Post on 14-Aug-2020
transcript
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
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:
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).
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).
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 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).
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.
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
Doncaster Local Plan : Representations to Draft Doncaster Local Plan - Publication Draft
Appendices
Appendix 1 Site Location Plan
Appendix 2 Draft Sites and Policies DPD – Policies map
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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.
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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.
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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
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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
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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.
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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.
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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:
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“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.
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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.
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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.
Doncaster Local Plan : Representations to Draft Doncaster Local Plan - Publication Draft
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.
Doncaster Local Plan : Representations to Draft Doncaster Local Plan - Publication Draft
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