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South Derbyshire Local Plan Part 2 Examination Matter 7A – Provision of Secondary School Sites (Policy INF12)

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South Derbyshire Local Plan Part 2 Examination Matter 7A – Provision of Secondary School Sites (Policy INF12) Matter 7a Provision of Secondary School Sites (Policy INF12) Growth Villages RPS for Bellway / Clowes South Derbyshire Local Plan Part 2 Examination Matter 7a – Provision of Secondary School Sites (Policy INF12) South Derbyshire Local Plan Part 2 Examination Session Thursday 27April 2017 Ref 056 - RPS obo Bellway / Clowes Matter 7a: Provision of Secondary School Sites (Policy INF12) Q62. Is policy INF12 justified in allocating 2 sites for the provision of a minimum of 800 secondary school places on 10 hectares of land? Bellway / Clowes raise no objection in principle to the allocation of 2 sites for secondary education provision within Policy INF12. The need for two sites has been identified as required by Derbyshire County Council (the County Council) as local education authority in their Cabinet Report dated 20 September 2016. This report (enclosed as Appendix 1) states that residential developments proposed in the adopted South Derbyshire Local Plan Part 1 are expected to require a total of 1,898 secondary aged pupils (11-18). As some 8,000 of the 12,618 houses allocated in the SDLPP1 are proposed on the edge of Derby City, there is a clear need, as stated in the report, for new secondary school infrastructure to accommodate housing growth at this location. The Cabinet Report indicates that there remains considerable uncertainty over the pattern and demand for admissions to a new secondary school. The situation and school capacity requirements are made more complex by the cross boundary context. Some 11,000 new homes are allocated in the recently adopted Core Strategy for Derby City, many of which are to be delivered in and around the southern boundary with South Derbyshire. It is therefore highly likely that housing development within Derby City will also feed into a new secondary school(s) within South Derbyshire. The County Council Cabinet Report models a scenario whereby some of the additional need (up to 1,500 pupils) is accommodated by the expansion of existing schools in South Derbyshire and Derby City. However, RPS understands that the feasibility of expanding these existing schools, comprising the John Port School in South Derbyshire and the Murray Park School and City of Derby Academy in Derby City has yet to be established. This is acknowledged in the Cabinet Report, which states that the expansion capacity of 1,500 is purely illustrative and there is a possibility that expansions to existing schools will not go ahead. Should this be the case the requirement for new purpose built secondary school infrastructure is likely to be far in excess of 800 places. Preferred Site The significant level of housing development and population growth coming forward to the south and west of Derby and the current uncertainty over the demand for school places, future admission arrangements and the expansion capability of existing secondary schools have led the County Council to confirm that two sites are required for new secondary education infrastructure. This is supported by the District Council at Policy INF12. Paragraph 14 of the National Planning Policy Framework (NPPF) requires Local Plans to have sufficient flexibility to adapt to rapid change. Embedding flexibility in Policy INF12 by allocating two sites for secondary education infrastructure is appropriate and consistent with the NPPF. However, RPS contends that further refinement of Policy INF12 is required in order to reflect the clear advice by the County Council in their Cabinet Report that Thulston Fields is the preferred site for a new school. The preference for Thulston Fields is not currently reflected in the drafting of Policy INF12. It is also evident within the Cabinet Report that in the view of the County Council the site at Lowes Farm should only come forward in the event that Thulston Fields is unable to do so or if it is subsequently revealed that there is insufficient capability to expand existing schools as 1 Ref 056 - RPS obo Bellway / Clowes Matter 7a: Provision of Secondary School Sites (Policy INF12) planned. It is therefore appropriate to specify in Policy INF12 that Lowes Farm should be regarded as a reserve site for the provision of secondary education facilities. The conclusions drawn by the County Council are based on a robust assessment and scoring of different site options. Despite being located within the Green Belt, Thulston Fields scored highest overall against a range of criteria used. This included criteria relating to sustainable development and planning considerations, where the site received a lower score due to its location within the Green Belt. However, should the site be removed from the Green Belt (as is proposed by Bellway / Clowes and discussed below in response to Q.63) the site would have scored even higher. In relation to meeting education need, it should be noted that Thulston Fields is located in a highly sustainable location in the immediate vicinity of the largest concentration of cross boundary housing growth; this being the strategic allocation at Boulton Moor. This strategic growth will comprise 2,750 dwellings, two new primary schools, a local centre and new public transport links. The new dwellings and primary schools would be located within walking distance of a new secondary school at Thulston Fields. Currently, the nearest secondary school is Chellaston Academy, which is full or exceeding capacity. Chellaston Academy has an admissions policy which reserved the right to exclude new developments and has administered this policy in respect of other new development adjacent to the strategic allocation at Boulton Moor i.e. land at Fellow Land Way, Derby (Planning Application DER/01/13/00082). Furthermore, Thulston Fields is located further away than Lowes Farm from the planned secondary school expansions. The absence of secondary school capacity nearby and the distance of Thulston Fields to planned secondary school expansions mean there is likely to be a particularly acute need for new secondary school provision in the vicinity of the site as housing growth at Boulton Moor is delivered. The County Council’s assessment of sites was also made against other key criteria relating to property and land acquisition and the presence of any technical constraints. In both these respects the site at Thulston Fields outscored the second best option at Lowes Farm. It should be noted that in addition to potential flood risk concerns, Lowes Farm was previously discounted from consideration by the District Council as a strategic residential allocation due to the absence of a suitable transport mitigation - (p172 of Local Plan Part 2 Sustainability Appraisal: Main Report (Core Ref Doc E.1). Q63. If justified, would the allocation of the site at Thulston Fields require the release of land from the Green Belt and would this be consistent with national policy on the protection of Green Belt land? If the site were not released from the Green Belt would the delivery of a new school on this site be at risk of inappropriate development in the Green Belt as defined in the NPPF? Bellway/ Clowes propose that the allocation of the site at Thulston Fields should elicit the release of the site (or part of the site) from the Green Belt. To not do so could risk the allocation being inconsistent with national policy on the protection of the Green Belt. Paragraph 83 of the NPPF is clear that Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. Whilst it is unfortunate that the need for a secondary school at Thulston Fields was not identified by the County Council during the preparation of the SDLPP1, its adopted policy on Green Belt (Policy S8), does state that ‘Green Belt boundaries will be reviewed through the Local Plan Part 2, to amend any existing anomalies since the adoption of the Green Belt’. In this 2 Ref 056 - RPS obo Bellway / Clowes Matter 7a: Provision of Secondary School Sites (Policy INF12) instance it is considered that Part 2 of the Local Plan should be regarded as an entirely appropriate point to amend a Green Belt boundary, if required. Indeed, when preparing Local Plans, the NPPF requires Local Planning Authorities to work with other authorities and providers to assess the quality and capacity of (education) infrastructure (para.162) and ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion (para.177). Infrastructure and development policies should be planned at the same time (para.177). It is the judgement of RPS that exceptional circumstances do exist to justify the release of Green Belt land at this location and it is necessary to do so to reliably meet the education infrastructure needs of the District during the early stages of the plan period. The clear need for at least one new secondary school on the edge of Derby City has been identified by the County Council as local education authority. The site at Thulston Fields has emerged as the preferred site, and this has been ratified by the County Council’s Cabinet following an extensive consultation and assessment exercise. In this instance therefore all other reasonable options have been considered prior to Thulston Fields emerging as the preferred option. Importantly, the site at Thulston Fields is best placed locationally to meet education needs, is free from technical or environmental constraint and is in the hands of a willing landowner. In terms of the Green Belt, the site comprises a large, (107ha) contained parcel of land within the urban boundary of the A50 and the A6 strategic highways. The NPPF states that when defining (Green Belt) boundaries, local authorities should use physical features that are readily recognisable and likely to be permanent (para.85). It should be noted that the site is the only parcel of land within the inner urban boundary of these strategic roads that is located in the Green Belt.
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