As a resident of S13, I would like to put on record my objection to the Main Modifications proposed to the Sheffield Local Plan, particularly MM410 and MM411, which relate to the SES29 and SES30 sites. I consider these to be unsound and request the removal of both sites from the Local Plan for the reasons outlined below.

Firstly, there are a number of city-wide environmental concerns presented by the proposed Main Modifications. According to the Integrated Impact Assessment, the modified Plan performs worse across several metrics, including biodiversity, landscape and transport.

In S13 specifically, the SES30 site has been identified as being of high ecological importance, and there is no clear plan as to how the legally required 10% Biodiversity Net Gain will be met. Some ecological assessments remain incomplete, and those that have been completed were produced after the allocation decision. In SES29, there is a lack of up-to-date evidence and missing ecological information. Both point towards a lack of adequate steps being taken to prevent environmental harm. It is not possible to properly plan mitigation without robust evidence of what is being mitigated, and the Habitats Regulations Assessment appears to rely on the assumption that effective mitigation will be delivered, rather than demonstrating it.

Secondly, there are a significant number of assumptions made based on vague prescriptions and limited evidence. As well as the reliance on mitigation that has not been fully developed, there is a lack of clarity on how the “Golden Rules” of Green Belt release will be met in practice.

In S13, for example, the proposed school and burial ground on the SES30 site have not been confirmed as needed and may later be reassessed (potentially for additional housing). This creates a risk that the original justification for Green Belt release, based on exceptional circumstances, is undermined.

On the SES29 site, there are also a number of unresolved constraints. For example, there has not been a comprehensive mining survey completed, which is essential in this high-risk area. There are also doubts about how much of the land is actually developable, meaning the capacity figures set out in the Plan may be overstated.

Both sites also appear to rely on unrealistic assumptions about building rates. This represents a clear divergence from the National Planning Policy Framework, particularly in relation to effectiveness and deliverability. Deliverability has not been demonstrated, and this conflicts with the requirement for plans to be effective. Other sites have been removed due to similar concerns, yet SES29 and SES30 have remained.

The Main Modifications also create and add to significant transport issues, including a wider issue of housing being directed towards car-dependent locations. This is particularly concerning given that the density estimates of city-centre developments in areas more easily accessed by public transport appear to be unusually low when compared to similar cities, conflicting with the NPPF requirement “plans should promote an uplift in density in urban areas.”

In S13, key access routes are already under significant pressure, particularly Beaver Hill Road and Retford Road. The additional traffic from these developments would create both air quality and safety concerns and is likely to result in severe congestion. There are currently no clear or fully evidenced plans to mitigate these impacts. Significant highway works would be required, which may further affect the viability of the sites. Improvements to public transport infrastructure have also not been funded or secured.

Finally, I would like to raise concerns about the procedural fairness of the Main Modifications consultation. I do not believe sufficient steps have been taken to ensure the process is widely understood or accessible, and some key evidence has been introduced late. Changes of this scale, including a substantial increase in housing numbers in South East Sheffield, should not be introduced solely through Main Modifications.

I consider Main Modification MM411 (site SES30) and MM410 (site SES29) to be unsound. It is not justified and not consistent with national policy. I request that SES30 and SES29 be removed from the Plan and retained as Green Belt.

Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate.

I consider the Local Plan to be unsound in relation to the proposed development in the S13 area. It does not meet the requirements of justification, effectiveness, or consistency with national policy, as outlined in the National Planning Policy Framework.

Firstly, there is a lack of recent, area-specific evidence demonstrating that air quality in S13 can accommodate the additional traffic and emissions the development will generate. Without updated modelling or local impact assessments, the plan fails to show that environmental and health impacts have been properly addressed. This is particularly concerning given existing concerns about pollution levels in the area.

Secondly, the proposal contributes to an increasingly unbalanced pattern of development across the city. The east of Sheffield, including S13, continues to take on a disproportionate share of housing growth, while areas in the west remain largely protected. This deepens existing disparities in access to green space, health services, infrastructure, and overall living conditions. The plan offers no clear justification for this imbalance. The proposed development would also result in the merging of two previously distinct urban areas. This loss of separation undermines local identity and removes the remaining green space that provides visual and environmental relief in the area. The plan fails to explain how such coalescence supports wider planning aims. There is also concern regarding local healthcare provision. The plan suggests that two rooms will be added to an existing GP surgery, which is not a credible or proportionate response to the likely increase in patient demand. There is no supporting evidence from health authorities to indicate this would be sufficient or deliverable within a suitable timeframe. Although the plan references improvements to public transport, there is no clear indication that such schemes are funded, scheduled, or formally committed to by relevant authorities. Relying on speculative transport improvements to support new development raises serious doubts about deliverability and long-term sustainability. Existing sewerage infrastructure in S13 is already under pressure. The plan does not demonstrate that the drainage and wastewater systems can support additional housing. No assurances appear to have been provided by the relevant utility companies. Without this, the plan carries a serious risk of infrastructure failure, which has implications for both public health and environmental protection.

Finally, there is a notable shortfall in accessible green space in and around the proposed development area. The plan does not adequately address this or propose meaningful new provision. This fails to meet national and local objectives for public health, wellbeing, and quality of life. In summary, the Local Plan, as it applies to S13, is not sound. It is based on insufficient evidence, lacks critical infrastructure planning, and contributes to an unfair and unsustainable pattern of growth across the city. It should be revised to address these issues before it can be considered acceptable.

Please set out the modification(s) you consider necessary to make the Local Plan legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above.

The first and most important modification required to make the Local Plan sound is the removal of proposed development from green belt land in the S13 area. This land should be protected in full, in line with national planning policy, which states that green belt boundaries should only be altered in exceptional circumstances, and that development within the green belt should be avoided unless there is a clear, evidenced justification. In this case, such justification has not been adequately provided.

The site in question plays a vital role in separating distinct urban areas, preserving local character, supporting biodiversity, and offering potential for improved public access to open space in a part of the city where this is already lacking. Development on this land would cause irreversible harm to the green belt and set a precedent for further encroachment. Removing the allocation of this site would bring the Local Plan into alignment with national policy on green belt protection and sustainable spatial development. If, despite these concerns, the site is to remain allocated for development, several substantial modifications would be required to make the plan sound: Air quality assessment: The Council must undertake and publish an up-to-date air quality assessment specific to the S13 area. This should model the cumulative impact of increased traffic and population associated with the proposed development. No development should proceed unless the results confirm compliance with air quality objectives and demonstrate that the local environment and public health will not be adversely affected.

Balanced spatial growth: The Local Plan should be modified to reduce the disproportionate concentration of housing growth in the east of the city, including S13. Clear policies should be introduced to ensure that future growth is more equitably distributed across all areas, particularly those in the west, to prevent the worsening of long-standing inequalities in infrastructure, health outcomes, and quality of life. Urban separation: Policy wording should be amended to ensure that development must not lead to the physical merging of previously separate urban areas. Green buffers between communities should be maintained and protected to preserve their individual character and to prevent overdevelopment. This would help maintain distinct community identities and avoid unplanned urban sprawl.

Healthcare provision: The existing plan proposes only a minor expansion to local healthcare capacity, which is clearly insufficient. The plan must require a full health impact assessment and include binding commitments to provide new or significantly expanded healthcare facilities before development begins. This must be based on clear evidence of need, agreed in advance with NHS providers.

Public transport delivery: Any references to future transport improvements must relate only to schemes with confirmed funding and delivery timelines. The current reliance on vague or aspirational public transport plans is not acceptable. The policy should be reworded to state that no development will proceed until adequate, reliable public transport services are in place and operational.

Drainage and sewerage infrastructure: The Local Plan must require written confirmation from Yorkshire Water or the relevant statutory undertaker that the existing drainage and sewer systems can cope with the additional load. Where upgrades are needed, these must be delivered in advance of housing construction.

Provision of green space: The area surrounding the proposed site already suffers from a shortage of accessible green space. The Plan must be amended to include the delivery of high-quality, accessible public open space within or immediately adjacent to the development. This should meet minimum standards for green space provision per resident and be secured as part of any planning consent.

Reference number: 4003809