and achievable for development.
Benefits of Site Reference ID45065 – Land at Furnace Hillock Way, Hasland
4.14 The development of the site would provide significant economic, social and environmental benefits. The site would provide housing that would meet the needs of the North East Derbyshire District Council’s housing market in a sustainable location.
4.15 In accordance with the Framework this representation has shown that:
• The site is suitable for housing and can deliver circa 850 new homes.
• The site can deliver a new local centre and school.
• The proposal can provide a good mix of housing commensurate to the demand and need in the area and diversify the housing stock
• The site is within a sustainable location situated in close proximity to facilities and services and also to bus stops for local bus routes.
• The scheme uses land efficiently and effectively.
• The proposal is in line with planning for housing objectives.
• The scheme will create direct and indirect job opportunities both during and after construction, plus employment opportunities with a local centre and school.
• The site can deliver new areas of public open space.
4.16 The proposal is an appropriate site to provide for the housing needs of North East Derbyshire and the wider East Midlands region during the local plan period. Confirmation of the allocation will contribute positively to a balanced housing supply in the area in sustainable locations. The site can deliver a full range and mix of housing as part of a sustainable community. Development of the site would deliver affordable housing. North East Derbyshire District Council needs to have a robust housing trajectory with a sufficient supply of deliverable sites. The site will assist with this delivery in the medium term. The site is situated within a prime location suitable for residential development and as such would facilitate the development of land in an effective and efficient manner. Development of the site would not harm or undermine the area’s wider policy objectives but seeks to reinforce the need to develop sites within sustainable locations as a priority.
4.17 The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.
Proposed Approach
4.18 To address the comments, the following approach is proposed:
• Allocate the site at Furnace Hillock Way, Hasland for housing purposes.

1.1 North East Derbyshire District Council (hereafter referred to as ‘the Council’) are reviewing the current local plan to ensure that it reflects changes to the district’s housing requirements along with new legislation and guidance introduced by the government. The Council is seeking to engage with key stakeholders, including individuals and organisations who have an interest in the district (in accordance with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012).
1.2 Spawforths have been instructed by Keyland Developments Ltd (Keyland) to submit representations to the North East Derbyshire District Council Local Plan Review Regulation 18 Consultation on the Strategic Approach to the Location of Development and Refined Sites.
1.3 Keyland have significant interest within North East Derbyshire, which can positively contribute to the housing and economic growth agenda, and therefore welcome the opportunity to engage with the Council in the preparation of an updated Local Plan. Keyland’s site is at Furnace Hillock Way, Hasland, Chesterfield (Site 45065):
1.4 Keyland would like to make comments on the following topics and sections of the North East Derbyshire District Local Plan Review:
• General Comments
• Strategic Approach
• Refined Schedule of Sites: Site 45065 – Land around Furnace Hillock Way, Hasland
1.5 In each case, observations are set out with reference to the provisions of the National Planning Policy Framework (hereafter referred to as “the Framework”) and where necessary, amendments are suggested to ensure that the Local Plan Update is found sound.
1.6 Keyland welcomes the opportunity for further engagement and the opportunity to appear at Examination in Public.
1.7 We trust that you will confirm that these representations are duly made and will give due consideration to these comments. Please do not hesitate to contact us to discuss any issues raised in this Representation further.
National Planning Policy context and Tests of Soundness
1.8 The Governments core objectives as established through the 2024 National Planning Policy Framework are sustainable development and growth. Paragraph 11 of the 2024 Framework stresses the need for Local Plans to meet, as a minimum, the objectively assessed needs of an area. The 2024 Framework sets out to boost significantly the supply of homes and ensure that a sufficient amount and variety of land can come forward where it is needed. The Local Housing Need identified through the standard method in the National Planning Practice Guidance should be met as a minimum. In terms of building a strong and competitive economy the 2024 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2024 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes and well-designed places.
1.9 In relation to Local Plan formulation, paragraphs 15 to 38 of the 2024 Framework state that Local Plans are the key to delivering sustainable development which reflect the vision and aspirations of the local community. The 2024 Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where. Paragraph 22 is clear that the Strategic policies should look ahead over a minimum period of 15 year period, andwhere larger scale development such as new settlements or significant extensions to existing villages and towns form part of the areas strategy, then policies should look ahead over a period of at least 30 years.
1.10 In relation to the examination of Local Plans, paragraph 36 of the 2024 Framework sets out the tests of soundness and establishes that:
Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
• Positively prepared – providing a strategy which as a minimum, seeks to meet the area’s objectively assessed need; and is informed by agreements with other authorities, so that unmet needs from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with policies in this Framework and other statements of national planning policy, where relevant.
1.11 The Local Planning Authority must demonstrate that the Local Plan Update complies with the legal and regulatory framework, including the legal requirements in ss19 and 24(1) of the Planning and Compulsory Purchase Act 2004 (PCPA 2004), Regulations under s.17 and any regulations under s. 36 relating to the preparation of DPD’s, and that the Local Plan Update is ‘Sound’, and that it complies with the Duty to Cooperate.
1.12 The PCPA 2004 requires the LPA to demonstrate that regard has been given to national policies and advice, development plan documents, and must undertake a sustainability appraisal. Plan making authorities are also required to have regard to the resources that are likely to be available for implementing the proposals1. As confirmed with legal judgements “resources” includes resources in the private sector “thus the viability and deliverability of the proposals are considerations to which the authority should have regard when preparing its policies” 2.
1.13 This document therefore considers the content of the consultation on behalf of Keyland in the light of this legal and planning policy context.
General Comments
2.1 Keyland consider that the Council needs to fully reflect the new 2024 Framework in relation to ambition and growth.
Justification
Housing and Economic Growth
2.2 Keyland welcomes a further opportunity to engage on the spatial strategy and locations for development.
2.3 The North East Derbyshire Local Plan was adopted in November 2021 and covered the period 2014-2034, which is now approaching 5 years ago. National planning policy and guidance has changed significantly in that time, with latest National Planning Policy Framework published in December 2024. This includes a refreshed approach to the standard methodology for calculating housing need.
2.4 The Framework establishes a more positive and pro-development policy framework to address the concern that the planning system is a major constraint to growth. The July 2024 Written Ministerial Statement (30th July 2024) confirms the Government’s position on restoring and raising housing targets; focussing new development into the ‘right places’ including within the Green Belt; moving towards strategic planning; building infrastructure to grow the economy; and supporting local planning.
2.5 The Framework is the immediate tool to unlock the planning system and reflects the new Labour Government’s aspirations for growth. Rachel Reeves gave a speech soon after the election to emphasise that “sustained growth is the only route to improving prosperity of our country”; that “nowhere is decisive reform needed more urgently than in our planning system”; and importantly “economic benefits of development will be a central consideration”.
2.6 Chapter 5 is all about ‘Delivering a sufficient supply of homes’ and the changes to the Framework reinforce and emphasise that local authorities should meet the identified housing need as a minimum and the baseline is the standard method. Para 62 of the NPPF states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” 2.7 Under the standard method for calculating housing need, North East Derbyshire District Council’s local housing need requirement is set at a minimum of 605 new homes per year.
2.8 The proposed changes to the NPPF were published for consultation on 16th December 2025. The Ministerial Statement that accompanied the proposed changes states that the overhaul of the NPPF is designed “to facilitate the delivery of high and sustainable rates of housebuilding” and to “boost the housing supply and unlock economic growth”. The proposed changes create a “permanent presumption in favour of sustainable development”, secure a diverse mix of homes and streamline local standards to speed up decision making. It is appreciated that the proposed changes are out for consultation, but they are a direction of travel contained in an accompanying Written Ministerial Statement.
2.9 Therefore, there is a need for the emerging Local Plan to address the updated national planning position and provide for the housing and employment needs for the area.
Plan period
2.10 Keyland welcomes the extension of the Plan period from the consultation undertaken in August 2025. The consultation material now suggests the emerging Local Plan will cover a Plan period from 2024-2044. The Framework is clear that all strategic policies should look ahead for a minimum of 15 years from the date of adoption. However, if there are large scale urban extensions / new towns then this should be over a 30 year period. Therefore, Keyland considers that there is potential for the Local Plan to cover a longer period and plan accordingly to drive economic and housing growth that the area needs.
Ambition
2.11 The Government’s ambition is to deliver sustained economic growth, improve prospective and enhance living standards. To deliver this ambition growth needs to be created throughout the country. The emerging Local Plan needs to reflect the Government’s ambition and recognise the housing crisis.
2.12 Furthermore, the Local Plan Update needs to reflect the ambitions both nationally, and for the sub-region. The East Midlands Vision for Growth (May 2025) sets out the region’s bold plan which will transform the region. Delivery of the vision will create 100,000 new jobs, deliver and add £4 billion to the East Midlands economy.
2.13 This vision sets out a clear direction for the region and establishes long-term objectives that will make the East Midlands an even greater place to live, work, and visit. The plan focuses on seven key locations where there are opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
2.14 This approach needs to be reflected and enshrined within the emerging Local Plan for North East Derbyshire.
Proposed Approach
2.15 To address the comments, the following approach is proposed:
• Reflect the new National Planning Policy Framework.
• With the economic ambitions and affordable housing need, the housing requirement should be set above the standard method Local Housing Need.
• Reflect the region’s ambitions and growth strategies.
Strategic Approach to the Location of Development
3.1 Keyland consider that the Council’s approach to the emerging Local Plan needs to reflect national policy and guidance and deliver the ambitions for housing and economic growth. The emerging Local Plan should not just be trying to achieve the minimum number of homes required.
3.2 The emerging Local Plan needs to address the big strategic issues of providing for new homes and businesses and supporting infrastructure.
Justification
Development Needs
3.3 The Vision needs to reflect national and regional policy ambitions. Nationally, the Government is seeking to deliver 1.5 million new homes and the housing crisis is a key policy issue to address over this parliamentary period. This flows through Written Ministerial Statements and the new Framework, which includes updated guidance and minimum housing targets, which the Vision should set out to achieve.
3.4 Furthermore, the Government seeks to increase economic growth, which is important to address prosperity and living standards, consistently highlighting that “sustained growth is the only route to improving prosperity of our country”.
3.5 Keyland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.6 Keyland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.7 The standard method calculates for North East Derbyshire that the housing need is 605 new homes per annum, or 12,100 over the 20 years of the Local Plan period. Furthermore, national policy and guidance states that Councils can choose to plan for more homes if they want to support things like economic growth or help meet housing needs in nearby areas.
3.8 The standard method represents a baseline for calculating housing need, and should not be seen as a ceiling for delivering housing. Whilst the standard method provides a minimum starting point for housing need, using household projections and affordability. It also fails to account for local economic growth, job creation, infrastructure changes, or specific demographic shifts.
3.9 Providing ambitious housing targets above the standard methodology also supports economic growth. This would match the East Midlands Vision for Growth (May 2025) which sets out the vision for transformative and ambitious growth within the region. Where significant employment growth is planned, housing supply must match job creation to avoid commuting issues and labour shortages.
3.10 At Examination, the Planning Inspectors may find the Loca Plan unsound if it fails adequately address all sources of housing need. A higher target for housing will demonstrate that the Local Plan is positively prepared, justified, and effective, which are key NPPF soundness tests.
3.11 The Local Plan should therefore establish a housing requirement above the standard method to reflect the economic ambitions for the area and affordable housing needs.
Spatial Distribution of Development
3.12 The location of development is a critical aspect of achieving sustainable development. As a general principal development should be located in areas that are accessible, sustainable, and benefit the local community.
3.13 The feedback from the August 2025 consultation shows the largest proportion of support (24%) was towards sites around the edge of Chesterfield. Keyland supports this approach. Chesterfield is the largest and most sustainable settlement in the area, which is surrounded by North East Derbyshire on three sides.
3.14 Furthermore, local government reorganisation is proceeding which is likely to merge Chesterfield with North East Derbyshire in the near future.
3.15 Therefore, through engagement and dialogue appropriate sustainable opportunities should be identified on the edge of Chesterfield, such as Keyland’s site at Furnace Hollock Way, Hasland (Site Ref 45065).
Proposed Approach to the Location of Development
3.16 Keyland support the proposed approach which identifies Priority Locations with Priority 1 including Edge of Chesterfield/Sheffield locations.
3.17 Keyland consider that this is an appropriate option in identifying land required to deliver sustainable growth within the district. Development around Chesterfield should be prioritised. Chesterfield is the most sustainable settlement in the area, which is surrounded by North East Derbyshire on three sides. Locating development on the edge of Chesterfield will ensure that new development has access to services, facilities, employment opportunities and access to public transport.
3.18 It is welcomed that higher positions in the spatial locations will be prioritised. However, it is slightly concerning that the consultation document states that “this does not override Green Belt or other desirable policy restrictions such as Local Settlement Gaps, provided that sufficient suitable sites can be found elsewhere in appropriate locations”. The consultation then states that the broad strategy is to “involve maximising allocations in areas outside of the Green Belt before considering sites within it; and then only where it can be shown to be necessary”. Given Chesterfield is surrounded by Green Belt, the Priority Locations and the spatial strategy are contrary.
3.19 The Council needs to recognise and accept that a Green Belt Review needs to occur and that the exceptional circumstances for releasing Green Belt is to meet housing needs in the most sustainable locations in accordance with the Priority Locations for development.
Settlement Hierarchy
3.20 The Settlement Hierarchy Study 2025 provides up to date information about settlements in North East Derbyshire District and the services and facilities they provide. One of the primary aims of establishing a settlement hierarchy is to promote sustainable communities by bringing housing, jobs and services closer together in an attempt to maintain and promote the viability of local facilities and reduce the need to travel to services and facilities elsewhere.
Sustainability Appraisal
3.21 It is welcomed that the Sustainability Appraisal has been published. However, the methodology and approach appears confused and it is unclear how the scoring, ranking and assessment has been applied.
3.22 For example, it is implied that Table 3.2 is summary of the Sustainability Appraisal for each site, however it portrays an inaccurate picture. Keyland’s site at Furnace Hillock Way, Hasland (Site 45065) is considered to have a negative score on transport. However, in the individual table it has a positive for buses and negative for railway station.
3.23 Nevertheless, the Sustainability Appraisal has not reflected the DfT connectivity tool which assesses the area to be extremely accessible and therefore the negative score is confusing.
3.24 The overall approach of the Sustainability Appraisal is confused and the methodology should be reviewed.
Proposed Approach
3.25 To address the comments, the following approach is proposed:
• Reflect national and regional policy ambitions.
• Set housing targets which are above the standard method baseline, and exceed for affordable housing and economic growth.
• Undertake a Green Belt Review that identifies grey belt.
• Amend approach to site identification that focusses on the most appropriate and sustainable locations first.
• Review the methodology and approach of the Sustainability Appraisal.
Site 45065 – Land around Furnace Hillock Way, Hasland
4.1 Keyland supports Site 45065 being short listed as a potential future housing allocation.
4.2 Keyland controls the site at Furnace Hillock Way, Hasland, which is available, suitable and achievable and therefore deliverable in accordance with national planning policy and guidance.
4.3 A Vision Report is attached to these representations, which explains the deliverability of the site.
4.4 Keyland considers the site can come forward in the short term and make a valuable contribution to the housing land supply.
Justification
4.1 Keyland considers that their Site at Furnace Hillock Way, Hasland should be allocated for housing use within the emerging Local Plan.
4.2 A Vision Report has been prepared and is attached at Appendix 1 to support the allocation of the site within the Local Plan. The Vision Report demonstrates that the site is available, suitable and achievable and therefore deliverable in accordance with the Framework and PPG. The Vision Report includes an illustrative masterplan and shows the vision for the site and how it could be delivered.
4.3 Keyland’s vision for the site is to create a logical extension to Chesterfield, creating a well-designed residential area that complements the existing community and enhances local character. The development of the site will support the Council’s and the East Midlands Region’s ambition to promote opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
4.4 Furnace Hillock Way, Hasland, presents an opportunity to make a significant contribution to the housing need in North East Derbyshire. The site creates an opportunity with Keyland’s Six Capitals philosophy to bring forward an exemplar residential scheme to meet a diverse range of occupiers and stakeholders.
4.5 The Six Capitals approach has therefore shaped the illustrative masterplan. As the starting point of the proposed scheme is different this leads to a different outcome. The development has been designed from the outset to meet the differing housing needs in the area. Furthermore, to meet the social, human and environmental ambitions a significant proportion of the site has been identified for a range of environmental, recreational and water management activities.
4.6 The site presents an opportunity to provide housing in a sustainable location. The site is contained on all sides, bounded by roads, residential development and a golf course.
4.7 Overall, this is a scheme that has strong potential to balance connectivity, sustainability, and community well-being. It will create a vibrant, healthy, and resilient place for people to live, work and thrive.
4.8 In response to the bulleted list in the consultation document relating to Site 45065 the Vision Report has been informed by technical assessments:
• Green Belt: Spawforths has undertaken a High Level Grey Belt Assessment which Assessment shows that against all five purposes of the Green Belt concludes that the site performs a WEAK/MODERATE role against the five purposes of the Green Belt. The site at Furnace Hillock Way, Hasland has the potential to be Grey Belt as it does not perform strongly against purposes (a), (b) and (d) and it does not contain any Footnote 7 matters. In addition the Assessment has shown to a high level that the boundary to the site is formed by recognisable features and is effectively contained, has urban influences on character with urban form on three sides and a golf course to the south. • Heritage: Adept has undertaken a Heritage Appraisal and there are no archaeological or heritage constraints to the scheme.
• Ecology and Trees: Brooks has undertaken a Preliminary Ecological Appraisal and BNG assessment and there are no ecological or arboricultural constraints to the scheme.
• Public Rights of Way and Green Space: the illustrative masterplan within the Vision Report demonstrates that the PROW’s and green spaces can be accommodated within the proposed scheme.
• Flood Risk and Drainage: OEC has undertaken a preliminary Flood Risk and Drainage Assessment and there are no flood risk or drainage constraints.
• Geo-Environmental: Lithos has undertaken a preliminary ground investigation and there are no geo-environmental constraints.
4.9 The technical reports and Vision Report demonstrate that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
Availability
4.10 Keyland has a legal agreement with the landowners to promote and develop the land for housing. Keyland is proud of their reputation for working with local and national builders to deliver high-quality desirable homes in sustainable locations. The site is currently available for residential development which can be brought forward early within the local plan period, representing a short term opportunity.
4.11 The land is therefore “available” in accordance with the Framework and the Planning Practice Guidance.
Suitability
4.12 Keyland believe that the site is suitable for residential development, with no constraints that cannot be appropriately mitigated or that would represent the site being unsuitable.
4.13 The proposed development can make an efficient and attractive use of the land. Although greenfield land, the site represents an excellent opportunity for future housing and development. This site would allow housing to be delivered within an appropriate and sustainable location at Hasland, Chesterfield. The development of this site would assist in creating a logical extension to the built up urban area.
4.14 The site occupies a highly sustainable location on the edge of Hasland, adjoining the existing built-up area and forming a logical extension to Chesterfield. It benefits from strong access to local services, education, and transport infrastructure, including proximity to Chesterfield and its wider employment opportunities.
4.15 Furnace Hillock Way provides direct connectivity through the site, linking key routes and supporting accessibility. The surrounding context, including residential areas, green spaces, and community facilities, reinforces its suitability for residential development.
4.1 While the site lies within the Green Belt, it is well contained and relates closely to the existing urban edge. It makes a limited contribution to Green Belt purposes and should be considered through the emerging Local Plan Review as a ‘grey belt’ opportunity.
4.2 Spawforths has undertaken a High Level Grey Belt Assessment (Appendix 2) and considers the site is capable of being ‘grey belt’. The site is bound by Chesterfield, B6039 Mansfield Road, B6038 Churchside, residential properties, a golf course, woodland, and tree belts. These existing conditions provide containment to the site, and provide significant urban influence on the character of the site. Partial enclosure leads to an assessment of weak to moderate contribution to the purposes of the Green Belt, and therefore presents a positive opportunity for residential growth as a grey belt site.
4.3 There is a clear need for new sites to come forward for housing to support the growth ambitions for the East Midlands region. The site provides an important opportunity to meet local housing needs. The proposed residential development would be developed to a high-quality design standard that respects the nature of the surrounding area. The development of the site for housing presents an ideal opportunity to address local housing needs by providing a diverse range of affordable and aspirational homes for families, older adults, and young professionals.
4.4 The site provides a unique opportunity that will benefit the area and wider district with economic, environmental and social benefits. The technical work that underpins the masterplan confirms that there are no known constraints to development. It is therefore considered that the proposed allocation of the site is suitable, in accordance with national guidance and PPG
4.5 The land is therefore “suitable” in accordance with the Framework and the Planning Practice Guidance.
Deliverability
4.6 Keyland consider that the Site can come forward immediately and be delivered within the Plan period. The Vision Report shows that there are no significant issues preventing the site coming forward.
4.7 The proposed development is located within close proximity to existing services and facilities. The indicative masterplan represents an efficient use of the land available. The scheme is therefore making an efficient and effective use of land and infrastructure.
4.8 The site provides a development opportunity that is available, suitable and achievable and therefore it is considered that the site is deliverable, in accordance with national planning policy and guidance. It is promoted by Keyland and is deliverable within the Plan period.
Achievable
4.9 A range of technical work has been undertaken and is ongoing. From these initial assessments there are no technical issues that would prevent the delivery of the site for residential purposes. The technical reports have informed the illustrative masterplan within the Vision Report and shows how a mix of housing can be accommodated within the site, alongside connectivity, landscaping and drainage features.
4.10 The Framework requires Local Planning Authorities to meet their full objectively assessed housing need. Keyland considers that the site is deliverable and will reinforce the housing supply and address the Council’s housing needs in the Local Plan period. Development of this site will support the delivery of a range of housing types and contribute towards meeting identified needs.
4.11 The Vision Report demonstrates that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
A Positive Response to the Key Objectives of the Framework
4.12 The Framework sets out that the Governments key housing policy goal of significantly boosting the supply of housing and proactively driving and supporting sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs. The Framework explains that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as extensions to towns, and creating mixed and sustainable communities with good access to jobs, key services and infrastructure. Sites should also make effective use of land and existing infrastructure.
4.13 In relation to the Framework:
• The proposal responds positively towards national guidance.
• The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.
• The proposed site is accessible to existing employment, local community facilities, infrastructure and services, including public transport.
• The site has been assessed as being is available, suitable and achievable for development.
Benefits of Site Reference ID45065 – Land at Furnace Hillock Way, Hasland
4.14 The development of the site would provide significant economic, social and environmental benefits. The site would provide housing that would meet the needs of the North East Derbyshire District Council’s housing market in a sustainable location.
4.15 In accordance with the Framework this representation has shown that:
• The site is suitable for housing and can deliver circa 850 new homes.
• The site can deliver a new local centre and school.
• The proposal can provide a good mix of housing commensurate to the demand and need in the area and diversify the housing stock
• The site is within a sustainable location situated in close proximity to facilities and services and also to bus stops for local bus routes.
• The scheme uses land efficiently and effectively.
• The proposal is in line with planning for housing objectives.
• The scheme will create direct and indirect job opportunities both during and after construction, plus employment opportunities with a local centre and school.
• The site can deliver new areas of public open space.
4.16 The proposal is an appropriate site to provide for the housing needs of North East Derbyshire and the wider East Midlands region during the local plan period. Confirmation of the allocation will contribute positively to a balanced housing supply in the area in sustainable locations. The site can deliver a full range and mix of housing as part of a sustainable community. Development of the site would deliver affordable housing. North East Derbyshire District Council needs to have a robust housing trajectory with a sufficient supply of deliverable sites. The site will assist with this delivery in the medium term. The site is situated within a prime location suitable for residential development and as such would facilitate the development of land in an effective and efficient manner. Development of the site would not harm or undermine the area’s wider policy objectives but seeks to reinforce the need to develop sites within sustainable locations as a priority.
4.17 The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.
Proposed Approach
4.18 To address the comments, the following approach is proposed:
• Allocate the site at Furnace Hillock Way, Hasland for housing purposes.

1.1 North East Derbyshire District Council (hereafter referred to as ‘the Council’) are reviewing the current local plan to ensure that it reflects changes to the district’s housing requirements along with new legislation and guidance introduced by the government. The Council is seeking to engage with key stakeholders, including individuals and organisations who have an interest in the district (in accordance with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012).
1.2 Spawforths have been instructed by Keyland Developments Ltd (Keyland) to submit representations to the North East Derbyshire District Council Local Plan Review Regulation 18 Consultation on the Strategic Approach to the Location of Development and Refined Sites.
1.3 Keyland have significant interest within North East Derbyshire, which can positively contribute to the housing and economic growth agenda, and therefore welcome the opportunity to engage with the Council in the preparation of an updated Local Plan. Keyland’s site is at Furnace Hillock Way, Hasland, Chesterfield (Site 45065):
1.4 Keyland would like to make comments on the following topics and sections of the North East Derbyshire District Local Plan Review:
• General Comments
• Strategic Approach
• Refined Schedule of Sites: Site 45065 – Land around Furnace Hillock Way, Hasland
1.5 In each case, observations are set out with reference to the provisions of the National Planning Policy Framework (hereafter referred to as “the Framework”) and where necessary, amendments are suggested to ensure that the Local Plan Update is found sound.
1.6 Keyland welcomes the opportunity for further engagement and the opportunity to appear at Examination in Public.
1.7 We trust that you will confirm that these representations are duly made and will give due consideration to these comments. Please do not hesitate to contact us to discuss any issues raised in this Representation further.
National Planning Policy context and Tests of Soundness
1.8 The Governments core objectives as established through the 2024 National Planning Policy Framework are sustainable development and growth. Paragraph 11 of the 2024 Framework stresses the need for Local Plans to meet, as a minimum, the objectively assessed needs of an area. The 2024 Framework sets out to boost significantly the supply of homes and ensure that a sufficient amount and variety of land can come forward where it is needed. The Local Housing Need identified through the standard method in the National Planning Practice Guidance should be met as a minimum. In terms of building a strong and competitive economy the 2024 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2024 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes and well-designed places.
1.9 In relation to Local Plan formulation, paragraphs 15 to 38 of the 2024 Framework state that Local Plans are the key to delivering sustainable development which reflect the vision and aspirations of the local community. The 2024 Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where. Paragraph 22 is clear that the Strategic policies should look ahead over a minimum period of 15 year period, andwhere larger scale development such as new settlements or significant extensions to existing villages and towns form part of the areas strategy, then policies should look ahead over a period of at least 30 years.
1.10 In relation to the examination of Local Plans, paragraph 36 of the 2024 Framework sets out the tests of soundness and establishes that:
Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
• Positively prepared – providing a strategy which as a minimum, seeks to meet the area’s objectively assessed need; and is informed by agreements with other authorities, so that unmet needs from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with policies in this Framework and other statements of national planning policy, where relevant.
1.11 The Local Planning Authority must demonstrate that the Local Plan Update complies with the legal and regulatory framework, including the legal requirements in ss19 and 24(1) of the Planning and Compulsory Purchase Act 2004 (PCPA 2004), Regulations under s.17 and any regulations under s. 36 relating to the preparation of DPD’s, and that the Local Plan Update is ‘Sound’, and that it complies with the Duty to Cooperate.
1.12 The PCPA 2004 requires the LPA to demonstrate that regard has been given to national policies and advice, development plan documents, and must undertake a sustainability appraisal. Plan making authorities are also required to have regard to the resources that are likely to be available for implementing the proposals1. As confirmed with legal judgements “resources” includes resources in the private sector “thus the viability and deliverability of the proposals are considerations to which the authority should have regard when preparing its policies” 2.
1.13 This document therefore considers the content of the consultation on behalf of Keyland in the light of this legal and planning policy context.
General Comments
2.1 Keyland consider that the Council needs to fully reflect the new 2024 Framework in relation to ambition and growth.
Justification
Housing and Economic Growth
2.2 Keyland welcomes a further opportunity to engage on the spatial strategy and locations for development.
2.3 The North East Derbyshire Local Plan was adopted in November 2021 and covered the period 2014-2034, which is now approaching 5 years ago. National planning policy and guidance has changed significantly in that time, with latest National Planning Policy Framework published in December 2024. This includes a refreshed approach to the standard methodology for calculating housing need.
2.4 The Framework establishes a more positive and pro-development policy framework to address the concern that the planning system is a major constraint to growth. The July 2024 Written Ministerial Statement (30th July 2024) confirms the Government’s position on restoring and raising housing targets; focussing new development into the ‘right places’ including within the Green Belt; moving towards strategic planning; building infrastructure to grow the economy; and supporting local planning.
2.5 The Framework is the immediate tool to unlock the planning system and reflects the new Labour Government’s aspirations for growth. Rachel Reeves gave a speech soon after the election to emphasise that “sustained growth is the only route to improving prosperity of our country”; that “nowhere is decisive reform needed more urgently than in our planning system”; and importantly “economic benefits of development will be a central consideration”.
2.6 Chapter 5 is all about ‘Delivering a sufficient supply of homes’ and the changes to the Framework reinforce and emphasise that local authorities should meet the identified housing need as a minimum and the baseline is the standard method. Para 62 of the NPPF states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” 2.7 Under the standard method for calculating housing need, North East Derbyshire District Council’s local housing need requirement is set at a minimum of 605 new homes per year.
2.8 The proposed changes to the NPPF were published for consultation on 16th December 2025. The Ministerial Statement that accompanied the proposed changes states that the overhaul of the NPPF is designed “to facilitate the delivery of high and sustainable rates of housebuilding” and to “boost the housing supply and unlock economic growth”. The proposed changes create a “permanent presumption in favour of sustainable development”, secure a diverse mix of homes and streamline local standards to speed up decision making. It is appreciated that the proposed changes are out for consultation, but they are a direction of travel contained in an accompanying Written Ministerial Statement.
2.9 Therefore, there is a need for the emerging Local Plan to address the updated national planning position and provide for the housing and employment needs for the area.
Plan period
2.10 Keyland welcomes the extension of the Plan period from the consultation undertaken in August 2025. The consultation material now suggests the emerging Local Plan will cover a Plan period from 2024-2044. The Framework is clear that all strategic policies should look ahead for a minimum of 15 years from the date of adoption. However, if there are large scale urban extensions / new towns then this should be over a 30 year period. Therefore, Keyland considers that there is potential for the Local Plan to cover a longer period and plan accordingly to drive economic and housing growth that the area needs.
Ambition
2.11 The Government’s ambition is to deliver sustained economic growth, improve prospective and enhance living standards. To deliver this ambition growth needs to be created throughout the country. The emerging Local Plan needs to reflect the Government’s ambition and recognise the housing crisis.
2.12 Furthermore, the Local Plan Update needs to reflect the ambitions both nationally, and for the sub-region. The East Midlands Vision for Growth (May 2025) sets out the region’s bold plan which will transform the region. Delivery of the vision will create 100,000 new jobs, deliver and add £4 billion to the East Midlands economy.
2.13 This vision sets out a clear direction for the region and establishes long-term objectives that will make the East Midlands an even greater place to live, work, and visit. The plan focuses on seven key locations where there are opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
2.14 This approach needs to be reflected and enshrined within the emerging Local Plan for North East Derbyshire.
Proposed Approach
2.15 To address the comments, the following approach is proposed:
• Reflect the new National Planning Policy Framework.
• With the economic ambitions and affordable housing need, the housing requirement should be set above the standard method Local Housing Need.
• Reflect the region’s ambitions and growth strategies.
Strategic Approach to the Location of Development
3.1 Keyland consider that the Council’s approach to the emerging Local Plan needs to reflect national policy and guidance and deliver the ambitions for housing and economic growth. The emerging Local Plan should not just be trying to achieve the minimum number of homes required.
3.2 The emerging Local Plan needs to address the big strategic issues of providing for new homes and businesses and supporting infrastructure.
Justification
Development Needs
3.3 The Vision needs to reflect national and regional policy ambitions. Nationally, the Government is seeking to deliver 1.5 million new homes and the housing crisis is a key policy issue to address over this parliamentary period. This flows through Written Ministerial Statements and the new Framework, which includes updated guidance and minimum housing targets, which the Vision should set out to achieve.
3.4 Furthermore, the Government seeks to increase economic growth, which is important to address prosperity and living standards, consistently highlighting that “sustained growth is the only route to improving prosperity of our country”.
3.5 Keyland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.6 Keyland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.7 The standard method calculates for North East Derbyshire that the housing need is 605 new homes per annum, or 12,100 over the 20 years of the Local Plan period. Furthermore, national policy and guidance states that Councils can choose to plan for more homes if they want to support things like economic growth or help meet housing needs in nearby areas.
3.8 The standard method represents a baseline for calculating housing need, and should not be seen as a ceiling for delivering housing. Whilst the standard method provides a minimum starting point for housing need, using household projections and affordability. It also fails to account for local economic growth, job creation, infrastructure changes, or specific demographic shifts.
3.9 Providing ambitious housing targets above the standard methodology also supports economic growth. This would match the East Midlands Vision for Growth (May 2025) which sets out the vision for transformative and ambitious growth within the region. Where significant employment growth is planned, housing supply must match job creation to avoid commuting issues and labour shortages.
3.10 At Examination, the Planning Inspectors may find the Loca Plan unsound if it fails adequately address all sources of housing need. A higher target for housing will demonstrate that the Local Plan is positively prepared, justified, and effective, which are key NPPF soundness tests.
3.11 The Local Plan should therefore establish a housing requirement above the standard method to reflect the economic ambitions for the area and affordable housing needs.
Spatial Distribution of Development
3.12 The location of development is a critical aspect of achieving sustainable development. As a general principal development should be located in areas that are accessible, sustainable, and benefit the local community.
3.13 The feedback from the August 2025 consultation shows the largest proportion of support (24%) was towards sites around the edge of Chesterfield. Keyland supports this approach. Chesterfield is the largest and most sustainable settlement in the area, which is surrounded by North East Derbyshire on three sides.
3.14 Furthermore, local government reorganisation is proceeding which is likely to merge Chesterfield with North East Derbyshire in the near future.
3.15 Therefore, through engagement and dialogue appropriate sustainable opportunities should be identified on the edge of Chesterfield, such as Keyland’s site at Furnace Hollock Way, Hasland (Site Ref 45065).
Proposed Approach to the Location of Development
3.16 Keyland support the proposed approach which identifies Priority Locations with Priority 1 including Edge of Chesterfield/Sheffield locations.
3.17 Keyland consider that this is an appropriate option in identifying land required to deliver sustainable growth within the district. Development around Chesterfield should be prioritised. Chesterfield is the most sustainable settlement in the area, which is surrounded by North East Derbyshire on three sides. Locating development on the edge of Chesterfield will ensure that new development has access to services, facilities, employment opportunities and access to public transport.
3.18 It is welcomed that higher positions in the spatial locations will be prioritised. However, it is slightly concerning that the consultation document states that “this does not override Green Belt or other desirable policy restrictions such as Local Settlement Gaps, provided that sufficient suitable sites can be found elsewhere in appropriate locations”. The consultation then states that the broad strategy is to “involve maximising allocations in areas outside of the Green Belt before considering sites within it; and then only where it can be shown to be necessary”. Given Chesterfield is surrounded by Green Belt, the Priority Locations and the spatial strategy are contrary.
3.19 The Council needs to recognise and accept that a Green Belt Review needs to occur and that the exceptional circumstances for releasing Green Belt is to meet housing needs in the most sustainable locations in accordance with the Priority Locations for development.
Settlement Hierarchy
3.20 The Settlement Hierarchy Study 2025 provides up to date information about settlements in North East Derbyshire District and the services and facilities they provide. One of the primary aims of establishing a settlement hierarchy is to promote sustainable communities by bringing housing, jobs and services closer together in an attempt to maintain and promote the viability of local facilities and reduce the need to travel to services and facilities elsewhere.
Sustainability Appraisal
3.21 It is welcomed that the Sustainability Appraisal has been published. However, the methodology and approach appears confused and it is unclear how the scoring, ranking and assessment has been applied.
3.22 For example, it is implied that Table 3.2 is summary of the Sustainability Appraisal for each site, however it portrays an inaccurate picture. Keyland’s site at Furnace Hillock Way, Hasland (Site 45065) is considered to have a negative score on transport. However, in the individual table it has a positive for buses and negative for railway station.
3.23 Nevertheless, the Sustainability Appraisal has not reflected the DfT connectivity tool which assesses the area to be extremely accessible and therefore the negative score is confusing.
3.24 The overall approach of the Sustainability Appraisal is confused and the methodology should be reviewed.
Proposed Approach
3.25 To address the comments, the following approach is proposed:
• Reflect national and regional policy ambitions.
• Set housing targets which are above the standard method baseline, and exceed for affordable housing and economic growth.
• Undertake a Green Belt Review that identifies grey belt.
• Amend approach to site identification that focusses on the most appropriate and sustainable locations first.
• Review the methodology and approach of the Sustainability Appraisal.
Site 45065 – Land around Furnace Hillock Way, Hasland
4.1 Keyland supports Site 45065 being short listed as a potential future housing allocation.
4.2 Keyland controls the site at Furnace Hillock Way, Hasland, which is available, suitable and achievable and therefore deliverable in accordance with national planning policy and guidance.
4.3 A Vision Report is attached to these representations, which explains the deliverability of the site.
4.4 Keyland considers the site can come forward in the short term and make a valuable contribution to the housing land supply.
Justification
4.1 Keyland considers that their Site at Furnace Hillock Way, Hasland should be allocated for housing use within the emerging Local Plan.
4.2 A Vision Report has been prepared and is attached at Appendix 1 to support the allocation of the site within the Local Plan. The Vision Report demonstrates that the site is available, suitable and achievable and therefore deliverable in accordance with the Framework and PPG. The Vision Report includes an illustrative masterplan and shows the vision for the site and how it could be delivered.
4.3 Keyland’s vision for the site is to create a logical extension to Chesterfield, creating a well-designed residential area that complements the existing community and enhances local character. The development of the site will support the Council’s and the East Midlands Region’s ambition to promote opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
4.4 Furnace Hillock Way, Hasland, presents an opportunity to make a significant contribution to the housing need in North East Derbyshire. The site creates an opportunity with Keyland’s Six Capitals philosophy to bring forward an exemplar residential scheme to meet a diverse range of occupiers and stakeholders.
4.5 The Six Capitals approach has therefore shaped the illustrative masterplan. As the starting point of the proposed scheme is different this leads to a different outcome. The development has been designed from the outset to meet the differing housing needs in the area. Furthermore, to meet the social, human and environmental ambitions a significant proportion of the site has been identified for a range of environmental, recreational and water management activities.
4.6 The site presents an opportunity to provide housing in a sustainable location. The site is contained on all sides, bounded by roads, residential development and a golf course.
4.7 Overall, this is a scheme that has strong potential to balance connectivity, sustainability, and community well-being. It will create a vibrant, healthy, and resilient place for people to live, work and thrive.
4.8 In response to the bulleted list in the consultation document relating to Site 45065 the Vision Report has been informed by technical assessments:
• Green Belt: Spawforths has undertaken a High Level Grey Belt Assessment which Assessment shows that against all five purposes of the Green Belt concludes that the site performs a WEAK/MODERATE role against the five purposes of the Green Belt. The site at Furnace Hillock Way, Hasland has the potential to be Grey Belt as it does not perform strongly against purposes (a), (b) and (d) and it does not contain any Footnote 7 matters. In addition the Assessment has shown to a high level that the boundary to the site is formed by recognisable features and is effectively contained, has urban influences on character with urban form on three sides and a golf course to the south. • Heritage: Adept has undertaken a Heritage Appraisal and there are no archaeological or heritage constraints to the scheme.
• Ecology and Trees: Brooks has undertaken a Preliminary Ecological Appraisal and BNG assessment and there are no ecological or arboricultural constraints to the scheme.
• Public Rights of Way and Green Space: the illustrative masterplan within the Vision Report demonstrates that the PROW’s and green spaces can be accommodated within the proposed scheme.
• Flood Risk and Drainage: OEC has undertaken a preliminary Flood Risk and Drainage Assessment and there are no flood risk or drainage constraints.
• Geo-Environmental: Lithos has undertaken a preliminary ground investigation and there are no geo-environmental constraints.
4.9 The technical reports and Vision Report demonstrate that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
Availability
4.10 Keyland has a legal agreement with the landowners to promote and develop the land for housing. Keyland is proud of their reputation for working with local and national builders to deliver high-quality desirable homes in sustainable locations. The site is currently available for residential development which can be brought forward early within the local plan period, representing a short term opportunity.
4.11 The land is therefore “available” in accordance with the Framework and the Planning Practice Guidance.
Suitability
4.12 Keyland believe that the site is suitable for residential development, with no constraints that cannot be appropriately mitigated or that would represent the site being unsuitable.
4.13 The proposed development can make an efficient and attractive use of the land. Although greenfield land, the site represents an excellent opportunity for future housing and development. This site would allow housing to be delivered within an appropriate and sustainable location at Hasland, Chesterfield. The development of this site would assist in creating a logical extension to the built up urban area.
4.14 The site occupies a highly sustainable location on the edge of Hasland, adjoining the existing built-up area and forming a logical extension to Chesterfield. It benefits from strong access to local services, education, and transport infrastructure, including proximity to Chesterfield and its wider employment opportunities.
4.15 Furnace Hillock Way provides direct connectivity through the site, linking key routes and supporting accessibility. The surrounding context, including residential areas, green spaces, and community facilities, reinforces its suitability for residential development.
4.1 While the site lies within the Green Belt, it is well contained and relates closely to the existing urban edge. It makes a limited contribution to Green Belt purposes and should be considered through the emerging Local Plan Review as a ‘grey belt’ opportunity.
4.2 Spawforths has undertaken a High Level Grey Belt Assessment (Appendix 2) and considers the site is capable of being ‘grey belt’. The site is bound by Chesterfield, B6039 Mansfield Road, B6038 Churchside, residential properties, a golf course, woodland, and tree belts. These existing conditions provide containment to the site, and provide significant urban influence on the character of the site. Partial enclosure leads to an assessment of weak to moderate contribution to the purposes of the Green Belt, and therefore presents a positive opportunity for residential growth as a grey belt site.
4.3 There is a clear need for new sites to come forward for housing to support the growth ambitions for the East Midlands region. The site provides an important opportunity to meet local housing needs. The proposed residential development would be developed to a high-quality design standard that respects the nature of the surrounding area. The development of the site for housing presents an ideal opportunity to address local housing needs by providing a diverse range of affordable and aspirational homes for families, older adults, and young professionals.
4.4 The site provides a unique opportunity that will benefit the area and wider district with economic, environmental and social benefits. The technical work that underpins the masterplan confirms that there are no known constraints to development. It is therefore considered that the proposed allocation of the site is suitable, in accordance with national guidance and PPG
4.5 The land is therefore “suitable” in accordance with the Framework and the Planning Practice Guidance.
Deliverability
4.6 Keyland consider that the Site can come forward immediately and be delivered within the Plan period. The Vision Report shows that there are no significant issues preventing the site coming forward.
4.7 The proposed development is located within close proximity to existing services and facilities. The indicative masterplan represents an efficient use of the land available. The scheme is therefore making an efficient and effective use of land and infrastructure.
4.8 The site provides a development opportunity that is available, suitable and achievable and therefore it is considered that the site is deliverable, in accordance with national planning policy and guidance. It is promoted by Keyland and is deliverable within the Plan period.
Achievable
4.9 A range of technical work has been undertaken and is ongoing. From these initial assessments there are no technical issues that would prevent the delivery of the site for residential purposes. The technical reports have informed the illustrative masterplan within the Vision Report and shows how a mix of housing can be accommodated within the site, alongside connectivity, landscaping and drainage features.
4.10 The Framework requires Local Planning Authorities to meet their full objectively assessed housing need. Keyland considers that the site is deliverable and will reinforce the housing supply and address the Council’s housing needs in the Local Plan period. Development of this site will support the delivery of a range of housing types and contribute towards meeting identified needs.
4.11 The Vision Report demonstrates that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
A Positive Response to the Key Objectives of the Framework
4.12 The Framework sets out that the Governments key housing policy goal of significantly boosting the supply of housing and proactively driving and supporting sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs. The Framework explains that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as extensions to towns, and creating mixed and sustainable communities with good access to jobs, key services and infrastructure. Sites should also make effective use of land and existing infrastructure.
4.13 In relation to the Framework:
• The proposal responds positively towards national guidance.
• The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.
• The proposed site is accessible to existing employment, local community facilities, infrastructure and services, including public transport.
• The site has been assessed as being is available, suitable and achievable for development.
Benefits of Site Reference ID45065 – Land at Furnace Hillock Way, Hasland
4.14 The development of the site would provide significant economic, social and environmental benefits. The site would provide housing that would meet the needs of the North East Derbyshire District Council’s housing market in a sustainable location.
4.15 In accordance with the Framework this representation has shown that:
• The site is suitable for housing and can deliver circa 850 new homes.
• The site can deliver a new local centre and school.
• The proposal can provide a good mix of housing commensurate to the demand and need in the area and diversify the housing stock
• The site is within a sustainable location situated in close proximity to facilities and services and also to bus stops for local bus routes.
• The scheme uses land efficiently and effectively.
• The proposal is in line with planning for housing objectives.
• The scheme will create direct and indirect job opportunities both during and after construction, plus employment opportunities with a local centre and school.
• The site can deliver new areas of public open space.
4.16 The proposal is an appropriate site to provide for the housing needs of North East Derbyshire and the wider East Midlands region during the local plan period. Confirmation of the allocation will contribute positively to a balanced housing supply in the area in sustainable locations. The site can deliver a full range and mix of housing as part of a sustainable community. Development of the site would deliver affordable housing. North East Derbyshire District Council needs to have a robust housing trajectory with a sufficient supply of deliverable sites. The site will assist with this delivery in the medium term. The site is situated within a prime location suitable for residential development and as such would facilitate the development of land in an effective and efficient manner. Development of the site would not harm or undermine the area’s wider policy objectives but seeks to reinforce the need to develop sites within sustainable locations as a priority.
4.17 The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.
Proposed Approach
4.18 To address the comments, the following approach is proposed:
• Allocate the site at Furnace Hillock Way, Hasland for housing purposes.

1.1 North East Derbyshire District Council (hereafter referred to as ‘the Council’) are reviewing the current local plan to ensure that it reflects changes to the district’s housing requirements along with new legislation and guidance introduced by the government. The Council is seeking to engage with key stakeholders, including individuals and organisations who have an interest in the district (in accordance with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012).
1.2 Spawforths have been instructed by Keyland Developments Ltd (Keyland) to submit representations to the North East Derbyshire District Council Local Plan Review Regulation 18 Consultation on the Strategic Approach to the Location of Development and Refined Sites.
1.3 Keyland have significant interest within North East Derbyshire, which can positively contribute to the housing and economic growth agenda, and therefore welcome the opportunity to engage with the Council in the preparation of an updated Local Plan. Keyland’s site is at Furnace Hillock Way, Hasland, Chesterfield (Site 45065):
1.4 Keyland would like to make comments on the following topics and sections of the North East Derbyshire District Local Plan Review:
• General Comments
• Strategic Approach
• Refined Schedule of Sites: Site 45065 – Land around Furnace Hillock Way, Hasland
1.5 In each case, observations are set out with reference to the provisions of the National Planning Policy Framework (hereafter referred to as “the Framework”) and where necessary, amendments are suggested to ensure that the Local Plan Update is found sound.
1.6 Keyland welcomes the opportunity for further engagement and the opportunity to appear at Examination in Public.
1.7 We trust that you will confirm that these representations are duly made and will give due consideration to these comments. Please do not hesitate to contact us to discuss any issues raised in this Representation further.
National Planning Policy context and Tests of Soundness
1.8 The Governments core objectives as established through the 2024 National Planning Policy Framework are sustainable development and growth. Paragraph 11 of the 2024 Framework stresses the need for Local Plans to meet, as a minimum, the objectively assessed needs of an area. The 2024 Framework sets out to boost significantly the supply of homes and ensure that a sufficient amount and variety of land can come forward where it is needed. The Local Housing Need identified through the standard method in the National Planning Practice Guidance should be met as a minimum. In terms of building a strong and competitive economy the 2024 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2024 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes and well-designed places.
1.9 In relation to Local Plan formulation, paragraphs 15 to 38 of the 2024 Framework state that Local Plans are the key to delivering sustainable development which reflect the vision and aspirations of the local community. The 2024 Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where. Paragraph 22 is clear that the Strategic policies should look ahead over a minimum period of 15 year period, andwhere larger scale development such as new settlements or significant extensions to existing villages and towns form part of the areas strategy, then policies should look ahead over a period of at least 30 years.
1.10 In relation to the examination of Local Plans, paragraph 36 of the 2024 Framework sets out the tests of soundness and establishes that:
Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
• Positively prepared – providing a strategy which as a minimum, seeks to meet the area’s objectively assessed need; and is informed by agreements with other authorities, so that unmet needs from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with policies in this Framework and other statements of national planning policy, where relevant.
1.11 The Local Planning Authority must demonstrate that the Local Plan Update complies with the legal and regulatory framework, including the legal requirements in ss19 and 24(1) of the Planning and Compulsory Purchase Act 2004 (PCPA 2004), Regulations under s.17 and any regulations under s. 36 relating to the preparation of DPD’s, and that the Local Plan Update is ‘Sound’, and that it complies with the Duty to Cooperate.
1.12 The PCPA 2004 requires the LPA to demonstrate that regard has been given to national policies and advice, development plan documents, and must undertake a sustainability appraisal. Plan making authorities are also required to have regard to the resources that are likely to be available for implementing the proposals1. As confirmed with legal judgements “resources” includes resources in the private sector “thus the viability and deliverability of the proposals are considerations to which the authority should have regard when preparing its policies” 2.
1.13 This document therefore considers the content of the consultation on behalf of Keyland in the light of this legal and planning policy context.
General Comments
2.1 Keyland consider that the Council needs to fully reflect the new 2024 Framework in relation to ambition and growth.
Justification
Housing and Economic Growth
2.2 Keyland welcomes a further opportunity to engage on the spatial strategy and locations for development.
2.3 The North East Derbyshire Local Plan was adopted in November 2021 and covered the period 2014-2034, which is now approaching 5 years ago. National planning policy and guidance has changed significantly in that time, with latest National Planning Policy Framework published in December 2024. This includes a refreshed approach to the standard methodology for calculating housing need.
2.4 The Framework establishes a more positive and pro-development policy framework to address the concern that the planning system is a major constraint to growth. The July 2024 Written Ministerial Statement (30th July 2024) confirms the Government’s position on restoring and raising housing targets; focussing new development into the ‘right places’ including within the Green Belt; moving towards strategic planning; building infrastructure to grow the economy; and supporting local planning.
2.5 The Framework is the immediate tool to unlock the planning system and reflects the new Labour Government’s aspirations for growth. Rachel Reeves gave a speech soon after the election to emphasise that “sustained growth is the only route to improving prosperity of our country”; that “nowhere is decisive reform needed more urgently than in our planning system”; and importantly “economic benefits of development will be a central consideration”.
2.6 Chapter 5 is all about ‘Delivering a sufficient supply of homes’ and the changes to the Framework reinforce and emphasise that local authorities should meet the identified housing need as a minimum and the baseline is the standard method. Para 62 of the NPPF states that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” 2.7 Under the standard method for calculating housing need, North East Derbyshire District Council’s local housing need requirement is set at a minimum of 605 new homes per year.
2.8 The proposed changes to the NPPF were published for consultation on 16th December 2025. The Ministerial Statement that accompanied the proposed changes states that the overhaul of the NPPF is designed “to facilitate the delivery of high and sustainable rates of housebuilding” and to “boost the housing supply and unlock economic growth”. The proposed changes create a “permanent presumption in favour of sustainable development”, secure a diverse mix of homes and streamline local standards to speed up decision making. It is appreciated that the proposed changes are out for consultation, but they are a direction of travel contained in an accompanying Written Ministerial Statement.
2.9 Therefore, there is a need for the emerging Local Plan to address the updated national planning position and provide for the housing and employment needs for the area.
Plan period
2.10 Keyland welcomes the extension of the Plan period from the consultation undertaken in August 2025. The consultation material now suggests the emerging Local Plan will cover a Plan period from 2024-2044. The Framework is clear that all strategic policies should look ahead for a minimum of 15 years from the date of adoption. However, if there are large scale urban extensions / new towns then this should be over a 30 year period. Therefore, Keyland considers that there is potential for the Local Plan to cover a longer period and plan accordingly to drive economic and housing growth that the area needs.
Ambition
2.11 The Government’s ambition is to deliver sustained economic growth, improve prospective and enhance living standards. To deliver this ambition growth needs to be created throughout the country. The emerging Local Plan needs to reflect the Government’s ambition and recognise the housing crisis.
2.12 Furthermore, the Local Plan Update needs to reflect the ambitions both nationally, and for the sub-region. The East Midlands Vision for Growth (May 2025) sets out the region’s bold plan which will transform the region. Delivery of the vision will create 100,000 new jobs, deliver and add £4 billion to the East Midlands economy.
2.13 This vision sets out a clear direction for the region and establishes long-term objectives that will make the East Midlands an even greater place to live, work, and visit. The plan focuses on seven key locations where there are opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
2.14 This approach needs to be reflected and enshrined within the emerging Local Plan for North East Derbyshire.
Proposed Approach
2.15 To address the comments, the following approach is proposed:
• Reflect the new National Planning Policy Framework.
• With the economic ambitions and affordable housing need, the housing requirement should be set above the standard method Local Housing Need.
• Reflect the region’s ambitions and growth strategies.
Strategic Approach to the Location of Development
3.1 Keyland consider that the Council’s approach to the emerging Local Plan needs to reflect national policy and guidance and deliver the ambitions for housing and economic growth. The emerging Local Plan should not just be trying to achieve the minimum number of homes required.
3.2 The emerging Local Plan needs to address the big strategic issues of providing for new homes and businesses and supporting infrastructure.
Justification
Development Needs
3.3 The Vision needs to reflect national and regional policy ambitions. Nationally, the Government is seeking to deliver 1.5 million new homes and the housing crisis is a key policy issue to address over this parliamentary period. This flows through Written Ministerial Statements and the new Framework, which includes updated guidance and minimum housing targets, which the Vision should set out to achieve.
3.4 Furthermore, the Government seeks to increase economic growth, which is important to address prosperity and living standards, consistently highlighting that “sustained growth is the only route to improving prosperity of our country”.
3.5 Keyland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.6 Keyland considers that the Local Plan review must ensure that housing delivery targets are suitably ambitious and above the standard method. Housing requirement is different to housing need and should also cater for economic growth. The standard method introduced by the NPPF should only be a minimum requirement.
3.7 The standard method calculates for North East Derbyshire that the housing need is 605 new homes per annum, or 12,100 over the 20 years of the Local Plan period. Furthermore, national policy and guidance states that Councils can choose to plan for more homes if they want to support things like economic growth or help meet housing needs in nearby areas.
3.8 The standard method represents a baseline for calculating housing need, and should not be seen as a ceiling for delivering housing. Whilst the standard method provides a minimum starting point for housing need, using household projections and affordability. It also fails to account for local economic growth, job creation, infrastructure changes, or specific demographic shifts.
3.9 Providing ambitious housing targets above the standard methodology also supports economic growth. This would match the East Midlands Vision for Growth (May 2025) which sets out the vision for transformative and ambitious growth within the region. Where significant employment growth is planned, housing supply must match job creation to avoid commuting issues and labour shortages.
3.10 At Examination, the Planning Inspectors may find the Loca Plan unsound if it fails adequately address all sources of housing need. A higher target for housing will demonstrate that the Local Plan is positively prepared, justified, and effective, which are key NPPF soundness tests.
3.11 The Local Plan should therefore establish a housing requirement above the standard method to reflect the economic ambitions for the area and affordable housing needs.
Spatial Distribution of Development
3.12 The location of development is a critical aspect of achieving sustainable development. As a general principal development should be located in areas that are accessible, sustainable, and benefit the local community.
3.13 The feedback from the August 2025 consultation shows the largest proportion of support (24%) was towards sites around the edge of Chesterfield. Keyland supports this approach. Chesterfield is the largest and most sustainable settlement in the area, which is surrounded by North East Derbyshire on three sides.
3.14 Furthermore, local government reorganisation is proceeding which is likely to merge Chesterfield with North East Derbyshire in the near future.
3.15 Therefore, through engagement and dialogue appropriate sustainable opportunities should be identified on the edge of Chesterfield, such as Keyland’s site at Furnace Hollock Way, Hasland (Site Ref 45065).
Proposed Approach to the Location of Development
3.16 Keyland support the proposed approach which identifies Priority Locations with Priority 1 including Edge of Chesterfield/Sheffield locations.
3.17 Keyland consider that this is an appropriate option in identifying land required to deliver sustainable growth within the district. Development around Chesterfield should be prioritised. Chesterfield is the most sustainable settlement in the area, which is surrounded by North East Derbyshire on three sides. Locating development on the edge of Chesterfield will ensure that new development has access to services, facilities, employment opportunities and access to public transport.
3.18 It is welcomed that higher positions in the spatial locations will be prioritised. However, it is slightly concerning that the consultation document states that “this does not override Green Belt or other desirable policy restrictions such as Local Settlement Gaps, provided that sufficient suitable sites can be found elsewhere in appropriate locations”. The consultation then states that the broad strategy is to “involve maximising allocations in areas outside of the Green Belt before considering sites within it; and then only where it can be shown to be necessary”. Given Chesterfield is surrounded by Green Belt, the Priority Locations and the spatial strategy are contrary.
3.19 The Council needs to recognise and accept that a Green Belt Review needs to occur and that the exceptional circumstances for releasing Green Belt is to meet housing needs in the most sustainable locations in accordance with the Priority Locations for development.
Settlement Hierarchy
3.20 The Settlement Hierarchy Study 2025 provides up to date information about settlements in North East Derbyshire District and the services and facilities they provide. One of the primary aims of establishing a settlement hierarchy is to promote sustainable communities by bringing housing, jobs and services closer together in an attempt to maintain and promote the viability of local facilities and reduce the need to travel to services and facilities elsewhere.
Sustainability Appraisal
3.21 It is welcomed that the Sustainability Appraisal has been published. However, the methodology and approach appears confused and it is unclear how the scoring, ranking and assessment has been applied.
3.22 For example, it is implied that Table 3.2 is summary of the Sustainability Appraisal for each site, however it portrays an inaccurate picture. Keyland’s site at Furnace Hillock Way, Hasland (Site 45065) is considered to have a negative score on transport. However, in the individual table it has a positive for buses and negative for railway station.
3.23 Nevertheless, the Sustainability Appraisal has not reflected the DfT connectivity tool which assesses the area to be extremely accessible and therefore the negative score is confusing.
3.24 The overall approach of the Sustainability Appraisal is confused and the methodology should be reviewed.
Proposed Approach
3.25 To address the comments, the following approach is proposed:
• Reflect national and regional policy ambitions.
• Set housing targets which are above the standard method baseline, and exceed for affordable housing and economic growth.
• Undertake a Green Belt Review that identifies grey belt.
• Amend approach to site identification that focusses on the most appropriate and sustainable locations first.
• Review the methodology and approach of the Sustainability Appraisal.
Site 45065 – Land around Furnace Hillock Way, Hasland
4.1 Keyland supports Site 45065 being short listed as a potential future housing allocation.
4.2 Keyland controls the site at Furnace Hillock Way, Hasland, which is available, suitable and achievable and therefore deliverable in accordance with national planning policy and guidance.
4.3 A Vision Report is attached to these representations, which explains the deliverability of the site.
4.4 Keyland considers the site can come forward in the short term and make a valuable contribution to the housing land supply.
Justification
4.1 Keyland considers that their Site at Furnace Hillock Way, Hasland should be allocated for housing use within the emerging Local Plan.
4.2 A Vision Report has been prepared and is attached at Appendix 1 to support the allocation of the site within the Local Plan. The Vision Report demonstrates that the site is available, suitable and achievable and therefore deliverable in accordance with the Framework and PPG. The Vision Report includes an illustrative masterplan and shows the vision for the site and how it could be delivered.
4.3 Keyland’s vision for the site is to create a logical extension to Chesterfield, creating a well-designed residential area that complements the existing community and enhances local character. The development of the site will support the Council’s and the East Midlands Region’s ambition to promote opportunities for growth, across the region’s cities, towns, villages, and natural spaces.
4.4 Furnace Hillock Way, Hasland, presents an opportunity to make a significant contribution to the housing need in North East Derbyshire. The site creates an opportunity with Keyland’s Six Capitals philosophy to bring forward an exemplar residential scheme to meet a diverse range of occupiers and stakeholders.
4.5 The Six Capitals approach has therefore shaped the illustrative masterplan. As the starting point of the proposed scheme is different this leads to a different outcome. The development has been designed from the outset to meet the differing housing needs in the area. Furthermore, to meet the social, human and environmental ambitions a significant proportion of the site has been identified for a range of environmental, recreational and water management activities.
4.6 The site presents an opportunity to provide housing in a sustainable location. The site is contained on all sides, bounded by roads, residential development and a golf course.
4.7 Overall, this is a scheme that has strong potential to balance connectivity, sustainability, and community well-being. It will create a vibrant, healthy, and resilient place for people to live, work and thrive.
4.8 In response to the bulleted list in the consultation document relating to Site 45065 the Vision Report has been informed by technical assessments:
• Green Belt: Spawforths has undertaken a High Level Grey Belt Assessment which Assessment shows that against all five purposes of the Green Belt concludes that the site performs a WEAK/MODERATE role against the five purposes of the Green Belt. The site at Furnace Hillock Way, Hasland has the potential to be Grey Belt as it does not perform strongly against purposes (a), (b) and (d) and it does not contain any Footnote 7 matters. In addition the Assessment has shown to a high level that the boundary to the site is formed by recognisable features and is effectively contained, has urban influences on character with urban form on three sides and a golf course to the south. • Heritage: Adept has undertaken a Heritage Appraisal and there are no archaeological or heritage constraints to the scheme.
• Ecology and Trees: Brooks has undertaken a Preliminary Ecological Appraisal and BNG assessment and there are no ecological or arboricultural constraints to the scheme.
• Public Rights of Way and Green Space: the illustrative masterplan within the Vision Report demonstrates that the PROW’s and green spaces can be accommodated within the proposed scheme.
• Flood Risk and Drainage: OEC has undertaken a preliminary Flood Risk and Drainage Assessment and there are no flood risk or drainage constraints.
• Geo-Environmental: Lithos has undertaken a preliminary ground investigation and there are no geo-environmental constraints.
4.9 The technical reports and Vision Report demonstrate that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
Availability
4.10 Keyland has a legal agreement with the landowners to promote and develop the land for housing. Keyland is proud of their reputation for working with local and national builders to deliver high-quality desirable homes in sustainable locations. The site is currently available for residential development which can be brought forward early within the local plan period, representing a short term opportunity.
4.11 The land is therefore “available” in accordance with the Framework and the Planning Practice Guidance.
Suitability
4.12 Keyland believe that the site is suitable for residential development, with no constraints that cannot be appropriately mitigated or that would represent the site being unsuitable.
4.13 The proposed development can make an efficient and attractive use of the land. Although greenfield land, the site represents an excellent opportunity for future housing and development. This site would allow housing to be delivered within an appropriate and sustainable location at Hasland, Chesterfield. The development of this site would assist in creating a logical extension to the built up urban area.
4.14 The site occupies a highly sustainable location on the edge of Hasland, adjoining the existing built-up area and forming a logical extension to Chesterfield. It benefits from strong access to local services, education, and transport infrastructure, including proximity to Chesterfield and its wider employment opportunities.
4.15 Furnace Hillock Way provides direct connectivity through the site, linking key routes and supporting accessibility. The surrounding context, including residential areas, green spaces, and community facilities, reinforces its suitability for residential development.
4.1 While the site lies within the Green Belt, it is well contained and relates closely to the existing urban edge. It makes a limited contribution to Green Belt purposes and should be considered through the emerging Local Plan Review as a ‘grey belt’ opportunity.
4.2 Spawforths has undertaken a High Level Grey Belt Assessment (Appendix 2) and considers the site is capable of being ‘grey belt’. The site is bound by Chesterfield, B6039 Mansfield Road, B6038 Churchside, residential properties, a golf course, woodland, and tree belts. These existing conditions provide containment to the site, and provide significant urban influence on the character of the site. Partial enclosure leads to an assessment of weak to moderate contribution to the purposes of the Green Belt, and therefore presents a positive opportunity for residential growth as a grey belt site.
4.3 There is a clear need for new sites to come forward for housing to support the growth ambitions for the East Midlands region. The site provides an important opportunity to meet local housing needs. The proposed residential development would be developed to a high-quality design standard that respects the nature of the surrounding area. The development of the site for housing presents an ideal opportunity to address local housing needs by providing a diverse range of affordable and aspirational homes for families, older adults, and young professionals.
4.4 The site provides a unique opportunity that will benefit the area and wider district with economic, environmental and social benefits. The technical work that underpins the masterplan confirms that there are no known constraints to development. It is therefore considered that the proposed allocation of the site is suitable, in accordance with national guidance and PPG
4.5 The land is therefore “suitable” in accordance with the Framework and the Planning Practice Guidance.
Deliverability
4.6 Keyland consider that the Site can come forward immediately and be delivered within the Plan period. The Vision Report shows that there are no significant issues preventing the site coming forward.
4.7 The proposed development is located within close proximity to existing services and facilities. The indicative masterplan represents an efficient use of the land available. The scheme is therefore making an efficient and effective use of land and infrastructure.
4.8 The site provides a development opportunity that is available, suitable and achievable and therefore it is considered that the site is deliverable, in accordance with national planning policy and guidance. It is promoted by Keyland and is deliverable within the Plan period.
Achievable
4.9 A range of technical work has been undertaken and is ongoing. From these initial assessments there are no technical issues that would prevent the delivery of the site for residential purposes. The technical reports have informed the illustrative masterplan within the Vision Report and shows how a mix of housing can be accommodated within the site, alongside connectivity, landscaping and drainage features.
4.10 The Framework requires Local Planning Authorities to meet their full objectively assessed housing need. Keyland considers that the site is deliverable and will reinforce the housing supply and address the Council’s housing needs in the Local Plan period. Development of this site will support the delivery of a range of housing types and contribute towards meeting identified needs.
4.11 The Vision Report demonstrates that there are no major constraints to the development of the site and that the site can be delivered in the Local Plan period. The site is therefore “achievable” in accordance with the Framework.
A Positive Response to the Key Objectives of the Framework
4.12 The Framework sets out that the Governments key housing policy goal of significantly boosting the supply of housing and proactively driving and supporting sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs. The Framework explains that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as extensions to towns, and creating mixed and sustainable communities with good access to jobs, key services and infrastructure. Sites should also make effective use of land and existing infrastructure.
4.13 In relation to the Framework:
• The proposal responds positively towards national guidance.
• The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.
• The proposed site is accessible to existing employment, local community facilities, infrastructure and services, including public transport.
• The site has been assessed as being is available, suitable and achievable for development.
Benefits of Site Reference ID45065 – Land at Furnace Hillock Way, Hasland
4.14 The development of the site would provide significant economic, social and environmental benefits. The site would provide housing that would meet the needs of the North East Derbyshire District Council’s housing market in a sustainable location.
4.15 In accordance with the Framework this representation has shown that:
• The site is suitable for housing and can deliver circa 850 new homes.
• The site can deliver a new local centre and school.
• The proposal can provide a good mix of housing commensurate to the demand and need in the area and diversify the housing stock
• The site is within a sustainable location situated in close proximity to facilities and services and also to bus stops for local bus routes.
• The scheme uses land efficiently and effectively.
• The proposal is in line with planning for housing objectives.
• The scheme will create direct and indirect job opportunities both during and after construction, plus employment opportunities with a local centre and school.
• The site can deliver new areas of public open space.
4.16 The proposal is an appropriate site to provide for the housing needs of North East Derbyshire and the wider East Midlands region during the local plan period. Confirmation of the allocation will contribute positively to a balanced housing supply in the area in sustainable locations. The site can deliver a full range and mix of housing as part of a sustainable community. Development of the site would deliver affordable housing. North East Derbyshire District Council needs to have a robust housing trajectory with a sufficient supply of deliverable sites. The site will assist with this delivery in the medium term. The site is situated within a prime location suitable for residential development and as such would facilitate the development of land in an effective and efficient manner. Development of the site would not harm or undermine the area’s wider policy objectives but seeks to reinforce the need to develop sites within sustainable locations as a priority.
4.17 The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.
Proposed Approach
4.18 To address the comments, the following approach is proposed:
• Allocate the site at Furnace Hillock Way, Hasland for housing purposes.