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 Mrs

First Name Joanne

Last Name Harding

Organisation (where relevant)

Home Builders Federation (HBF)

Address – line 1 HBF House

Address – line 2 27 Broadwall

Address – line 3 London

Postcode SE1 9PL

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:

Home Builders Federation (HBF)

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.: Please see separately attached letter.

Site Ref.:

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 see separately attached letter.

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).

Please see separately attached letter.

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 allow for greater discussion of the industry concerns and to address any points that arise during 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 28/09/2019

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.

The Voice of the home building industry www.hbf.co.uk follow us on twitter @homebuildersfed

Home Builders Federation HBF House, 27 Broadwall, London, SE1 9PL T: E:

Local Plans Team

Planning, Regeneration and Environment Services

Doncaster Council

Civic Office

Waterdale

Doncaster

DN1 3BU

SENT BY EMAIL

23/01/2020

Dear Sir / Madam,

DONCASTER LOCAL PLAN

Thank you for consulting with the Home Builders Federation on the Doncaster Local

Plan consultation on the Draft Policies and Proposed Sites.

The HBF is the principal representative body of the house-building industry in

England and Wales. Our representations reflect the views of our membership, which

includes multi-national PLC’s, regional developers and small, local builders. In any

one year, our members account for over 80% of all new “for sale” market housing

built in England and Wales as well as a large proportion of newly built affordable

housing.

We would like to submit the following comments, these follow on from previous

comments made to the Issues & Options, Home & Settlements consultation, Draft

Local Plan carried out in 2015, 2016 and 2018 respectively.

Plan Period

It is noted that the Plan period runs from 2015 until 2035. Paragraph 22 of the NPPF

looks for Plans to have a 15-year period from adoption. As the consultation is only

just being undertaken for the Regulation 19 stage, it is unlikely that the Plan will be

adopted in 2020. Therefore, the HBF consider that it may be beneficial to take a

cautious approach and to extend the Plan period.

The HBF also note that the Plan period for land supply runs from 2018, and in the

case of housing appears to run until 2033. This appears confused and an

unnecessary complication.

Vision

The HBF is generally supportive of the bullet point within the vision states that states

that Doncaster will ‘meet our communities housing needs and aspirations focusing

growth in the main urban area, main towns, service towns and larger villages

providing a diverse range of homes’. Meeting the housing needs of the area is a key

element of the plan, which will not only provide social benefits but is required if the

Council is to meet its economic aspirations

Policy 2: Spatial Strategy and Settlement Hierarchy (Strategic Policy)

This policy sets out the proportion of homes that will be completed in the ‘Main Urban

Area’, ‘Main Towns’ and the ‘Service Towns and Larger Villages’. The HBF would

expect the spatial distribution of sites to follow a logical hierarchy, provide an

appropriate development pattern and support sustainable development within all

market areas.

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

Policy 3 is not considered to be sound as it is not positively prepared, justified or

consistent with national policy for the following reasons:

The Council has continued to identify a net housing requirement of 920 dwellings per

annum (dpa) over the plan period 2015-2035.

Paragraph 60 of the NPPF 2019 states that ‘to determine the minimum number of

homes needed, strategic policies should be informed by a local housing need

assessment, conducted using the standard method in national planning guidance –

unless exceptional circumstances justify an alternative approach which also reflects

current and future demographic trends and market signals’.

The HBF have considered the local housing need (LHN) using the Standard

Methodology set out in PPG, it can be calculated as follows:

Step 1 - Setting the baseline:

2014-based household projections in England average annual household growth

over a 10 year period, with the current year being used as the starting point.

The household projection for 2019 is 131,355 and in 2029 it is 136,591, therefore the

growth equals 5,236, giving an average of 523.6 dwellings each year.

Step 2 - An adjustment to take account of affordability:

The most recent median workplace-based affordability ratio for Doncaster (2018) is

4.81.

Where an adjustment is to be made, the formula is:

For Doncaster this would be: Adjustment Factor = (((4.81 - 4) / 4) x 0.25) + 1 = 1.051

Minimum annual local housing need figure = (adjustment factor) x projected

household growth

For Doncaster this would be: Minimum annual local housing need figure = 1.051 x

523.6 = 550 dpa.

Step 3 - Capping the level of any increase

The Doncaster Core Strategy was adopted more than 5 years ago, therefore the

local housing need figure is capped at 40% above whichever is the higher of: the

projected household growth for the area over the 10 year period identified in step 1;

or the average annual housing requirement figure set out in the most recently

adopted strategic policies.

The Doncaster Core Strategy has a housing requirement of 1,230 new homes each

year 2011-2028, 40% above 1,230 would be 1,772dpa. The capped figure is greater

than the minimum annual local housing need figure and therefore does not limit the

increase to the local authority’s minimum annual housing need figure.

It should be noted that the Standard Method identifies a minimum annual housing

need figure, it does not produce a housing requirement figure. It should also be noted

that the Government is committed to ensuring that more homes are built and

supports ambitious authorities who want to plan for growth. The Standard Method

provides a minimum starting point, and there may be circumstances where it is

appropriate to consider whether the actual housing need is higher than the Standard

Method indicates. PPG (ID: 2a-010) goes on to states that these circumstances can

include growth strategies for the area; strategic infrastructure improvements;

previous levels of delivery; or where previous assessments of need are significantly

greater than the outcome from the Standard Method.

The Peter Brett Economic Forecasts and Housing Needs Assessment 2018 identifies

a demographic starting point from the 2014-based household projections of 562dpa,

which if adjusted to match a business as usual job forecast would equate to 579dpa.

However, to match the jobs growth aspiration of the Sheffield City Region it identifies

a jobs-led housing need pf 1,073dpa. Therefore, it is clearly apparent that there are

circumstances identified that would require a housing figure significantly greater than

the outcome of the Standard Method.

The Council identify that the housing requirement will be expressed as a range with

the bottom of the range being the LHN and the top of the range being the 920 dpa.

As set out above the HBF do not consider that the LHN produced from the Standard

Method would provide an appropriate housing requirement, it is evident that the

actual housing requirement should be higher. The HBF do not consider that it would

be appropriate to limit the housing requirement at the top end of the requirement

either, and do not consider that this would be consistent with the NPPF requirement

to support the Government’s objective to boost the supply of homes.

The HBF do not wish to comment upon the exact distribution of development. The

HBF is keen to ensure that the Council produces a plan which can deliver against its

housing requirement. To do this it is important that a strategy is put in place which

provides a sufficient range of sites to provide enough sales outlets to enable delivery

to be maintained at the required levels.

The HBF consider that it is important that the levels of development proposed for

each settlement is informed by appropriate analysis of the deliverability and viability

of the sites. The HBF and our members can provide valuable advice on issues of

housing delivery and would be keen to work proactively with the Council on this

issue. It is no use continually promoting growth in locations if there is little or no

prospect of them being brought forward.

The HBF also consider that it would not be appropriate to utilise the settlement

hierarchy to limit development in other suitable locations, and as such it is important

that the housing figures are taken as a minimum not a limit.

Policy 6: Housing Allocations (Strategic Policy)

Policy 6 is not considered to be sound as it is not positively prepared or consistent

with national policy for the following reasons:

The HBF are keen that the Council produces a plan which can deliver against its

housing requirement. To do this it is important that a strategy is put in place which

provides a sufficient range of sites to provide enough sales outlets to enable delivery

to be maintained at the required levels throughout the plan period. The HBF and our

members can provide valuable advice on issues of housing delivery and would be

keen to work proactively with the Council on this issue.

The HBF also strongly recommends that the plan allocates more sites than required

to meet the housing requirement as a buffer. This buffer should be sufficient to deal

with any under-delivery which is likely to occur from some sites. Such an approach

would be consistent with the NPPF requirements for the plan to be positively

prepared and flexible. The HBF recommends an appropriate contingency (circa 20%)

to the overall housing land supply to provide sufficient flexibility for unforeseen

circumstances and in acknowledgement that the housing requirement is a minimum

not a maximum figure.

The HBF does not wish to comment upon the acceptability or otherwise of individual

sites. It is, however, important that all the sites contained within the plan are

deliverable over the plan period and planned to an appropriate strategy. The

Council’s assumptions on sites in relation to delivery and capacity should be realistic

based on evidence supported by the parties responsible for housing delivery and

sense checked by the Council based on local knowledge and historical empirical

data.

The HBF representations are submitted without prejudice to any comments made by

other parties on the deliverability of specific sites included in the overall HLS, 5 YHLS

and housing trajectories. However, the HBF do have some concerns about the

delivery of homes and seek assurance that the housing requirement will be delivered.

Policy 8: Delivering the necessary range of housing (Strategic Policy)

Policy 8 is not considered to be sound as it is not justified or consistent with national

policy for the following reasons:

Housing Mix

The HBF understands the need for a mix of house size, type, price and tenure and is

generally supportive of providing a range and choice of homes to meet the needs

and market demand in the local area. It is, however, important that any policy is

workable and ensures that housing delivery will not be compromised or stalled due to

overly prescriptive requirements or the need to provide significant amounts of

additional evidence.

The HBF recommends a flexible approach is taken regarding housing mix which

recognises that needs and demand will vary from area to area and site to site;

ensures that the scheme is viable; and provides an appropriate mix for the location.

The HBF would also highlight the need for creating a housing market that will attract

investors to Doncaster, and to provide an element of aspiration to ensure working

people and families are retained within the area. The HBF consider that the Council

need to be aware that the latest Housing Need Assessment will only ever identify

current deficits and reflects a snap-shot in time. Therefore, even the latest HNA may

not reflect the position at the time of an application. The HBF would like to ensure

greater flexibility within this policy to acknowledge that the mix can vary both

geographically and over the plan period.

Affordable Housing

This policy requires housing sites of 15 or more homes in the Borough’s high value

housing market areas to include 23% affordable homes and for 15% of affordable in

other areas.

The HBF does not dispute the need for affordable housing within Doncaster and

indeed supports the need to address the affordable housing requirements of the

borough. The NPPF is, however, clear that the derivation of affordable housing

policies must not only take account of need but also viability. Paragraph 34 of the

NPPF (2019) established the importance of viability to ensure that development

identified in the Plan should not be subject to such scale of obligations and policy

burden that their ability to be delivered might be threatened.

The Whole Plan Viability Testing (2019) report shows the issues of viability for a

number of sites. It shows that schemes in the low value areas are not viable and will

not be able to support the affordable housing requirement.

The Council should be mindful that it is unrealistic to negotiate every site on a one by

one basis because the base-line aspiration of a policy or combination of policies is

set too high as this will jeopardise future housing delivery. Therefore, site by site

negotiations on these sites should occur occasionally rather than routinely.

Policy 29: Open Space Provision in New Developments Policy 29 is not considered to be sound as it is not justified or consistent with national

policy for the following reasons:

This policy looks for residential developments to provide open space to address local

green space needs and deficiencies. Overall, the HBF is supportive of the drive

towards incorporating additional green space within new communities. However,

developers should only be expected to provide for those facilities which are made

necessary by the development proposed and not simply in order to make up for

existing deficiencies in provision or provide benefits for the community at large. It

should also be acknowledged that this may have a knock-on effect on housing

density and the need for additional land to be allocated for new development.

Policy 46: Housing Design Standards (Strategic Policy)

Policy 46 is not considered to be sound as it is not justified or consistent with national

policy for the following reasons:

Nationally Described Space Standard

This policy looks for all new housing to meet national spaces standards as a

minimum. However, these enhanced standards, as introduced by Government, are

intended to be optional and can only be introduced where there is a clear need and

they retain development viability. As such they were introduced on a ‘need to have’

rather than a ‘nice to have’ basis.

PPG (ID 56-020) identifies the type of evidence required to introduce such a policy. It

states that ‘where a need for internal space standards is identified, local planning

authorities should provide justification for requiring internal space policies. Local

planning authorities should take account of the following areas:

Need – evidence should be provided on the size and type of dwellings currently

being built in the area, to ensure the impacts of adopting space standards can be

properly assessed, for example, to consider any potential impact on meeting

demand for starter homes.

Viability – the impact of adopting the space standard should be considered as

part of a plan’s viability assessment with account taken of the impact of potentially

larger dwellings on land supply. Local planning authorities will also need to

consider impacts on affordability where a space standard is to be adopted.

Timing – there may need to be a reasonable transitional period following adoption

of a new policy on space standards to enable developers to factor the cost of

space standards into future land acquisitions’.

The Housing Design Standards Policy Evidence Paper (June 2019) surveyed 246

homes across 47 sites, to determine how many met the NDSS. It is not apparent if

these sites had been submitted after the Government introduction of the NDSS, but it

seems unlikely that it would have been in place at the time many of the applications

were submitted. The Council indicate that through there research they have identified

that a number of properties have not been built to the NDSS. They state that ‘201 out

of the 246 plans assessed met the gross internal floor area based on their proposed

number of bedrooms’ and that ‘plans were more likely to fail against the NDSS based

on storage space or bedroom size, highlighting an internal design issue as opposed

to dwelling plot size’. The Council also suggest that the NDSS would be beneficial in

providing ventilation, reducing under-occupancy and over-crowding. However, the

evidence provided is limited in terms of numbers of properties considered and the

potential market comparisons made. It is not evident from the information provided

what ‘need’ there actually is for properties built to the standards there is no evidence

that these smaller properties are not selling, there is no evidence provided that

customers are not satisfied with these properties or that these properties are not

comparable to other properties available in the market area. The HBF consider that if

the Government had just expected all properties to be built to NDSS that they would

have made these standards mandatory not optional.

The HBF consider that standards can, in some instances, have a negative impact

upon viability, increase affordability issues and reduce customer choice. In terms of

choice some developers will provide entry level two, three and four-bedroom

properties which may not meet the optional nationally described space standards but

are required to ensure that those on lower incomes can afford a property which has

their required number of bedrooms. The industry knows its customers and what they

want, our members would not sell homes below the enhanced standard size if they

did not appeal to the market.

It should be noted that the HBF Annual Industry Customer Satisfaction Survey

published March 2019 and completed by 60,955 new homeowners highlights that

90% of people who have bought a new home would do so again. It also highlights

that 93% of homeowners are satisfied with the internal design and layout of their new

home. This does not suggest that new homeowners have issues with the size of

rooms provided or that there is a need for the NDSS to be introduced.

Accessible and Adaptable Dwellings (M4(2))

Policy 46 looks for 65% of homes on developments of 10 or more (or over 0.5ha) to

be at M4(2) standards, and for 5% to be provided at M4(3) standards.

The HBF is generally supportive of providing homes that are suitable to meet the

needs of those with limiting long term illnesses or disabilities. However, if the Council

wishes to adopt the higher optional standards for accessible, adaptable and

wheelchair homes the Council should only do so by applying the criteria set out in the

PPG.

It must be remembered that all new homes will be built to part M4(1). According to

Part M of the Building Regulations meeting M4(1) will ensure reasonable provision

for most people, including wheelchair users, to approach and enter the dwelling and

to access habitable rooms and sanitary facilities on the entrance storey. As such

these standards are likely to be suitable for the majority of people.

PPG (ID 56-07) identifies the type of evidence required to introduce such a policy,

including the likely future need; the size, location, type and quality of dwellings

needed; the accessibility and adaptability of the existing stock; how the needs vary

across different housing tenures; and the overall viability. It is incumbent on the

Council to provide a local assessment evidencing the specific case for Doncaster

which justifies the inclusion of optional higher standards for accessible / adaptable

homes in its Local Plan policy.

The Housing Design Standards Policy Evidence Paper (June 2019) identifies that

18.78% of the population of Doncaster was over 65 yrs in 2017 and that 24.83% will

be by 2035. The HBF does not dispute the ageing population within Doncaster,

however, it is not clear how this ageing population and potential future need reflects

in the need for 65% of all new homes to be provided at M4(2) standards. If it had

been the Government’s intention that generic statements identifying an ageing

population justified adoption of the accessible & adaptable homes standards, then

the logical solution would have been to incorporate the M4(2) as mandatory via the

Building Regulations which the Government has not done. The optional higher M4(2)

standard should only be introduced on a “need to have” rather than a “nice to have”

basis. The evidence does not demonstrate this need.

The Housing Design Standards Policy Evidence Paper (June 2019) also that older

people and individuals with a long-term health problem or disability (LTHPD) would

prefer to live in smaller, one or two bed- properties. It is not clear how this evidence

has been considered in relation to the policy.

The Whole Plan Viability Testing (2019) report shows the issues of viability for a

number of sites. It shows that schemes in the low value areas are not viable and will

not be able to support the optional housing standards along with the cumulative

requirements from other policies.

If the Council can provide the appropriate evidence and this policy is to be included,

then the HBF recommend that an appropriate transition period is included within the

policy. The PPG also identifies other requirements for the policy including the need to

consider site specific factors such as vulnerability to flooding, site topography and

other circumstances; and that policies for wheelchair accessible homes should only

be applied to dwellings where the local authority is responsible for allocating or

nominating a person to live in that dwelling.

Policy 67: Development Viability (Strategic Policy)

Policy 67 is not considered to be sound as it is not consistent with national policy for

the following reasons:

The HBF considers that there may be some circumstances where this policy and the

use of trigger points can be utilised to bring forward the delivery of homes. However,

the HBF have significant concerns around the implementation of this policy and how

frequently it will be used. The use of trigger points could add further burdens to any

developer who will need to reproduce viability assessments at a potentially regular

basis, going against Government initiatives which are looking to reduce the need for

viability assessments. The HBF considers that this policy causes unnecessary

uncertainty and additional risk for developers, and that such disincentivising of

developers could become an impediment to the development process and

compromise the deliverability of large sites particularly those phased and

implemented over long time periods.

Future Engagement

I trust that the Council will find these comments useful as it continues to progress its

Local Plan. I would be happy to discuss these issues in greater detail or assist in

facilitating discussions with the wider house building industry.

The HBF would like to be kept informed of all forthcoming consultations upon the

Local Plan and associated documents. Please use the contact details provided below

for future correspondence.

Yours sincerely,

Joanne Harding

Local Plans Manager – North

Email:

Phone: