Doncaster

Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

Please respond by 6pm Monday 30 September 2019. The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination. Please email your completed form to us at If you can’t use email, hard copies can be sent to:

Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU. All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan

This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations)

Part A Please complete in full. Please see the Privacy Statement at end of form.

1. Personal Details 2. Agent’s Details (if applicable)

Title Mr Mrs

First Name G Janet

Last Name Turnbull Hodson

Organisation (where relevant)

JVH Town Planning Consultants LTD

Address – line 1 C/O Agent Houndhill Courtyard

Address – line 2 Houndhill

Address – line 3 Marchington

Postcode ST14 8LN

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form) What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be

helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.

• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.

• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.

• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).

Question 8 (below) – Do I need to attend the Public Examination? You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.

1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be

at the request of the Inspector, based on the matters and issues

she/he identifies for examination.

If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at:

or

Name / Organisation Name:

JVH Planning Town Planning Consultants Ltd for Mr G Turnbull

1. To which document does your response relate? (Please tick all that apply)

Doncaster Local Plan Publication Draft ☒ Policies Map ☒

Sustainability Appraisal ☐ Habitats Regulations Assessment ☐

Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☐

2. To which part(s) of the document / map does your response relate?

Page No.: Table 5, Appendix 2 Paragraph: 4.38

Policy Ref.: Policies 2, 3, 6, 8, 67 Site Ref.: 164 and 430.

Policies Map: Object

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☒ Yes ☐

4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☒ Justified ☒

Effective ☒ Consistent with National Policy ☒

6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.

Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.

You can attach additional information but please make sure it is securely attached and clearly referenced.

Land East of Warning Tongue Lane

Allocations ref 164 and 430.

Objection to Policy2 Spatial Strategy and Settlement Hierarchy

Objection is made to this Policy

The Doncaster main urban area is defined on the Proposals Map. The development limits shown on the map

exclude the proposed allocation from the urban area. The allocation of the site as an extension of the urban area

means that it is necessarily part of the Doncaster urban area. The Plan should be changed to reflect this,

together with the text in Policy 2 at part 1, which defines the extent of the Doncaster Urban Area.

Objection to Policy 3 the Level and distribution of housing growth

Objection is made to this Policy

The level of housing growth for the Plan period 2015-2035 is set at 18,400 new homes.

The Plan seeks to allocation land for 15 years of 13,230 new homes having deducted the completions from the

first three years of the Plan period up to 2018.

The Plan should allocate land for the complete Plan Period and on the basis of the Policy as drafted only takes

account of 18 of the 20 year plan period. There is no explanation

of the remaining 2 years.

The housing requirement is set out as a range from 920 dwellings per annum, down to 882 dwellings per annum

and indicates that this will be reviewed through the plan period to reflect updated projections and the need for

affordable homes. It is unclear from the Plan on what basis revised requirements would be considered and how

this would affect the land allocations or future requirements.

The Policy as drafted is not clear if provision is being made for the entire 18,400 new homes or for a lesser

figure. There is no clear explanation of this in the supporting text. Paragraph 4.38 of the text indicates that the

requirement is 912 homes per year over the Plan Period, which is 18,240 new homes net. There is no

explanation of the net and gross figures in the text.

The plan should clearly set out the gross requirement over the plan period, what deductions are made for

completions, the residual requirement for the remainder of the plan period, and the allocations therefore made.

Net and gross figures would assist the ability to understand the Plan.

The range of figures in the table for the settlements in the hierarchy are difficult to match up with the overall

requirements. The figures for the bottom end of the range add to 10,850 housing allocations and the top of the

range add to 15,390, neither of which figures match the 13,230 in the first part of the Policy.

The Plan is therefore unclear and imprecise about the housing allocation and how this is justified compared to

the report relied upon which sets out the housing need.

The proposed allocations should be listed in Policy 6 in a comprehensive table to enable

a proper understanding and reading of the Plan. A plan of each site should also be included in the plan

document, to ensure clarity about the site boundaries.

Policy H6 Housing Allocations.

Support is made in principle for the allocation of site 164 and 430 Land East of Warning Tongue Lane

Doncaster .

The site area is noted as 11.06 hectares with an indicative capacity of 275 dwellings.

Objection is made to Table 5 of the Plan that sets out the housing requirement. The text indicates that the

requirement is variable between the bottom and top of the requirement range, but the table sets out the

requirement at the top of the range. It is therefore unclear.

The Plan should allocate sites and plan for the top of the range figure, and allocate sufficient land to meet the

remaining requirements for the 17 years of the Plan. The table as drafted allocates land for 15 years rather than

17 years and appears to under allocate the residual requirement which is 15,000 new homes.

The supply figures in the table do not reconcile with the figures at paragraph 16.21.

Some of this issue relates to the fact that sites with planning permission are also allocated.

Allocating sites with permission is confusing the plan and sites with permission do not need to be specifically

allocated. The Plan should be clear about what the contribution of the sites with Planning Permission is and how

this number is discounted, and what are the new allocations. The Plan is imprecise as drafted.

Table 5 Housing land supply calculations.

It is proposed to use the bottom of the range of the housing requirement in calculating the five year supply,

equating to the base requirement only. The Plan however is predicated on delivering land to meet the base

requirements and the economic uplift. It is not the right approach to calculating a five year housing land

requirement to ignore part of the housing requirement and base the supply on a partial element of the

requirement. This will give a false picture of the five year land supply required to deliver the housing needs

identified in the Local Plan. The plan should be amended to make it clear that the five year supply will be based

on the full housing requirement of the Local Plan.

Policy 8 Housing Mix and Affordable Housing and Policy 67 Development Viability

Objection is made to this Policy as drafted, the requirement for 23% affordable homes in the

higher value areas in the District is not justified by the evidence. It is noted in para 6.9

that the overall requirement for 209 units per annum, which is 23% of the annual housing target [believed to be

the upper end of the range] does not take account of what has been committed through applications and is

therefore an unreliable figure.

The Plan should include a robust figure, and needs to include text that makes it clear that the affordable housing

has to be viable. Viability testing on sites at this stage will be unreliable until a full suite of technical documents

have assessed the site development costs and infrastructure requirements. The Plan should therefore reflect

affordable housing requirements as aspirational but subject to detailed site viability.

Appendix 2 Developer Guidelines Site 164 and 430

Objection is made to the wording of the Developer guidelines, the design comments are over prescriptive at this

stage and may inhibit the development of the most appropriate layout of the site when the detailed site details

have been established.

The guidelines do not explain why an education contribution will be required and which schools this would

benefit.

Objection is made to the Policies Map

The interactive policies map indicates that the site lies outside the proposed development boundary for

Doncaster Urban Area. The allocation of the site an extension to the existing built form of the settlement means

that the site will be part of the urban area and the development boundary of the urban area should be amended

to include the allocated site. The proposal map needs amending on this basis.

7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.

(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).

1. To include the proposed allocations 164 and 430 within the development limit of Doncaster Urban

Area.

2. Allocate sufficient land for the complete plan period and to meet the full housing requirement.

3. Provide consistency between the housing requirement calculations, the supply and the allocated sites.

4. Provide a table and plan in the text clearly indicating allocations.

5. Provide a housing land supply calculation based on the full housing requirement.

6. Provide a robust figure for affordable housing.

7. Amend the developer guidelines to be flexible and justified.

8. Amend the polices map to reflect the urban area boundary.

As explained in detail above.

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

☐ No, I do not wish to participate at the examination. I would like my representation to be dealt with by written representation.

☒ Yes, I wish to appear at the Examination.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:

We act for a number of major land owners in the Doncaster area , we have detailed knowledge of the sites and

the planning history of the Borough. We have previously been involved with the Core Strategy Plan and with

the Examination of the draft Sites and Policies DPD. Our knowledge of the various land parcels, ownerships,

the strategic land position and site specific details, means that we have information to inform the debate

regarding the overall housing requirement and the specific allocation of sites which will assist the

examination.

Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature

Date 27/09/2019

Please send your completed form, by no later than 6pm on 30th September 2019, to:

• Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU

• or email: Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan

Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:

The Council reserves the right not to publish or take into account any representations which are openly offensive

or defamatory.

Doncaster

Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

Please respond by 6pm Monday 30 September 2019. The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination. Please email your completed form to us at If you can’t use email, hard copies can be sent to:

Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU. All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan

This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations)

Part A Please complete in full. Please see the Privacy Statement at end of form.

1. Personal Details 2. Agent’s Details (if applicable)

Title Mr Mrs

First Name G Janet

Last Name Turnbull Hodson

Organisation (where relevant)

JVH Town Planning Consultants LTD

Address – line 1 C/O Agent Houndhill Courtyard

Address – line 2 Houndhill

Address – line 3 Marchington

Postcode ST14 8LN

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form) What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be

helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.

• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.

• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.

• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).

Question 8 (below) – Do I need to attend the Public Examination? You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.

1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be

at the request of the Inspector, based on the matters and issues

she/he identifies for examination.

If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at:

or

Name / Organisation Name:

JVH Planning Town Planning Consultants Ltd for Mr G Turnbull

1. To which document does your response relate? (Please tick all that apply)

Doncaster Local Plan Publication Draft ☒ Policies Map ☒

Sustainability Appraisal ☐ Habitats Regulations Assessment ☐

Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☐

2. To which part(s) of the document / map does your response relate?

Page No.: Table 5, Developer Guidelines Appendix 2 Paragraph:

Policy Ref.: Policies 2, 3, 6, 8, 67 Site Ref.: 186 165.

Policies Map: Object

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☒ Yes ☐

4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☒ Justified ☒

Effective ☒ Consistent with National Policy ☒

6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.

Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.

You can attach additional information but please make sure it is securely attached and clearly referenced.

Land off Crabgate Lane Carcroft Skellow

Sites 186 and 165

Objection to Policy 2 Spatial Strategy and Settlement Hierarchy

Objection is made to the policy as drafted on the basis that the text indicates that the split of new development

will be 50% of new homes to Doncaster urban, 40% to main towns and 10% to the service towns and villages.

Of these proportions only local needs housing is distributed on a pro rata basis, and the economic led housing

growth is distributed only to Doncaster Urban and the Main towns.

None of this part of the housing growth is allocated to the service towns and villages

and there is no cogent explanation of why these sustainable settlements should not have

a proportionate share of this part of the proposed housing growth.

The strategy as drafted in this Policy therefore does not reflect the sustainability and potential of the service

towns and villages to meet a share of the economic led housing growth.

Part 3 of the Policy sets out the role of the service towns and villages, and indicates that

these settlements will be a focus for a level of growth to meet their “local needs”

as well as regenerating run down areas. There is no explanation of what is meant by local needs in this part of

the policy, but it can only be assumed that this is the local needs housing element of the overall requirement

minus the economic growth housing.

This is a false distinction in terms of land allocation in these settlements which should receive a proportionate

share of economic growth housing as set out above.

Within these service towns and villages, growth within the development boundaries is considered favourably.

The Policy also makes provision for other new development on sites adjacent/outside the development boundary

in certain circumstances; which include the situation where the Planning Authority cannot demonstrate a five

year land supply.

The Plan does not identify any locations where this could take place and does not make clear what the role of

the other reserve sites are in this context. It is not considered that the current

reserved sites represent the best options for future land release.

Part 6

The alteration to the Green Belt Boundary at Carcroft Skellow around sites 186 and 165

is supported. The proposed new boundary is a logical and defensible boundary for the

Green Belt, the A1 and Green Lane form substantial and well defined boundaries to the settlement. It is noted

that the Proposals Map that the boundary now includes the two properties to the north west of the site; however

the Map in the Developer

Requirements on pages 272 and 273 do not have the same boundary shown.

This Plan needs to be amended to match the Proposals Map

Objection to Policy 3 the Level and distribution of housing Growth

Objection is made to this Policy

The level of housing growth for the Plan period 2015-2035 is set at 18,400 new homes.

The Plan seeks to allocation land for 15 years of 13,230 new homes having deducted the completions from the

first three years of the Plan period up to 2018.

The Plan should allocate land for the complete Plan Period and on the basis of the Policy as drafted only takes

account of 18 of the 20 year plan period. There is no explanation

of the remaining 2 years.

The housing requirement is set out as a range from 920 dwellings per annum, down to 882 dwellings per annum

and indicates that this will be reviewed through the plan period to reflect updated projections and the need for

affordable homes. It is unclear from the Plan

on what basis revised requirements would be considered and how this would affect the land allocations or future

requirements.

The Policy as drafted is not clear if provision is being made for the entire 18,400 new homes or for a lesser

figure. There is no clear explanation of this in the supporting text. Paragraph 4.38 of the text indicates that the

requirement is 912 homes per year over the Plan Period, which is 18,240 new homes net. There is no

explanation of the net and gross figures in the text.

The plan should clearly set out the gross requirement over the plan period, what deductions are made for

completions, the residual requirement for the remainder of the plan period, and the allocations therefore made.

Net and gross figures would assist the ability to understand the Plan.

The range of figures in the table for the settlements in the hierarchy are difficult to match up with the overall

requirements. The figures for the bottom end of the range add to 10,850 housing allocations and the top of the

range add to 15,390, neither of which figures match the 13,230 in the first part of the Policy.

The Plan is therefore unclear and imprecise about the housing allocation and how this is justified compared to

the report relied upon which sets out the housing need.

Paragraph 4.40 seeks to explain the distribution of the housing baseline figure and the economic growth housing

figure. It sets out that not all of the baseline figure is allocated to the service function settlements and some 632

dwellings are then reallocated to the higher order settlements. These settlements already have the additional

growth from the economic led housing. The distribution should be reapportioned as set out in our comments

above to apportion the whole requirement of housing need to the sustainable settlements.

The explanation in para 4.41 that 4,905 homes of the allocation requirement is directed to the urban area and

main towns is misconceived for the reasons stated above. The plan does not explain how this has been worked

out in exact allocations, and appears to be subject to interpretation by a future topic paper.

On its face the Plan is not justified in Policy 3 about the following matters.

• What is the overall requirement

• What is the actual allocation

• Why is there is distinction between baseline housing growth and economic growth in distribution terms

• What is going to each settlement and why

The proposed allocations should be listed in Policy 6 in a comprehensive table to enable a proper understanding

and reading of the Plan. A plan of each site should also be included in the plan document, to ensure clarity

about the site boundaries.

Policy 6 Housing Allocations.

Support is made in principle for the allocation of sites 186 and 165. Carcroft Skellow is the largest of the

service towns and villages and a sustainable location with a good range of services.

The sites total some 15.11 hectares and the indicative capacity is 300 new homes. It is not known why the

development of the site should be included as delivering in years 6-15 of the Plan period , the site is available

and deliverable early in the Plan Period.

.

Objection is made to Table 5 of the Plan that sets out the housing requirement. The text indicates that the

requirement is variable between the bottom and top of the requirement range, but the table sets out the

requirement at the top of the range. It is therefore unclear.

The Plan should allocate sites and plan for the top of the range figure, and allocate sufficient land to meet the

remaining requirements for the 17 years of the Plan. The table as drafted allocates land for 15 years rather than

17 years and appears to under allocate the residual requirement which is 15,000 new homes.

The supply figures in the table do not reconcile with the figures at paragraph 16.21.

Some of this issue relates to the fact that sites with planning permission are also allocated.

Allocating sites with permission is confusing the plan and sites with permission do not need to be specifically

allocated. The Plan should be clear about what the contribution of the sites with Planning Permission is and how

this number is discounted, and what are the new allocations. The Plan is imprecise as drafted.

Table 5 Housing land supply calculations.

It is proposed to use the bottom of the range of the housing requirement in calculating the five year supply,

equating to the base requirement only. The Plan however is predicated on delivering land to meet the base

requirements and the economic uplift. It is not the right approach to calculating a five year housing land

requirement to ignore part of the housing requirement and base the supply on a partial element of the

requirement. This will give a false picture of the five year land supply required to deliver the housing needs

identified in the Local Plan. The plan should be amended to make it clear that the five year supply is based on

the full housing requirement of the Local Plan

Chapter 16 Spatial Proposals

The Chapter sets out the role and function of the settlements in the hierarchy. Paragraph 16.150 sets out that this

level of settlement will receive growth relating to their share of the baseline requirement, with each settlement

having a target figure relative to the existing population.

Objection is made to the fact that only the baseline growth is apportioned to the service towns and villages and

that the economic housing growth should also form part of the growth proposals for these settlements.

Carcroft /Skellow has a target of 250 new homes. This figure is objected to on the basis that

this is a highly sustainable settlement where a higher growth figure can be accommodated

on the proposed site allocation. This would reflect the sustainability of the settlement and its position near to

major industrial areas and allocations

The concept of target figures based on population and baseline growth only is flawed

and the Plan should reflect allocations in the most sustainable service towns and villages

that includes economic housing growth and should not be based solely on the existing population figures

Policy 8 Housing Mix and Affordable Housing Policy 67 Development Viability

Objection is made to this Policy as drafted, the requirement for 23% affordable homes in the

higher value areas in the District is not justified by the evidence. It is noted in para 6.9

that the overall requirement for 209 units per annum, which is 23% of the annual housing target [believed to be

the upper end of the range] does not take account of what has been committed through applications and is

therefore an unreliable figure.

The Plan should include a robust figure, and needs to include text that makes it clear that the affordable housing

has to be viable. Viability testing on sites at this stage will be unreliable until a full suite of technical documents

have assessed the site development costs and infrastructure requirements. The Plan should therefore reflect

affordable housing requirements as aspirational but subject to detailed site viability.

Policies Map

We object to the Policies Map for Carcroft /Skellow. The sites allocated as 186 and 165

should be included with the development boundary as they will form part of the settlement and should therefore

be within the residential policy area.

The alteration to the Green Belt Boundary to exclude sites 186 and 165 is supported.

Appendix 2 Development Guidelines

Objection is made to the developer guidelines as set out on pages 272 and 273, the design comments are over

prescriptive at this stage and may inhibit the development of the most appropriate layout of the site when the

detailed site details have been established.

The guidelines do not explain why an education contribution will be required and which schools this would

benefit.

7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.

(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).

1. To include the proposed allocations 186 and 165 within the development limit of Carcoft/ Skellow.

2. Allocate sufficient land for the complete plan period and to meet the full housing requirement.

3. Provide consistency between the housing requirement calculations, the supply and the allocated sites.

4. Redistribute the full housing requirement to include the service towns and villages.

5. Provide a table and plan in the text clearly indicating allocations.

6. Provide a housing land supply calculation based on the full housing requirement.

7. Provide a robust figure for affordable housing.

8. Amend the developer guidelines to be flexible and justified.

9. Amend the polices map to reflect the settlement boundary.

As explained in detail above.

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

☐ No, I do not wish to participate at the examination. I would like my representation to be dealt with by written representation.

☒ Yes, I wish to appear at the Examination.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:

We act for a number of major land owners in the Doncaster area , we have detailed knowledge of the sites and

the planning history of the Borough. We have previously been involved with the Core Strategy Plan and with

the Examination of the draft Sites and Policies DPD. Our knowledge of the various land parcels, ownerships,

the strategic land position and site specific details, means that we have information to inform the debate

regarding the overall housing requirement and the specific allocation of sites which will assist the

examination.

Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature

Date 27/09/2019

Please send your completed form, by no later than 6pm on 30th September 2019, to:

• Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU

• or email: Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan

Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:

The Council reserves the right not to publish or take into account any representations which are openly offensive

or defamatory.