Consultation Draft (February 2017)

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Comment

Consultation Draft (February 2017)

Housing Provision by Settlement

Representation ID: 5380

Received: 03/04/2017

Respondent: Ackroyd & Abbott Homes Ltd.

Agent: Charlotte Stainton

Representation Summary:

Planning for only 156 units above the minimum housing requirement does not give sufficient certainty regarding delivery and does not achieve growth, particularly in light of persistent under-delivery.

Given the previous under-delivery of housing on the strategic sites, the anticipated delivery rates for these is unrealistic. The disproportionate reliance on them makes the housing provision strategy weak.

The reliance on many Green Belt dwellings is also a significant weakness. There are numerous non-Green Belt sites which have been discounted for reasons which should not outweigh Green Belt designation. Not all other reasonable options have been considered, making the plan unsound.

Full text:

Four letters have been submitted as representations to the Draft North East Derbyshire Local Plan 2011-2033 which is submitted on behalf of clients Ackroyd and Abbott Ltd.

North East Derbyshire Local Plan Representation - Station Road, Killamarsh

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Station Road, Killamarsh - 07/00865/FL
Full planning permission 07/00865/FL has been granted for the residential development of the site of the Old Station at Killamarsh and we believe that it should be shown as a housing allocation in the Local Plan. We have a letter dated 22 May 2015 from Adrian Kirkham which confirms that this permission remains extant. Failure to allocate this site appears to be a missed opportunity to deliver housing within the built framework of Killamarsh.

The development of this site stalled due to the crash in the housing market and then latterly due to uncertainties about the route of HS2. I confirm however that this site is now available and deliverable.

We therefore request that the site covered by 07/00865/FL be allocated for residential development. The development of this site is in accordance with the Council Local Plan Strategy and could reduce pressure on the Green Belt surrounding Killamarsh.
North East Derbyshire Local Plan Representation - Hasland

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the 5740 allocated dwellings would be on just two strategic sites. This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

In terms of the Green Belt review and the subsequent draft housing allocations within Green Belt, there is no evidence that this has been undertaken in consultation with the adjoining Local Authorities and this lack of cooperation potentially makes the plan unsound.

Land at Churchside, Hasland
The two parcels of land shown on the attached plan were previously submitted to the 'call for sites' process for consideration. They can be considered as one large site or two separate sites. They are both available and deliverable within 5 years.

We do not believe that sufficient consideration has been given to the opportunity that these sites offer to deliver housing adjacent to Chesterfield under the Duty to Cooperate.
These sites are positioned immediately adjacent to the built-up settlement of Hasland. The release of this land parcel would not result in harm to the countryside to the east or west and an area of open green belt would remain to the south, thus avoiding the coalescence of settlements.

Numerous areas of land are proposed to be taken out of the Green Belt in the north of the District and the removal of these sites in Hasland would be no more harmful to the purposes of Green Belt than the majority of those Green Belt sites that are proposed housing allocations. There is a lack of consistency in approach and because of this the Green Belt evidence is flawed.

For the reasons submitted as part of the Call for Sites, we therefore request that these sites at Hasland be removed from the Green Belt and allocated for residential development.

Another option would be to safeguard these sites for future development, possibly to deliver future housing for Chesterfield.

The development of these sites could therefore reduce pressure on the Green Belt to the north of the District and/or deliver future housing for Chesterfield.

North East Derbyshire Local Plan Representation - Holmewood
Proposed Housing Allocation - Holmewood (ab)
We wish to support the allocation of the housing site in Holmewood given the reference - ab. The site has planning permission under reference 14/00312/OL.

We confirm that this site which has planning permission is available for development and discussions are ongoing with potential developers and the landowner.

The site can confidently be included in the Local Plan as available and deliverable within 5 years.

It is important however that the viability issues relating to the provision of affordable housing and developer contributions are recognised for this site which is in a relatively low value area.

We therefore request that draft housing site allocation ab is carried forward to future drafts of the Local Plan.
North East Derbyshire Local Plan Representation -
Hanging Banks, Wingerworth
Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Local Settlement Gaps
The evidence that the Local Settlement Gaps designation is based on is fundamentally flawed. This is because the perceived 'gaps' that the designations are seeking to protect do not exist in reality and there is no consistency or logic to which areas are concluded to be important settlement gaps in the evidence.

The Council has then adopted this flawed evidence by including the recommended settlement gaps in the Draft Local Plan without any narrative about the merits of each gap and whether the perceived need for a gap should outweigh the opportunity to deliver development adjacent to existing settlements. The provision of local settlement gaps would actually result in the loss of Green Belt land elsewhere.

In the case of the Local Settlement Gap shown to the south of Nottingham Drive, Wingerworth (in the area known as Hanging Banks) the explanation of why this area forms a settlement gap of such importance that it should be protected from development (at the expense of Green Belt elsewhere), is severely lacking. There is already development on the east side of the A61, which is also part of Wingerworth. It is not logical to try to keep a field between two parts of the same settlement. The development of Hanging Banks would unify the settlement, not result in harm to the identity of the settlement.

The proposed settlement gap in this location is not based on a clear understanding of the settlement and should be removed from the Local Plan.

Hanging Banks, Wingerworth - 16/00656/OL
Planning permissions 14/00763/OL and 16/00656/OL have been granted for the residential development of the Hanging Banks site and we firmly believe that it should be
shown as a housing allocation in the Local Plan.

There was minimal local objection/comment to these planning applications which suggests that the protection of this land as countryside is not of significant concern to local residents.

In determining the initial outline planning application, the Council concluded that the development of this site would be sustainable and that all technical requirements could be met. In addition, the Council participated in the OPUN design review process and carried out significant work with the District Valuer. It does not make sense for all this work to be put to one side when the site is an available and deliverable housing development opportunity.

This development would deliver a high quality residential scheme which would respond to the various constraints and opportunities presented by the site e.g. site frontage to A61, retention of hedgerows, responding to the woodland, backing on to properties on Nottingham Drive, soft edge to the countryside boundaries (outward facing) and the delivery of dwellings to meet the local market and deliver affordable housing such as bungalows for the retirement market etc. The development of this site would sit comfortably adjacent to the existing built up area as a natural extension. Agricultural land and woodland will remain to the south and west and there is already development on the eastern side of the A61.

We therefore request that this site be allocated for residential development and as such that the Local Settlement Gap designated is removed from this site. The development of this site is in accordance with the Council Local Plan Strategy and would reduce pressure on the Green Belt.

Comment

Consultation Draft (February 2017)

Relationship with other Local Plans and the Duty to Co-operate

Representation ID: 5382

Received: 03/04/2017

Respondent: Ackroyd & Abbott Homes Ltd.

Agent: Charlotte Stainton

Representation Summary:

In terms of the Green Belt review and the subsequent draft housing allocations within Green Belt, there is no evidence that this has been undertaken in consultation with the adjoining Local Authorities and this lack of cooperation potentially makes the plan unsound.

Full text:

Four letters have been submitted as representations to the Draft North East Derbyshire Local Plan 2011-2033 which is submitted on behalf of clients Ackroyd and Abbott Ltd.

North East Derbyshire Local Plan Representation - Station Road, Killamarsh

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Station Road, Killamarsh - 07/00865/FL
Full planning permission 07/00865/FL has been granted for the residential development of the site of the Old Station at Killamarsh and we believe that it should be shown as a housing allocation in the Local Plan. We have a letter dated 22 May 2015 from Adrian Kirkham which confirms that this permission remains extant. Failure to allocate this site appears to be a missed opportunity to deliver housing within the built framework of Killamarsh.

The development of this site stalled due to the crash in the housing market and then latterly due to uncertainties about the route of HS2. I confirm however that this site is now available and deliverable.

We therefore request that the site covered by 07/00865/FL be allocated for residential development. The development of this site is in accordance with the Council Local Plan Strategy and could reduce pressure on the Green Belt surrounding Killamarsh.
North East Derbyshire Local Plan Representation - Hasland

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the 5740 allocated dwellings would be on just two strategic sites. This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

In terms of the Green Belt review and the subsequent draft housing allocations within Green Belt, there is no evidence that this has been undertaken in consultation with the adjoining Local Authorities and this lack of cooperation potentially makes the plan unsound.

Land at Churchside, Hasland
The two parcels of land shown on the attached plan were previously submitted to the 'call for sites' process for consideration. They can be considered as one large site or two separate sites. They are both available and deliverable within 5 years.

We do not believe that sufficient consideration has been given to the opportunity that these sites offer to deliver housing adjacent to Chesterfield under the Duty to Cooperate.
These sites are positioned immediately adjacent to the built-up settlement of Hasland. The release of this land parcel would not result in harm to the countryside to the east or west and an area of open green belt would remain to the south, thus avoiding the coalescence of settlements.

Numerous areas of land are proposed to be taken out of the Green Belt in the north of the District and the removal of these sites in Hasland would be no more harmful to the purposes of Green Belt than the majority of those Green Belt sites that are proposed housing allocations. There is a lack of consistency in approach and because of this the Green Belt evidence is flawed.

For the reasons submitted as part of the Call for Sites, we therefore request that these sites at Hasland be removed from the Green Belt and allocated for residential development.

Another option would be to safeguard these sites for future development, possibly to deliver future housing for Chesterfield.

The development of these sites could therefore reduce pressure on the Green Belt to the north of the District and/or deliver future housing for Chesterfield.

North East Derbyshire Local Plan Representation - Holmewood
Proposed Housing Allocation - Holmewood (ab)
We wish to support the allocation of the housing site in Holmewood given the reference - ab. The site has planning permission under reference 14/00312/OL.

We confirm that this site which has planning permission is available for development and discussions are ongoing with potential developers and the landowner.

The site can confidently be included in the Local Plan as available and deliverable within 5 years.

It is important however that the viability issues relating to the provision of affordable housing and developer contributions are recognised for this site which is in a relatively low value area.

We therefore request that draft housing site allocation ab is carried forward to future drafts of the Local Plan.
North East Derbyshire Local Plan Representation -
Hanging Banks, Wingerworth
Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Local Settlement Gaps
The evidence that the Local Settlement Gaps designation is based on is fundamentally flawed. This is because the perceived 'gaps' that the designations are seeking to protect do not exist in reality and there is no consistency or logic to which areas are concluded to be important settlement gaps in the evidence.

The Council has then adopted this flawed evidence by including the recommended settlement gaps in the Draft Local Plan without any narrative about the merits of each gap and whether the perceived need for a gap should outweigh the opportunity to deliver development adjacent to existing settlements. The provision of local settlement gaps would actually result in the loss of Green Belt land elsewhere.

In the case of the Local Settlement Gap shown to the south of Nottingham Drive, Wingerworth (in the area known as Hanging Banks) the explanation of why this area forms a settlement gap of such importance that it should be protected from development (at the expense of Green Belt elsewhere), is severely lacking. There is already development on the east side of the A61, which is also part of Wingerworth. It is not logical to try to keep a field between two parts of the same settlement. The development of Hanging Banks would unify the settlement, not result in harm to the identity of the settlement.

The proposed settlement gap in this location is not based on a clear understanding of the settlement and should be removed from the Local Plan.

Hanging Banks, Wingerworth - 16/00656/OL
Planning permissions 14/00763/OL and 16/00656/OL have been granted for the residential development of the Hanging Banks site and we firmly believe that it should be
shown as a housing allocation in the Local Plan.

There was minimal local objection/comment to these planning applications which suggests that the protection of this land as countryside is not of significant concern to local residents.

In determining the initial outline planning application, the Council concluded that the development of this site would be sustainable and that all technical requirements could be met. In addition, the Council participated in the OPUN design review process and carried out significant work with the District Valuer. It does not make sense for all this work to be put to one side when the site is an available and deliverable housing development opportunity.

This development would deliver a high quality residential scheme which would respond to the various constraints and opportunities presented by the site e.g. site frontage to A61, retention of hedgerows, responding to the woodland, backing on to properties on Nottingham Drive, soft edge to the countryside boundaries (outward facing) and the delivery of dwellings to meet the local market and deliver affordable housing such as bungalows for the retirement market etc. The development of this site would sit comfortably adjacent to the existing built up area as a natural extension. Agricultural land and woodland will remain to the south and west and there is already development on the eastern side of the A61.

We therefore request that this site be allocated for residential development and as such that the Local Settlement Gap designated is removed from this site. The development of this site is in accordance with the Council Local Plan Strategy and would reduce pressure on the Green Belt.

Comment

Consultation Draft (February 2017)

Killamarsh

Representation ID: 5384

Received: 03/04/2017

Respondent: Ackroyd & Abbott Homes Ltd.

Agent: Charlotte Stainton

Representation Summary:

Planning permission 07/00865/FL has been granted for the residential development of the site of the Old Station at Killamarsh and we believe that it should be shown as a housing allocation in the Local Plan. We have a letter dated 22 May 2015 from Adrian Kirkham which confirms that this permission remains extant.

I confirm that this site is now available and deliverable. We therefore request that the site covered by 07/00865/FL be allocated for residential development. The development of this site is in accordance with the Local Plan Strategy and could reduce pressure on the Green Belt surrounding Killamarsh.

Full text:

Four letters have been submitted as representations to the Draft North East Derbyshire Local Plan 2011-2033 which is submitted on behalf of clients Ackroyd and Abbott Ltd.

North East Derbyshire Local Plan Representation - Station Road, Killamarsh

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Station Road, Killamarsh - 07/00865/FL
Full planning permission 07/00865/FL has been granted for the residential development of the site of the Old Station at Killamarsh and we believe that it should be shown as a housing allocation in the Local Plan. We have a letter dated 22 May 2015 from Adrian Kirkham which confirms that this permission remains extant. Failure to allocate this site appears to be a missed opportunity to deliver housing within the built framework of Killamarsh.

The development of this site stalled due to the crash in the housing market and then latterly due to uncertainties about the route of HS2. I confirm however that this site is now available and deliverable.

We therefore request that the site covered by 07/00865/FL be allocated for residential development. The development of this site is in accordance with the Council Local Plan Strategy and could reduce pressure on the Green Belt surrounding Killamarsh.
North East Derbyshire Local Plan Representation - Hasland

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the 5740 allocated dwellings would be on just two strategic sites. This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

In terms of the Green Belt review and the subsequent draft housing allocations within Green Belt, there is no evidence that this has been undertaken in consultation with the adjoining Local Authorities and this lack of cooperation potentially makes the plan unsound.

Land at Churchside, Hasland
The two parcels of land shown on the attached plan were previously submitted to the 'call for sites' process for consideration. They can be considered as one large site or two separate sites. They are both available and deliverable within 5 years.

We do not believe that sufficient consideration has been given to the opportunity that these sites offer to deliver housing adjacent to Chesterfield under the Duty to Cooperate.
These sites are positioned immediately adjacent to the built-up settlement of Hasland. The release of this land parcel would not result in harm to the countryside to the east or west and an area of open green belt would remain to the south, thus avoiding the coalescence of settlements.

Numerous areas of land are proposed to be taken out of the Green Belt in the north of the District and the removal of these sites in Hasland would be no more harmful to the purposes of Green Belt than the majority of those Green Belt sites that are proposed housing allocations. There is a lack of consistency in approach and because of this the Green Belt evidence is flawed.

For the reasons submitted as part of the Call for Sites, we therefore request that these sites at Hasland be removed from the Green Belt and allocated for residential development.

Another option would be to safeguard these sites for future development, possibly to deliver future housing for Chesterfield.

The development of these sites could therefore reduce pressure on the Green Belt to the north of the District and/or deliver future housing for Chesterfield.

North East Derbyshire Local Plan Representation - Holmewood
Proposed Housing Allocation - Holmewood (ab)
We wish to support the allocation of the housing site in Holmewood given the reference - ab. The site has planning permission under reference 14/00312/OL.

We confirm that this site which has planning permission is available for development and discussions are ongoing with potential developers and the landowner.

The site can confidently be included in the Local Plan as available and deliverable within 5 years.

It is important however that the viability issues relating to the provision of affordable housing and developer contributions are recognised for this site which is in a relatively low value area.

We therefore request that draft housing site allocation ab is carried forward to future drafts of the Local Plan.
North East Derbyshire Local Plan Representation -
Hanging Banks, Wingerworth
Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Local Settlement Gaps
The evidence that the Local Settlement Gaps designation is based on is fundamentally flawed. This is because the perceived 'gaps' that the designations are seeking to protect do not exist in reality and there is no consistency or logic to which areas are concluded to be important settlement gaps in the evidence.

The Council has then adopted this flawed evidence by including the recommended settlement gaps in the Draft Local Plan without any narrative about the merits of each gap and whether the perceived need for a gap should outweigh the opportunity to deliver development adjacent to existing settlements. The provision of local settlement gaps would actually result in the loss of Green Belt land elsewhere.

In the case of the Local Settlement Gap shown to the south of Nottingham Drive, Wingerworth (in the area known as Hanging Banks) the explanation of why this area forms a settlement gap of such importance that it should be protected from development (at the expense of Green Belt elsewhere), is severely lacking. There is already development on the east side of the A61, which is also part of Wingerworth. It is not logical to try to keep a field between two parts of the same settlement. The development of Hanging Banks would unify the settlement, not result in harm to the identity of the settlement.

The proposed settlement gap in this location is not based on a clear understanding of the settlement and should be removed from the Local Plan.

Hanging Banks, Wingerworth - 16/00656/OL
Planning permissions 14/00763/OL and 16/00656/OL have been granted for the residential development of the Hanging Banks site and we firmly believe that it should be
shown as a housing allocation in the Local Plan.

There was minimal local objection/comment to these planning applications which suggests that the protection of this land as countryside is not of significant concern to local residents.

In determining the initial outline planning application, the Council concluded that the development of this site would be sustainable and that all technical requirements could be met. In addition, the Council participated in the OPUN design review process and carried out significant work with the District Valuer. It does not make sense for all this work to be put to one side when the site is an available and deliverable housing development opportunity.

This development would deliver a high quality residential scheme which would respond to the various constraints and opportunities presented by the site e.g. site frontage to A61, retention of hedgerows, responding to the woodland, backing on to properties on Nottingham Drive, soft edge to the countryside boundaries (outward facing) and the delivery of dwellings to meet the local market and deliver affordable housing such as bungalows for the retirement market etc. The development of this site would sit comfortably adjacent to the existing built up area as a natural extension. Agricultural land and woodland will remain to the south and west and there is already development on the eastern side of the A61.

We therefore request that this site be allocated for residential development and as such that the Local Settlement Gap designated is removed from this site. The development of this site is in accordance with the Council Local Plan Strategy and would reduce pressure on the Green Belt.

Comment

Consultation Draft (February 2017)

Housing Allocations

Representation ID: 5385

Received: 03/04/2017

Respondent: Ackroyd & Abbott Homes Ltd.

Agent: Charlotte Stainton

Representation Summary:

The two parcels of land shown on the attached plan were previously submitted to the 'call for sites' process. They can be considered as one large site or two separate sites. They are both available and deliverable within 5 years.

We do not believe that sufficient consideration has been given to the opportunity that these sites offer to deliver housing adjacent to Chesterfield under the Duty to Cooperate.

The development of these sites could reduce pressure on the Green Belt to the north of the District and/or deliver future housing for Chesterfield, either as an allocation or safeguarded land.

Full text:

Four letters have been submitted as representations to the Draft North East Derbyshire Local Plan 2011-2033 which is submitted on behalf of clients Ackroyd and Abbott Ltd.

North East Derbyshire Local Plan Representation - Station Road, Killamarsh

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Station Road, Killamarsh - 07/00865/FL
Full planning permission 07/00865/FL has been granted for the residential development of the site of the Old Station at Killamarsh and we believe that it should be shown as a housing allocation in the Local Plan. We have a letter dated 22 May 2015 from Adrian Kirkham which confirms that this permission remains extant. Failure to allocate this site appears to be a missed opportunity to deliver housing within the built framework of Killamarsh.

The development of this site stalled due to the crash in the housing market and then latterly due to uncertainties about the route of HS2. I confirm however that this site is now available and deliverable.

We therefore request that the site covered by 07/00865/FL be allocated for residential development. The development of this site is in accordance with the Council Local Plan Strategy and could reduce pressure on the Green Belt surrounding Killamarsh.
North East Derbyshire Local Plan Representation - Hasland

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the 5740 allocated dwellings would be on just two strategic sites. This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

In terms of the Green Belt review and the subsequent draft housing allocations within Green Belt, there is no evidence that this has been undertaken in consultation with the adjoining Local Authorities and this lack of cooperation potentially makes the plan unsound.

Land at Churchside, Hasland
The two parcels of land shown on the attached plan were previously submitted to the 'call for sites' process for consideration. They can be considered as one large site or two separate sites. They are both available and deliverable within 5 years.

We do not believe that sufficient consideration has been given to the opportunity that these sites offer to deliver housing adjacent to Chesterfield under the Duty to Cooperate.
These sites are positioned immediately adjacent to the built-up settlement of Hasland. The release of this land parcel would not result in harm to the countryside to the east or west and an area of open green belt would remain to the south, thus avoiding the coalescence of settlements.

Numerous areas of land are proposed to be taken out of the Green Belt in the north of the District and the removal of these sites in Hasland would be no more harmful to the purposes of Green Belt than the majority of those Green Belt sites that are proposed housing allocations. There is a lack of consistency in approach and because of this the Green Belt evidence is flawed.

For the reasons submitted as part of the Call for Sites, we therefore request that these sites at Hasland be removed from the Green Belt and allocated for residential development.

Another option would be to safeguard these sites for future development, possibly to deliver future housing for Chesterfield.

The development of these sites could therefore reduce pressure on the Green Belt to the north of the District and/or deliver future housing for Chesterfield.

North East Derbyshire Local Plan Representation - Holmewood
Proposed Housing Allocation - Holmewood (ab)
We wish to support the allocation of the housing site in Holmewood given the reference - ab. The site has planning permission under reference 14/00312/OL.

We confirm that this site which has planning permission is available for development and discussions are ongoing with potential developers and the landowner.

The site can confidently be included in the Local Plan as available and deliverable within 5 years.

It is important however that the viability issues relating to the provision of affordable housing and developer contributions are recognised for this site which is in a relatively low value area.

We therefore request that draft housing site allocation ab is carried forward to future drafts of the Local Plan.
North East Derbyshire Local Plan Representation -
Hanging Banks, Wingerworth
Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Local Settlement Gaps
The evidence that the Local Settlement Gaps designation is based on is fundamentally flawed. This is because the perceived 'gaps' that the designations are seeking to protect do not exist in reality and there is no consistency or logic to which areas are concluded to be important settlement gaps in the evidence.

The Council has then adopted this flawed evidence by including the recommended settlement gaps in the Draft Local Plan without any narrative about the merits of each gap and whether the perceived need for a gap should outweigh the opportunity to deliver development adjacent to existing settlements. The provision of local settlement gaps would actually result in the loss of Green Belt land elsewhere.

In the case of the Local Settlement Gap shown to the south of Nottingham Drive, Wingerworth (in the area known as Hanging Banks) the explanation of why this area forms a settlement gap of such importance that it should be protected from development (at the expense of Green Belt elsewhere), is severely lacking. There is already development on the east side of the A61, which is also part of Wingerworth. It is not logical to try to keep a field between two parts of the same settlement. The development of Hanging Banks would unify the settlement, not result in harm to the identity of the settlement.

The proposed settlement gap in this location is not based on a clear understanding of the settlement and should be removed from the Local Plan.

Hanging Banks, Wingerworth - 16/00656/OL
Planning permissions 14/00763/OL and 16/00656/OL have been granted for the residential development of the Hanging Banks site and we firmly believe that it should be
shown as a housing allocation in the Local Plan.

There was minimal local objection/comment to these planning applications which suggests that the protection of this land as countryside is not of significant concern to local residents.

In determining the initial outline planning application, the Council concluded that the development of this site would be sustainable and that all technical requirements could be met. In addition, the Council participated in the OPUN design review process and carried out significant work with the District Valuer. It does not make sense for all this work to be put to one side when the site is an available and deliverable housing development opportunity.

This development would deliver a high quality residential scheme which would respond to the various constraints and opportunities presented by the site e.g. site frontage to A61, retention of hedgerows, responding to the woodland, backing on to properties on Nottingham Drive, soft edge to the countryside boundaries (outward facing) and the delivery of dwellings to meet the local market and deliver affordable housing such as bungalows for the retirement market etc. The development of this site would sit comfortably adjacent to the existing built up area as a natural extension. Agricultural land and woodland will remain to the south and west and there is already development on the eastern side of the A61.

We therefore request that this site be allocated for residential development and as such that the Local Settlement Gap designated is removed from this site. The development of this site is in accordance with the Council Local Plan Strategy and would reduce pressure on the Green Belt.

Comment

Consultation Draft (February 2017)

ab. Land to the South of, 205 Chesterfield Road, Holmewood

Representation ID: 5386

Received: 03/04/2017

Respondent: Ackroyd & Abbott Homes Ltd.

Agent: Charlotte Stainton

Representation Summary:

Support the allocation. The site has planning permission under reference 14/00312/OL.

We confirm that this site which has planning permission is available for development and discussions are ongoing with potential developers and the landowner.

The site can confidently be included as available and deliverable within 5 years.

It is important however that the viability issues relating to the provision of affordable housing and developer contributions are recognised for this site which is in a relatively low value area.

We therefore request that draft housing site allocation ab is carried forward to future drafts of the Local Plan.

Full text:

Four letters have been submitted as representations to the Draft North East Derbyshire Local Plan 2011-2033 which is submitted on behalf of clients Ackroyd and Abbott Ltd.

North East Derbyshire Local Plan Representation - Station Road, Killamarsh

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Station Road, Killamarsh - 07/00865/FL
Full planning permission 07/00865/FL has been granted for the residential development of the site of the Old Station at Killamarsh and we believe that it should be shown as a housing allocation in the Local Plan. We have a letter dated 22 May 2015 from Adrian Kirkham which confirms that this permission remains extant. Failure to allocate this site appears to be a missed opportunity to deliver housing within the built framework of Killamarsh.

The development of this site stalled due to the crash in the housing market and then latterly due to uncertainties about the route of HS2. I confirm however that this site is now available and deliverable.

We therefore request that the site covered by 07/00865/FL be allocated for residential development. The development of this site is in accordance with the Council Local Plan Strategy and could reduce pressure on the Green Belt surrounding Killamarsh.
North East Derbyshire Local Plan Representation - Hasland

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the 5740 allocated dwellings would be on just two strategic sites. This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

In terms of the Green Belt review and the subsequent draft housing allocations within Green Belt, there is no evidence that this has been undertaken in consultation with the adjoining Local Authorities and this lack of cooperation potentially makes the plan unsound.

Land at Churchside, Hasland
The two parcels of land shown on the attached plan were previously submitted to the 'call for sites' process for consideration. They can be considered as one large site or two separate sites. They are both available and deliverable within 5 years.

We do not believe that sufficient consideration has been given to the opportunity that these sites offer to deliver housing adjacent to Chesterfield under the Duty to Cooperate.
These sites are positioned immediately adjacent to the built-up settlement of Hasland. The release of this land parcel would not result in harm to the countryside to the east or west and an area of open green belt would remain to the south, thus avoiding the coalescence of settlements.

Numerous areas of land are proposed to be taken out of the Green Belt in the north of the District and the removal of these sites in Hasland would be no more harmful to the purposes of Green Belt than the majority of those Green Belt sites that are proposed housing allocations. There is a lack of consistency in approach and because of this the Green Belt evidence is flawed.

For the reasons submitted as part of the Call for Sites, we therefore request that these sites at Hasland be removed from the Green Belt and allocated for residential development.

Another option would be to safeguard these sites for future development, possibly to deliver future housing for Chesterfield.

The development of these sites could therefore reduce pressure on the Green Belt to the north of the District and/or deliver future housing for Chesterfield.

North East Derbyshire Local Plan Representation - Holmewood
Proposed Housing Allocation - Holmewood (ab)
We wish to support the allocation of the housing site in Holmewood given the reference - ab. The site has planning permission under reference 14/00312/OL.

We confirm that this site which has planning permission is available for development and discussions are ongoing with potential developers and the landowner.

The site can confidently be included in the Local Plan as available and deliverable within 5 years.

It is important however that the viability issues relating to the provision of affordable housing and developer contributions are recognised for this site which is in a relatively low value area.

We therefore request that draft housing site allocation ab is carried forward to future drafts of the Local Plan.
North East Derbyshire Local Plan Representation -
Hanging Banks, Wingerworth
Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Local Settlement Gaps
The evidence that the Local Settlement Gaps designation is based on is fundamentally flawed. This is because the perceived 'gaps' that the designations are seeking to protect do not exist in reality and there is no consistency or logic to which areas are concluded to be important settlement gaps in the evidence.

The Council has then adopted this flawed evidence by including the recommended settlement gaps in the Draft Local Plan without any narrative about the merits of each gap and whether the perceived need for a gap should outweigh the opportunity to deliver development adjacent to existing settlements. The provision of local settlement gaps would actually result in the loss of Green Belt land elsewhere.

In the case of the Local Settlement Gap shown to the south of Nottingham Drive, Wingerworth (in the area known as Hanging Banks) the explanation of why this area forms a settlement gap of such importance that it should be protected from development (at the expense of Green Belt elsewhere), is severely lacking. There is already development on the east side of the A61, which is also part of Wingerworth. It is not logical to try to keep a field between two parts of the same settlement. The development of Hanging Banks would unify the settlement, not result in harm to the identity of the settlement.

The proposed settlement gap in this location is not based on a clear understanding of the settlement and should be removed from the Local Plan.

Hanging Banks, Wingerworth - 16/00656/OL
Planning permissions 14/00763/OL and 16/00656/OL have been granted for the residential development of the Hanging Banks site and we firmly believe that it should be
shown as a housing allocation in the Local Plan.

There was minimal local objection/comment to these planning applications which suggests that the protection of this land as countryside is not of significant concern to local residents.

In determining the initial outline planning application, the Council concluded that the development of this site would be sustainable and that all technical requirements could be met. In addition, the Council participated in the OPUN design review process and carried out significant work with the District Valuer. It does not make sense for all this work to be put to one side when the site is an available and deliverable housing development opportunity.

This development would deliver a high quality residential scheme which would respond to the various constraints and opportunities presented by the site e.g. site frontage to A61, retention of hedgerows, responding to the woodland, backing on to properties on Nottingham Drive, soft edge to the countryside boundaries (outward facing) and the delivery of dwellings to meet the local market and deliver affordable housing such as bungalows for the retirement market etc. The development of this site would sit comfortably adjacent to the existing built up area as a natural extension. Agricultural land and woodland will remain to the south and west and there is already development on the eastern side of the A61.

We therefore request that this site be allocated for residential development and as such that the Local Settlement Gap designated is removed from this site. The development of this site is in accordance with the Council Local Plan Strategy and would reduce pressure on the Green Belt.

Comment

Consultation Draft (February 2017)

Wingerworth

Representation ID: 5387

Received: 03/04/2017

Respondent: Ackroyd & Abbott Homes Ltd.

Agent: Charlotte Stainton

Representation Summary:

Planning permissions 14/00763/OL and 16/00656/OL have been granted for the residential development of the Hanging Banks site and we firmly believe that it should be shown as a housing allocation in the Local Plan.

We request that this site be allocated for residential development and as such that the Local Settlement Gap designated is removed from this site. The development of this site is in accordance with the Council Local Plan Strategy and would reduce pressure on the Green Belt.

Full text:

Four letters have been submitted as representations to the Draft North East Derbyshire Local Plan 2011-2033 which is submitted on behalf of clients Ackroyd and Abbott Ltd.

North East Derbyshire Local Plan Representation - Station Road, Killamarsh

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Station Road, Killamarsh - 07/00865/FL
Full planning permission 07/00865/FL has been granted for the residential development of the site of the Old Station at Killamarsh and we believe that it should be shown as a housing allocation in the Local Plan. We have a letter dated 22 May 2015 from Adrian Kirkham which confirms that this permission remains extant. Failure to allocate this site appears to be a missed opportunity to deliver housing within the built framework of Killamarsh.

The development of this site stalled due to the crash in the housing market and then latterly due to uncertainties about the route of HS2. I confirm however that this site is now available and deliverable.

We therefore request that the site covered by 07/00865/FL be allocated for residential development. The development of this site is in accordance with the Council Local Plan Strategy and could reduce pressure on the Green Belt surrounding Killamarsh.
North East Derbyshire Local Plan Representation - Hasland

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the 5740 allocated dwellings would be on just two strategic sites. This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

In terms of the Green Belt review and the subsequent draft housing allocations within Green Belt, there is no evidence that this has been undertaken in consultation with the adjoining Local Authorities and this lack of cooperation potentially makes the plan unsound.

Land at Churchside, Hasland
The two parcels of land shown on the attached plan were previously submitted to the 'call for sites' process for consideration. They can be considered as one large site or two separate sites. They are both available and deliverable within 5 years.

We do not believe that sufficient consideration has been given to the opportunity that these sites offer to deliver housing adjacent to Chesterfield under the Duty to Cooperate.
These sites are positioned immediately adjacent to the built-up settlement of Hasland. The release of this land parcel would not result in harm to the countryside to the east or west and an area of open green belt would remain to the south, thus avoiding the coalescence of settlements.

Numerous areas of land are proposed to be taken out of the Green Belt in the north of the District and the removal of these sites in Hasland would be no more harmful to the purposes of Green Belt than the majority of those Green Belt sites that are proposed housing allocations. There is a lack of consistency in approach and because of this the Green Belt evidence is flawed.

For the reasons submitted as part of the Call for Sites, we therefore request that these sites at Hasland be removed from the Green Belt and allocated for residential development.

Another option would be to safeguard these sites for future development, possibly to deliver future housing for Chesterfield.

The development of these sites could therefore reduce pressure on the Green Belt to the north of the District and/or deliver future housing for Chesterfield.

North East Derbyshire Local Plan Representation - Holmewood
Proposed Housing Allocation - Holmewood (ab)
We wish to support the allocation of the housing site in Holmewood given the reference - ab. The site has planning permission under reference 14/00312/OL.

We confirm that this site which has planning permission is available for development and discussions are ongoing with potential developers and the landowner.

The site can confidently be included in the Local Plan as available and deliverable within 5 years.

It is important however that the viability issues relating to the provision of affordable housing and developer contributions are recognised for this site which is in a relatively low value area.

We therefore request that draft housing site allocation ab is carried forward to future drafts of the Local Plan.
North East Derbyshire Local Plan Representation -
Hanging Banks, Wingerworth
Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Local Settlement Gaps
The evidence that the Local Settlement Gaps designation is based on is fundamentally flawed. This is because the perceived 'gaps' that the designations are seeking to protect do not exist in reality and there is no consistency or logic to which areas are concluded to be important settlement gaps in the evidence.

The Council has then adopted this flawed evidence by including the recommended settlement gaps in the Draft Local Plan without any narrative about the merits of each gap and whether the perceived need for a gap should outweigh the opportunity to deliver development adjacent to existing settlements. The provision of local settlement gaps would actually result in the loss of Green Belt land elsewhere.

In the case of the Local Settlement Gap shown to the south of Nottingham Drive, Wingerworth (in the area known as Hanging Banks) the explanation of why this area forms a settlement gap of such importance that it should be protected from development (at the expense of Green Belt elsewhere), is severely lacking. There is already development on the east side of the A61, which is also part of Wingerworth. It is not logical to try to keep a field between two parts of the same settlement. The development of Hanging Banks would unify the settlement, not result in harm to the identity of the settlement.

The proposed settlement gap in this location is not based on a clear understanding of the settlement and should be removed from the Local Plan.

Hanging Banks, Wingerworth - 16/00656/OL
Planning permissions 14/00763/OL and 16/00656/OL have been granted for the residential development of the Hanging Banks site and we firmly believe that it should be
shown as a housing allocation in the Local Plan.

There was minimal local objection/comment to these planning applications which suggests that the protection of this land as countryside is not of significant concern to local residents.

In determining the initial outline planning application, the Council concluded that the development of this site would be sustainable and that all technical requirements could be met. In addition, the Council participated in the OPUN design review process and carried out significant work with the District Valuer. It does not make sense for all this work to be put to one side when the site is an available and deliverable housing development opportunity.

This development would deliver a high quality residential scheme which would respond to the various constraints and opportunities presented by the site e.g. site frontage to A61, retention of hedgerows, responding to the woodland, backing on to properties on Nottingham Drive, soft edge to the countryside boundaries (outward facing) and the delivery of dwellings to meet the local market and deliver affordable housing such as bungalows for the retirement market etc. The development of this site would sit comfortably adjacent to the existing built up area as a natural extension. Agricultural land and woodland will remain to the south and west and there is already development on the eastern side of the A61.

We therefore request that this site be allocated for residential development and as such that the Local Settlement Gap designated is removed from this site. The development of this site is in accordance with the Council Local Plan Strategy and would reduce pressure on the Green Belt.

Comment

Consultation Draft (February 2017)

Local Settlement Gaps

Representation ID: 5389

Received: 03/04/2017

Respondent: Ackroyd & Abbott Homes Ltd.

Agent: Charlotte Stainton

Representation Summary:

Evidence on which LSG designation is based is fundamentally flawed.

The Draft Local Plan does not include narrative about the merits of each gap and whether the perceived need for a gap should outweigh the opportunity to deliver development adjacent to existing settlements. It is resulting in loss of Green Belt land elsewhere.

Explanation for the Gap at Hanging Banks is lacking. There is already development on the east of the A61, which is part of Wingerworth. It is not logical to keep a field between two parts of the same settlement. The development would unify the settlement, not harm.

Full text:

Four letters have been submitted as representations to the Draft North East Derbyshire Local Plan 2011-2033 which is submitted on behalf of clients Ackroyd and Abbott Ltd.

North East Derbyshire Local Plan Representation - Station Road, Killamarsh

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Station Road, Killamarsh - 07/00865/FL
Full planning permission 07/00865/FL has been granted for the residential development of the site of the Old Station at Killamarsh and we believe that it should be shown as a housing allocation in the Local Plan. We have a letter dated 22 May 2015 from Adrian Kirkham which confirms that this permission remains extant. Failure to allocate this site appears to be a missed opportunity to deliver housing within the built framework of Killamarsh.

The development of this site stalled due to the crash in the housing market and then latterly due to uncertainties about the route of HS2. I confirm however that this site is now available and deliverable.

We therefore request that the site covered by 07/00865/FL be allocated for residential development. The development of this site is in accordance with the Council Local Plan Strategy and could reduce pressure on the Green Belt surrounding Killamarsh.
North East Derbyshire Local Plan Representation - Hasland

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the 5740 allocated dwellings would be on just two strategic sites. This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

In terms of the Green Belt review and the subsequent draft housing allocations within Green Belt, there is no evidence that this has been undertaken in consultation with the adjoining Local Authorities and this lack of cooperation potentially makes the plan unsound.

Land at Churchside, Hasland
The two parcels of land shown on the attached plan were previously submitted to the 'call for sites' process for consideration. They can be considered as one large site or two separate sites. They are both available and deliverable within 5 years.

We do not believe that sufficient consideration has been given to the opportunity that these sites offer to deliver housing adjacent to Chesterfield under the Duty to Cooperate.
These sites are positioned immediately adjacent to the built-up settlement of Hasland. The release of this land parcel would not result in harm to the countryside to the east or west and an area of open green belt would remain to the south, thus avoiding the coalescence of settlements.

Numerous areas of land are proposed to be taken out of the Green Belt in the north of the District and the removal of these sites in Hasland would be no more harmful to the purposes of Green Belt than the majority of those Green Belt sites that are proposed housing allocations. There is a lack of consistency in approach and because of this the Green Belt evidence is flawed.

For the reasons submitted as part of the Call for Sites, we therefore request that these sites at Hasland be removed from the Green Belt and allocated for residential development.

Another option would be to safeguard these sites for future development, possibly to deliver future housing for Chesterfield.

The development of these sites could therefore reduce pressure on the Green Belt to the north of the District and/or deliver future housing for Chesterfield.

North East Derbyshire Local Plan Representation - Holmewood
Proposed Housing Allocation - Holmewood (ab)
We wish to support the allocation of the housing site in Holmewood given the reference - ab. The site has planning permission under reference 14/00312/OL.

We confirm that this site which has planning permission is available for development and discussions are ongoing with potential developers and the landowner.

The site can confidently be included in the Local Plan as available and deliverable within 5 years.

It is important however that the viability issues relating to the provision of affordable housing and developer contributions are recognised for this site which is in a relatively low value area.

We therefore request that draft housing site allocation ab is carried forward to future drafts of the Local Plan.
North East Derbyshire Local Plan Representation -
Hanging Banks, Wingerworth
Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Local Settlement Gaps
The evidence that the Local Settlement Gaps designation is based on is fundamentally flawed. This is because the perceived 'gaps' that the designations are seeking to protect do not exist in reality and there is no consistency or logic to which areas are concluded to be important settlement gaps in the evidence.

The Council has then adopted this flawed evidence by including the recommended settlement gaps in the Draft Local Plan without any narrative about the merits of each gap and whether the perceived need for a gap should outweigh the opportunity to deliver development adjacent to existing settlements. The provision of local settlement gaps would actually result in the loss of Green Belt land elsewhere.

In the case of the Local Settlement Gap shown to the south of Nottingham Drive, Wingerworth (in the area known as Hanging Banks) the explanation of why this area forms a settlement gap of such importance that it should be protected from development (at the expense of Green Belt elsewhere), is severely lacking. There is already development on the east side of the A61, which is also part of Wingerworth. It is not logical to try to keep a field between two parts of the same settlement. The development of Hanging Banks would unify the settlement, not result in harm to the identity of the settlement.

The proposed settlement gap in this location is not based on a clear understanding of the settlement and should be removed from the Local Plan.

Hanging Banks, Wingerworth - 16/00656/OL
Planning permissions 14/00763/OL and 16/00656/OL have been granted for the residential development of the Hanging Banks site and we firmly believe that it should be
shown as a housing allocation in the Local Plan.

There was minimal local objection/comment to these planning applications which suggests that the protection of this land as countryside is not of significant concern to local residents.

In determining the initial outline planning application, the Council concluded that the development of this site would be sustainable and that all technical requirements could be met. In addition, the Council participated in the OPUN design review process and carried out significant work with the District Valuer. It does not make sense for all this work to be put to one side when the site is an available and deliverable housing development opportunity.

This development would deliver a high quality residential scheme which would respond to the various constraints and opportunities presented by the site e.g. site frontage to A61, retention of hedgerows, responding to the woodland, backing on to properties on Nottingham Drive, soft edge to the countryside boundaries (outward facing) and the delivery of dwellings to meet the local market and deliver affordable housing such as bungalows for the retirement market etc. The development of this site would sit comfortably adjacent to the existing built up area as a natural extension. Agricultural land and woodland will remain to the south and west and there is already development on the eastern side of the A61.

We therefore request that this site be allocated for residential development and as such that the Local Settlement Gap designated is removed from this site. The development of this site is in accordance with the Council Local Plan Strategy and would reduce pressure on the Green Belt.

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