Dronfield Town Council Report to Council Meeting on 3 rd April 2017 BACKGROUND Members were informed at the Town Council meeting held on 6 March 2017 that the North East Derbyshire Local Plan Consultation draft was available for public consultation between 24 th February and 7 th April 2017. The Consultation Draft sets out the proposed strategy for growth and development across North East Derbyshire to 2033, together with land use allocations and key policies that will be used to decide on planning applications. The Council are invited to submit comments on the Plan by Friday 7th April 2017 at 5pm. The Neighbourhood Plan Steering Group agreed to formulate an official Council response to the consultation on the Local Plan at the next meeting on 15 March for Council approval at the April meeting. The response for consideration by Council is detailed below. RECOMMENDATION FOR CONSIDERATION For Decision by Council i) That the Council object to the draft local plan for the following reasons: ii) a) Loss of Greenbelt land and its use for housing development. b) Level of Housing development proposed. c) Extension of Callywhite Lane. That the following Executive Summary and detailed response from Dronfield Town Council is submitted to North East Derbyshire District Council to their consultation on the Local Plan. RESPONSE Local Plan Consultation response from Dronfield Town Council These comments have been formulated using feedback from residents of Dronfield. Executive Summary: Dronfield Town Council (DTC) object to the Draft Local Plan for the following reasons: a) Loss of Greenbelt land and its use for housing development. The emerging local plan is unacceptable as it proposes a significant loss of green belt land around our town. We believe that our Greenbelt is vital to the well-being of our residents and the preservation of the character of Dronfield as a semi-rural town. It should remain protected from development permanently. National planning policy also places great weight on the protection of Green Belt land in order to preserves its openness and permanence. The local plan should be in accordance with national policy. In extending the Dronfield settlement limit closer to Unstone village, the proposals are contrary to national planning policy on the green belt, which clearly states such land is to be protected in order to prevent the coalescence of neighbouring communities. Dronfield and Unstone are two separate communities, proud of their own identity and the remaining
greenbelt separating the two are vital in that they prevent them merging into one another. It also preserves the setting and special character of the two parishes. To the North, the greenbelt provides a much needed distinct boundary between Dronfield and Sheffield. The Town s Greenbelt land also serves a vital need to prevent the unrestricted sprawl of large built-up areas and assist in safeguarding the country side from encroachment, thus providing vital access to the countryside to many of our residents. The draft local plan (paragraph 7.6) already describes Dronfield as lacking in green spaces. Removing large parcels of land from the greenbelt will result in the loss of significant green spaces. National Planning Policy Context The National Planning Policy Framework (NPPF) has at its heart a presumption in favour of sustainable development. The NPPF details that there are three dimensions to sustainable development: economic, social and environmental; with each playing a vital role. The NPPF attaches great importance to Green Belts and in particular their openness and permanence (Paragraph 79). Paragraph 80 of the NPPF sets the five purposes of the Green Belt which includes checking unrestricted sprawl, preventing neighbouring towns merging and safeguarding the countryside from encroachment. Paragraph 83 of the NPPF states that Green Belt boundaries should only be altered in exceptional circumstances. Paragraph 84 also states that local planning authorities should consider the consequences for sustainable development In order for the Local Plan to be considered sound, it should accord with paragraph 182 of the NPPF in respect of being positively prepared, justified, effective and consistent with national policy. In consideration of the NPPF, we do not consider that the emerging strategy in the Draft Local Plan accords with the NPPF as it: Does not propose the most appropriate strategy in respect of the level of development proposed in the Green Belt, particularly around Dronfield; Has not demonstrated at this stage that it is deliverable; Is not consistent with national planning policy. For the above reasons and further justification provided in these representations, we consider that the local planning authority should make significant alterations to the emerging plan, particularly in respect of the quantum and location of development proposed in and around Dronfield. b) Level of housing development proposed: The level of proposed housing development apportioned to Dronfield (860 dwellings) is based on unrealistic and over inflated housing projections, which are not supported by the evidence base to the draft plan. Furthermore, the level of growth proposed for Dronfield in the Draft Plan does not fully take account of the impact on the community in relation to local infrastructure such as; the local highways network, local schools, medical/health services and public transport. Many of these services are already under existing pressures and therefore the level of housing proposed would adversely impact on the availability of these services to existing and future residents. For example, the Strategic Transport Studies Report (2012) considered that based on 2008 data Dronfield centre had a medium/high level of delay during the morning
AM peak. The introduction of 860 dwellings to the town would significantly increase this level of delay and congestion throughout the Town. The adverse impact from the proposed level of housing would significantly reduce the quality of life for residents and spoil the community feel in the Town. We therefore consider that the level of housing in Dronfield should be appropriately revised down to a more sustainable and natural level of growth. The plan should also include an allowance for "windfall" housing sites, which have made a positive contribution to housing delivery in the District in the recent past. We consider that the Draft Plan should follow emerging guidance from the Housing White Paper which supports releasing more small and medium sized sites (p.18) to help provide housing where it is required. Once the level of housing need has been significantly reduced to sustainable levels for Dronfield, the Draft Plan should accord with the NPPF by using previously developed land first. At present, we do not consider that a brown field first approach has been taken and therefore exceptional circumstances for releasing Green Belt land cannot be justified, particularly in Dronfield. c) Extension of Callywhite lane: The proposed extension of the Callywhite Lane Industrial Estate and the new link road which is reliant on public funding onto Chesterfield Road will result in a significant increase in HGV and other vehicles travelling through Chesterfield Road and Unstone. Such extension would also have a further impact on the level of HGVs coming through Bowshaw and Dronfield bottom, past Fanshaw School and onto a very small roundabout leading to Callywhite Lane. This will worsen the existing problems. It will further impact air quality, road safety and the condition of the road on what is a planned cycle route. The extension of Callywhite Lane does not respond to an evidenced need in a town where a large portion of the working population is commuting. Detailed Response a) Loss of Greenbelt land: Dronfield Town Council disagree that the parcels of land surrounding Dronfield no longer serve all five of the green belt purposes as defined in the NPPF. Feedback from residents show that most residents feel the land around Dronfield meets all of the purposes. One of the often overlooked purposes is to promote urban regeneration. The Greenbelt surrounding Dronfield fulfil the following purposes: Providing opportunities for access to the open countryside for the urban population. Providing opportunities for outdoor sport and outdoor recreation near urban areas. The retention of attractive landscapes and the enhancement of landscapes, near to where people live. Improving damaged and derelict land around towns. The securing of nature conservation interests. The retention of land in agricultural, forestry and related uses.
The Draft Local Plan has not demonstrated the exceptional circumstances requiring the development of Green Belt. It has not provided a Brownfield review and demonstrated that all other options have been exhaustively studied. In addition, as part of the background evidence to the Draft Local Plan, the Green Belt Functionality Study (2015) considers the value of Green Belt in consideration of the five purposes outlined in the NPPF. It should be noted that all parcels of land in the Green Belt around Dronfield were considered valuable in respect of checking the unrestricted sprawl of large built up areas. All parcels of land were also considered valuable in terms of preventing neighbouring towns merging and/or safeguarding the countryside from encroachment. The land proposed to be released from the Green Belt for housing would therefore have a major adverse impact on the character of the area especially when considered cumulatively. i) Land off Shakespeare Crescent and Sheffield Road This parcel of land is vital in providing a separation between Unstone and Dronfield. The proposed development on those fields (currently farm land) together with other proposed developments nearby (Callywhite lane extension, new housing on the site of Fleur de Lys) would have a dramatic visual impact as it would effectively create a continuous built up area along the Chesterfield Road with no distinction between the two parishes. The cumulative effect of these developments will increase traffic, pollution and impact on the local wildlife and Nature Park nearby. ii) Hallowes Lane Removing part of the Hallowes golf course out of the green belt would lead to a loss of recreational space. The Draft Local Plan also recognises that there are challenges relating to accessing the area. Hallowes Lane has no pedestrian path for much of its length and there are already concerns about traffic speed and volumes. The removal of this land from Greenbelt and development would impact residents' access to the local countryside. This area is commonly used by runners, walkers and bicycles. The Green Belt review (2017) also considered that development of the site would adversely impact on the five purposes of the Green Belt as defined in the NPPF. iii) Land off Hill Top Road The roads leading to this parcel of land are inadequate to provide access to what would be a significant increase in traffic. The Draft Plan also refers to the potential coal site risk in the area. (para. 5.21) The Green Belt review (2017) also considered that development of the site would adversely impact on the five purposes of the Green Belt as defined in the NPPF. iv) Land North of Eckington Road This would lead to the removal of important recreational space which would have a serious impact on the Moss Valley Conservation Area as described in the draft Local Plan. The Moss Valley is an important local asset and provides high quality landscape. Any development on this area would be visually detrimental. (The evidence base to the Draft Plan also does not support development on this site: The Green Belt Functionality Study considered this area north of Dronfield as the most valuable parcel of land in terms of Green Belt function; The Green Belt review (2017) considered that development of the site would adversely impact on the five purposes of the Green Belt as defined in the NPPF;
Agenda Item 12 The Sustainability Appraisal (2017) of the site gave the site a low score in comparison with all sites considered for housing in Dronfield, with impact on landscape highlighted a significantly adverse. The proposed allocation of this site would therefore not accord with the evidence base and national policy.) v) Stubley Drive and Stubley Hollow These are relatively small areas but still provide access to countryside to nearby residents and provide a much needed green space in an otherwise built up area. Access would also be difficult and increase an already well documented difficult situation with regards to volume of HGV s using Stubley Lane as a main route to Gunstones. b) Housing development proposed: i) Relationship of the Draft Local Plan with other local plans and the duty to co-operate (pp4 1.16) Dronfield Town Council is content that rather than it being an economic or social hub for the District, Dronfield is predominately a residential town with a separate identity distinct from the District and that economically, only a minority of residents have worked in the town itself tending to commute to larger employment hubs such as Sheffield, Chesterfield et al. No details have been provided on how the District is co-operating with other local authorities to meet their own, outside this District, housing needs, or disclosing any intention to enter into such arrangements to help them. The assumptions for 860 new houses are in our opinion, based on inflated assumptions on growth and jobs with possible multiple or double counting. This means that the main commuter job market destinations such as Sheffield or Chesterfield may each be counting and competing for the same person and so their jobs/houses may being counted more than once. The Appendix C Projections does not set out its bases and assumptions underlying these projections which are also substantially higher than the historic rate of completions for Dronfield as set out in Appendix A. ii) No evidence is provided to reconcile the 860 completions set out in Appendix C and how this will actually be achieved each year from the clear evidence in Appendix A on what has been built and sold evidencing a normal sustainable rate meeting local market demand. The District should provide the number of successful planning applications against actual completions. DTC commends two 2017 reports by Shelter, New Civic House Building 2017 and Shelter 2017. The Shelter analysis of 12 month rolling data from the land registry (2016) shows too few homes, built too slowly and a price premium for new homes versus second homes; it provides support for the view that in general, developers limit production to a pace which the local market can absorb so as not to reduce local sales prices. New builds are sold at a premium to existing housing stock in each English region from 14,000 to 68,000 per unit and our East Midlands is at the higher end of this premium. The gap between the existing availability of housing has not been reconciled with evidence and appears to demonstrate too high and unrealistic assumptions. If there were a significant shortage of housing in Dronfield itself, then its house prices relative to the competing locations such as Sheffield or Chesterfield would be rising faster than those alternative residential areas such as Totley, Bradway, Dore or Abbeydale. No evidence has been shown to this effect.
There is no evidence provided that suggests Dronfield should have 30% of affordable housing. (p84) The housing Market Assessment makes a number of assumptions which are becoming dated. The Draft Local Plan states that Only a quarter of the population in North East Derbyshire cannot afford market housing. This would suggest a need for 25% only in the whole of the District. More evidence should be provided by the Plan to support the 30% need for Dronfield (40% in other areas). Evidence such as housing waiting list, homelessness figures, demographics. The latest census show that the demographic in the District is growing slower than the rest of the Country. Dronfield has an aging population and this should be considered by the Draft Plan in respect of the percentage of affordable housing apportioned to Dronfield. The type and levels of housing required in Dronfield should be supported by a local needs assessment of the Town which is currently not available. The NEDDC Draft Local Plan provides no evidence that the District is undergoing a Demographic Transition which would require their proposed numbers. In fact a top line analysis of the U.K. Census for 1991, 2001 and 2011 suggests the opposite. The District population has only increased from 97,800 in 1991 to 99,023 in 2011 and in fact depopulated to 96,940 in 2001. The current (all numbers 2011) District average age is 43 and median age 45 compared to an England average and median age of 40. The population of England increased from 48m in 1991 to 49m in 2001 through to 53m in 2011. This would infer that the District population is no undergoing the increases in population and Demographic Transition seen elsewhere; in fact the 2011 Sheffield average age is 38 and median age is 36 with its census population increasing by 7.6% from 513,234 in 2001 to 2011 with a reported estimate for 2016 of 569,700. We believe that further evidence of changes in the population and trends should be undertaken by NEDDC and in an ideal world would wait for the results of the next census to be available before removing Greenbelt forever from the town, at best NEDDC seems to be trying to satisfy Sheffield's housing demands without evidence or admission when the District population Structure appears stable and in a lower growth and older structure. iii) Tourism and the Gateway to the Peak District (pp21 D3) and pp.23n1 Regeneration Networks for the Dronfield Town Centre: Whilst these are welcome objectives, these goals give no detail and must be seen against the stated objective of protection of natural assets such as open spaces, countryside access, protecting local amenities (pp.22d13) and environmental quality. A 860 housing figure will negatively impact on a limited infrastructure, some of which is difficult to expand, access routes such as Hallowes Lane are narrow lanes and difficult to widen. There are current levels of anti-social heavy traffic and parking resulting from existing industrial use near or within residential areas creating excessive noise, anti-social parking, bad odours, HGVs are using small lanes such as Stubley Hollow to Stubley Lane 24 hours a day. In order to develop Dronfield as a destination for hospitality, tourism or shopping, the issue of too many stakeholders in key land sites around the Rail Station or the area in front of the Civic Hall and Leisure Centre needs to be addressed by new offerings, such retail property, which attracts anchor tenants with the draw to bring in customers. iv) Sustainable Places Chapter 7 pp125 to pp129 We note that the no alternative options were either considered or selected, we also note that the key evidence base has not included local knowledge or data collected from residents and local businesses. We therefore challenge the assumption that Dronfield is the social
and economic hub in the District or even its north (SP1 (a) and therefore question the need to allocate more employment land at the expense of allocating that land for future residential or recreational use. This needs further research and evidence. We contend that all possible Brownfield Sites may not have been exhaustively considered. The Draft Local Plan seems to suggest that if these exist, they should be identified now and be site specific. DTC rejects this restriction as (i) more direct research and consultation is need over the next 3-6 months with Dronfield residents and business able to produce such a list and to establish the real level of local demand for industrial property (ii) that a list of sites should not be rejected if they come without landowner's approval, it is unfair that land can be taken out of Greenbelt and granted planning permission with no obligation on the land owner to develop the site (See Shelter Report 2017 and (iii) that Dronfield s place in the wider local economy and geography is as a leading quality residential and commuter town and that its economic development and strategy should support this c) Callywhite Lane Extension: North East Derbyshire as the District has no uniform economy or civic identity, Dronfield does, it has an old history recorded in the Doomsday Book Since the Gosforth Valley estate was developed from the late 1960 s it has been a significant dormitory town attracting residents with higher incomes, skills and qualifications, but who mainly work, or worked before their retirement in a main employment hub elsewhere. What work has been done to establish that these new employment sites will create high EVA (Economic Value Added) businesses? Or, higher skilled full time employment paying higher incomes, or recruited locally? Will these new employment sites instead create predominately part time, lower pay, semi-skilled or unskilled jobs, many on zero hours or agency contracts, from outside the District? If Dronfield was an economic cluster of specialised high EVA value businesses we may conclude differently, but it is not. A review of the top 20 business ratepayers shows that the main business rate payers are Schools, Medical Centres and Supermarkets etc. which support a resident based economy. DTC therefore challenges the assumptions, strategy and policy for the expansion of employment sites in Dronfield, so part of these sites could be rezoned to meet housing or recreation needs. Dronfield Town Council support new employments sites which: Promote the Draft Local Plan Objectives in relation to regenerate the town centre to become a destination and as a gateway to the Peak District; Are Green with low environmental impact and that existing businesses which cannot meet these are given incentives to move Have high EVA, are likely to employ full time, not agency or part time and have potential for higher paid, skilled posts Continue to support the expansion needs of existing business subject to (ii) above Support new venture creation, self-employment and small business by residents of Dronfield and the District Offer key Support Services for a residential town e.g. medical centre or supportive housing Local Needs: The overall new housing requirement for Dronfield should be based on its real internal market and not inflated assumptions about growth or employment when that growth located in neighbouring employment hubs
Diffusion: Whilst we disagree that the District is a uniform economy, if it was, the local plan should instead allocate more new housing in smaller zones evenly spread throughout the District to reflect this. Uncertainty: The Callywhite Lane extension is reliant on a Chesterfield Road link, which is conditional on public funding and carries a delivery risk of uncertainty. Conclusion No greenbelt land should be used for housing development. Brownfield site around the Town should be reviewed and checked for viability and sustainability. A proposal for 860 new houses to 2033 is too high and based on unrealistic and inflated assumptions about jobs and growth, which ignore Dronfield s separate identity and economic position in relation to the District. It should therefore be reviewed. As an alternative, the housing and employment site requirements should be in proportion to existing and proven market evidence, taking into account existing needs and to include an element for the real level of suppressed demand from the Dronfield itself as opposed to a speculative figure for satisfying areas outside the District. A full review of infrastructure and the cumulative effect further development should be undertaken.