LOCAL PLAN UPDATE ~ AUGUST 2019

LOCAL PLAN – UPDATE – AUGUST 2019

As I advised previously the new Conservative-led administration have ‘paused’ the Local Plan, i.e. it will not be implemented until further consultation has happened with the government Inspector.

Letters have been exchanged during which the current leaders of NEDDC have sought the advice of the Inspector over how they can further protect Green Belt areas ‘at risk’ (from development), including those identified within Killamarsh.

This is a tricky legal situation because of the policies put in place by the previous administration, and the fact that the Local Plan is a long way down the line of completion.

The Inspector has responded to say that she sees three options;

1. Continue with the current plan, with further consultation on minor changes already made (none of which helps us),

2. Review the evidence base in respect of site allocations to see whether any new evidence is available (this will involve further public consultation),

3. Withdraw the Plan (and presumably submit another Plan).

There is no indication at the moment as to which option NEDDC will pursue.

I am making my own representations to the new NEDDC on behalf of RAGE members, particularly in respect of the Green Lane site (where I have lots of relevant information) and the Rotherham Road site (where I have very little information).

I will keep you updated on developments, but I will not post for the sake of it; merely when something of relevance has happened.  It may be a while!

The two letters (initially from the Council, with a response from the Inspector) can be viewed at:-

https://www.ne-derbyshire.gov.uk/index.php/local-plan-examination

When you reach this site select   ~   ‘Latest News and Updates’   then scroll down to 7/8/19 and you will see 2 x documents ED85 and ED86

 

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APPLICATION TO BUILD 397 HOUSES – OFF GREEN LANE

Please note the following link to an objection letter from Paul Johnson, chairman, RAGE to NEDDC Planning Department

Local Plan – application for OLP (Green Lane)

 

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COPY OF PAUL JOHNSONS RESPONSE TO LOCAL PLAN DOCUMENT – PUBLIC INQUIRY2018

Below you will find a LINK to a copy of RAGE Chair Paul Johnsons response to the Public Inquiry on the proposed NEDDC Local Plan for additional Housing and it’s affects on Killamarsh.   Please feel free to download/print this off to assist you in formulating your own response for submission.

Your response needs to be submitted to the Inspector before 5pm MONDAY 22nd OCTOBER, which is NEXT MONDAY

The submission needs to be paper based, in TRIPLICATE, STAPLED and HOLE PUNCHED and needs to be sent to:-

.     Louise St. John-Howe     Programme Officer

.     PO Box 10965

.     Sudbbury

.     Suffolk   CO10 3BF

Please also email an electronic copy to her at   programme.officer@ne-derbyshire.gov.uk

Here is Paul’s response

Local Publication Plan Public Inquiry Oct 2018 – Paul Johnson

Just after this post you will find a copy of our MP, Lee Rowley’s, response as well as the official documents relating to the inquiry

PLEASE MAKE YOUR VOICE HEARD

 

 

 

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Copy of MP Lee Rowley’s response to Local Plan Document

As promised at the meeting at Nether Green Tuesday 9th October, the following is a link to MP Lee Rowley’s response to the Local Plan

Local Plan response – 05042018 – Lee Rowley

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NEDDC Local Plan 2018 – Main Matters, Issues & Questions (MIQ)

The following are THREE documents relating to the  NEDDC Local Plan 2018

 

North East Derbyshire Local Plan Examination

Inspector – Mrs S Housden BA (Hons) BPl MRTPI
Programme Officer – Louise St John Howe
programme.officer@ne-derbyshire.gov.uk

EXAMINATION BRIEFING NOTE

ED12 Examination Briefing Note 28.8.18

 

Examination of the North East Derbyshire Local Plan 2014 – 2034

Draft Hearings timetable (Version1: 28 August 2018)

Venue: North East Derbyshire District Council Offices, 2013 Mill Lane,
Wingerworth, Chesterfield, Derbyshire S42 6NG

ED10 NEDDC Draft Timetable 29.8.18 minus policies

 

 

Main Matters, Issues & Questions (MIQ)

ED11 Inspector’s Matters, Issues and Questions 28.8.18

 

 

 

 

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BREAKING NEWS FROM OUR MP & HARWORTH ESTATES/CODE

Lee Rowley and myself recently had a meeting with Adam Murray and two of his Colleagues from CODA/Harworth Estates at which their proposals for housing development on the greenbelt land between Green Lane and Upperthorpe Road were discussed.

They informed us that they would be putting in an outline planning application by the end of this month (June) for 396 houses to be built on the site. However, they said they don’t expect that their application will be approved until into next year.

It is expected that the building will be done by two separate developers.

When asked what types of properties would be built they said all types up to 4 and 5 bedroom executive houses. They added as an after thought that there would be SOME affordable. Lee asked if there would be any bungalows but it would appear not.

We queried the issue of the land being greenbelt and they suggested that Lee should be following his party line.

When we raised our concerns about the impact on traffic in the village they suggested that there was only ONE hot spot with the amount of traffic and that was the small roundabout near the Midland pub. Their attitude was that traffic on this roundabout is so bad already that adding the traffic from another 396 houses wouldn’t make the problem any worse than it already is !!!!!

They are clearly putting in their application to tie in with the North East Derbyshire District Council Local Plan (on a “you scratch my back, I’ll scratch yours’ basis).

WHETHER OR NOT YOU WANT THE HOUSING THE BE BUILT, IT IS ESSENTIAL THAT YOU LET YOUR VIEWS BE KNOWN.

You may be concerned about the village losing its GREENBELT and being completely covered with concrete and having no green spaces for future generations and the impact on the environment and wildlife.

If this is not your concern you may have issues about the amount of traffic coming in, out and around the village. The lack of car parking spaces. The air pollution, The impact on the schools and the GPs surgery. Definitely on our quality of life.

I am one of the three new members of the Parish Council (thank you to all those who voted us in), and for the past seven years I have been a member of R.A.G.E. (fighting against the excessive building of houses in Killamarsh).

As a member of Killamarsh Parish Council, a member of R.A.G.E., and as a resident of Killamarsh, I will continue to object to CODA/Harworth’s plans, but we need your help and support.

In our meeting Lee Rowley stated very clearly to them that he will be backing the people of Killamarsh and objecting to the plans.

It is now time for the people of Killamarsh to say what THEY want for the village. When the time comes PLEASE put in your objections AND attend and show your support at the Planning meeting when it happens.

If you would like to contact us – please email enquiries@killamarsh.org

Pat

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REPRESENTATION DOCUMENTS RE: 2018 LOCAL PLAN

The following are individual representations regarding the 2018 Local Plan

NED-Plan-Representation_form-Ch-2..docx (207 downloads)

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NED-Plan-Representation_form-2A.docx (128 downloads)

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NED-Plan-Representation-form-4-1.docx (126 downloads)

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NED-Plan-Representation-form-4A-1.docx (104 downloads)

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NED-Plan-Representation_form-4B.docx (155 downloads)

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NED-Plan-Representation-Form-5.docx (213 downloads)

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NED-Plan-Representation-Form-6-1.docx (234 downloads)

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NED-Plan-Representation_form-7.docx (217 downloads)

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NED-Plan-Representation_form-8.docx (116 downloads)

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NED-Plan-Representation_form-9.docx (135 downloads)

 

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NEDDC Local Plan Representation form

Below is a LINK to the NEDDC Representation Form which is required for submitting your comments / concerns relating to the Local Plan.

http://www.ne-derbyshire.gov.uk/images/Repository/R/Representation_form.docx

There is a 6 page document GUIDANCE NOTE to assist in completing the Form but it’s quite confusing so i’m attempting to compile a more user-friendly note & will post it here as soon as i’ve managed it.

It is also possible to submit your comments ON-LINE using the link below :-

https://bolsover.jdi-consult.net/localplan

 

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NEDDC DRAFT PUBLICATION LOCAL PLAN 2018 – HOW TO OBJECT/COMMENT

NEDDC DRAFT PUBLICATION LOCAL PLAN, 2018

HOW TO OBJECT/COMMENT.

I have placed my comments and supporting evidence on the RAGE website.  The document is quite lengthy, but then it is distilled from literally thousands of pages of planning documents and background evidence papers – some of the latter being more lengthy than the Plan itself.

I have tried to provide my own views, backed up by evidence where this is available.

It is important that you respond in your own words to any of the issues that you wish to object to, or support.  Your response must be what you think about the issue, not what I have put.  My own views are published in the hope that they may help to crystallize your own thoughts.

If you intend to use the online Consultation System you may find it to be quite complicated.

At the Killamarsh Consultation evening I did ask Helen Fairfax, the Planning Policy Manager, if it was possible to send a letter of objection/comment.  She said that it was but the probability was that it would not be seen by the Government Inspector because it was not in the specified format.  It would be fortunate if he/she saw it.  However, if that is what you want to do, send it anyway.  It will be counted and should be read.

Paper copies of the form can be downloaded from the online form.  Can those more technically aware help those not so aware, if they need it.

Kevin Wood is doing a helpful guide to completing the form which will be on the RAGE website together with this document and my submission.

A separate form must be completed in respect of your comments about each of the sections in the Local Plan.  I have a couple of spare forms if they are needed.  There are 10 chapters to the Local Plan and so you will require 10 separate forms if you want to comment on them all.  I have commented on 7 of them. Each of your comments must be no more than 100 words long, although your full submission may be as long as you wish.  Your 100 word précis should be shown in Question 3 of the Representation Form.  Anything more needs a separate sheet of paper. 100 words equates to about 9 lines of writing.

If you would like a meeting, at a convenient location, on any day this week, please contact Pat at www.secretary@killamarsh-rage.co.uk.  If you have any specific queries we can try to help with them. Let us show that Killamarsh does care!

Please cry for help on the Rage Facebook page, or on the Rage website if you need it, but please ensure that you make the effort to comment.  This is our last chance before the inspection of the Plan by the Government official.  Complaining then may be fruitless if we have shown indifference at this last consultation stage.

Paul Johnson, Chair of R.A.G.E.

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NEDDC – LOCAL PLAN. PBLICATION DRAFT 2018

NEDDC – LOCAL PLAN
PUBLICATION DRAFT, 2018.

My comments relate to the plans in respect of the north of the District, but my specific
interest is in the effect that issues contained within the Publication draft Local Plan would
have on Killamarsh.

Chapter 2 – Spatial Portrait.

This shows that the Constrained North has a mining history and comments that little
evidence of it exists today.

This is true of the overt aspects of mine working, but not so of its legacy. Sites will require
Coal Mining Assessment Reports concerning the known mines worked during the 20th
Century, but little is known, other than through historical records, about mines pre-dating
this period.

Historical accounts detail hundreds of small, sometimes family owned and operated, mines, stretching through Killamarsh as far as Barlborough, that have been abandoned without the benefits of the Health and Safety concerns prevalent today. It is known that there are dangerous areas in the prime site of Killamarsh (Westthorpe Fields) because a previous farmer on the site had the misfortune to have his tractor fall into a sinkhole on the plot. Recent drilling has discovered a dangerous area near to a potential entrance to the site.

To support the dangerous ground theory a number of established houses on Green Lane
have suffered significant subsidence, as their own submissions will verify.

As evidence of this research in 1947 into the Nationalisation of Mines shows that there
were more than 442 abandoned mine workings in the immediate vicinity of Killamarsh and Barlborough. Their location is not known with any certainty.

One specific one relates to a mine known as Worrall’s Colliery which was sunk in ‘green
fields off the main Rotherham Road in Killamarsh’ (the site of one main development).
Owned by JJ Worrall, the mine was sunk by his grandfather. It closed in the early 1900’s
but was reopened in 1913, operating until 1943. The shaft drove 60 feet underground(source Holbrook and Halfway, the early years, by James Walton, 1996).

This network of subterranean tunnels holds hidden dangers, including subsidence and gas
escapes, not only for workmen on the site but to new home occupiers and existing
residents.

This does not support sustainable development, more likely, dangerous development.

Paragraph 2.6 acknowledges the link between Killamarsh (and others) to the Sheffield
conurbation, with just under 25% of people commuting out of the District to work in the
city. Other evidence-base documents state that 61% of people commute out of the district
daily. This is relevant to a later comment on the employment strategy, jobs growth and
sustainability.

Affordable Housing Need (LC2)

The requirement for affordable homes within the District has varied wildly throughout the
protracted term of the Plan’s submission.

– 2012 consultation version – requirement 494 affordable homes p.a.
– 2015 consultation version – requirement 381 affordable homes p.a.
– 2018 publication version – requirement 172 affordable homes p.a., enhanced by
demographic requirement to 248, with 10% added, presumably for ‘good luck’, giving a total of 273 affordable homes p.a.

Whilst accepting that situations change over time it does appear that there is a declining
trend, which makes the enhancement of the affordable homes ‘need’ figure aspirational,
without good evidence.

Research by the National Trust has shown that some 330,000 building plots, each with
planning permission, have not been developed, mostly by the ‘big’ builders.

Research carried out by NEDDC shows between 2006 and 2011 there was a growing
proportion of larger houses built, with a significant decline in 1 or 2 bedroom properties.
Equally disturbing are the figures which show that, between 2002 and 2011, only 9.5% of
the properties built were in the affordable category – this in an era when the requirements
was 40%. As I understand from previous evidence documents then need is for one, two and three bedroomed homes. I have not seen any more up-to-date figures

Whilst I agree that the District Council should have the provision of affordable housing as a priority it should be to provide a ‘reasonable’ number of affordable units in ‘appropriate’ places, for ‘local’ need. This should exclude Green Belt areas.

This view is supported by a comment, reported in a national newspaper, by a spokesperson for the Department of Communities and Local Government. When commenting about the NPPF she said, “This will put power back in the hands of local people, ensuring they are in charge of deciding the areas they wish to see developed and those to be protected, including green spaces of value to the community”.

Killamarsh Residents Against Greenbelt Erosion (RAGE) has a petition with more than 1,100 signatures of local residents strongly opposed to the development of Green Belt sites surrounding Killamarsh. The signatories to this petition, and many others not yet mobilised, will form a significant opposition group in the prevention of building on Killamarsh Green Belt land.

Paragraph 2.15 relates to the alleged link between affordability and home owning,
apparently necessitating the building of more homes in the north.

It is worth pointing out that home values have fallen in real terms by 22% in the Killamarsh

West ward and by 12% in Killamarsh East, according to the BBC Business News report on
the 17th October, 2017.

Paragraph 2.16 espouses the ‘need to provide employment locally in order to provide the opportunity for people to work close to where they live.’

The two employment sites specified for Killamarsh are located at the Westthorpe Business
Centre and the Norwood Industrial Estate. Westthorpe has capacity for one more unit only
on a site of .35 of a hectare. The last time I saw figures for this complex it was operating at
about 50% of capacity.

The Norwood site has proved unpopular with developers, according to the District’s
environmental scan. This is, no doubt, because of its proximity to the former sites of
Yorkshire Tar Distillers, Lee Environmental and, currently Veolia, in view of the
significant contamination known to have emanated from those sites.

This is reinforced by the assessment of the site, during a study entitled, ‘NE Derbyshire
Employment Sites’, by Aspinall Verdi, which concluded that Norwood (and Callywhite
Lane at Dronfield) each scored 13 – the lowest of the sites studied. In contrast, Markham
Vale and Biwaters/Clay Cross scored 25 and 23 respectively.

The scoring parameters encompassed strategic communications, proximity to the labour
market, local services, adjoining uses, development constraints and attractiveness to
occupiers.

How does this lack of options for employment equate with the regeneration aspiration
and the building of homes for local employment use.
——————————————————————————————————-
Chapter 4 – Spatial Strategy

Paragraph 4.2 relates to sustainable development.

The Plan states that sustainable growth will lead to residents enjoying a ‘better quality of
life’, but that it means ‘encouraging suitable development.’ The two are, to a large extent,
incompatible, unless there is sufficient capacity within settlements to sustain increased
development. If not it will diminish the quality of life not only during the development
process, with all the inherent inconvenience and upset that this entails, but also by ‘building in’ pressure on services and facilities for the longer term.

Paragraph 4.31 appears to recognise that villages such as Killamarsh will be used as
‘dormitories’ for other areas where employment and the economic benefits that engenders
for that area, not Killamarsh. Due to traffic movements, and the pollution accompanying
them, through commuting, this is unsustainable development.

The negligible proposed infrastructure developments for Killamarsh within the Local Plan
are laughable in the context of the massive 20th Century development already undertaken,
coupled with the planned addition of 523 homes, leading realistically to 2,000 extra people and 1,000 extra vehicles within the village. This is an extra 20% added to the current population of Killamarsh.

No road improvements are planned by either Derbyshire County Council or the District
Council, with the only potential alleviation being ‘new site specific’. Even then any light at
the end of a very dark tunnel depends on the unreliable source of developer contributions
via S. 106 agreements. Factor in the ‘viability get-out-of-jail-free card’ and the prospects
of any positive benefits for current residents are extremely uncertain.

Paragraphs 4.6 – 4.12 detail the rationale for the figure of 330 new dwellings p.a. This
figure contradicts the Government target of 276 dwellings p.a., based on the aspiration for
the maximum increased employment growth. The CPRE suggest that this number should
be 270.

The document links housing requirement to employment growth, pitching the latter right at the top of an estimated scale. I am aware that such targets should be challenging, but I am also aware that such targets should be realistic and achievable. These are not.

The rationale is incompatible with the requirements within paragraph 17 of the Housing
and Economic Needs Assessment, PPG, which requires that estimates be ‘clearly explained and justified on the basis of established sources of robust evidence’. This aspirational target does not meet that criterion. The Local Plan admits as much where, in paragraph 3.33, it states that ‘a level of policy intervention and support would likely be required’ to achieve the challenging target.

GL Hearn’s comments within the Economic Growth Analysis, 2018, confirm that when
considering a regeneration/growth scenario, the District Council should ‘test the potential to support the higher growth or regeneration scenario figure in bringing together the evidence during the Plan-making process.  Such evidence has not been presented; neither has the policy intervention been identified or explained in the Plan.

Settlement Hierarchy. (Paragraphs 4.29 to 4.35 and Table 4.2)

The Settlement Hierarchy approach designates the areas with current facilities as being
appropriate for future development. This takes for granted that the facilities present are
adequate, or will endure.

Taking Killamarsh as an example, there is a bus service, the Council Leisure Facility, a
Post Office, a Doctors Surgery and Dental surgery and numerous shops. This may seem
adequate on a shallow (desk top) overview.

The reality is somewhat different.

The private provider of the bus services is currently withdrawing some services.  According to local sources, other services are planned for withdrawal, whilst others are significantly curtailed.

The Council Leisure facility is a massive drain on local finances and the Parish Council has previously had had to borrow money from the NEDDC to survive until the end of the financial year.   It runs at a massive overspend which, for the new Council Tax year, has to be made up by a huge rise in the Parish precept. This causes much local disquiet.

The Post Office survived the last ‘cull’ of similar offices and its continuing existence must be debateable.   The Doctors surgery, despite a recent extension, is full to capacity and the Dental Surgery is not able to accept new NHS patients for the foreseeable future.

The shops consist predominantly of a mixture of fast food outlets (hardly conducive to a healthy lifestyle or the fitness aspiration of the Vision), and a number of hair and nail salons.   The evidence base shows that 90% of evening leisure activity in Killamarsh involves takeaways  Apart from being an indictment of lifestyle in Killamarsh it does not help any objective aimed at healthy living.

There is no bank (except a limited facility at the Post Office and Co-op), no butcher, minimal bakery options and no fresh fish or seafood outlet. The greengrocer was forced out of business by a very limited, publicly funded option provided by the Parish Council
which has itself been supplanted by the Aldi supermarket.

The Aldi Supermarket, has replaced the former Kwiksave Supermarket. Although an excellent facility for local people it also attracts people from other local townships, exacerbating the problem of greenhouse gas emissions.

People who have the option also travel to Supermarkets in South Yorkshire for their retail needs. The situation is unlikely to alter significantly in the future. This will increase the need for vehicle journeys, not reduce them, as per District Objective 10.

There are no planned road improvements in the Infrastructure Plan and a bad traffic situation for Killamarsh will become significantly worse if more houses are built here, now, as planned, or if future development is concentrated in the areas with supposed good facilities.

This is a recipe for the demise of the village, not a renaissance.

Green Belt Review (SS10).

Paragraph 4.67 acknowledges that Green Belt boundaries should only be altered in
‘exceptional circumstances’ (paragraph 83, NPPF).

Paragraph 4.68 again refers to land values being driven up by high demand, but the BBC Business report previously referred to shows a significant ‘real terms’ drop of 22% in
Killamarsh West, where a major site of 330 dwellings is suggested, and 12% in Killamarsh
East, where a further 70 are proposed.

Case Law (Gallagher v Solihull BC, 2014) states that the preparation of a Local Plan is not
sufficient in itself to justify alterations to a Green Belt boundary. It is necessary to show:-
– Effective use of suitable brownfield and estate generation;
– The potential offered by under-used land (including surplus public sector land);
– That the optimisation of density of development has taken place;
– An exploration as to whether other authorities can help to meet some of the need of
the identified development requirement.

Once again, this asks a question about whether housing need has been objectively and
rationally decided. There are a number of issues that suggest that this need has been
overestimated and that other provision that should have been included in the appropriate
calculation have not been so included.

In paragraph 4.7 of the Housing Topic paper (2018), used within the evidence base,
NEDDC demonstrates that planning permissions for dwellings on major sites in level 1 and 2 settlements are included as part of the housing supply up to 17.1.18. However, major
sites in settlements 3 and 4 were only included up to 31.3.17, meaning that sites that gained planning permission between 31.3.17 and 17.1.18 have been excluded from the housing supply.

A 5% lapse rate, based on past trends, has been applied to the figures. Since 2014 records show that the lapse rate figure has been well below 5% (Paragraph 8 of the Five Year Housing Land Supply Statement, 2017).

In fact, Table 2.13 of the Housing Topic Paper (2018) shows that since 2012/13 the average lapse rate has been 2.13%. More up-to-date information may show a further diminution in the lapse rate. The LGA guidance suggests that lapse rates should be based on ‘historic data that sets out the number of permissions compared with completions on similar sized sites’, not on a ‘standard approach’, which the 5% calculation appears to be.

Equally, the figures shown for Strategic Sites exclude large numbers of potential dwellings
for various reasons:
– 660 dwellings at the Coalite site – because of the HS2 route (as yet unconfirmed)
affecting a small part of the estate;
– Chesterfield Road, Holmewood – 325 dwellings not deliverable, although an
additional 225 are assessed as deliverable on the site;
– The Avenue – 700 granted planning permission, but not another 400 potential ones
without current planning permission, despite the site being under construction
making the additional 400 potentially deliverable.

The figures also fail to include windfall sites granted planning permission since 31.3.17.

Yet another factor is the number of empty homes in North East Derbyshire. As at March,
2017, there were 731 such homes. In February, 2018, there were 941. The Council are
currently assisting in bringing 30 of these back into occupation.

Taking account of this excluded potential would completely obviate the need to build on any Green Belt land. It also contradicts the ‘extreme circumstances’ argument used to undertake a Green Belt review in the first instance.

A Local Plan submitted by County Durham was rejected by the Government Inspector
because it was unjustifiable for the planning authority to propose Green Belt development
because the decision to do so was made before evidence of exceptional circumstances was
provided. The same judgement should be applied to the NEDDC Plan because the
‘exceptional circumstances’ have not been evidenced.
——————————————————————————————————-

Chapter 5 – Living Communities

Killamarsh – Specific Sites (Paragraphs 5.32 – 5.40) (Policy SS2).

Paragraphs 5.32 – 5.34 inclusive deal with a major site at Westthorpe, Killamarsh. The site
is currently within the Green Belt and is expected to deliver 330 dwellings, the majority
within the first 10 years of the Plan.

This site is within the High Risk area because of historical mining work. There is anecdotal
evidence of house subsidence and sinkholes on the planned site.

The Sustainability Appraisal for this site raised a number of issues:-

– Significant increase in Greenhouse Gas emissions;
– Inefficient land use;
– Outside limits for GP and hospitals;
– Close to site of three Grade II listed buildings;
– It would alter the urban fringe and intrude into the countryside;
– Disturbance to local wildlife sites, potentially damage ancient hedgerows, trees and
biodiversity;
– In a mining high risk area.

This site is owned by Harworth Estates Limited, Part of the Harworth Group of companies.   The land passed to RJB Mining Ltd., which became UK Coal Limited which had Harworth Estates Limited under its corporate umbrella.

Other residents suffered the dust, dirt and inevitable disruption that the scale and nature of working coal mines entail. After the collieries closed subsequent reclamation projects
returned the land to its former rural appearance. These sites are now used as recreational
areas by walkers, dog walkers and those who enjoy the proliferation of species of flora and
fauna that abound in the fields.

It is interesting to note some comments made by RJB Mining (UK) Ltd. When they
obtained permission to open cast for coal on the Westthorpe and High Moor areas of
Killamarsh, and promised to restore the sites:

“….some of the lower quality land will be converted into woodland and wildlife habitats to
enhance the species diversity and recreational amenity of the area.”

“Steps will be taken to protect and preserve part of this site, and upon restoration create a
larger habitat than presently exists to enhance wildlife interest in the area.”

“The…. scheme is an opportunity to substantially enhance wildlife habitats and species
diversity. Advance planting, including the creation of a wetland habitat will extend beyond
the site boundary…”

As you will be aware, RJB Mining was the predecessor of UK Coal, which owns Harworth
Developments, and which now wants to build 330 houses (if they are to be believed) on this same land. To allow them to do so would be tantamount to an act of environmental criminality.

There are five footpaths (not four) crossing this proposed development site, passing through the created wildflower meadow. These are used by local residents to walk dogs or just to walk for health and recreation.

The road network around the site is totally unsuitable for the addition of large numbers of
additional people and vehicles.

The unique position of Killamarsh within the North East Derbyshire District needs to be
considered as well.

Situated on the far north eastern corner of the District it abuts Sheffield City, Rotherham
Borough, Bolsover District and Chesterfield Borough councils.

Due to this unique position Killamarsh is vulnerable to development in the four areas and,
to a lesser extent, to that within the Bassetlaw District and Eckington. Here is an example
of relevant development within those areas:-

– Clowne (Bolsover District) – 1,800 homes and an industrial estate;
– Sheffield City – 745 dwellings in directly adjoining areas;
– Bolsover (Bolsover District) – 500+ dwellings;
– Cresswell (Bolsover District) – 277 dwellings;
– Whitwell (Bolsover District) – 200 dwellings;
– Barlborough (Bolsover District) – 150 dwellings;
– Eckington (NEDDC) – 400 dwellings.

All of the named development will impact the roads around Killamarsh, with the most
likely to be affected being the unclassified Spinkhill Road/Station Road/The Avenue/Syday Lane being most impacted. This will be the main road used by residents of the proposed Westthorpe estate if travelling anywhere south of the District.

The Transport Evidence Base, 2017 shows that employment and Residential trip generation is estimated at 586 additional trips (a.m. – 1 hour only) and in the evening (1 hour only) 585 additional trips. The ‘rush’ periods extend to more than two hours each in both morning and evening.

The report places Killamarsh in 15th place in the Transport Sustainability table (out of 35),
with only Clay Cross of the Level 1 settlements being worse off at 18. However, Clay
Cross will benefit from the provision of significant money to ameliorate problems on their
main trunk route, the A61.

The same report includes a map showing where potential work may ease traffic flows in
Killamarsh. It refers to a number of pedestrian crossings being present, road width reduced by parking bays (the few that there are), a mini roundabout at Norwood and a bad bend on Upperthorpe Road. The map also refers to the river bridge on the B6058 (Sheffield Road).   It shows ‘the potential to remove footway to increase road width.’ This shows the folly of looking at maps after a quick drive through of an area. The removal of the footpath at this point would leave the bridge parapet vulnerable to a vehicle strike, thus damaging the bridge and closing the road. It could also allow a vehicle to fall into the river.

There have been two fairly recent fatal accidents near this bridge and the removal of the
footpath on the ‘offending’ corner would possibly add to these tragic incidents. In any
event, the removal of the footpath, which is very narrow at this point, would give about 18”
of additional room. Unfortunately vehicles still need that 18” to miss the bridge parapet
(Transport Evidence Base, 2017, figure 3.5).

The Transport Evidence Base also refers to Travel to Work Patterns (Figures 3.17 and
3.18). These show that North East Derbyshire is a significant net exporter of commuters.
The accuracy of the evidence currently is debatable as it was compiled using the 2011
Census. Significant building has continued in Killamarsh during the period 2011 to 2018.
It still continues.

There are only three access/egress routes in Killamarsh, the main one being the B 6058/A
618 Rotherham Road/Mansfield Road. The A618 Rotherham Road leads towards J31 of
the M1 motorway. The other route is the unclassified Spinkhill Road leading to J30 of the
M1 motorway. This latter route is used as a ‘rat run’ from Killamarsh to the M1
southbound and, due to satellite navigation directions, sees heavy goods vehicle traffic
along a totally unsuitable road.

The other main site in Killamarsh is at Rotherham Road. This has similar drawbacks to
Westthorpe. The sustainability appraisal finds similar issues, excluding proximity to Grade
II listed buildings but including the potential for air and light pollution from the proximate
Norwood Industrial Estate. In addition, a family living in a house beside the proposed
development site had to leave their home for 18 months so that subsidence damage could
be repaired.

Traffic leaving this site would need to enter the A 618 road.

The A 618 Rotherham Road is the only route to travel to the M1 northbound at J31. The
Rother Valley Country Park is located in the Rotherham Borough area, literally yards from
the boundary with Killamarsh/North East Derbyshire. Traffic is very heavy on this road at
peak times, and weekends in the Summer. This situation will be exacerbated as the
development of the Gulliver’s Valley theme park progresses after it successfully obtained
planning permission in March, 2017. This development includes three hotels and parking
spaces for 1,600 vehicles, when completed. The entrance is on Rotherham Road (A 618).
A large proportion of vehicles wishing to access this Park will travel through Killamarsh.

The B 6058 Sheffield Road is the major route out of Killamarsh into which all other traffic
wishing to traverse the centre of Killamarsh flows. At morning and evening rush periods
the road is heavily congested, a situation exacerbated by the narrowing of the road at a
longstanding road bridge over the River Rother. The angle of the bridge to the road means
that it is virtually one-way if a heavy goods vehicle, or a bus or other large vehicle, is trying
to pass in either direction.
—————————————————————————————————
Chapter 6 – Working Communities and Economic Development.

Certainly in the case of Killamarsh high employment growth targets would not be
achievable. Both identified sites within the village are not popular with developers without, in the case of the Westthorpe Business Park, being capable of any significant expansion.

In respect of the larger area of land promoted as a General Employment Area under Policy
WC3 (Land to the south of Norwood Industrial Estate) the situation is even worse.

Paragraph 6.28 states, “…satisfactory access cannot easily be achieved for the remainder of
the land (the 5.4 acres of protected employment land). The development of the site may
also impinge on education and recreational land”.

The Plan refers to Dronfield and Killamarsh as being the main focus for employment in the north. Given the facts above this seems a ludicrous assertion, particularly when the Plan shows that 500 net jobs have been lost in the 15 years prior to 2015. With not viable
employment sites to build into, or options identified, how is this going to happen?

This means that the significant growth planned for Killamarsh will not lead to increased
jobs for local people. Any one of the ‘new’ residents would have to look for work, or travel
to their established job, outside the village, with the majority commuting to outside areas
such as Sheffield, Rotherham, Chesterfield, Markham Vale etc. This is the ultimate of
unsustainability.

The proposed Sustainable Transport option is doomed to failure because of issues with the
topography of the area and the location of proposed sites at the periphery of the current
settlement limits (outside them, currently). The fact that the main site is situated as far as
possible from the village centre, with a significant hill to descend and climb, militate
against the use of a bicycle, or walking, unless the residents are very fit. The bus service is
diminishing through lack of current use.

Whilst the use of public transport is an option, if that option is not regular and guaranteed
the use of cars will prevail.

Background evidence papers support the view that the majority of new residents will
commute to work elsewhere. This includes the independent Sustainability Appraisal.
——————————————————————————————————-
Chapter 7 – Sustainable Places.

Paragraph 7.37 suggests that Killamarsh is “well served by public transport”. All the
evidence from local people, with actual knowledge of the locality, is to the contrary.

This chapter acknowledges a ’high demand for growth due to its (Killamarsh’s) close
proximity to Sheffield’. This was a factor in previous iterations of the Local Plan which
proposed a housing target that did not need to utilise any Green Belt land. However, it was
alleged by the District Council, that the then targets were not deliverable because ‘the
developers did not want to build there’. Who actually makes the Plan? Is it the Council or
developers?

Killamarsh has been overdeveloped throughout the 20th Century without a commensurate
growth, in fact, barely any growth, in infrastructure. This is true of the other towns in the
north of the District.

The strategy of placing at least 50% of new housing in the four main towns in the
settlement hierarchy assumes that there is unused capacity that can be easily met in the
event of massive new development. That is not the case. The services that are currently
there are full to capacity, more properly over their capacity currently, without additional
development. To say that there is a doctor’s surgery, a dentist, is fine but the important
issue is their spare capacity. They have none. The NHS dentist has not accepted new
patients for a considerable time and the waiting time for an appointment with a doctor or
for a referral service such as podiatry or physiotherapy is months rather than weeks.

Killamarsh has the least green space in the major towns. This is because all space within
the settlement limits has been built on or has development planned within it. Green spaces
and playing fields have been developed.

Because of this overdevelopment it is assumed that the inexorable growth in housing must
continue, therefore we must use the Green Belt.

Building at Westthorpe will destroy a wild flower meadow and various habitats, including
those of protected species, but the cunning ‘plan’ is to build a small green space to replace
the huge one that will have been taken. Five footpaths cross this proposed site, showing its
use by locals. Ancient hedgerows will be impacted. Two fine oak trees on this land were
felled by someone renting the land from Harworth Estates in the fairly recent past.

The Plan explains that the site will not be obtrusive because it is built beside existing
development so it will be unobtrusive. The argument that it will not close the gap between
Killamarsh and Spinkhill is proffered because of the presence of the Westthorpe Fields
Business Park.

When travelling from Spinkhill towards Killamarsh the Business Park is located in a
hollow in the ground. The new development will be on a hill leading away from the current
houses and intruding into the countryside. It cannot be anything else but obtrusive. It may
not close a mathematical map but it will close a visual one.

The Plan suggests amelioration for development in the form of a Park built on the east side
of Killamarsh and the forming of a greenway, abutting the Chesterfield Canal, when this is
repaired. All of these plans depend on S. 106 money, apart from the Canal refurbishment
which has other funding sources. The houses will be built in the first ten years of the Plan,
but the money from S. 106 agreements will not come forward until development is well
underway. This is definitely a case of ‘jam tomorrow.’

The town centre of Killamarsh is assessed as good. More than 5% of all shopping is
formed by food takeaway outlets. Twice this amount consists of hair and beauty treatment
outlets. However, we do have two pharmacies (within 50 metres of each other), two ecigarette outlets (opposite each other), two cash machines (within feet of each other) and
two funeral directors to cater for the needs of the increasingly ageing population. The rest
of the shopping unit contain some esoteric established businesses but many attempts to try ‘something different’ founder on the apparent need to visit the Meadowhall or Crystal
Peaks shopping centres.

Research from a previous iteration of the Plan shows that 80% of money spent on retail
products by Killamarsh inhabitants goes elsewhere than Killamarsh, predominantly to
Sheffield outlets. How is this sustainable and how does it improve the local economy and
job prospects?

However, the District Council appears content with this situation and for Killamarsh to be a mere satellite and dormitory town for Sheffield and Chesterfield. This cannot be right.
To conclude, the Sustainability Appraisal scoring matrix, shown at Table 5.1 of the
Sustainability Appraisal Report, shows an adverse impact for the Westthorpe site in respect of Climate Change mitigation, Natural Resources, Health, Cultural Heritage, Landscape and Biodiversity.

The Rotherham Road site shows similar scores, but excluding Cultural Heritage whilst
including Pollution.
——————————————————————————————————-
Chapter 8 – Sustainable Development and Communities.

Paragraph 8.8 relates to trees, woodland and hedgerows are acknowledged as important for both recreational use and amenity value, whilst helping to reduce noise and atmospheric pollution.

The environmental value of flora within open spaces, due to its absorption of CO2, is well
known (Sustainability Appraisal, Feb 2018, paragraph 6.54.2). The ability of the landscape
to absorb excess water slowly, helping to avoid flooding, is also well known (Paragraph
6.55.2 SA, 2018 report) The landscape character of Wooded Farmland, upon which the
two Killamarsh Green Belt proposed sites are located, would contribute to SA Objective 9.
That value will be compromised and may exacerbate flooding along Green Lane – a
location prone to flooding during heavy and prolonged rainfall – if development were to
take place at Westthorpe.

SA Objective 3 states that Public Rights of Way will be protected from development unless
a suitable alternative route can be sought. There are five footpaths crossing the proposed
Westthorpe site. Re-routing will be difficult on a site containing 330 new dwellings. This
will diminish the amenity value for local residents, discouraging the important physical
activity of walking (SA Objective 8).

In terms of ecology Box 6.1 of the SA Appraisal, 2018, describes the cumulative impacts
on biodiversity, flora and fauna. The effects of development at Westthorpe and, to a lesser
extent, Rotherham Road, Killamarsh are perfectly described.

‘The cumulative effects of development proposed in the Local Plan is anticipated to result in further loss and fragmentation of habitats and an increase in barriers to the movement of species. This is anticipated to particularly be the case for wildflower-rich grassland…hedgerow…field margins…and the flora and fauna species they support.’

‘The overall impact will potentially be one which disrupts the District’s ecological network and diminishes the important ecological services they provide.’

‘The cumulative impact of all sitesin combination would be likely to constitute a significant loss of important arable field margin and hedgerow habitats.’

Both Killamarsh Green Belt sites, particularly the Westthorpe one will be impacted by such development. The SA Report, 2018 refers to the cumulative impact of all sites proposed in the Draft Publication Local Plan, but it could easily be referring to the cumulative effect of excess development within Killamarsh during the latter half of the 20th Century which continues to the present day.

Paragraph 6.35.3 of the SA, 2018, refers to the deficiency in green space and children’s
play space in Killamarsh. It talks about the protection of green space within the settlement
limits but the comment could equally relate to the large, open, publically used Green Belt
space at Westthorpe, crossed by five public footpaths, upon which large-scale development
is proposed.

Paragraph 3.8.24 refers to a local wildlife site at the former Westthorpe Colliery. The
development at Westthorpe, 100 metres to the north east, has the ‘potential to impact’ this
designated local wildlife site.

The sustainability of these sites, at the very periphery of Killamarsh has many other
sustainability implications that have been covered in associated submissions.

The site at Rotherham Road will be impacted by possible air pollution from the Norwood
Industrial Estate. Current residents will be similarly impacted by the additional traffic
movements from the proposed site and from traffic movement to and from the planapproved site for the Gulliver’s Valley theme park which, when operating fully, will
provide 244 rooms in 3 hotels and 1,600 visitor car parking spaces. The entrance to this
site will be approximately 1 mile away from the Rotherham Road proposed site.

The east side of Killamarsh has the poorest air quality due to its proximity to the M1
motorway. Whilst not currently an air management area the air quality has been judged to
be amongst the poorest in the District. Since the last review of air quality a Biomass energy
plant has been opened in the Sheffield City area, but adjacent to the NE Derbyshire
boundary to the west of Killamarsh. This plant burns waste, pre-used wood.

Burning wood emits a similar range and level of pollutants as burning coal. Pollutants
include nitrogen dioxide (NOx), carbon monoxide (CO) and small particulates (PM10 and
PM2.5). Burning chemically treated waste wood involves those pollutants but also can
include heavy metals, dioxins and furans. Other emissions will depend on the chemicals
used to treat the wood.

World Health Organisation research indicates that:-
– Air pollution is strongly linked to heart disease and strokes;
– Long-term exposure to NO2 is linked to reduced lung function and increased
bronchitis in children with asthma;
– Short-term exposure to NO2 is linked to the inflammation of airways;
– NO2 is an important source of fine particulates (PM2.5);
– NO2 is a source of ground-level ozone, which is linked to breathing problems,
asthma attacks, reduced lung function and heart/lung disease;
– Long-term exposure to small particulates (PM10 and PM2.5) is linked to respiratory
and heart disease, and to lung cancer. There are no safe levels of exposure to
PM2.5.
– Dioxins and furans are highly toxic and persist long-term in the environment. They
can cause reproductive and developmental problems, damage the immune system,
cause cancer and interfere with hormones. Air emissions of dioxins can be inhaled
but they can also pollute the food chain.

It is interesting to note that the Sheffield City Council has built two of these plants, one
located as close to its border with Rotherham as is possible, with the other being as close to North East Derbyshire, and Killamarsh, as is possible. I wonder why?

NO and NO2 are emitted from Biomass plants but by far the largest source of such
pollutants, and particulates, is from petrol and diesel vehicle movement.

Sheffield Road (B 6058) is by far the busiest road in Killamarsh. Delays on this road at
peak times can be extensive, very often from 20 minutes to an hour, creating a perfect
storm of pollutants for those living close to the road. This is currently unacceptable, but
will be more so if the planned development is allowed to be built.
——————————————————————————————————-
Section 9 – Infrastructure and Delivery.

Many previous comments throughout my responses deal with infrastructure issues. I will
not repeat them.

The Infrastructure and Delivery Plan Report, 2017, states that ‘much of the infrastructure needed to support the growth in the Local Plan is capable of successful delivery through the current S 106 regime’ (Paragraph 9.13 of the Draft Publication Local Plan, 2018).

Once again, the residents of Killamarsh, and other areas in the north of the District, will be
waiting for infrastructure development until many new dwellings have been built. Sitespecific issues will be dealt with in the planning stage, so .the newly-arrived residents will be fine. The current residents will just have to cope with the massive disruption that
building the two large proposed sites in Killamarsh will bring. This is totally unfair.

The building of a children’s park in the east of Killamarsh is welcome, but long overdue.
Similarly the new western Greenway will be a welcome addition to enhance the meagre
recreational opportunities available within Killamarsh. The Infrastructure Plan indicates (in table 81)

However, the draft Plan contains a note of caution that a cynical person (where developers
are concerned, I am one such cynic) might be concerned about.

Paragraph 9.15 states, “Given the viability assessment found relatively tight margins of development viability across significant parts of the district it is considered that the flexibility afforded through the S 106 regime is of particular benefit to the successful delivery of development in the district.” The viability get-out clause rears its head yet
again.

Paragraph 9.20 appears to give a measure of comfort in stating, In cases where
essential/critical site specific infrastructure and mitigation cannot be secured because of viability concerns and the infrastructure is an essential prerequisite to enable the development to proceed, schemes will not be supported.

Paragraph 9.18 says where the viability of a development is in question a ‘site specific
financial evaluation’ will be undertaken to the Council’s satisfaction at the earliest stage in the application process.  Paragraph 9.19 goes further in saying ‘where a scheme is agreed to be unviable or marginal the Council will review…..the timing or phasing of payments to assist the financial viability of the scheme’.

I suggest that the highly paid lawyers employed by rich developers will have a wonderful
time arguing about the definition of the underlined phrases. Essentially, local people will
have the mess, disruption and chaos, over at least a ten year period, without any substantial guarantee of the small mitigation areas promised in terms of green infrastructure. Even then the mitigation will not make up for the Green Belt land lost.

Within the NEDDC infrastructure Plan and that of the Derbyshire County Council there is
no acknowledged need to enhance the road system around Killamarsh, despite the
acknowledged out-commuting by current and future residents of Killamarsh. Local people
are fully aware of the problems on the B 6105 Sheffield Road and the A618 Rotherham
Road, but apparently those carrying out The Transport Study are not.

A recent extension to the Killamarsh doctor’s surgery is, a short time later, proving
inadequate due to the continual building in Killamarsh and the ability of patients to register with a doctor outside their own practice area. This will not improve.

There is a plan to utilise Children’s Centres to enhance Early Years educational provision,
which is excellent, but the funding mechanism and timescale are both shown as ‘unknown’
in the Infrastructure Study and Delivery Plan, 2018 (ISDP), Table 76.

The Killamarsh Leisure Centre is shown as an important facility for Killamarsh which
should be maintained ‘to ensure ongoing availability to the general public.’ The delivery mechanism and funding are show as unknown again. The Killamarsh Leisure Centre is different to similar Centres in Eckington and Dronfield. The latter two are District Council-owned, while the former is owned by the Parish Council. In the absence of
external funding the only source of money are the council tax payers of Killamarsh (Table
79 ISDP).

The Killamarsh Leisure Centre is a loss-making entity, as evidenced by the ever-increasing
Parish precept for Killamarsh, making the Council tax payable by Killamarsh residents the
most expensive in North East Derbyshire. There is no sign of any change to this situation
as the pattern shows an inexorable rise. Is this fair? Killamarsh Council tax payers would
say no.

Killamarsh deserves the family play area to the east and the new western greenway, to
supplement the Chesterfield canal restoration, because of historic overdevelopment without infrastructure enhancement. Its residents should not have to suffer more unwelcome  development to fund it. This should be funded by the District Council through the non-ring fenced New Homes Bonus and affordable Homes bonus in acknowledgement of the previous planning damage done to Killamarsh (Table 81 ISDP).

At least the initial stages of the Chesterfield canal restoration are funded and properly
planned. This restoration will be a bonus and will give a boost to almost non-existent
tourism in Killamarsh (Table 81 ISDP).

The Derbyshire County Council Infrastructure Plan, 2013, contains nothing in terms of
infrastructure enhancement for Killamarsh except the restoration of the Chesterfield canal
through Killamarsh. The DCC is a partner, with other Councils and agencies, in this
scheme, so this commitment is not exactly a revelation or a game-changer.

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