COMMENTS (REPRESENTATION) FORM... · If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations

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

First Name Justin

Last Name Gartland

Organisation (where relevant)

Don Parkinson Partnership Lichfields

Address – line 1 C/O Agent 3rd Floor, 15 St Paul’s Street

Address – line 2 Leeds

Address – line 3

Postcode LS1 2JG

E-mail Address

Telephone Number

http://www.doncaster.gov.uk/localplan

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



http://www.harrogate.gov.uk/info/20101/planning_policy_and_the_local_plan/556/local_plan_-_evidence_base


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:

Don Parkinson Partnership

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.: Paragraph:

Policy Ref.: 2, 3, 6, 26, 58 Site Ref.: 002, 003, 004 and 005

Policies Map:

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.

Please refer to accompanying representation ‘Doncaster Local Plan Representations to Draft Doncaster Local Plan - Publication Draft’ (September 2019) on behalf of Don Parkinson Partnership (doc ref. 60752/01/JG/AK).

Policy 2 – see pages 10, 11 of accompanying representation. Policy 3 – see pages 3-5, 11 of accompanying representation.

Policy 6 – see pages 5-6, 7-9, 11 of accompanying representation. Policy 26 – see pages 10, 11 of accompanying representation.

Policy 58 – see pages 10, 11 of accompanying representation. Also see Appendix 1 and 2 of accompanying representation.

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).


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:

To fully represent our clients land interest and respond to matters that may be raised at the hearing sessions.


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

Date 30/09/2019

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.

http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice

Doncaster Local Plan

Representations to Draft Doncaster Local Plan - Publication Draft

Don Parkinson Partnership

September 2019

© 2019 Nathaniel Lichfield & Partners Ltd, trading as Lichfields. All Rights Reserved. Registered in England, no. 2778116. 14 Regent’s Wharf, All Saints Street, London N1 9RL Formatted for double sided printing. Plans based upon Ordnance Survey mapping with the permission of Her Majesty’s Stationery Office. © Crown Copyright reserved. Licence number AL50684A 60752/01/JG/AK

Doncaster Local Plan : Representations to Draft Doncaster Local Plan - Publication Draft

Contents

1.0 Introduction and Summary of Representation 1

2.0 Context 2

3.0 Housing Requirement 3

Local Plan Period 3

Flexibility 3

Five Year Housing Land Supply 4

4.0 Housing Policies 5

Policy 3 - Level and Distribution of Growth (Strategic Policy) 5

Policy 6 - Housing Allocations (Strategic Policy) 5

5.0 Housing allocation 7

Land Between Thorne & Moorends (Site refs. 002,003, 004 and 005) 7

Overview 7

Sustainability 7

Flood Risk 8

Summary 9

6.0 Other Policies 10

Policy 2 – Spatial Strategy and Settlement Hierarchy (Strategic Policy) and Policy 26 –

Development in the Countryside 10

Policy 58 – Flood Risk Management 10

7.0 Conclusion 11


Appendices

Appendix 1 Site Location Plan

Appendix 2 Draft Sites and Policies DPD – Policies map


Pg 1

1.0 Introduction and Summary of Representation

1.1 Lichfields is instructed by Don Parkinson Partnership (Don Parkinson) to make representations

to the Publication Version of the Doncaster Local Plan published for consultation by Doncaster

Council (the Council) on 12 August 2019.

1.2 These representations relate specifically to an area of land measuring approximately 32 ha in

size between the existing built up areas of Thorne and Moorends, identified in earlier iterations

of the draft local plan as Sites 002,003, 004 and 005, and referred to for the remainder of these

representations as the ‘subject site’ (Appendix 01) They build on earlier representations made

by J R A Moorhouse Planning to the Draft Policies and Proposed Sites October 2018

consultation on behalf of the same landowner.

1.3 The land is in the full control of Don Parkinson, the site is strategically positioned to

accommodate housing and there are no insurmountable constraints to bringing this land

forward for development as an allocation in the Local Plan. Further, there is no justification for

reversing the Council’s previous decision to allocate the land for housing development in the

previous draft Local Plan.

1.4 The land (and wider Thorne/Moorends settlement) has long been recognised as a sustainable

location for growth. The Draft Sites and Policies DPD (2014) identified the northern and

southern section of the site as a residential allocation (Appendix 02). The Housing and

Economic Land Availability Assessments (2018) identifies the full site as available, deliverable

& developable within the first 6-10 years, capable of supporting 754 units and suitable for

development but with national policy or physical constraints. The Settlement Profiles, Local

Plan Evidence Base (2018) report identified the settlement as having excellent access via road

and rail and “one of the best scoring settlements against the Settlement Audit Criteria”

1.5 Despite the site’s obvious strengths and long-standing history as a preferred location for

residential growth, the Publication Draft of the Local Plan fails to identify the site as a preferred

location for residential growth.

1.6 The remainder of these representations are dedicated to demonstrating that the Plan in its

current form is unsound when considering relevant national policies, and that despite the

Council’s latest conclusions on the suitability of this site for housing, there are no

insurmountable constraints to brining the subject site forward in the plan period. In particular,

it is the view of Don Parkinson that the Plan fails to deliver a sustainable pattern of

development, by not allocating sufficient growth to Thorne/Moorends in line with the Plan’s

own hierarchy.


Pg 2

2.0 Context

2.1 Thorne is defined as one of the Boroughs Main Towns and is expected to accommodate 510 –

1,020 dwellings which equates to 5.5% of the 40% of new homes allocated to this centre over the

plan period. The Policies Map allocates sites (without planning permission) capable of

supporting just 345 dwellings (736 dwelling including allocations with permission) within

Thorne/Moorends, allowing few opportunities for choice and competition in the local housing

market and a reduced delivery of much needed affordable housing. The remainder of the

proposed allocations to Moorends is made up of sites with extant planning permission, although

not necessarily being delivered or capable of being delivered.

2.2 Don Parkinson is concerned that the number of dwellings proposed to be allocated for the

Borough has been significantly underestimated in this iteration of the Local Plan. We note that

this concern has been shared by a number of other parties during the local plan consultation

process, with a number of the parties raising similar concerns as part of earlier representations.

In summary, Don Parkinson considers that contrary to the Council’s latest claims in relation to

its housing needs, the number of houses currently identified will not meet the objectively

assessed housing needs of the community over the plan period, particularly in locations such as

Thorne/Moorends where significant employment growth is expected.


Pg 3

3.0 Housing Requirement

Local Plan Period

3.1 Draft Policy 3 states that the plan period in which to meet the Council’s aspirations for

Doncaster is 2015 – 2035.

3.2 Paragraph 22 of National Planning Policy Framework (NPPF) states that strategic policies

should look ahead over a minimum 15 year period from adoption. This is to ensure that the plan

responds to long-term requirements and opportunities. It is important that the Council makes

robust assumptions within their evidence base in respect of expected adoption of the Local Plan.

3.3 The Council’s latest Local Development Scheme (LDS) (March 2019) states that the plan will not

be adopted until Summer 2020. It is considered that the LDS is optimistic in its timeframes

from submission of the Local Plan up to adoption. It is unclear if the Council has made an

allowance for Main Modifications to be drawn up, consulted on and considered within the

estimated examination period.

3.4 From Lichfields’ experience of Local Plan examinations within the Yorkshire area, it is

considered that the timeframes within the LDS should be amended, particularly in respect of

timeframes between submission and examination. As an example, the Kirklees Local Plan took 6

months from submission to the Secretary of State to the start of the examination, the

examination (including main modifications) lasted 12 months, and the Inspector’s report was

received three months following the close of the main modifications consultation. These

timeframes are considered to be a more realistic indication of the likely time which will be

needed at Doncaster and would suggest an estimated date of adoption of September 2021, as

shown in Table 3.1.

Table 3.1 Estimated timeframe for Local Plan examination

Stage DC Estimate Lichfields Estimate

Submission to the Secretary of State Late Autumn 2019

November 2019

Estimated examination period (assumed this period includes Main Modifications)

Winter 2019/20

May 2020 – May 2021

Receipt of inspector's report Spring 2020 August 2021

Estimated date of adoption Summer 2020

September 2021

Source: Lichfield Analysis

3.5 It is considered that the plan period should be extended to account for the estimated adoption

based on Lichfields timeframes and to ensure that a minimum 15 year time period from

adoption is achieved. Based on the Council’s housing requirement (920 dpa) this would result in

at least 19,320 dwellings to be delivered during the plan period up to 31st March 2036.

Flexibility

3.6 Paragraph 11 of the NPPF states that:

plans should positively seek opportunities to meet the development needs of their area, and be

sufficiently flexible to adapt to rapid change

3.7 This flexibility can be achieved by identifying land as housing allocations which appropriately

exceeds the housing requirement to provide market choice and to act as a buffer should


Pg 4

allocations not become available in the time or manner expected, or should circumstances

prevent the expected site yields being fulfilled.

3.8 The Plan should therefore seek to allocate land which will meet the minimum requirement and

then apply an appropriate buffer on top of this residual requirement. The Council should also be

looking to allocate sites across the whole plan period and it is unclear why the Council choose to

apply different plan periods when calculating its five year housing land supply and considering

allocations to meet its housing need. It is noted that the draft Local Plan currently proposes to

allocate sites which will have a combined capacity significantly in excess of the residual

requirement of 15,000 dwellings. However, there is scope for this to be further increased to

deliver housing within sustainable settlements such as Thorne/Moorends to meet housing needs

across a full NPPF-compliant plan period.

Five Year Housing Land Supply

3.9 Draft Policy 3 states that the Council will apply the proposed housing requirement of 920 dpa

when considering allocations during the plan period (2015 – 2035), however for the purposes of

calculating five year housing land supply the Council will rely on the Standard Methodology

figure. It is considered that this approach does not meet national policy and guidance. The PPG1

states that:

Housing requirement figures identified in adopted strategic housing policies should be used for

calculating the 5 year housing land supply figure where:

• the plan was adopted in the last 5 years, or

• the strategic housing policies have been reviewed within the last 5 years and found not to

need updating.

In other circumstances the 5 year housing land supply will be measured against the area’s

local housing need calculated using the standard method.

3.10 Therefore, once the local plan is adopted the Council should be applying the housing

requirement which was adopted and not the standard methodology. The Council should revisit

this policy to ensure it is in compliance with national planning policy (paragraph 73 of the

NPPF).

1 Paragraph: 005 Reference ID: 68-005-20190722


Pg 5

4.0 Housing Policies

Policy 3 - Level and Distribution of Growth (Strategic Policy)

4.1 Draft Policy 3 as drafted is considered to be unsound and should be amended to state that the

Council will seek to deliver a minimum of 18,400 new homes during the plan period in

accordance with paragraph 60 of the NPPF.

4.2 It is considered that there is scope to allocate additional housing over and above what is

currently proposed, to provide a buffer and ensure delivery throughout the plan period. The

Council should look at distributing additional housing sites in accordance with the settlement

hierarchy, such as Thorne. From a review of the current distribution of allocations it is

considered that the Council should revisit the current strategy and seek to focus further housing

to the Main Town settlements rather than Service Towns and Villages as shown on the table

below.

Table 4.1 Distribution of proposed allocations

Settlement Proposed distribution

(Policy 3)

Proposed Allocation

Up to 2035

(Table H1 and H2)* **

Percentage of Total

Allocations

(Table H1 and H2)

Doncaster MUA 6,805 – 7,315 7,441 46%

Main Towns 2,985 – 6,715 6,292 39%

Service Towns and Villages 1,360 2,382 15%

Total 11,150 – 15,390 16,115 100%

Source: Lichfields Analysis

Excludes delivery beyond plan period*

Uses units remaining in respect of Table H1**

4.3 The plan in its current form is neither adequate nor proportionate and fails to take account of

local market signals within the Thorne/Moorends settlement, and if allowed to continue will

both stifle market conditions and cause additional affordability concerns for local residents. The

Council should seek to distribute additional housing to Thorne over and above its current

allocation in order to fully meet the proportion of housing distributed to the settlement.

Policy 6 - Housing Allocations (Strategic Policy)

4.4 Draft Policy 6 identifies the proposed housing allocation which will deliver the housing

requirement during the plan period. The proposed allocations are detailed within Tables H1 and

H2 of the local plan and identify allocations with and without planning permission. The

distribution of housing is considered to be based on the settlement hierarchy set out within

Draft Policy 3. As drafted, Don Parkinson considers that the policy is unsound and is not

consistent with national policy. The local plan is proposing to allocate a number of sites (without

planning permission) currently in the Green Belt (including Site refs. 033, 115, 040, 501, 777,

141, 165/186, 929, 1028) before considering other sustainable sites located outside of the Green

Belt (NPFF paragraphs 135, 136, 137).

4.5 Whilst Don Parkinson accept that Green Belt land will need to be released to support the future

housing needs of Doncaster, it is considered these sites should only come forward and Green

belt land released after the opportunities to allocate and develop on non-Green Belt land have

been exhausted.


Pg 6

4.6 It is considered that the Council must seek to allocate additional housing on Countryside land in

the first instance, particularly in sustainable locations, where the current levels of housing

allocation fall short of the Plan’s own growth expectations under the terms of the settlement

hierarchy. The distribution of additional dwellings should follow the Council’s settlement

hierarchy and therefore consider further housing allocations within Main Towns should as

Thorne. Don Parkinson is promoting a site within a sustainable location, which can help deliver

additional housing on non-Green Belt land located on the edge of and well-related to a

sustainable Main Town settlement. Further details are provided within Section 5 below.


Pg 7

5.0 Housing allocation

Land Between Thorne & Moorends (Site refs. 002,003, 004 and 005)

5.1 The subject site (and wider Thorne/Moorends settlement) has long been recognised as a

sustainable location for growth. The Draft Sites and Policies DPD, 2014 identified the northern

and southern section of the subject site as a residential allocation (Appendix 02). Clearly, at the

point of the proposed allocation it was known that the sites were within Flood Zone 3 but the

Council proposed to allocate the sites for housing despite this designation.

5.2 The Housing and Economic Land Availability Assessments (2018) identifies the full site as

available, deliverable & developable within the first 6-10 years, capable of supporting 754 units

and suitable for development but with national policy or physical constraints. It is considered

that this constraint can be overcome in respect of flood risk, similar to other proposed housing

allocations within Thorne.

Overview

5.3 The subject site, which comprises an irregular piece of agricultural land measuring 32 ha in size,

is located off Marshland Road, between the settlements of Thorne and Moorends. It is

surrounded by residential land uses to the east and employment land uses to the west. Ferndale

Drive residential area is located to the immediate north-east of the site, with the wider

Moorends residential area beyond. A large employment corridor runs in a north-east to south-

west direction (parallel with the nearby M18) to the west of the site.

5.4 The site is extremely well positioned from a transport perspective, with the M18 just 540 metres

to the west and Thorne North Railway Station just 1 kilometre to the south west. Indeed, Thorne

is the only settlement outside of the Main Urban Area to have two train stations. The site is also

within walking distance of both the Moorends and Thorne High Streets.

5.5 Vehicular access is available from both the north (Bloomhill Road) and east (Marshland Road)

of the site and from the south from Lands End Road/Alexandra Street and potentially Ivy Road.

Vehicular access is also available from Willow Avenue to the east of Ivy Road and also Ferndale

Drive at the North East of the site.

5.6 The River Don is located approximately 1.1 km west of the site. This river flows in a

northerly/north-easterly direction to its confluence with the River Ouse at Goole approximately

10.0 km north-east of the site.

5.7 In policy terms, the site is located within the Countryside and therefore is in a sustainable

location which can deliver new housing on a non-Green Belt site.

Sustainability

5.8 As noted above, both the Council and the Thorne and Moorends Town Council have previously

recognised the northern and southern section of the subject site as a sustainable location for the

delivery of houses. The site’s potential to support new housing was initially acknowledged

through the allocation of the site under the Sites and Policies DPD (2014) allocated the northern

and southern section of the site to meet Thorne/Moorends strategic housing requirements.

5.9 The Council has also continued to recognise the wider Thorne/Moorends settlement as one of

the most sustainable locations for housing within the Borough:


Pg 8

“Thorne & Moorends is one of the best scoring settlements against the Settlement Audit

criteria…The combined population is 17,295, and the settlement is one of only three in the

borough to have a town centre, which serves a wider catchment than just the town itself…

Thorne and Moorends is the only settlement in the borough (outside of the Main Urban

Area) to have two train stations” (Settlement Profiles, Local Plan Evidence Base)

Flood Risk

5.10 The draft Local Plan recognises that over two fifths of the Borough is located within areas at a

medium to high risk of flooding from both the river Don and Trent catchments (Paragraph

2.26). This includes Main Towns such as Thorne which is considered to be in a very sustainable

locations for development and are otherwise appropriate locations for growth in line with wider

spatial planning objectives.

5.11 Furthermore, in respect of Thorne the Council state:

The Local Plan housing allocation at the Main Town of Thorne-Moorends is constrained by a

lack of potential development sites not at high risk of flooding. Although sufficient sites have

been identified to meet the town’s local needs housing, and some economic-growth led housing

as well, were it not for this physical constraint to plan-making then the Main Town would

have seen an allocation towards the top of the growth range. This is due to the town’s size and

population as being one of our largest communities outside of the Main Urban Area with

strong sustainability credentials, for example: 2 train stations; frequent bus links; large town

centre with excellent range of services and facilities; and no Green Belt constraints to growth.

(Paragraph 16.142)

5.12 Despite the suitability of the subject site and the settlement, the Council has not identified the

subject site as a preferred location for housing within the local plan. The Council has instead

chosen to dismiss this site on flood risk grounds.

5.13 Don Parkinson has met with the Environment Agency (EA) to discuss the proposed housing

development of the subject site. The EA is satisfied that if appropriate finished floor levels can

be achieved on site then the proposals could be delivered satisfactorily to address any flood risk

concerns. The scale of the subject site is such that an increase in floor levels to +3.5m AOD can

be achieved without any negative impact in townscape terms. Don Parkinson is currently

instructing further modelling work to support an application for residential development on the

subject site, which is likely to indicate floor levels lower than a +3.5mAoD increase can be

achieved.

5.14 It is considered that the Council should review the application of the Sequential Test in relation

to the proposed allocation of sites for residential development within Thorne. Whilst it is

accepted that some sites have prepared site specific Flood Risk Assessments and passed the

Sequential Test, a number of the Thorne sites were scored similar to the subject site within the

Level 1 Strategic Flood Risk Assessment. As such, it is considered that there should be the

opportunity through the local plan process for other sustainable sites, such as the subject site, to

demonstrate it can overcome flood risk issues and be allocated for housing development to:

1 Ensure that the Council has fully explored the extent of non-Green belt land available for

development before releasing Green Belt land; and

2 Ensure that Thorne is allowed to grow in line with the settlement hierarchy and the

Council’s own consideration of the proportion of growth that should rightly be apportioned

to the town.


Pg 9

Summary

5.15 The Publication Draft Plan is not positively prepared as it fails to provide the required housing

allocations to meet a NPPF-compliant Plan period. Nor does it allocate sufficient land to meet

the borough’s housing requirement. The draft Plan is unsound on the basis of its failure to give

full consideration to the growth potential of Thorne as one of the borough’s most sustainable

locations and has failed to comply with NPPF by not considering non-Green Belt land before

allocating substantive areas of Green Belt for development. The absence of the subject site as an

allocation for housing development is a failure of the draft Local Plan.

5.16 The subject site represents a wholly sustainable location for growth for the following reasons:

• The site is situated within one of Doncaster’s Main Towns and is thus a location within

which there is strong policy support for future growth

• The site is located outside of the Green Belt and its allocation will reduce the need to seek to

allocate additional housing sites which are located within the Green Belt, in accordance with

the NPPF.

• The site is well-contained and represents an excellent example of a rounding-off

edge of settlement housing site being bounded by existing residential development to

the north, east and south and the railway line to the west.

• The site is well-connected to the existing settlement centres of Thorne and

Moorends by both road and by foot.

• There is a technical solution (raised finished floor levels) to the sites flood zone designation

that would overcome floor risk concerns that would prevent this site from being

developed. Discussions are ongoing with the EA in respect of this matter.

• The site is of a size and location capable of supporting a sustainable and viable

mix of housing types, tenures and sizes.


Pg 10

6.0 Other Policies

6.1 This section reviews other draft policies in the emerging Local Plan which are relevant to major

housing development.

Policy 2 – Spatial Strategy and Settlement Hierarchy (Strategic Policy) and Policy 26 – Development in the Countryside

6.2 Draft Policy 2 sets out that residential development will be supported in the Countryside if

adjacent to a Development Limit of a settlement in levels 1-3 and will meet a number of criteria.

As drafted, Don Parkinson considers that the policy is unsound and not positively prepared or

justified. It is considered that the Council should consider unallocated sites which may come

forward during the plan period which are considered to be sustainable development. Part 5e is

considered to be unduly onerous and is totally unjustified. As drafted it restricts any unallocated

development which is found to be sustainable, the NPPF is clear that five year supply and

proposed allocations should identify a minimum of housing.

6.3 Furthermore, it is considered that the Development Limits of Thorne should be amended to

include the subject site (Sites 002,003, 004 and 005).

6.4 Draft Policy 26 sets out that planning permission for new dwellings within the Countryside will

be granted for dwellings to meet the essential needs of agriculture, forestry, or other enterprise

which justifies a rural location (which also meets a range of criteria). The policy does not take

into account that some areas of Countryside identified on the policies map is located adjacent to

Main Towns which are more urban in character than rural. The policy should be amended to

support the delivery of unallocated housing sites which may come forward within such areas.

6.5 Don Parkinson considers that draft Policy 2 and 26 as drafted is unsound and not effective or

justified. The Council should seek to amend the policies as discussed above.

Policy 58 – Flood Risk Management

6.6 Draft Policy 58 sets out the approach the Council will take when considering development

proposals within areas of flood risk. Don Parkinson supports the Council’s approach in respect

of identifying areas of search when undertaking Sequential Tests. It is considered appropriate

that the Council is seeking to confine areas of search within the same settlement.


Pg 11

7.0 Conclusion

7.1 In these representations it has been demonstrated that the draft Local Plan is not sound as

drafted. This is due to the plan not being positively prepared and failing to identify and allocate

deliverable non-Green Belt sites before considering the release of Green Belt land in accordance

with the NPPF. Don Parkinson considers that the Council should revisit its strategy for housing

allocations and seek to deliver housing on non-Green Belt sites in the first instance.

7.2 Don Parkinson has control of a sustainable site within Thorne which is not currently allocated

but suitable to help meet the Council’s housing requirement and reduce the need for Green Belt

release sites. Don Parkinson has entered into discussions with the Environment Agency in

respect of the site currently in a Flood Zone 3 designation and it is considered that there is a

suitable technical solution to support the delivery of housing on the subject site.

7.3 Other policies which should be modified to ensure they are capable of being considered sound

include, Policies 2 and 26, which restrict the delivery of sustainable unallocated housing sites

coming forward if the Council can demonstrate a five-year supply. Furthermore, the policy seeks

to restrict housing delivery to circumstances which justify a rural location. These policies do not

reflect the fact that areas of Countryside are located adjacent to Main Towns which are more

urban in character and can be brought forward as sustainable extensions to established

settlements.

7.4 Don Parkinson considers that the proposed amendments to the Plan, which could result in the

Plan being considered to be both positively prepared and sound, can be achieved through the

process of Main Modifications to the Publication Plan, should it proceed to Examination in the

current form.


Pg 12

Doncaster Local Plan: Appendix 1 Site Location Plan

Appendix 1 Site Location Plan

21

El

2.1m

WIL LOW

16

MP 13.0

1

41

BLOOMHIL L ROAD

29

Sw eet

CAMBRIDGE DRIV E

ET L

1

11a

66

57

84

34

2

North

3

24

3c

1.9m

35

28

2

3

15

Club

North Com m on13

4

32

48

2

12

1314

159

61

Northcote

53

30

PW

CRESCENT

13

7

1

3

42

Pa th (um)

5

46a

Bloom hill Stud Fa rm

14

Drain

Dra in

Drain

North Com m on Farm

1

108

2

1

Drain

26

121

Green

1

Gara ge

68

El Sub Sta

17

MOU NT

L iby

Bide A Wee

911

MP 0.50

16

BIRCHWOOD CLOSE

T he Hedgerow

11

Rivendell

1

(PH)

60

PW

Acres

WIL LOW

18

Dra in

17

3

46

Drain

3460

Gov

ROAD

Ra lglen

Mount

T horn Enterprise Park

15

1d

1.6m

15

West Croft

31

3436

19

Co Const Bdy

15

8

42

MARSHLAND ROAD

2

Rosedene

9

55

T he Old Nursery

45

MAPLE ROAD

ALEXANDRA

IV Y ROAD

MOUNT PLEASANT

7

Ridgew a y

Bloom hill

13

10

T a nks

1.8m

72

14

Children's Centre

Drain

149

11

121

WIL LOW GROV E37

34

Drain

27

5

120

Dra in

25

14

71

1

1a

1

18

3b

15

ROAD

58

Stone L ea

Drain

SL

Bunga low

158

10

13

26

1.7m

8

37

39

8

1

ESS

2a

HOL L Y ROAD

Drain

160

12

10

Drain

44

Moorends

Depot17

Lodge

60

1

FERNDALE DRIV E

16

15

Co Const Bdy

FERNDALE DRIVE

Ma st

1

11

65

WALNU T ROAD

1

46

80

Co Const Bdy

6

5

PLEASANT

Moorville

67

42

10

86

14

5

House

26

Sa lva tion Arm y Cita del

2

MULBERRY AV ENUE

2

1.8m

ST REET

2c

15

1

31

44a

Comm on Dra in

40

T udor Lodge

19

51

13

Kelw a y

49a

1

50

9

4

24

151

Drain

45

43

15

10

21

Redm ore

28

BLOOM HIL L GROVE

Bria r 26

5.7m

1b

House

41

WIL LOW AVENU E

7

Field V iew

3e

Ashlea

1.5m

Broa dbent House

Plea sa nt

18

3

2.5m

CEDAR ROAD2

2

19

21

Bloom hill

10

Drain

27

Drain

11

Moorends

Moorcroft

18

8

47

20

1.6m

2

7

ROWAN CLOSE

49

BLOOMHIL L ROAD

17

2

Dra in

49

3d

20

2

Denby Da le

Dra in

54

8 46

19

20

96

Am bleside

5

Com m on

1

15

49

El Sub Sta

2.8m

North

58

1c

18b

22

20

68

LC

2

10

2.9m

Ga s Gov

Path (um)

7

11

2.6m

Dra in

Drain

36

36

Relay House

LABU RNUM AVENU E

Ford

3a

25

11

1

22

29

Sub Sta

1

14

2

L AU REL AV ENU E

Dra in

20

Stoneholt

Ea stga te

1

29

Pond

79

2

LC

MP 0.25

FB

15

15Priory

3.0m

North Comm on Dra in

68

OXFORD ST REET

1

39

2b

T he Bra m bles

16

New fields

Ga bles

Stud Farm

GP

11

2

32

2

18a

18

35

Works

Dra in

48a

76

40

Shelter

Gas

30

2

Fern V iew

T he

Def

1.8m

25

Ordna nce Survey, (c) Crown Copyright 2019. All rights reserved. L icence num ber 100022432

KeySite Boundary

L a nd betw een T horne & Moorends,Donca sterSite Loca tion Pla n

Don Parkinson

09.07.20191 : 3,500 @ A3MARGIS\LF\60752\01-01

GIS Reference: S:\LF Jobs\LF60752 - L a nd betw een T horne a ndMoorends\LF60752 - L a nd betw een T horne a nd Moorends - SiteLoca tion - 09.07.2019.m xd

Ba sed upon Ordna nce Survey m a pping with the perm ission of Her Ma jesty’sSta tionery Office. © Crown Copyright reserved. L icence num ber 100017707

Project

T itle

Client

DateSca leDra wn byDrg. No

N

0 10050 m

Doncaster Local Plan: Appendix 2 Draft Sites and Policies DPD – Policies map

Appendix 2 Draft Sites and Policies DPD – Policies map

80

85

38433

9

382653

418

179

60435

180

41

201

34

241

483

60

46

29

57

49

88

500

239

48

489

375

27

36

135

656

606

420

458

654

154421

409

21

188

40823

551

331

336

651

R02

MUA02MUA01

MUA03

MUA04

E03

AW01

MEX03

E02

MUA07

ASK01

CON01

HS01

T04

MEX02

MUA10

MUA14

MUA06

MUA08

MUA15

ASK04

HS02

MUA11

T01

MUA12

MUA21

CON02D01

HS05

MUA16

MUA13

MUA12

R01

MEX10

MUA25

MUA23

HS03

MEX06

HS06

MUA30

MEX05

MUA19

E04

MUA18

MEX04

MUA20

MUA27

MEX09

HS04

HS07

T03

MUA17MUA17

MEX07

T02

ASK03

MUA31

MUA26

MUA22

CON03

MUA24

CS01

MEX08

MUA28

DN7

MX02

MX10

MX07

MX05

MX03

MX01

MX08

MX06

MX04

MX09

Title :

Scale :

Date :

Notes :

Key :

Sites and PoliciesHousing Sites

1:30,000

31 October 2012

This map is reproduced from Ordnance Survey material with the permission of Ordnance Survey on behalf of the Controller of Her Majestys Stationery Office (c) Crown copyright. Unauthorised reproduction infringes Crown copyright and may lead to prosecution or civil proceedings. License Number 100019782. 2012.The map may contain Aerial Photography Supplied by the GeoInformation Group (c) 1997, (c) 2002, (c) 2005, (c) 2007.

Proposed Housing Sites

Housing Sites with Permission

Boundary of DN7 Mixed UseRegeneration Project

Doncaster Boundary

Employment Sites

Armthorpe Neighbourhood Plan Boundary

Lakeside - Mixed Use

Potential Mixed Use Site (* see note below)

* A number of potential housing sites consulted onpreviously have now been subsumed within the mixed usesites shown on the map, as summarised below:

Housing sitessubsumed

215479, 480, 481 and 214211, 212 and 213542MUA05 and MUA32MUA09MEX01ASK0218, 339 and 655E01

Mixed UseSite Reference

MX01MX02MX03MX04MX05MX06MX07MX08MX09MX10

Documents

COMMENTS (REPRESENTATION) FORM... · If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations