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Barnsley Local Plan Examination
BARNSLEY MBC RESPONSE TO STAGE 1 MAIN MATTERS, ISSUES AND
QUESTIONS (MIQs)
The text below answers the Main Matters, Issues and Questions for Stage 1. In addition relevant information can also be found in the completed PAS Soundness
Self- Assessment Checklist (SD29) and the PAS Local Plan Legal Compliance Checklist (SD28).
Main Matter 1 – An Overview of the Soundness of the Barnsley Local
Plan Duty to Co-operate
1.1 What are the relevant strategic matters in relation to the duty to
co-operate?
The Council presented the key strategic elements of the plan during early
engagement, which included housing requirement (including provision for Gypsies and Travellers), employment land, safeguarded and Green Belt
land, heritage, transport and infrastructure. The opportunity for prescribed bodies to contribute any further concerns was given at this stage and throughout the plan making process.
The relevant strategic matters that have arisen during engagement through
the Duty to Cooperate process are listed in the matrix at appendix 1 of the Duty to Cooperate Statement Submission 2016 (SD15) https://www.barnsley.gov.uk/media/4535/sd15-duty-to-cooperate-
statement-submission-2016.pdf
1.2 Has the Council maximised the effectiveness of the Barnsley Local
Plan (BLP) by engaging constructively, actively and on an ongoing
basis with the prescribed bodies on these relevant strategic matters during the preparation of the plan, including:
The Council considers the effectiveness of the Local plan has been
maximised by engaging constructively, actively and on an ongoing basis with the prescribed bodies on relevant strategic matters. The Duty to Co-operate background paper (SD15) sets out our approach and includes the
matrix of issues discussed and outcomes. Joint working will be ongoing throughout the examination period.
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Highway authorities including Highways England and Integrated Transport Authorities with regard to:
The impact of proposed development on the strategic road network, including the M1 Junction 36 and the Birdwell roundabout and M1
Junction 37 and associated distributor roads and the A61(T) and A616;
At a meeting on 29th March 2017 Highways England confirmed
verbally that they were comfortable with the jointly agreed and
funded mitigation work already taking place at M1 junction 36. The
works currently underway have been designed following modelling to
resolve current traffic issues and also to accommodate the relevant
BLP proposals having any individual or cumulative impact on M1J36.
In order to confirm the M1J36 situation the Council and Highways
England are progressing the preparation of a joint position statement
to inform the BLP examination. A first draft has been exchanged with
Highways England on 27th April 2017.
Highways England are progressing their proposals regarding A61(T)
and A616 taking account of and accommodating any impacts arising
from the BLP proposals.
As regards M1J37 improvements have already been made to the
interaction of the local road network with the junction. Current BLP
proposals and their traffic impact modelling and mitigating highway
design work is indicating that practical and viable solutions to the
local road network are possible such that the recent M1J37
enhancements will be able to accommodate traffic impacts arising
from BLP proposals.
In order to confirm the M1J37 situation the Council and Highways
England are progressing the preparation of a joint position statement
to inform the BLP examination. A first draft has been exchanged
with Highways England on 27th April 2017.
The implications of a Pan Northern route to connect Manchester with the A1 and Humber Ports; and
The Council is aware of current Highways England pan northern route
studies and the potential benefits for Barnsley. Equally Highways
England and its Pan Northern studies are aware of the BLP.
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Any prospect of its delivery is beyond the submitted BLP plan period
and if progressed by Government would be a consideration to be taken
account of in a future BLP review.
The Council is progressing with Highways England the drafting of joint
position statement on this issue for submission to the BLP
examination. A first draft was exchanged with Highways England on
27th April, 2017.
The effect of development on the local highway network and public transport.
The BLP has been prepared taking account of existing infrastructure
including the highway network. The Council’s highways expertise has
been deployed to advise on both individual site highways and traffic
implications supported by use of the Barnsley Transport Model to
identify cumulative and junction traffic impacts (AECOM consultants
are custodians of the Barnsley Transport Model and also provide
junction modelling support).
Where potential junction issues have been identified then more
detailed modelling has been undertaken eg as for M1J36 and
associated roads as described above. This approach will be continued
as sites are brought forward for development supported by BLP
policies (T3) and site policy requirements.
Additionally and consistent with NPPF through support for travels plans
eg for schools the Council is seeking to minimise vehicular traffic and
where use of vehicles is appropriate promote public transport. To
assist this there has been continuous liaison with the SYPTE in
ensuring that BLP site proposals are either closely related to the ‘core’
bus network and railway services or have the opportunity to be viably
connected to the public transport network.
The Council through its Bus Partnership and Railway Vision is engaged
with public transport operators in promoting improvements to the
public transport offer as an attractive alternative to use of the private
car. It is recognised that this engagement needs to be maintained and
where possible strengthened. The Council is about to update its Rail
Vision and is active in supporting SYPTE in studies such as the Dearne
Bus Rapid Transit, and A61 bus corridor studies and proposals.
Natural England, with regard to Sustainability Appraisal and Habitat Regulations Assessment and the impact of proposed
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development on the South Pennine Moors Phase 1 and 2 Special Area of Conservation and Special Protection Area;
Natural England has confirmed that in respect of their area of interest the SA is fit for purpose.
In respect of HRA Natural England has confirmed that there are no
outstanding areas of concern. The Council has worked with them to address concerns outlined in their representation on the Publication Version. A letter from Natural England dated 3rd March 2017 states
the following:-
“Natural England welcomes the modifications and clarifications set
out in the Barnsley Local Plan Habitats Regulations Assessment Submission Version dated December 2016 which we consider to fully
satisfy the concerns raised by Natural England regarding the Habitats Regulations Assessment at publication draft stage.
We note that there have been no substantial updates to the assessment of recreational pressures subsequent to the November
2016 revision of the Habitats Regulation Assessment. Natural England considers that this section would benefit from further clarification, as noted in our response dated 14 December 2016 (our
ref 196846), however we are broadly satisfied with your conclusions that the plan will not lead to adverse effects on the integrity of the
South Pennine Moors European designated sites, based on the information provided.”
Historic England, having regard to whether any significant
adverse effects on the historic environment have been adequately mitigated and whether there would be any harm to the significance of designated heritage assets arising from
any of the proposed site allocations;
Many comments from Historic England during the Local Plan process have resulted in amendments to policies and to reductions in
developable area on some sites.
At a DtC meeting on 1st March the Council agreed which issues had
been dealt with to the satisfaction of Historic England.
Some outstanding issues were raised as follows:-
RSV1 – amendment to heritage impact paper re. views in/out of Billingley CA to demonstrate the longer distance view contributes
little and therefore harm is low Mod to amend site policy for H77 re. ownership issue, maintenance and repair of Hoyland Lowe Stand
Text re safeguarded land to go in the plan itself therefore a mod required.
Text changes to H2 site policy to reflect findings of HAA
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Add reference to the potential opportunities for cross boundary funding (future major HLF capital bids) and the risk allocation of the
former Elsecar sites might pose.
In respect of three sites further site visits were arranged. Following
the site visits further comments have been received from Historic England as follows:-
“Site H73 – Land between Mount Vernon Road and Upper Sheffield
Road
The site visit demonstrated how intact the field structure shown in
the 1850 OS First Edition still is and confirmed our view about the
important contribution this site makes to the setting of both the
group of Listed Buildings around Darley Cliff Hall and to Elmhurst
Farm to the west. Despite the reduction in the extent of the
developable area, it was evident when walking along the public
footpath that runs south from Upper Sheffield Road, just how
visible these buildings are across this area and the importance of
this rural landscape to their setting. This is especially so of Elmhurst
which is located on the brow of the hill and whose principal
elevation faces eastwards providing a commanding view across this
area. What was also notable was the intervisibility between Darley
Cliff Hall and Elmhurst Farm.
As a result, we maintain our originally-expressed concerns about
the harm which the loss of the fields and their subsequent
development (as currently-proposed in the Publication Draft) would
cause to the setting and appreciation of these buildings.
However, because of the topography, the site visit did demonstrate
that there may be potential for sensitively-designed residential
development on the 1.4ha field immediately to the south of the
existing cul-de-sac on Mount Vernon Crescent. Consequently, we
would not oppose the Allocation of that area within the Plan
providing that the development principles set out in the Plan made
it clear that any development of this area was of low density and of
good quality materials similar to the adjacent cul-de-sac to help
mitigate any impact on Elmhurst Farm.
Site H77 – Land west of Upper Hoyland Road
The site visit confirmed the conclusions of the Heritage Impact
Assessment regarding the importance of Site 77 to the setting of
the Grade II Listed Hoyland Lowe Stand. In our response to the
Publication Draft, whilst we fully supported the principle of
safeguarding an open area immediately to the west of the Lowe
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Stand, we had concerns that the proposed extent of the
undeveloped area didn’t appear to relate particularly well to the
topography or follow any identifiable boundary.
What was particularly interesting from the site visit was the
prominence of the Listed Building from the west, especially in long-
distance views (such as the one from Worsbrough Road) and how
important the fields adjacent to the Lowe Stand are to the setting
of this building. What was apparent was just how important it is to
retain the profile of the hill. It was evident from the Lowe Stand
itself, however, that the contours shown on the current OS maps do
not accurately reflect the position on the ground and that the large
square field which defines the eastern limit of the development is
actually far flatter than we had originally thought.
With the benefit of having been on the site itself, we now consider
that the western edge of the area to be excluded from the
development site should run from the corner of the playing field (at
its southern end) to the southern corner of the farmyard on Upper
Hoyland Road (at its northern end). The development principles for
this site which are set out in the Plan should also include a
requirement that the heights of any buildings on the eastern side of
the allocation adjacent to the safeguarded open space should be
single-storey similar to that of the existing historic farmstead to the
north. These measures would better-safeguard the rural setting of
the building, especially the important in longer-distance views
towards the Lowe Stand from the west.
Site H2 - Land west of Fitzwilliam Street, Elsecar
Historic England considered that Site H2 should not be identified as
a housing site until the Historic Area Assessment of Elsecar had
been completed. Now that this study has been published, we have
the following observations to make regarding this allocation.
The Heritage Area Assessment divides Site H2 into five areas (as
shown on the attached map).
Area 4 – This area is identified as making little or no contribution
to the understanding and appreciation of major iron and coal
mining in the Elsecar area. Historic England has no objection to
the development of this site.
Area 5 – This area is identified as making some contribution to
the understanding and appreciation of major iron and coal
mining in the Elsecar area. Although this area of scrubland has a
poor visual appearance, it is considered to contribute to the
setting of the former Milton Ironworks site and its development
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would obscure long-distance views from the Milton Forge
Recreation Ground towards Elsecar Conservation Area and the
Central Workshops. This site should be excluded from the
Allocation.
Area 6 – This area is identified as making some contribution to
the understanding and appreciation of major iron and coal
mining in the Elsecar area. This site is a remnant of the historic
field pattern of this area and shows remains of ridge and furrow.
The Heritage Area Assessment considers that this site
contributes to the setting of the surviving 19th Century foundry
(identified as a non-designated heritage asset which makes a
substantial contribution to the understanding and appreciation of
the Elsecar area). This site should be excluded from the
Allocation.
Area 7 – This area is identified as making some contribution to
the understanding and appreciation of major iron and coal
mining in the Elsecar area. However, this contribution stems
from its archaeological potential. Therefore, provided that the
development principles for this area set out a requirement for an
appropriate archaeological mitigation strategy, Historic England
has no objection to the development of this area.
Area 9 – This part of the site forms part of a larger area
identified as making a substantial contribution to the
understanding and appreciation of major iron and coal mining in
the Elsecar area. Its southern edge follows no clearly identifiable
boundary. The field is identified as being part of the historic field
pattern in this area which contributes to the setting of the
inclined plane. Its southern edge follows no clearly identifiable
boundary. This area should not be included in the allocation
In conclusion, we have no objections to the development of the
parts of the site which front onto Hill Street (or, indeed, to the area
at the on the southern side of Foundry Street with its junction with
Fitzwilliam Street) but consider that the fields to the north and west
of Foundry Street should not be included within the allocation.”
In response to these comments as appropriate, it is proposed to
add changes to SD30 Minor Modifications document or where site
specific issues, add them to the document that the Council is
preparing on policy amendments in response to Inspectors initial
questions.
In order to deal with the issues raised following the site visits to
H73, H77 and H2, the Council proposes the following:-
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H73 reducing the net developable area accordingly so that the
hatched area protects the area of the site as indicated by Historic
England
H77 the housing trajectory shows the developable site area as
2.2ha, therefore there is no impact on potential yield for this site
H2 the Council has considered leaving the parcels that Historic England are content to see development on as stand alone allocations. However on balance given their size they are less likely
to be viable, therefore removal of site H2 in its entirety is proposed.
In order to deal with the implications of the above, it is proposed that site H79 at Platts Common, Hoyland that was consulted on in 2014 and proposed as safeguarded land in the Publication version
be proposed as a housing allocation as a main modification.
In order to account for the loss of safeguarded land the Council proposes to widen the parcel of safeguarded land proposed as SAF5.
Environment Agency, in particular ensuring that a sequential, risk based approach has been taken to the location of development to avoid flood risk to people and property, as required by the
National Planning Policy Framework (NPPF);
The Environment Agency confirmed via email dated 14th November, 2016 that they were content with the Flood Risk and Sequential Test note which indicated that text would be added to site policies to state that
development would not take place in areas of flood risk. At the Duty to Cooperate meeting on 8th March it came to light that these proposed
additions to site policies had not been included on the minor modifications list (SD30). At the meeting it was agreed that they would be added to SD30. The Environment Agency has confirmed in an email to the
Inspector that their attendance at the hearings is not required, subject to all additions being incorporated within SD30.
Barnsley NHS Clinical Commissioning Group, with regard to provision for health facilities.
The NHS Clinical Commissioning Group has been involved in and contributed to the development of the Infrastructure Delivery Plan
(SD15).
The wider Council has also worked in partnership with the CCG to prepare the Joint Strategic Needs Assessment (JSNA) published 2016 (EB8) and, as reported in the Duty to Cooperate Statement Submission 2016 (SD15)
the Barnsley Local Plan has informed the CCG Pharmaceutical Needs Assessment.
The CCG Estates strategy, as set out in its Strategic Commissioning Plan 2014-2019 and its 2015-2019 refresh , is to work with relevant providers
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to improve utilisation of current properties and maximise use of existing buildings.
(http://www.barnsleyccg.nhs.uk/CCG%20Downloads/strategies%20policies%20and%20plans/Barnsley%20CCG%20Strategic%20Plan%202014-
19%202015%20refresh.pdf)
1.3 Is the BLP based on effective joint working with neighbouring local
authorities on relevant cross boundary strategic priorities as set out in paragraph 156 of the NPPF, including with:
The Council considers the Local plan is based on effective joint working with
neighbouring authorities on relevant cross boundary strategic priorities. The
Duty to Co-operate background paper (SD15) sets out our approach and includes the matrix of issues discussed and outcomes. Joint working will be
ongoing throughout the examination period.
Sheffield City Region Partnership with regard to the scale of
employment and housing development, impact on the strategic highway network and bus and rail transport, infrastructure
requirements and Green Belt review;
A letter has been received from Sheffield City Region welcoming the
growth aspirations set out in the Barnsley Local Plan and the investment
opportunities and benefits it creates for the region.
The SCR has a Strategic Economic Plan which aims to create a bigger
stronger private sector and to transform the region’s economy; creating
70,000 new private sector jobs, uplift in gross value added (GVA) and
6,000 new businesses.
To create the conditions for achieving this growth, investment is required
in strategic infrastructure to unlock development sites, ensure
connectivity, defend against flooding, ensure digital connectivity etc. The
SCR recognises that infrastructure is key to its success and is already
investing through the Sheffield City Region Investment Fund (SCRIF). The
SCRIF, valued at over £650m, has the potential to support 24,000 jobs
and to help unlock the land to deliver 13,000 homes and to generate £5bn
in GVA.
Joint working on SCR infrastructure requirements has taken place for both
the SCRIF projects as well as the recently launched Integrated
Infrastructure Plan (IIP).
The IIP is about creating the conditions for growth, to stimulate the
market and create attractive investment propositions. The IIP determines
existing SCR infrastructure capacity, anticipates future demand and
identifies opportunities to support future economic growth.
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The existing SCRIF programme contains a number of projects within
Barnsley that could unlock significant employment and housing growth to
support our Strategic Economic Plan. These include:
M1 J36 Phase 1 Hoyland and Phase 2 Goldthorpe (£15.7m SCRIF investment) – The SCRIF investment will provide infrastructure which will open up two key clusters of employment (maximum of 295ha gross)
creating up to 10,000 new jobs.
M1 J37 – Claycliffe Link (£11.8m SCRIF investment) – Infrastructure investment via SCRIF will enable the delivery of a significant mixed use
development on 121.96ha of land comprising of 43ha of employment land and 1700 new homes including affordable housing, plus public open space and new primary school provision..
The SCRIIP contains seven spatial growth areas. Two of these are within
Barnsley -the Dearne Valley, M1 (Junctions 36 and 37) and Barnsley
Town Centre remain priorities for infrastructure investment.
These infrastructure projects are predicated upon changes in the
allocations of land within the Local Plan to allow for development to come
forward and the outcomes to be achieved. The SCRIIP demonstrates that
these changes create the potential for significant employment and housing
opportunities for the city region including 6562 new jobs and 5503 new
homes.
Leeds City Region Partnership with regard to the scale of employment and housing development, impact on the strategic
highway network and public transport and other infrastructure provision;
A letter has been received from WYCA on behalf of Leeds City Region confirming that the Local Plan aligns with LCR SEP.
Employment, housing and impact on the strategic highway network and public transport and other infrastructure provision are supported.
The Council has completed a template setting out how the Local Plan aligns with and achieves the objectives of the SEP. This is contained in the Duty to
Co-operate Statement (SD15) as appendix 2.
Adjoining local/planning authorities (including Sheffield City
Council, High Peak District Council, Peak District National Park Authority, Rotherham Borough Council, Doncaster Metropolitan
Borough Council, Wakefield Council and Kirklees Council) on relevant cross boundary strategic priorities.
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No objections have been received to quantum of housing and employment land proposed from any adjacent local authority. The issues of interest to
each authority and how they have been resolved are set out below or are covered in response question 1.5.
There are no other issues that the adjoining authorities have raised outside
those listed below.
1.4 How has that co-operation been undertaken and have any formal
agreements or Memorandum of Understanding been produced? Discussions have taken place in one to one meetings. There have been no
issues where a SoCG or MoU have been felt to be necessary. A joint position statement with Highways England and Doncaster Council is being
prepared.
1.5 What outcomes have resulted from the co-operation with adjoining authorities including in relation to:
1. The strategic highway network, bus and rail transport;
The principal outcomes of the cooperation with adjoining authorities on the
preparation and submission of the BLP as regards strategic highway
network, bus and rail transport are that:
no issues have been raised to warrant objection to the BLP; Kirklees MDC support the BLP/ Barnsley Rail Vision improvements to the
frequency of service on the Penistone Line (Sheffield-Barnsley-Huddersfield route) but will leave to a review of the recently submitted
Kirklees Local Plan to assess the potential for emphasising development around those stations in Kirklees on the Penistone line and
agreement that neighbouring authorities will be consulted on transport
assessments and travel plans associated with progressing development proposals in proximity to the Barnsley MBC boundary.
Additionally as regards the strategic highway network, bus and rail
transport the BLP has and continues to inform joint working eg as part of
the Sheffield City Region and Leeds City Region integrated infrastructure
plans.
Pages 13-24 of the Sheffield City Region Infrastructure Plan (SCRIIP)
shows the joint summary of infrastructure needs and opportunities for
each of the city region growth areas http://sheffieldcityregion.org.uk/wp-
content/uploads/2016/10/FINAL-Sheffield-City-Region-181016-online-.54-
107.pdf .
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Pages 14 and 15 summarise how the BLP challenges and opportunities have
been acknowledged by the SCRIIP.
2. Meeting Sheffield’s unmet housing needs at the former Oughtibridge Paper Mill (Site AC44);
The decision was taken to show the former Paper Mill site at Oughtibridge that lies within Barnsley’s boundary as an allocation that
could count towards Sheffield’s housing need as all of the impact of the development lies within Sheffield’s area. Although given the stage of plan making that Sheffield is at their need is not fully quantified or
the implications for the wider City Region known. It was considered reasonable to propose the site as a housing allocation as a planning
application was in the process of being determined. Planning permission has subsequently been granted.
3. Measures to deal with the impact of traffic on the A635 and on the Air Quality Management Areas at Hickleton and Marr;
The Council has agreed addition of text as minor modification (additional change) to the site specific policies of D1 and RSV1.
4. Approach to the Green Belt review; A Common Approach to Green Belt Review was agreed across
Sheffield City Region. This gave flexibility for each local authority to tailor Green Belt review to local circumstances within the parameters
set by the common approach. It is considered that our GB methodology conforms to the agreed approach and took the best elements of some of the examples being used when establishing the
common approach.
Paragraph 6.2 of the Green Belt and Safeguarded Land Background Paper refer:-
6.2. In the summer of 2013, the Sheffield City Region Planning Officers Group decided that it would achieve the principles of Duty
to Cooperate and be beneficial for all Local Authorities within the Sheffield City Region to share Green Belt Review experiences and produce a common approach for future reviews. The work started in
November 2013 and the Common Approach was agreed by the Sheffield City Region Heads of Planning in September 2014. A
copy of the Common Approach is included in the supporting evidence. The Barnsley Green Belt Review methodology has been prepared to align with this Common Approach.
5. Areas of search for wind turbines;
Liaison with Peak District National Park has resulted in a proposed additional change (minor modification) in respect of LC1 Landscape
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Character policy which clarifies how the impact of proposed development on the Peak District National Park will be assessed and
the National Park Authority consulted. This policy appropriately addresses this issue and does not need to be replicated within policy
RE AC1 on Wind Turbine Areas of Search. The Council, together with neighbouring authorities to the north and
west, commissioned the ‘South Pennines Wind Energy Landscape
Study’ to identify landscape sensitivity of different areas to wind
turbines. The Study is strategic in nature and does not remove the
need for individual site assessments. It does however provide a
common approach to landscape sensitivity to enable a consistent
approach to be taken to the determination of planning application for
wind turbines. In addition, the authorities who were party to the Study
have also worked together to produce a GIS-linked database of wind
energy development within the member authority boundaries.
6. Contributing to the regional supply of minerals including aggregates; and
Barnsley does not have aggregates to contribute to the regional supply. This is acknowledged across both the Leeds and Sheffield City
Regions.
The draft Barnsley Local Aggregates Assessment (EB174) concludes in section 6 that :-
Because Barnsley is largely located on the exposed part of the Yorkshire Coalfield, the range of workable minerals is limited to
Coal Measure beds of coals, shales, fireclays and clays. Accordingly we are unable to contribute towards the sub regional apportionments for sand and gravel or crushed rock through site
allocations or planning permissions.
As we are located within both Leeds & Sheffield City Regions, we continue to work closely with colleagues from West Yorkshire, South Yorkshire and Derbyshire and Nottinghamshire County
Councils to ensure that sufficient provision can be made to meet the demand for aggregates as a result of the growth proposed in
our adopted Core Strategy and emerging Local Plan.
The Local Plan proposes to safeguard non-aggregate minerals
where appropriate, such as shallow coal, fireclay and brick clay.
7. Ensuring that development does not harm the landscape of the Peak District National Park.
Discussions with colleagues in Peak District National Park (PDNP) have not resulted in any sites being highlighted of concern in terms of impact on Peak District National Park.
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Liaison with PDNP has resulted in a proposed additional change (minor
modification) in respect of LC1 Landscape Character policy/ cross referencing to policy RE AC1 on Wind Turbine Areas of Search.
1.6 What mechanisms will be put in place to ensure that there is future
co-operation in relation to cross boundary issues that could arise as
the plan is implemented and development progresses?
Officers attend, and will continue to attend, regular planning officer group meetings in both Leeds and Sheffield City Regions and will continue to be involved in any updated pieces of evidence base and discussions with
neighbouring authorities. Officers will reciprocate attending one to one meetings to specifically discuss emerging plans with neighbouring
authorities at the appropriate time. These groups will be used to table any DtC issues arising from the implementation of the plan and its associated development at these meetings, and arrange more detailed discussion and
engagement with the relevant bodies as appropriate.
Legal Requirements
1.7 Do the content and timescale for preparation of the BLP accord with
the latest version of the Local Development Scheme addendum
(SD19)?
The initial Local Development Scheme (SD21) was approved by Cabinet 2nd January 2008, this referred to the Local Development Framework (LDF).
Subsequently the decision was taken to move from preparing an LDF to
preparing a composite Local Plan. A revision to the timetable for preparation of the Local Plan was approved by Cabinet on 9th April 2014 (SD20). Real time information on the timescales for the plan making
process was provided on our website during this time.
The last Local Development Scheme (LDS) approved in 2015 set out the Council’s programme for preparing the new development plan for Barnsley, to be called Barnsley’s Local Plan. It also set out which existing
documents and policies that it would replace.
The LDS clarified that the Local Plan would set out strategy and policies on how we want to see Barnsley
develop over the time period of the Local Plan, and
cover the plan period 2014 to 2033. contain detailed policies on various topics that will be used in
determining planning applications (topics were detailed in appendix 1)
set out policies to be applied to Barnsley Town Centre.
Show proposed site allocations on a Policies map.
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The contents of the Submitted Local Plan reflects the framework described. In terms of timescale, the LDS anticipated submission in
Autumn 2016 and examination in February 2017. The submission of the Local Plan was slightly delayed to December 2016 due to the scale of
representations received. Whilst the reference to examination indicated examination hearings, taking the examination process in its wider sense, that is, from submission to receipt of Inspector’s report, progress is
broadly in alignment with the LDS.
On 25th May Full Council will be considering a report which delegates authority to us to amend the Local Development Scheme and keep it up to date throughout the examination process1.8 Has public consultation
complied with the public consultation requirements in the Town and Country Planning (Local Plan) (England) Regulations 2012?
Consultation has been carried out in compliance with the Town and
Country Planning (Local Plan) (England) Regulations 2012. Further detail is set out in the PAS Local Plan Legal Compliance Checklist
2017 (SD28).
1.9 Has the BLP consultation complied with the Council’s adopted Statement of Community Involvement (2006 & 2015 update) (SD13 & SD14)?
The Draft Local Plan 2014 consultation was carried out in compliance with
the 2006 Statement of Community Involvement (SCI) (SD13) where
practicable. This document was prepared prior to the changes to the LDF
system introduced by PPS12 in June 2008 and subsequent publication of
the National Planning Policy Framework and associated amendments to
Local Plan Regulations.
Despite the changes to the LDF system the Council consistently tried to
undertake the preparation of the Local Plan 2014 Draft in the spirit of the
SCI. One of the key changes has been to the stages of plan preparation.
The requirements for the 2014 consultation were the equivalent of the SCI
‘Preferred Options’ stage for Development Plan Documents.
Some aspects could not be carried out due to changes in governance
arrangements and availability of resources as follows:
The Government Office could not be consulted as the organisation has
since been dissolved.
A postcard was not sent to all homes and businesses in the borough.
However, an article letting people know about the forthcoming
consultation was published in the Council’s Open Door Magazine and
delivered to all households in September 2014. In addition, press
releases were also publicised via the Council’s Facebook, Twitter and Open
Mail e-newsletter (sent to over 1900 people) and an advert was placed in
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the ‘Your Town’ magazine, distributed widely across the borough during
the consultation.
It was not possible to make a presentation to Area Forums as following
organisational changes, the forums have been disbanded.
The SCI was updated in 2015. Consultation on Local Plan Additional
Consultation 2015 and Local Plan Publication Version 2016 was carried out
in compliance with the updated SCI 2015 (SD14). Further detail on the
consultation carried out is contained within Regulation 19 Statement of
Representations 2016 (SD9) and Statement of Consultation 2016 (SD8).
1.10 Has the BLP been subject to a Sustainability Appraisal (SA) and have the requirements for Strategic Environmental Assessment been met?
The Barnsley Local Plan has been subject to Sustainability Appraisal (SA) at
each stage. The Sustainability Appraisal (SD4) states that “This document follows on from a number of key stages in the development of the Barnsley Local Plan and the SA. Specifically:
1. Scoping the SA – 2013/2014.
2. Consultation on the draft Local Plan, and the Draft SA – 2014-2015. 3. Consultation on additional policies and sites – 2015.
This version of the SA report presents results of the SA for the Publication Version of the Barnsley Local Plan.”
Through the SA the requirements of SEA have been met. The 2014 SA
Scoping Report (SD5) sets out how it is considered to have been met.
Extract below refers:
Integrating SEA requirements into SA 1.6 The SEA Directive (2001/42) requires a formal environmental assessment of certain plan and programmes which are likely to have
significant effects on the environment, including development plans. SEA is a systematic and comprehensive process for evaluating the environmental
effects of a plan or programme (including its alternatives) in order to ensure they are fully included and appropriately addressed at the earliest appropriate stage of the plan-making process1.
1 Sadler B. & Verheem R. (1996). Strategic Environmental Assessment:
Status, Challenges and Future Directions. Ministry of Housing, Spatial Planning and the Environment, The Netherlands, and the International
Study of Effectiveness of Environmental Assessment.
1.7 SA differs from SEA in that it expands the focus of the assessment to
include social and economic considerations. Therefore, the requirements of SEA have been subsumed into the SA to produce one coherent appraisal
using a standard methodology.
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1.8 The table below sets out the SEA requirements and outlines how they
have been addressed through the SA process.
Table 1: Signposting where the requirements of the SEA have been met
Required stages from the SEA Directive
Signpost to the relevant SA Report
(a) An outline of the contents, main objectives of the plan or programme
and relationship with other relevant plans and programmes (article 5)
Scoping report – Section 5 & Appendix B
(b) The relevant aspects of the current state of the environment and the likely evolution thereof without
the implementation of the plan or programmes;
SA report for Local Plan Scoping report – Section 4
(c) The environmental characteristics of areas likely to be significantly
affected
Scoping report – Section 6
(d) Existing environmental problems
which are relevant to the plan or programme including, in particular, those relating to any areas of a
particular environmental importance such as areas designated pursuant to
Directives 79/409/EEC and 92/43/EEC
Scoping report – Section 6
(e)The environmental protection objectives, established at international, community or member
state level, which are relevant to the plan or programme and the way
those objectives and any environmental considerations have been taken into account during its
preparation
Scoping report – Section 7 & Appendix B
(f)The likely significant effects on the
environment including on issues such as biodiversity, population, human
health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including
architectural and archaeological heritage, landscape and the
interrelationship between the above factors.
SA report for local plan.
(g) The measures envisaged to prevent, reduce and as fully as possible offset any significant
adverse effects on the environment
SA report for Local Plan
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of implementing the plan or
programme
(h) An outline of the reasons for
selecting alternatives dealt with and a description of how the assessment was undertaken including any
difficulties encountered in compiling the required information
SA DPD reports
LDF background papers Key issues consultation document & Remaking Barnsley Strategic
Development Framework Scoping report – Section 4
(i) A description of the measures envisaged concerning monitoring
Scoping report – Section 8 & Appendix A
(j) A non-technical summary of the information provided under the
above headings
Non-technical summary
Consultation
Authorities with environmental responsibility, when deciding on the scope and level of detail of the
information which must be included in the environmental report (Art.
5.4)
The consultation on the scoping will
take place in December 2013 to January 2014. Consultation on the SA will take place in June 2014 as
part of the wider Local Plan consultation.
1.11 Is it clear how the SA influenced the BLP policies and how
mitigation measures have been dealt with?
The non technical summary of the Sustainability Appraisal (SA) of the
Consultation draft Local Plan 2014 sets out how the Local Plan was
considered against the SA objectives. Table i) sets out the objectives and
assessment criteria, and is included below.
This appraisal covered all of the Local Plan policy options not linked to the
allocation of land for specific uses. These policy options and the alternatives
considered are listed in the table below. It also sets out the reasons for not
selecting the alternative options. In many cases the only alternative was to
not have a policy. Where this is the case a ‘no planning policy’ scenario has
been assessed (however the assessment still takes into account other
planning policies (such as the National Planning Policy Framework and
legislation).
None of the policies that have been selected for the draft Local Plan have
been assessed as being likely to result in significant adverse effects, either
in isolation or in combination with other plans and programmes. The SA
matrices set out in Appendix D of the 2014 SA show that many of the
proposed policies have the potential to result in significant beneficial effects
for borough and the people that live, work and visit it.
An SA update has been carried out at both 2015 consultation and
Publication stage.
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20
Table i): SA objectives and assessment criteria.
21
22
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1.12 Does the SA test the plan against reasonable alternatives in terms of the overall requirement for land for housing and employment and
its broad distribution as set out in the spatial strategy? What alternatives were considered in the SA?
Alternative strategy and policies were considered in the SA. The alternative options for location of growth are considered under policy LG2. Table ii of
the Non- technical summary of the Local Plan consultation draft 2014 SA sets these out, extract included below.
Table ii). Summary of the options subject to SA and the reasons for selecting the preferred policy options.
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
Additional policy areas introduced in 2015 in the Additional Consultation were assessed in the Sustainability Appraisal Additional Consultation Addendum 2015
EB6), see below.
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Table 6: Summary of the additional options subject to SA and the reasons for selecting the preferred policy options
1.13 How have the results of the Habitats Regulations Assessment
(HRA) influenced the BLP and will the policies achieve the necessary mitigation to avoid an Adverse Effect on Integrity of the European protected sites as set out in the HRA?
The HRA set out relevant policies which mitigate any likely significant
effects and sets out where policies and text have been added in response to HRA issues.
1.14 Have the requirements for Appropriate Assessment under the
Habitats Regulations been met?
The submission Habitat Regulations Assessment (SD16) includes an updated Appropriate Assessment. The Council has worked with Natural England to address their comments on the HRA as referred to in response
to question 1.2 above. It is therefore considered that requirements for Appropriate Assessment under the Habitats Regulations have been
adequately met.
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1.15 Has the preparation of the BLP complied with Part 2 of the Planning
and Compulsory Purchase Act 2004 and the Town and Country Planning (Local Plan) (England) Regulations 2012 in all other
respects? The Barnsley Local Plan has been prepared in accordance with Part 2 of the
Compulsory Purchase Act 2004 (as amended) and the Town and Country Planning (Local Plan) (England) Regulations 2012. Further detail is set out
in the PAS Local Plan Legal Compliance Checklist 2017 (SD28). 1.16 What is the status of the ‘List of Minor Modifications’? (SD30)?
The list of Minor Modifications (SD30) (Additional Changes) are changes the
Council wishes to make to the Local Plan following Publication Consultation and have arisen either to deal with comments made, to provide greater clarity or to ensure the Local Plan is as up to date as possible.
The Council is content to consider this list of proposed changes as those
falling into the term ‘Additional Changes’ that it is able to make prior to adoption. It would be helpful to know if the Inspector considers any of them
to be ‘Main Modifications’ as may arise through the examination hearings. The Council would like to have a separate list of Main Modifications that will require consultation prior to close of the examination.
Main Matter 2 –Vision and objectives and Barnsley’s role in the Sheffield
and Leeds City Regions 2.1 Are the objectives appropriate, positively prepared and justified
and will they be effective in delivering the vision for Barnsley set out in the plan?
The Council consider the objectives to be appropriate, positively prepared and justified. They will be effective in delivering the vision for Barnsley as
set out in the Local Plan as they are clear and focus on the key areas that will deliver the overall vision. The objectives accord with the National
Planning Policy Framework and paragraph 2.3 sets out the mechanisms by which they will be achieved.
2.2 What evidence justifies the aim to deliver ‘substantial and
sustainable’ economic growth for the Borough and will the plan be effective in delivering this within the plan period?
The employment background paper includes evidence on levels of deprivation, particularly within the east of the borough. This deprivation
has been present for almost three decades and can be linked to the demise of the coal mining industry. The most effective way to address this is by substantially growing the economy and creating a step change.
The area of Barnsley to the east of the M1 is strategically located within the
Leeds-Sheffield corridor defined by the M1 and A1M motorways and which
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also includes two railway lines running north south between the two cities via Wakefield and Barnsley (Dearne Valley and Hallam lines). By the end of
the plan period HS2 will run through this corridor potentially with a parkway station located close to the borough boundary. By virtue of Barnsley’s
strategic location, it is therefore well placed in respect of delivering sustainable economic growth within the plan period and with enhancements to strategic east-west connectivity, the level of growth has the potential to
be even more substantial.
The plan identifies the most deliverable strategy based on scale and market attractiveness of the employment allocations and maximising use of existing infrastructure.
2.2 How will the plan’s vision and objectives address the economic
disadvantages faced by residents in some parts of the Borough? The vision seeks to enhance Barnsley as a location to do business and a
place that will improve the quality of life for all residents. Achieving the vision will enhance Barnsley’s image as a place to invest, thereby improving
economic prosperity across the borough. Where objectives address the economic disadvantages faced by residents of some parts of the borough is
as follows:- Provide Opportunities for the creation of new jobs and protection of
existing jobs
The Local Plan provides the most realistic and deliverable strategy for attracting inward investment and business growth to increase job opportunities initially in industrial/manufacturing and logistics sectors as
well as construction associated with delivery of the commercial buildings and the housing sites. In turn this will reduce the need to commute out of
the borough for work, reducing travel expenses. The growth in disposable income will bring about a positive multiplier effect helping to support job creation in other sectors, in particular retail and the visitor economy.
Improve the conditions in which people live, work, travel and take
leisure This objective seeks to improve conditions for all, including those that face
economic disadvantage.
Widen the choice of high quality homes Delivery of a wider choice of homes will provide more opportunities for
housing that is affordable to those facing economic disadvantage.
Improve the design of development Improved design will make areas more attractive, thereby improving the
quality of life for existing residents, but may also increase market attractiveness of areas resulting in an economic uplift.
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2.4 Has an appropriate balance been struck between providing for economic development, supporting the role of the town centre and
delivering new homes having regard to the effect on the environment, the transport network and other infrastructure and local services and facilities?
The Council considers that the policies and proposed allocations in the Local
Plan provide an appropriate balance between allocating enough land in the right places to support an appropriate level of growth to meet our economic aspirations whilst protecting the best of what the borough has. The
Infrastructure Delivery Plan (SD 24) considers infrastructure requirements arising from our proposed strategy. The associated Delivery Programme
includes details of committed and planned schemes by infrastructure type required to ensure that infrastructure is fit for purpose and facilitates the planned growth across the borough.
The Council has refrained from pursuing higher jobs growth which would
take us to regional averages within the plan period in recognition of deliverability and Green Belt constraints.
2.5 Is the plan period of 2014 – 2033 justified?
The Council considers that plan period is justified. Local Plan para 3.22 sets
out that this plan period was chosen particularly because of our economic position and the lead in time for employment land to be developed. The issue of lead in time for employment land is supported in the Employment
Land evidence produced by Mott Macdonald (EB37) at table 5.4. A longer plan period also ensures the Green Belt boundary will endure, which is
essential given the amount of Green Belt proposed to be released in the plan period. It is also likely that the plan will be adopted in 2018 so this gives a 15 year period from adoption
2.5 Is the role of Barnsley within the Sheffield City Region (SCR) and Leeds City Region (LCR) clear? Has an appropriate balance been struck between contributing to the growth of the city regions,
meeting the development needs arising from the needs of the town’s resident population and addressing the effect on the
environment?
The Strategy Background Paper (BP1) states that: “As Barnsley sits
within the functional economic areas of both the Sheffield City Region and the Leeds City Region and is adjacent to the Manchester City Region, it has
a key role to play as the link between the Leeds and Sheffield City Regions, a position that is reflected in Barnsley’s Core Strategy. At the time it was
felt that Barnsley was able to support growth in the two city regions by offering housing and employment opportunities to those in the Sheffield to Leeds corridor.
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This position was also reflected in our transportation strategy accessibility priorities where we have defined an ‘Accessibility Improvement Zone”
(AIZ). The Accessibility Improvement Zone covers the east of the borough where we propose to put most of our growth, associated with our Growth
Point status which has been re-affirmed and supported by the new coalition government. This would give support to Barnsley’s own and the Growth Point partner strategies and its potential role in the Sheffield City Region.
The AIZ is directly associated with the main focus of development and renewal set out in the Core Strategy. It is a targeted area reflecting the
focus of growth within the Barnsley Growth Corridor, the regeneration initiatives in the Dearne Valley and our location as a key part of the transportation corridor connecting the Sheffield and Leeds City Regions
where some 19, 400 homes and 330 hectares of employment land will be provided. Given the scale of growth proposed across the borough, and
Barnsley’s role and location, references in City Region work have been sought to accessibility improvements and improved public transport connections within and external to Barnsley. “
The Regional Spatial Strategy (RSS) for Yorkshire and Humber adopted in
2008, whilst revoked, recognised Barnsley’s potential. Paragraph 7.5 states that “…It is a significant market town and sub regional service centre
between Sheffield and Leeds, with further potential for developing strong housing, labour market and land supply connections with Sheffield and Wakefield, and the wider Leeds City Region.”
RSS went on to say at paragraph 7.21 that “Sheffield, Doncaster,
Rotherham and Barnsley represent major physical and social investment capital, which are being comprehensively enhanced through distinctive urban renaissance programmes. Continuing to develop the main urban
areas is essential . They will continue to be the focus of development and the engines of growth for the sub area as a whole.”
Barnsley has a very important role in respect of providing jobs growth in the Dearne Valley and along the M1 motorway junctions. Barnsley Town
Centre will remain an important sub-regional town which is significantly bolstered by the £120m Better Barnsley/Glassworks scheme that is
currently being developed. Historically Barnsley has been a significant contributor of housing growth within Sheffield and Leeds City Regions and when viewed along with Wakefield it is apparent that the Leeds-Sheffield
corridor that includes Wakefield and Barnsley has been and will continue to be hugely important in respect of providing all types and tenures of
housing. The Council considers that through the strategy, policies and proposed
allocations of the Local Plan an appropriate balance has been struck with the meeting our development needs whilst seeking to retain and protect the
best of what the borough has. This is evidenced through the approach to Green Belt review and site selection methodologies.
2.6 What implications does the production of a SCR Spatial Plan have for Barnsley and does the BLP have sufficient flexibility to respond
to any requirements that may arise during the plan period?
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The Sheffield City Region Devolution Agreement 2015 includes the power to
create a Mayoral Spatial Framework for Sheffield City Region:
The devolution deal was contingent upon the combined Authority agreeing
to a directly elected Mayor. In order to translate the deal into law the
SCA was obliged to conduct a governance review and articulate its
scheme of devolution and then consult with the public on the
proposals. The Secretary of State then has to draft these into an order
and be satisfied that the order should be made. The governance review
and scheme were published in June 2016 as one document (attached) and
consulted upon over the summer. Mayoral elections were scheduled for
May 2017. However a successful judicial review of the consultation has
resulted in the SCR having to undertake further consultation and the
Mayoral elections have had to be postponed until May 2018.
The governance review contained a summary of the powers intended to
be devolved to the Mayor at Table 2 (page 21) of the Review and
paragraph 6.9 of the Scheme (page 47). The power to create a spatial
framework is based upon the London Mayor’s powers to do the same with
the variations set out in paragraph 6.9. The Mayoral plan will deal with
strategic matters only. The inspector’s attention is drawn to the fact that
the spatial framework is not part of the development plan. In the London
Mayor model local plans are required to be in general conformity with the
spatial framework whereas in the SCR model articulated in the scheme
Local Plans only have to have regard to the Mayoral Plan. The Mayor also
has to have regard to Local plans when formulating his own plan.
Given that the Mayor when formulating his first plan will have to have
regard to BMBC’s recently adopted local plan and the LPA will only be
required to have regard to the Mayoral plan rather than be in general
conformity with it, it is not expected that the content of the Mayor’s first
plan is likely to be able to significantly depart from the content of the
BMBC local plan especially given that the Mayoral plan needs to be
unanimously approved by all members of the Combined Authority, which
includes BMBC. If the Mayoral plan did significantly differ from the local
plan the legal obligation is only for BMBC to have regard to it rather than
be in general conformity with it, so there would be no immediate need for
a review of the plan. However if a mayoral plan was approved that
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significantly departed from BMBC’s own local plan this would need to be
addressed as a relevant consideration as to whether it would be
reasonable for BMBC to look to an early review.
However at the moment BMBC is not in a position to ascertain what
implications a mayoral plan might have given that:
(1) no order has been made for powers to be devolved to the Mayor
(2) If that order is made there is no certainty as to whether the spatial
plan powers will be devolved
(3) if there is a spatial plan whether that spatial plan will be of the form
and effect proposed in the CA scheme or some other form and effect;
(4) a mayoral election won’t take place until May 2018 and it will be some
time after this before any work on a spatial plan can begin so the content
of any spatial plan will be unknown for several years
The Council considers that the Local Plan is well placed to respond flexibly to requirements during the plan period. Examples of areas of flexibility are
policy H8 which has flexibility on densities. Should more housing development be required there is scope to seek higher densities than 40
dwellings per hectare. The amount of employment land proposed includes a Reserve Site that could accommodate a large scale footloose end user should the need arise across the City Region during the plan period.
A five year supply of safeguarded land is proposed and this provides flexibility to consider exceptional circumstances to release that within the
plan period if the need arises. 2.7 What are the implications of Barnsley’s location within the wider
functional economic areas of the SCR and LCR? How will the employment and other policies in the plan contribute to the
Strategic Economic Plans of the Sheffield and Leeds City Regions? It is considered that there are positive reciprocal implications of Barnsley
being within the functional economic areas of SCR and LCR, as Barnsley is well placed within the city regions to deliver growth in a Sheffield to Leeds
corridor. The benefit for Barnsley of being central to both is investment to enable Barnsley to achieve its growth potential.
Barnsley’s proposed strategy and policies contribute to the delivery of the Strategic Economic Plans of both the Leeds and Sheffield City Regions.
As set out in question 1.3 above a letter has been received from Sheffield
City Region welcoming the growth aspirations set out in the Barnsley Local
Plan and the investment opportunities and benefits it creates for the region.
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The SCR has a Strategic Economic Plan which aims to create a bigger
stronger private sector and to transform the region’s economy; creating
70,000 new private sector jobs, uplift in gross value added (GVA) and
6,000 new businesses.
To create the conditions for achieving this growth, investment is required in
strategic infrastructure to unlock development sites, ensure connectivity,
defend against flooding, ensure digital connectivity etc. The SCR recognises
that infrastructure is key to its success and is already investing through the
Sheffield City Region Investment Fund (SCRIF). The SCRIF, valued at over
£650m, has the potential to support 24,000 jobs and to help unlock the
land to deliver 13,000 homes and to generate £5bn in GVA.
Joint working on SCR infrastructure requirements has taken place for both
the SCRIF projects as well as the recently launched Integrated
Infrastructure Plan (IIP).
The IIP is about creating the conditions for growth, to stimulate the market
and create attractive investment propositions. The IIP determines existing
SCR infrastructure capacity, anticipates future demand and identifies
opportunities to support future economic growth.
The existing SCRIF programme contains a number of projects within
Barnsley that could unlock significant employment and housing growth to
support our Strategic Economic Plan. These include:
M1 J36 Phase 1 Hoyland and Phase 2 Goldthorpe (£15.7m SCRIF
investment) – The SCRIF investment will provide infrastructure which will open up two key clusters of employment (maximum of 295ha gross) creating up to 10,000 new jobs.
M1 J37 – Claycliffe Link (£11.8m SCRIF investment) – Infrastructure
investment via SCRIF will enable the delivery of a significant mixed use development on 121.96ha of land comprising of 43ha of employment land and 1700 new homes including affordable housing, plus public open space
and new primary school provision..
The SCRIIP contains seven spatial growth areas. Two of these are within
Barnsley -the Dearne Valley, M1 (Junctions 36 and 37) and Barnsley
Town Centre remain priorities for infrastructure investment.
These infrastructure projects are predicated upon changes in the
allocations of land within the Local Plan to allow for development to come
forward and the outcomes to be achieved. The SCRIIP demonstrates that
these changes create the potential for significant employment and housing
opportunities for the city region including 6562 new jobs and 5503 new
homes.
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A letter has been received from WYCA on behalf of Leeds City Region confirming that the Local Plan aligns with the LCR SEP.
Employment, housing and impact on the strategic highway network and public transport and other infrastructure provision are supported.
2.8 Does the economic growth of the Manchester City Region have any implications for the BLP and if so should they be identified in the plan?
Given the issues with Trans Pennine connectivity, Barnsley is not within
either the functional economic area of housing market area of Manchester City Region with no prospect of interventions changing this within the plan period. In addition, the rural western part of the borough which is closest
to Manchester City Region is significantly constrained within limited capacity for additional growth.
This isn’t to say that the position could not change beyond the plan period and if there have been announcements regarding major infrastructure
projects to address Trans Pennine connectivity, they could act as a catalyst for inward investment on the employment sites at J36 and J37 in
anticipation of the infrastructure schemes being delivered.
Main Matter 3 – Objectively assessed need for employment
The soundness of the allocated employment sites set out in the
Economy chapter will be considered at Stage 2 of the Examination, other than the questions asked below in relation to specific sites.
Context – The Employment Land Review (EB33) sets out three Jobs Growth Scenarios. As explained in the Employment Background
Paper (BP6), the plan is based on Growth Scenario 2 ‘Jobs-led Policy On’ for 33,000 new jobs within the plan period, based on the
aims of the ‘Jobs and Business Plan’ 2014 – 2017.
Issue – Does the plan appropriately identify the objectively
assessed quantative and qualitative need for employment as required by the Planning Practice Guidance? Is the OAN for
employment soundly based and supported by robust and credible evidence?
The Council considers that the plan does appropriately identify the objectively assessed quantative and qualitative need for employment as
required by the Planning Practice Guidance and that the OAN for employment is soundly based and supported by robust and credible
evidence.
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The Employment Background Paper (BP6) sets out our approach and draws on evidence from various sources including:-
Employment Land Review 2016 (EB33)
Employment Land Evidence, Mott Macdonald, 2016 (EB37) Jobs and Business Plan (EB31)
3.1 Does the Borough represent the appropriate functional economic
area for the purposes of assessing the OAN for employment? The Council considers LCR and SCR to be the functional economic area
within which Barnsley sits, as set out in section 3 of the Employment Background Paper (BP6).
3.2 What evidence justifies the statement in paragraph 4.6 of the plan
that ‘Barnsley’s economy is too small for the size of the Borough’
and what implications does that have for the plan?
The Jobs and Business Plan (EB31) states that “Barnsley’s economy is too small for the size of the borough. The town is unable to maintain enough
jobs and businesses to support its working population.” The facts set out in the Jobs and Business Plan (EB)(page 11) that underpin
this assertion are:
24.7% of all jobs in Barnsley are Public sector based. The Private sector has been unable to absorb the number of jobs that have been lost to date
It is taking Barnsley longer to recover from the recession that the rest of the UK, where recovery appears to be almost complete
An increasing number of skilled Barnsley people are commuting for better jobs in other parts of South Yorkshire. This is due to the lack of opportunities closer to home and those that do exist are mainly
low paid and part time There are also low numbers of business start-ups and 60% are either
lifestyle or businesses simply replacing others that have ceased to exist, with limited additional employment opportunities
The Employment Land evidence April 2016 produced by Mott Macdonald (EB37) confirms in section 3 that “Barnsley’s economy is relatively small
compared to its population size; which means it does not have enough businesses and jobs to support the working age population.”
3.3 In addition to the ‘baseline’ of 12,555 jobs based on previous rates
of job growth, the plan anticipates an additional 17,588 jobs through council and partner interventions. Is that realistic and achievable? What interventions are necessary to achieve the
additional job growth and are they likely to happen?
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The Jobs and Business Plan (EB 31) sets out the strategic objectives and the steps that are proposed to deliver those objectives. Allocating
appropriate sites through the Local Plan is critical to achieving Barnsley’s ambitions.
These can be summarised as follows:-
Strategic objectives
More businesses More jobs Improved businesses
Improved workforce
Steps
Invest in infrastructure
Attract inward investment Improve the Town Centre
Grow existing businesses Encourage higher productivity start ups
The Mott Macdonald report (EB) at paragraph 7.6 considers whether the additional jobs assumed will be delivered and sets out the following:-
BMBC’s jobs target is challenging, especially if there is a significant economic recession during the Local Plan period. In other words, some of the critical success factors are not within the control of BMBC; for example
the intentions of land owners and developers. The evidence suggests that the Borough has the capacity to achieve its employment targets
particularly if the proposed sites are taken forward and developed. Section 3.10 of this report points out that there is currently a shortage of good quality warehousing accommodation across the region, due to the
depletion of stock. This report has also shown, with data from BDA, that the period from March 2014 to March 2015 recorded a 46% decrease in
the stock of available industrial and office accommodation. Between 2006 and 2014, employment in Barnsley grew more strongly than in other comparator areas as shown in Table 2.1. However historical
legacies remain. For example, the local workforce is currently over represented with regards to lower skilled occupations like process, plant
and machine operatives and under-represented in terms of professional occupations and senior managers. Resident salaries are lower than average but workplace wages are relatively high as shown in Section 2.
This suggests that the local economy has key strengths in highly skilled occupations but non-Barnsley residents often access these jobs.
The resident Barnsley workforce possesses relatively lower skill levels (using qualifications as a proxy for skills) than the England, LCR or SCR
averages. For example 26% of the Barnsley workforce possess NVQ4 or above qualifications compared to 40% in England as a whole, 35% in LCR
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and 32% in SCR. This partly explains the relatively lower resident wage levels presented in Section 2. This however, adds to the attraction of
Barnsley as a destination as wage levels are a key determining factor in the destination of footloose investment.
Table 5.4.1 of the Mott Macdonald report states that:-
“…the proposed employment sites in Barnsley could deliver almost 10,000 net new jobs, with almost 7,100 of these occurring within the Local Plan
period. This represents 72% of the net employment capacity of the sites. Approximately 223ha of the 309ha proposed could be developed within this period. In the first 10 years 127ha could be developed representing 42% of
the total proposed allocation.”
Monitoring data included in the Leeds City Region Strategic Employment
Land Review indicates that employment land take up within Wakefield
during the period 2005-2015 was 174 hectares. This period has included
both boom years leading up to the financial crash in 2008/09 and the
subsequent economic slow-down and can therefore be used as a reliable
indicator for the whole of an economic cycle. A 17.4 hectare average would
equate to 330.6 hectares over a 19 year plan period. As Barnsley is based
in the same Leeds-Sheffield corridor as Wakefield with good access to the
M1 and A1M and with the prospect of enhanced Trans Pennine connectivity,
it is therefore realistic to assume that the employment land will be taken up
within the plan period, albeit with much of this coming during the latter
stages of the plan.
Within Barnsley, figure 5 in the Employment Land Review shows that a
total of 173.9 ha of land has been developed for B class uses over the past
17 years. This equates to an average take up of 10.23 ha per year and was
achieved during a period where Barnsley did not have a significant quantum
of site allocations in locations most attractive to the market. In addition, it
included the recession of 2008/09 and the subsequent downturn in
commercial development the scale of which had not been seen for decades.
Although another recession cannot be ruled out during the plan period,
should it occur, the allocation of market attractive sites should hopefully
mean that the commercial property market can recover more quickly than
it did in the years following the 2008/09 recession.
There are a host of interventions being implemented that support the economic
aspirations of the borough. Some of these are:
Glassworks, a component of the Better Barnsley project to redevelop Barnsley Town centre. The Glass Works will provide a modern,
contemporary retail and leisure destination, whilst complimenting the traditions of Barnsley’s historic markets, and reflecting the famous
Barnsley spirit.
J36 infrastructure improvements are underway
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A Property Investment Fund has been set up
Speculative Development by private sector is taking place.
J37 infrastructure – SCRIF bid submitted for infrastructure investment.
3.4 What evidence justifies the conclusion that there are likely to be
land availability and topographical constraints in other Boroughs in the City Regions that could provide an opportunity for employment development to be located in Barnsley?
The CPP report (EB35) sets out in section 7 the following:-
“Sites around Junction 33 & 34 M1 (Sheffield & Rotherham) would be
considered more prime than Barnsley. This is primarily due to the size of the conurbation and existing critical mass of industrial occupiers. However, future development in these locations is likely to become more constrained
due to lack of sites coming forward. The topography of Sheffield and Rotherham limits the availability of large development sites. Sheffield has
also been more successful in the manufacturing sector and this continues to be the focus for new investment, rather than distribution and warehousing.”
The report goes on to say in respect of Doncaster:
“The M18 corridor is a competing location, particularly around Doncaster. Doncaster has been hugely successful over recent years in attracting large
scale logistics development and is now a recognised location nationally for warehousing. The majority of the existing sites have now been developed out, although, the release of iPort at Rossington (Junction 3 M18) will
release a substantial amount of land to the market. This site extends to circa 350 acres and has planning consent for 6 million sq ft of warehouse
space. In addition to iPort is G Park, Doncaster which is a 126 acre site at Junction 4 of the M18 which has planning consent for 1.5 million sq ft of warehousing.
Doncaster may be favoured by some warehouse occupiers due to the
motorway access north and south (via the A1(M) and M1), east via the M18 and east and west via the M62. However, this is a marginal advantage and other occupiers equally prefer an M1 location as this is seen as a better
arterial route.”
The following article states that Knight Frank has reported a marked
improvement in occupier demand for logistics and industrial properties with
take-up in South Yorkshire for the second half of 2016 finishing well ahead
of the half yearly average.
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Take-up of units above 50,000 sq ft reached 1.8m sq ft in the last six
months of the year, more than double the level of take-up over the
previous six months.
Knight Frank has reported a marked improvement in occupier demand for
logistics and industrial properties with take-up in South Yorkshire for the
second half of 2016 finishing well ahead of the half yearly average.
Take-up of units above 50,000 sq ft reached 1.8m sq ft in the last six
months of the year, more than double the level of take-up over the
previous six months.
The full article can be accessed by link below:-
https://www.scci.org.uk/2017/02/industrial-occupier-demand-up-for-south-
yorkshire/
The following ‘Big Shed Briefing’ by Savills also indicates high demand for
warehouse space, particularly from online retail suppliers.
http://pdf.euro.savills.co.uk/uk/commercial---other/big-shed-briefing-
january-2017.pdf
http://www.verdion.com/wp-content/uploads/2015/06/SHD.pdf
This article talks about demand in South Yorkshire with a focus on
speculative build taking place at Doncaster’s i-port.
The following article provides a useful summary of facts around supply and
demand of logistics premises.
http://www.colliers.com/-
/media/files/emea/uk/research/speciality/201703_industrialandlogisticsbar
ometer.pdf?la=en-GB
The following extracts from the Strategic Employment Land Review For
Leeds City Region October 2016 support our approach. The full document
can be found at the following link:
https://www.the-
lep.com/LEP/media/New/Research%20and%20publications/LCR-
Employment-Land-Review-Final-Report-Oct-16.pdf
4.33 To an extent the variations in the rates of take up shown in the
table above reflect the scale of the local economy in that part of the
city region. Also take up is higher in Barnsley and Wakefield as these
area are well endowed with flat sites and have good transport links
both of which favour the logistics industry which is an extensive user of
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land. The average take up over the period 2005/6 to 2013/14 is 75ha.
If this figure is multiplied by 17 (years) it will provide a comparison
with the REM forecast of land required. 75x17=1275ha. A figure which
is considerably higher than the REM forecast. Most employment land
studies show such a disparity between econometric forecasts and take
up projections. The reality of overall demand lies somewhere between
these two figures. However the approach taken in seeking to meet
demand should be to achieve an overall supply that is closer to the
projection of take up as this will provide a greater choice and flexibility
in the provision of employment land.
5.3 In the feedback from the local authorities on the initial findings of this work there was widespread agreement that the current supply of
employment land is inadequate. Furthermore the geography and topography in the west presents a challenge, as does the legacy of old
allocation in development plans that are not suited to modern requirements. More land is required in highly accessible locations such
as the M62 corridor. The potential opportunities arising from redundant public sector land has also been identified, examples include network
rail land in central York and MoD land in Ripon.
5.4 Infrastructure capacity is seen as barrier in the city region; transport infrastructure being a common concern along with broadband
capacity, power supply is highlighted as an expansion issue to resolve in at least two locations in the city region. Specific examples were
provided by a number of authorities which provide a start point for identifying a portfolio of constrained sites which would need strategic
investment. The potential role of strategic sites
5.5 Before exploring the circumstances in the individual districts there is a further city region wide issue to be explored, that of the role of
strategic sites in the employment portfolio of the city region. Historically strategic sites have been associated with large scale inward
investment proposals such as a new motor car assembly plant. In the last 10 or more years reserving sites for such rare occurrences has
fallen out of favour in most parts of England; the exceptions being the West Midlands and the East Midlands the latter only reserving land for
Logistics. However strategic sites can fulfil other functions such as promoting agglomeration trends in specific sectors, e.g. medical
technology or in supporting advanced manufacturing. The discussion with agents on the market for employment land reported later in this
section makes reference to the need to identify sites that serve specific economic niches, some of which may require large scale sites, and the competitive advantage that may be gained from such sites.
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5.6 As the West Midlands has continued to pursue strategic sites as a key component of their approach to growing the economy they have a
body of work which analyses the value of such sites. Their most recent work is a report to the West Midland Chief Executives by Peter Brett
Associates – The West Midlands Strategic Employment Sites study – completed in September 2015. This work is a useful analysis of the
purpose of strategic employment sites, though it must be recognised that characteristics of the economy of the West Midlands are rather
different to those of the Leeds City Region.
5.7 The work by Peter Brett defines a strategic site as: - Strategic employment sites are business development sites that can
bring net additional activity and jobs to the region by: Attracting nationally or internationally mobile business activity;
Providing accommodation that would not otherwise come forward through the local planning system, principally because:
They are large sites, providing at least some 25 ha and often much
more; They may be in greenfield locations.
5.8 The work goes on to identify the value of a ‘larger than local’ policy being a key ingredient to justify the identification and investment in
such a site which would by its very nature bring benefits to an area larger than an individual authority. In part this is because the regime
for examining individual development plans needs such a strategic policy context to justify the decision to choose a specific location rather
than a site in a neighbouring Development Plan area. Additionally the policy would need to be underpinned by evidence of the need/demand
for such sites and the options currently available either through existing adopted Plans or planning consents.
5.9 The City Region and the wider region has not made provision for
strategic sites as defined in the West Midlands study. Furthermore that study has shown that the competition from other EU countries for large
international investments is intense and England is disadvantaged in this competition by its labour and other costs (with further uncertainty now arising from the vote to leave the EU). Therefore the city region
should be considering whether there is need for sites to meet the second component of the policy; that of providing accommodation that
would otherwise not come forward in the local planning system, and what evidence there is of the need for sites. Examples of where the
City Region could support the identification of strategic sites in a Local Plan could be: in Leeds for an Airport related site, in Wakefield
Barnsley and possibly Selby for Logistics, and for University related activity in York, Leeds Bradford or Huddersfield, and in the heart of the
west Yorkshire conurbation for advanced manufacturing which could be growth in indigenous business and/or inward investment.
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5.10 In the responses from the local authorities into the initial findings there is support for the identification of strategic sites that are tailored
to the different economic strengths and priorities across the city region. However such sites are seen as less of a priority in some of the
rural parts of the city region that tend to see growth largely through indigenous businesses. The next part of this section of the report
presents an analysis of the loss of employment sites and buildings to other uses; and then the local land supply circumstances in each
authority and actions they are taking to improve their supply position.
5.50 Overall land supply in the city region is 1440ha however within that supply there are sites which are the legacy of old Development
Plans and which may not be suitable for modern employment requirements. Local authorities are addressing the variable quality of
the supply through their own employment land reviews and in proposals being made in emerging Development Plans. Of the larger
authorities Bradford, Calderdale, Kirklees and possibly York all are for varying reasons facing challenges in identifying a suitable, available and deliverable supply of sites to meet modern employment
requirements. The smaller more rural areas are facing challenges in both identifying sites and retaining land which has been vacated where
high land values are leading to housing redevelopments and the consequence loss of a valuable supply. This loss of employment land
and buildings to other uses is a concern for all authorities and the proposed changes to the NPPF work exacerbate this.
5.54 The role of strategic sites is a matter that will require further consideration and evidence gathering. However a start point is
identified here, that of providing accommodation that may otherwise not come forward in the local planning system.
Examples of where the City Region could support the identification of strategic sites in a Local Plan could be: in Leeds for an Airport related
site (action is already addressing this point through the emerging sites DPD), in Wakefield, Barnsley and possibly Selby for Logistics, and for University related activity in York, Leeds Bradford or Huddersfield , and
in the heart of the west Yorkshire conurbation for advanced manufacturing which could be growth in indigenous business and/or
inward investment.
3.5 Are the jobs created likely to meet the job requirements of
Barnsley’s resident working age population? Are there any identified skills gaps/shortages? What would be the consequences of jobs not being filled by the resident working age population?
In our view many of the jobs created will meet the requirements of the
resident working age population. One of the consequences of none of the jobs being filled by residents may be greater levels of in-commuting and
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out-commuting. It is too early to foresee other consequences. The Council intends to adopt a plan, monitor manage approach and any issues arising
will be picked up in the review of the Local Plan as appropriate.
Current identified issues with skills gaps and shortages, and proposed interventions to deal with these, are set out in the Council’s Employment and Skills Strategy: More and Better Jobs (EB32) which builds on the Jobs
and Business Plan (EB31).
The Employment and Skills Strategy: More and Better Jobs sets out on page 14 where Barnsley is now with jobs and skills.
The labour market in Barnsley is complex and changing and there are challenges around the skills level of Barnsley people.
• Outside of the public sector, the important employment sectors are
manufacturing, wholesale, retail, business services, logistics and construction.
Logistics and ICT have experienced the biggest recent business growth.
• We have a relatively high employment rate (73.4%) and an improving
employment outlook in recent years.
• However, job opportunities remain low with an average of 74 jobs per 100
working-age residents, suggesting that many well qualified residents commute for
work.
• Employers in low wage sectors still dominate the economy. Nearly half of all
employed residents are working in lower level occupations and workplace earnings
are the second lowest in the Sheffield City Region.
• Only around two fifths of the adult population hold qualifications at level 3 or
above.
• Rates for those neither in work nor looking for a job are relatively low, however a
high proportion (37%) is due to long-term sickness. This relates directly to the
high proportion of residents who are claiming benefits.
• The number of young people not in education, employment or training (NEET)
has improved significantly, with the rate currently standing at 5.8% of 16 to 18
year olds.
• Education attainment levels continue to lag behind the city regional and national
averages, threatening the future labour supply, business productivity and incomes.
Page 18 highlights the key gaps in employment and skills delivery. The diagram below highlights that a good range of provision continues to make a difference to employment and skills in Barnsley. However there are gaps
at key stages of the learning journey, and without intervention these will hold back business progress and our ambition for more and better jobs. The
diagram below illustrates employment and skills provision across the learning and work journey in terms of what is in place and what the needs are:
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Page 28 of the Employment and Skills Strategy (EB32) Sets out the Priorities
and proposed actions necessary to deliver more and better jobs. These are set out below:
Priority 1
Raise the ambition of Barnsley businesses, institutions, people and communities
Action to Deliver
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• Increase the attainment of children and young people in school and further education to close the gap with national averages at level 2 and 3.
• Raise young people’s aspirations by working with schools and communities.
• Encourage businesses to develop their workforces to increase their productivity.
• Promote lifelong learning and aspiration in individuals and families.
• Coordinate local and regional jobs and skills provision.
• Give leadership to our larger public and private employers to use procurement
to incentivise creation of local jobs and training opportunities. Priority 2
Improve education, employability andwork readiness
Action to Deliver
• Close the gap with national and regional educational attainment, especially in English and Maths.
• Promote teaching and learning of transferable skills in schools and colleges.
• Build business and education collaborations.
• Equip young people with skills in enterprise.
• Enhance college/FE course provision in response to the Area Based Review. Priority 3
Improve routes into work
Action to Deliver
• Coordinate and strengthen services that facilitate employment, including health, transport and childcare.
• Improve the quality of information, advice and guidance (IAG) for young
people and adults.
• Increase the number and range of work experience and training opportunities.
• Increase the number of quality of apprenticeships, especially at higher levels.
• Create a joined up employment and health programme for people over 25.
Priority 4 Enhance business skills and progression in the workplace
• Promote the uptake of Sheffield City Region business growth and skills
development support by local businesses.
• Strengthen workforce progression in local businesses.
• Develop support to retain and increase higher-level skills in local businesses.
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• Co-create a local ‘skills escalator’ programme with larger public and private sector employers.
The extracts of the Employment and Skills Strategy: More and Better Jobs above
set out the gaps and proposed actions. The strategy provides further information on the proposed outcomes and how delivery will be measured.
It is envisaged that delivery of the Employment and Skills strategy will complement delivery of the Jobs and Business Plan to ensure that local residents
are as well placed as possible to benefit from newly created job opportunities.
Issue – Will the plan meet the OAN for employment within the plan period?
3.6 Is Policy E1 which seeks to allocate ‘around 300 hectares’ of land to support the provision of approximately 33,000 jobs over the plan period soundly based and supported by robust and credible
evidence?
The Council considers that the policy is supported by robust and credible evidence. The sites proposed as allocations represent our preferred
portfolio in terms of suitability and deliverability total 307.1ha. Whilst this is around 18 ha above the employment land requirement figure, the Council consider this to be reasonable in order to achieve the optimum portfolio of
sites in terms of a mix of sizes.
How the requirement figure has been arrived at is set out in the Employment Background Paper (BP6) set out in the table which is table 16 from the Employment Land Review, December 2016.(EB33).
Some of the smaller proposed allocations are remaining plots within
existing employment sites. Some proposed allocations are in the control of end users as expansion land for their own firms. Paragraph 8.15 of the Local Plan states: Amongst the proposed allocations are some sites which
we consider to be expansion land. As these are regarded as under the control of an existing/ neighbouring end user they may not be immediately
available to the market. They are however new sites that are proposed, and therefore they are included as part of our employment land supply. These sites are unlikely to be brought forward in the short to medium term, or
sites whose owners intend to develop for their own purposes. Flexibility in the figure is therefore considered prudent.
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Above is an extract of the Core Strategy Inspector’s report. Paragraph 46 of
the report was supportive of the approach that it is prudent to have some employment land remaining at the end of the plan period. Given the lead in
times for employment land and that several proposed sites are predicated on Green Belt release it is considered appropriate to allocate the amount proposed in this Local Plan.
3.7 How has the OAN for employment been translated into a requirement for floorspace and land? Are the assumptions for the following factors realistic and justified by the evidence:
Site coverage/plot ratio1 – 40%;
Job densities2:
B1a (offices) – 19 sqm B1b/c (research and development/light industry) – 34 sqm
B2 (general industry) – 34 sqm B8 – (storage and distribution) - 50 – 80 sqm
Loss of employment land to other uses – 5 hectares per annum;
Margin to allow for choice and flexibility in the employment land market –
30%;
Occupancy rates - 75%.
The Employment Land Background Paper (BP6) (paragraphs 6.3 to 6.5) sets
out how the above factors were derived and what evidence there is to
1 The amount of employment floorspace that can be developed as a proportion of the
site area 2 Expressed as amount of floorspace per worker in square metres
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support them. Relevant extracts from the Background Paper are set out
below:-
Site coverage/ plot ratio 40%
This 40% is supported by the Mott Macdonald Employment Land Evidence report 2016 at paragraph 5.5.1 which states that the plot ratio (or floor area ratio)
typically ranges between 40-50%. Therefore the Council consider 40% to be a reasonable assumption as it is within this range.
Job densities
The job density assumptions used are taken from the Regional Econometric
Model (REM.) They are considered appropriate for Barnsley as they are reflective of the job densities seen in the Yorkshire and Humber region.
Loss of employment land to other uses 5 ha per annum
A 5ha per annum allowance has been included to account for the anticipated loss of employment land to other uses. This figure was arrived at through the analysis of Council AMR data which illustrated that over the 8 year period 2004/5
to 2011/12 70.39 ha of employment land was lost to residential development, amounting to an average loss of 8.79ha per annum. The loss of employment
land has tailed off in recent years, in part due to the introduction of more stringent employment land safeguarding policies. Consequently, it was deemed appropriate to reduce the replacement allowance to 5 ha per annum.
Margin of Choice 30%
A 30% margin has been included in the calculations to allow for choice and flexibility in the market. This margin is comparable to that used by other
authorities; a summary of the benchmarking information is set out below. The impact of a range of flexibilities (30%, 35% and 40%) were tested on all of the
policy on scenarios explored and the Council subsequently decided to opt for the 30% option which relates most closely to the benchmark information. A choice of
sites is needed to meet a range of business need and provide flexibility for the plan to respond to changing economic circumstances. There are some large sites proposed that will take time to build out. The amount of choice will also provide
flexibility whilst businesses transition from older to more modern stock. There is evidence of some older outdated stock in the Borough.
Sheffield (allowed for an extra 2 ha pa) Rotherham and Leeds (allowed for extra 5 years of total supply)
Doncaster (allowed for extra proportion depending on useB1 25%, B8 strategic 10%, B8 non-strategic 50%, B2 50%)
Other LPAs allow for an extra 20 to 30 %
Occupancy Rates 75%
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The justification for the assumption of 75% occupancy rates is set out in the Employment Land evidence prepared by Mott Macdonald (EB). The justification is
as follows:-
“This assumed occupancy rate is based on the following:
The overall strength of the Barnsley economy, which is recovering well
from the recent recession but has historically underperformed compared to the national and regional average
The extent of current competition for employment sites, particularly along
the key motorways near Barnsley
The historical take-up of existing sites and spaces in Barnsley and the sub region
The latest forecasts for economic growth in the UK to 2020 (based on the end of the 2016 Budget Forecast period)
The judgement of the study team based on their experience and expertise.
The initial occupancy rate considered ranged between 65 and 90%. Some of the well placed sites in Barnsley are likely to achieve or even exceed the higher end
of the range. However the team concluded that a cautious average of 75% should be taken as the occupancy rate which will be achieved. This is not to say
that over time this figure would remain the same and is likely to fluctuate, depending on economic considerations at the time.
For example, it is often more harmful for an economy of an area if there is an under-supply of employment land compared to an over-supply. It is therefore
judicious to ensure from a planning point of view that the allocation of employment land is not only sufficient for current demand (in terms of range of
sizes, quality and location) but also retains enough scope for flexibility, if economic conditions change unexpectedly as they can do. This is important for existing indigenous businesses that may want or need to expand and/or
relocate, new businesses seeking to relocate from outside the area and who would want to ensure there is sufficient space for future growth and new local
businesses that will need appropriate space in the right location. In all these circumstances there is a requirement for the supply to be in excess of the average occupancy rate, in particular in an area where it is proposed that the
economy is encouraged and planned to grow substantially.
The local planning authority should therefore consider the quantum, location and range of site sizes to be allocated which will achieve the right balance between meeting current and identified need based on estimates of the average
occupancy rate over the Plan period, and also securing enough flexibility for future growth, particularly if the economy grows faster than currently
anticipated. With this in mind, the 75% occupancy figure should be seen and be considered to be the lower end of a range. Given the right economic conditions, the economy could generate demand for more land and premises than this
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figure can satisfy which, if sufficient land was not allocated, would constrain the market and could lead to the economic activity and growth of Barnsley in future
being stifled contrary to the objectives set for the Barnsley Local Plan area.”
3.8 How much of the land allocated for employment has been ‘carried
forward’ from the Barnsley Unitary Development Plan (EB14 –
EB25)?
Table 10 of the Employment Land Review (EB) and repeated in the Employment Background Paper (EB6) lists the sites that are remaining UDP
employment land which is still considered suitable for employment use and proposed as allocations in the Local Plan. The total figure is 92 ha.
3.9 Will the location of employment sites at M1 Junctions 36 and 37
influence the extent to which jobs will be occupied by the working age population of Barnsley?
The Council considers that our proposed portfolio of sites provides the
optimum range of sites and sizes to meet the needs of the borough and is able to provide opportunities for the resident working age population. The location of the sites at Junction 36 and 37 will enable convenient access
both from across/ within Barnsley as well as to and from other parts of the City Regions. In addition to the sites at junction 36 and 37 sites are
proposed across the borough including site D1 proposed at Goldthorpe in order to provide opportunities to residents in one of the most deprived areas of the borough.
Deliverability has been a criteria in site selection. The Council have sought
to develop a portfolio of sites that are in the right places and are also viable and attractive to the market to ensure their delivery. A portfolio of sites that may be more accessible to local people but does not deliver the
required jobs due to market attractiveness will not achieve the needs of the borough.
3.10 Does Policy E1 make clear the breakdown of employment land type
to be delivered and what type of employment use is to be delivered on each of the allocated sites? Will it help to deliver the priority
and enabling sectors identified in the ‘Jobs and Business Plan’ (EB31)?
Proposed Local Plan policy E5 sets out the appropriate uses that will be supported on employment sites in order to protect the allocations from
inappropriate development that will not contribute to job creation.
Policy E1 does not provide a breakdown of employment land type to be delivered. The Employment Land evidence by Mott Macdonald (EB) does
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indicate the potential uses on each site, which are also summarised in the table of proposed allocations set out in the Employment Background Paper
(EB6). If it would be helpful the Council could consider including the potential uses in the site specific policies.
3.11 Should the plan make provision for 3 Business Parks of at least 100
hectares each as envisaged in ‘Growing Barnsley’s Economy 2012 – 2033’?
Since Barnsley’s economic strategy ‘Growing Barnsley’s Economy’ was
drafted, further work has been done to update elements of it through the
Jobs and Business Plan (EB31)
The sites proposed in the Local Plan are considered to be the best portfolio of sites to meet the needs of the borough in terms of providing a range and mix of sites and sizes. The vision in the Jobs and Business Plan
acknowledges that the Local Plan supports four of the key Council Strategies (Housing, Jobs and Business, Transport and Employment and
Skills) and as such the Local Plan as submitted is in line with the latest corporate objectives and ambitions for Barnsley.
3.12 Is the reserve employment site at Goldthorpe (Policy RSV1)
required to meet the OAN for employment and the employment land
requirement?
Site RSV1 is not included in the total amount of employment set out in policy E1. The Council proposes this site as Land Reserved for employment. Proposed Local Plan Policy E4 sets out that a need must be proven for its
use for employment purposes. Paragraph 6.7 of the Employment Background Paper (BP6) states:“In addition to around 307.1ha of new
employment land we have proposed a reserve site. This is adjacent to site D1 at Goldthorpe and totals 98.4ha. The allocation of the reserve site adjacent to the proposed Goldthorpe allocation will be of benefit to Barnsley
and the City Regions as it will mean that should a footloose large scale use come forward, that cannot be accommodated on a site elsewhere in
Barnsley or the wider City Regions, this reserved land could be released. Barnsley is a prime location to accommodate such uses given its motorway location.”
Main Matter 4 – Objectively assessed need for housing
Context – The Strategic Housing Market Assessment 2014 and its Addendum (March 2017) (EB45) identify the objectively assessed
housing need (OAHN) as a range from 967 to 1389 dwellings. This is based on demographic analysis as set out in the Barnsley
Demographic Analysis and Forecasts Report (EB55), Addendum and Update (March 2017) (EB56) and the jobs growth envisaged in the ‘Jobs and Business Plan 2014 – 2017’ (EB31).
Issue – Is the OAHN soundly based and supported by robust and
credible evidence and is it consistent with national policy?
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4.1 Does the geographical area of the Borough represent a robust and
appropriate basis for assessing housing needs?
Table 2.1 Flows of residents (all moves)
Origin/
Destination
Supply Side (Origin) Demand Side (Destination)
All Moves
Excluding
Long
Distance
Moves All Moves
Excluding
Long
Distance
Moves
Number % % Number %
Barnsley 15,044 74.1 81.0 15,044 74.3 81.8
Sheffield 878 4.3 4.7 701 3.5 3.8
Wakefield 689 3.4 3.7 553 2.7 3.0
Rotherham 677 3.3 3.6 638 3.2 3.5
Doncaster 348 1.7 1.9 416 2.1 2.3
Kirklees 331 1.6 1.8 271 1.3 1.5
Leeds 269 1.3 1.4 266 1.3 1.4
Bradford 82 0.4 0.4 37 0.2 0.2
East Riding of Yorkshire 57 0.3 0.3 79 0.4 0.4
Kingston upon Hull, City
of 33 0.2 0.2 42 0.2 0.2
North East Lincolnshire 33 0.2 0.2 35 0.2 0.2
York 29 0.1 0.2 75 0.4 0.4
North Lincolnshire 24 0.1 0.1 39 0.2 0.2
Selby 24 0.1 0.1 28 0.1 0.2
Elsewhere Y&H 66 0.3 0.4 173 0.9 0.9
East Midlands 367 1.8 472 2.3
North West 279 1.4 301 1.5
Elsewhere UK 1,076 5.3 1,079 5.3
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Yes the Council considers that it does. Please see Chapter 2 ‘Defining the
Housing Market Area’ of the Barnsley 2017 SHMA Addendum (EB45).
This considers: house prices, migration and travel to work data. Of
particular note:
Migration
Para 2.9 of the SHMA Addendum (EB45): A suitable test are two migration containment ratios:
Supply Side (origin): moves within the area divided by all moves
whose origin is in the area, excluding long-distance moves;
Demand site (destination): moves within the area divided by all
moves whose destination is in the area, excluding long-distance migration.
Description of flows
Supply-side (origin): Moves within the district and moves to outside the district (out-migration) (starting point)
Demand-side (destination): Moves within the district and moves from elsewhere
into the district (in-migration) (destination point)
Table 2.2 Containment ratios
Origin
Moves within the
area
Moves originating in
the area Containment Ratio
15,044 18,584 81.0%
Destination
Moves within the area
Moves whose destination is in the
area
Containment Ratio
15,044 18,397 81.8%
Source: 2011 Census
Total 20,306 100 100 20,249 100 100
Base (excluding long-
distance moves) 18,584 18,397
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TRAVEL TO WORK
Table 2.3 Barnsley 2011 census commuting flows: workers (aged 16-
74)
Where do people who live in Barnsley work?
Live Work Number %
Barnsley
Barnsley 57,866 60.0
Sheffield 8,353 8.7
Rotherham 8,226 8.5
Wakefield 7,028 7.3
Other 14,945 15.5
Workers 96,418 100.0
Where to people who work in Barnsley live?
Live Work Number %
Barnsley
Barnsley
57,866 76.9
Sheffield 3,961 5.3
Rotherham 3,363 4.5
Wakefield 3,024 4.0
Other 6,985 9.3
Jobs 75,199 100.0
Source 2011 census
SHMA Addendum (EB45):
2.13 In terms of defining market areas, NPPG does not suggest an appropriate
self-containment figure. However, the ONS provides a definition of Travel to Work areas as:
‘The current criterion for defining TTWs is that generally at least 75% of
an area’s resident workforce in the area and at least 75% of the people who work in the area also live in the area…however, for areas with a
working population in excess of 25,000, self-containment rates as low as 66.7% are accepted’3
2.14 On this basis, it can be concluded that Barnsley MB cannot be considered
to be self-contained in terms of travel to work but part of a wider functional economic area with linkages in particular to the Sheffield and
Leeds City Regions.
3https://www.ons.gov.uk/employmentandlabourmarket/peopleinwork/employmentande
mployeetypes/articles/commutingtoworkchangestotraveltoworkareas/2001to2011
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4.2 Is the SHMA’s conclusion that the Borough is a self-contained housing market area justified by the evidence on migration and
travel to work patterns?
Conclusions of SHMA Addendum (EB45) Chapter 2
2.18 For the purposes of Local Plan policy making, Barnsley is an appropriate Housing Market Area, whilst recognising its functional interactions with
neighbouring districts.
4.3 Has any further work been completed in respect of housing market
geographies within the LCR? (Housing Background Paper (BP3)
paragraph 3.22)
The Leeds City Region Housing Market report was carried out by the Centre for Urban and Rural Development Studies (CURDS). The final report is dated July 2016 and therefore the background paper at submission stage
should have contained an update to paragraph 3.22.
However the final report continues to reflect the position of the draft report in that the boundary with Wakefield MDC is shown as being less permeable
than it has been previously. This is illustrated in map 18 page 33. It is proposed that this dcoument is added to the Examination Library on the City Region evidence page as reference number (EB175).
4.4 What adjustments have been made to reflect the 2014 sub-national
population and household projections (SNPP and SNHP)?
The SHMA evidence base (EB45), which informs the OAN calculation, has
been updated in the Barnsley 2017 SHMA Addendum with the latest 2014-
based sub-national population projections.
4.5 Have appropriate adjustments to the SNPP and SNHP been made to form the demographic starting point for assessing OAHN? In
particular:
Past trends in migration and the likelihood or otherwise of these continuing in the future;
The demographic modeling which supports the 2017 SHMA Addendum
(EB45) considers past 5- and 10-year migration trends.
Chapter 4 of the SHMA Addendum (EB45) and (EB55 & 56):
4.12 The following alternative trend scenarios have been developed by Edge Analytics:
PG-5Yr: internal and international migration assumptions are derived from the last 5-years of historical evidence (2010/11 to 2014/15). The
‘Unattributable Population Change’ (UPC) component is included in international migration assumptions;
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PG-10Yr: internal and international migration assumptions are derived from the last 10-years of historical evidence (2005/06 to 2014/15).
The ‘Unattributable Population Change’ (UPC) component is included in international migration assumptions
Past trends in household formation and the likelihood or otherwise of
these continuing in the future.
Para 4.13 of the SHMA Addendum (EB45)
The Edge analysis also considers headship rate sensitivities. Nationally, younger age groups have been more adversely affected by housing supply and unaffordability issues, which in some areas may have led to
‘suppressed’ rates of household formation. Therefore, each of the demographic scenarios has been run with alternative headship rate
assumptions that examine an ‘improvement’ in the headship rates of the younger age groups. In the 2014-based Return sensitivity, headship rates in the male younger age groups (15-44) return to their 2001 values by
2024, continuing the original rate of growth thereafter.
4.6 Is any adjustment required to take account of market signals
including:
Land prices;
House prices; Rents;
Affordability; Overcrowding.
Chapter 3 of the Barnsley 2017 SHMA Addendum (EB45) considers a range of
market signal data for Barnsley and comparator areas.
Para 3.18 of the Addendum (EB45): In conclusion, a review of Market Signal
data and past delivery would suggest that there is no uplift necessary. ONS
house price to income indicators in particular, would not suggest an uplift is
necessary
Note that the LPEG report provides advice and is not guidance.
VOA data LQ rent Oct15 to Sept 16 was £390 and median £433; 26.5% LQ and
20.4% Median
4.7 Has an appropriate vacancy rate been used in converting the
household projections into a dwelling requirement?
A rate of 4% has been used in modeling carried out by Edge Analytics.
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Paras C.40 and C.40 of Edge Report (EB55&56) states;
Vacancy Rate
C.40 The relationship between households and dwellings is modelled using a
‘vacancy rate’, sourced from the 2011 Census. The vacancy rate is calculated
using statistics on households (occupied household spaces) and dwellings
(shared and unshared).
C.41 A vacancy rate of 4.0% for Barnsley has been applied, fixed throughout
the forecast period. Using the vacancy rate, the ‘dwelling requirement’ of each
household growth trajectory has been evaluated.
4.8 Does the OAHN take account of the need to ensure that the identified requirement for affordable housing is delivered? (annual
net shortfall of 292 affordable dwellings)
PPG Paragraph 2a-029 advises on how housing needs assessments should take
account of affordable housing need: ‘the total affordable housing need should be considered in the context of its likely delivery as a proportion of mixed market
and affordable housing developments, given the probable percentage of affordable housing to be delivered by market housing-led developments. An increase in the total housing figures included in the local plan should be
considered where it could help deliver the required number of affordable homes’.
The SHMA establishes a net imbalance of 292 affordable dwellings each year.
This figure expresses the overall need from household survey evidence compared with the current supply of affordable housing. The 292 figure assumes that backlog need is cleared over a five year period.
If the backlog is cleared over the plan period, the annual net imbalance falls to 82.
PAS4 guidance provides helpful guidance in interpreting affordable need in the context of objectively assessed need. Paragraph 9.6 states ‘in practical terms, there is no arithmetical way of combining the two calculations set out in PPG to
produce a joined-up assessment of overall housing need’. We cannot add together the calculated OAN and the calculated affordable need, because they
overlap: the OAN of course covers both affordable and market housing, but we cannot measure these components separately, because demographic projections – which are the starting point for the OAN – do not distinguish between different
sectors of the housing market. Para 9.7 continues ‘In summary, it seems
4 Planning Advisory Service Objectively Assessed Need and Housing Targets Technical
Advice Note Second Edition July 2015
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logically clear that affordable need, as defined and measured in paragraphs 22-29 of the PPG, cannot be a component of the OAN. The OAN does have an
affordable component – which cannot be measured separately but will normally be much smaller than the affordable need discussed at paragraphs 22-30’. When
paragraph 47 of the NPPF says that plans should meet in full ‘the need for market and affordable housing’, it is referring to that component rather than the separately calculated affordable need.
Pragmatically, the view taken by arc4 is that the modeling of housing need
establishes the magnitude of affordable need based on defined assumptions.
Varying these assumptions (e.g. increasing the % of household income that can
be spent on housing costs) reduces the net imbalance.
The Government’s Feb 2017 White Paper also recommends including ‘Affordable
Private Rented’ as part of affordable supply which was not taken into account
when the modeling was prepared.
Our view is that an affordable housing delivery programme will help to deliver
more affordable housing but this is subject to economic viability of delivery and
Government policy. Adjusting the overall quantum of housing delivery to
increase affordable supply through developer contributions would not be
recommended.
4.9 Have the needs of particular groups (eg older people and those requiring
specialist support) been appropriately taken into account in the OAHN? How will
the plan help to deliver the housing needs of these groups?
4.9 Have the needs of particular groups (eg older people and those
requiring specialist support) been appropriately taken into account in the OAHN? How will the plan help to deliver the housing needs of these groups?
The OAHN is derived from population modelling prepared by Edge Analytics
using POPGROUP. POPGROUP outputs separate out the population in
households from the population not in households. The population in
households is used to inform OAN calculations. Therefore, older people and
those with specialist support needs living within the residential population
will be included. The population in communal establishments will not be
part of the modelling used to inform the OAN.
The Edge Report (EB55&EB56) Appendix C comments:
Communal Population Statistics
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C.38 Household projections in POPGROUP exclude the population ‘not-in-
households’ (i.e. the communal/institutional population). These data are
drawn from the DCLG 2014-based household projections, which use
statistics from the 2011 Census. Examples of communal establishments
include prisons, residential care homes and student halls of residence.
C.39 For ages 0–74, the number of people in each age group not-in-
households is fixed throughout the forecast period. For ages 75–85+, the
proportion of the population not-in-households is recorded. Therefore, the
population not-in-households for ages 75–85+ varies across the forecast
period depending on the size of the population.
The 2014 SHMA includes a review of household groups who have particular
housing requirements (Core Output 8 page 102 para 6.117 to 6.140). This
helps the Council to identify strategic priorities for delivery of housing for
these groups.
4.10 Is the identified need for 15 additional pitches for gypsies and
travellers (Policy GT1) over the 5 year period 2014/15 – 2019/19 justified by the evidence? What evidence supports the use of a 1.83 multiplier to produce an annualised requirement of 18 pitches
over the five-year period?
The 2015 GTAA establishes a shortfall of 15 pitches over the 5 years
2014/15 to 2018/19 based on analysis of current authorised pitch provision
and household survey data. The survey data establishes future need from
emerging households and also the impact of moves of existing households
planning to move in the next 5 years.
Total need = 73 pitches
Total supply = 58 pitches (53 occupied authorised plus 5 vacants_
No turnover is assumed on sites as Council reports very low turnover on its
sites and most respondents have stated that they do not intend moving in
the next 5 years
The above would previously have been viewed as a minimum requirement
based on the current supply of pitches, the views expressed by Gypsy and Traveller households who have been interviewed and assumptions regarding need from households living in bricks and mortar dwellings.
However, with the new revised guidance altering the definition of Travellers it is actually more likely that these may be seen as a maximum given that
the new definition focuses on the needs of those who are actually Travelling or planning to travel.
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In the longer-term (2019/20 to 2033/34), there is expected to be a need
from 18 emerging households.
The inclusion of an annualised pitch requirement was simply to express the
total need (33) over the plan period - this assumed an 18 year period with
33/18=1.83. Over a 19 year period this would be 1.74.
However, it is the conclusion of the GTAA that there is a shortfall of 15
pitches over the period 2014/15 to 2018/19 and 18 pitches 2019/20 to
2033/34
4.11 In expressing the OAHN as a range related to the ‘Jobs Led Policy On’ scenario, do the SHMA, SHMA Addendum and Housing
Background Paper make clear what assumptions have been made in relation to the following factors? Are the assumptions robust and supported by the evidence:
Improving economic activity rates (16 – 74 year olds);
Unemployment rate; Changes to the commuting ratio.
It is considered that the SHMA addendum does make clear what assumptions have been made in relation to the above factors.
The Edge Report (EB55&56) state all assumptions regarding economic
activity, unemployment and commuting ratios. The SHMA Addendum
(EB45) at Table 4.6 presents recent trends in economic activity,
employment rates and unemployment, with data drawn from the Annual
Population Survey
Table 4.6 Recent trends in economic activity, employment rate and unemployment trends
Time Period
Economic Activity
Rate
Employment
Rate Unemployment
Rate
Oct 2010-Sep 2011 73.9 65.7 11.1
Oct 2011-Sep 2012 74.7 67.1 10.2
Oct 2012-Sep 2013 78.6 69.9 11.0
Oct 2013-Sep 2014 80.6 72.8 9.6
Oct 2014-Sep 2015 78.0 73.0 6.5
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Oct 2015-Sep 2016 75.5 71.5 5.3
Source: Annual Population Survey
By way of further explanation, both economic activity and employment rates
have the same base. The unemployment rate uses as a base the economic
activity rate
Measure Numerator Denominator %
Economic activity rate - aged
16-64 115,400 152,800 75.7
Employment rate - aged 16-
64 109,300 152,800 71.5
Unemployment rate 6,100 115,400 5.3
Improving economic activity rates (16 – 74 year olds);
The assumptions made by Edge Analytics regarding economic activity rates are
set out in the Edge Report (EB55&EB56). In summary, they have used Census
data to derive economic activity rates but these have been adjusted to take
account of changing economic activity rates amongst older age group based on
work by the Office for Budget Responsibility (OBR)
The following assumptions have been made in the Edge Report (EB55 & 56):
Economic Activity Rates
C.44 The level of labour force participation is recorded in the economic activity
rates. Economic activity rates by five year age group (ages 16-89) and sex have
been derived from Census statistics.
C.45 Between the 2001 and 2011 Censuses, rates of economic activity
increased, most notably for females and males in the older age groups (Figure
11).
OBR Rates
C.46 The Office for Budget Responsibility (OBR) has undertaken analysis of
labour market trends in its 2015 Fiscal Sustainability Report. Included within its
analysis is a forecast of changing economic activity rates for males and females,
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extending to a long-term 2066 forecast horizon. This forecast has been used to
generate an alternative set of economic activity rates for Barnsley.
C.47 Adjustments have been made for the older age groups only (60–89) as set
out in the (Table 8). The economic activity rate profiles are summarised in
Figure 12. Table 8: OBR Economic Activity Rate
C.48 These economic activity rate adjustments have been applied in all
demographic and jobs-led scenarios except Jobs-led Policy On EA SENS and
Jobs-led Policy On EA CR SENS.
C.49 Under the Jobs-led sensitivity scenarios (Jobs-led Policy On EA SENS and
Jobs-led Policy On EA CR SENS), the 2014 aggregate economic activity rate (16–
89) of 60.6% for Barnsley has been achieved by 2033.
Unemployment rate;
The assumptions regarding unemployment are robust and based on ONS data
The Edge Report (EB55&56) comments that:
Unemployment Rate
C.55 The unemployment rate, together with the commuting ratio, controls the
balance between the size of the labour force and the number of jobs available
within an area.
C.56 In all scenarios, historical unemployment rates are defined up to 2015.
From 2015, the unemployment rate reduces from 6.1% to the lowest historical
unemployment rate of 4.5% by 2033 (Table 10).
Table 10: Historical unemployment rates 2004–2015
Unemployment
rate (%) Barnsley
2004 4.5
2005 4.9
2006 5.9
2007 5.7
2008 7.0
2009 9.6
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2010 10.0
2011 10.5
2012 10.4
2013 9.9
2014 7.7
2015 6.0
Source: ONS model-based estimates of unemployment, from NOMIS
Changes to the commuting ratio.
The Edge Report (EB55&56) sets out how the commuting ratio in Barnsley has
varied beween the 2001 and 2011 census
The report states:
Commuting Ratio
C.50 The commuting ratio, together with the unemployment rate, controls the
balance between the number of workers living in a district (i.e. the resident
labour force) and the number of jobs available in the district.
C.51 A commuting ratio greater than 1.00 indicates that the size of the resident
workforce exceeds the number of jobs available in the district, resulting in a net
out-commute. A commuting ratio less than 1.00 indicates that the number of
jobs in the district exceeds the size of the labour force, resulting in a net in-
commute.
C.52 From the 2011 Census ‘Travel to Work’ statistics, published by ONS in July
2014, commuting ratios have been derived for Barnsley. This is compared to the
2001 Census value in Table 9.
Barnsley E080000
16
2001
Census
2011
Census
Workers a 88,760 104,015
Jobs b 74,520 83,384
Commuting
Ratio a/b 1.19 1.25
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C.53 In all but the Jobs-led Policy On CR SENS and Jobs-led Policy ON EA CR
SENS scenarios, the 2011 Census commuting ratio has been applied, fixed
throughout the forecast period.
C.54 In the Jobs-led Policy On CR SENS and Jobs-led Policy ON EA CR SENS
scenarios, the commuting ratio incrementally reduces from the 2011 Census
value of 1.25 to 2001 Census value of 1.19 by 2033 (Figure 13).
. . Figure 13: Commuting ratio in Jobs-led Core and CR sensitivity scenarios
Issue - Will the plan meet the full OAHN within the plan period?
It is anticipated that the Plan will meet the proposed housing requirement within the plan period of 1100 per annum, as set out in Housing Background Paper version 2 para 4.49.
Context – Policy H1 of the plan allocates land for at least 20,900 net
additional homes or approximately 1100 within the plan period 4.12 What is the appropriate OAHN for Barnsley within the range of 967
to 1389 dwellings set out in the SHMA?
The Council proposes that the OAHN is presented as a range of 967 to 1389 dwellings per annum. The housing requirement figure is then derived from
that range. The Council considers a range is appropriate rather than a fixed OAHN
figure given there are uncertainties, for example around jobs growth housing implications, the fact DCLG is to introduce a standard methodology
which would almost certainly produce a different figure. However it is anticipated that a figure derived using a new methodology would be within the established range.
4.13 How has the range of OAHN informed the housing requirement in Policy H1?
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Paragraphs 4.33-4.49 of version 2 of the Housing Background Paper (BP3)
set out the issues the Council has considered following the flowchart in the
PAS guidance document.
Issues considered include: Affordable Housing need; supply capacity; cross
boundary unmet need; and Barnsley MBC policy objectives.
Paragraph 4.49 of the Housing Background Paper version 2 (BP3) concludes
the following:-
The above factors have been considered in determining our housing
requirement. It is concluded that the 1,100 per annum figure quoted in the
Publication version draft Local Plan (previously referred to as our OAN
figure), is an appropriate housing requirement figure. 1,100 is within the
OAHN range recommended by the SHMA addendum 2017, which is based
on up to date demographic modelling. It is considered that the issues
raised above justify setting the requirement at this mid-point of the range
rather than higher, in order to ensure the local plan is deliverable, and in
accordance with Green Belt policy. It is considered that the 1,100 figure
represents an ambitious and aspirational figure which addresses housing
needs and supports economic growth ambitions, and would still require a
step up in delivery. The 1,100 per annum figure, expressed as at least
20,900 net additional homes over the plan period figure in policy H1, whilst
not a ceiling, means that Barnsley would be able to meet its own housing
requirement.
In setting the housing requirement figure, in addition to the issues for consideration in the PAS flowchart the Council has been mindful of past
delivery rates. Paragraph 4.18 of the Housing Background Paper sets the context for previous housing requirement figures where the best completion
rate achieved was in the boom year of 2004/5 at 1305 dwellings. This has to be offset against the worst year of 2009/10 when the completion rate was 556.
Whilst the Council contends that at present the Housing White Paper carries
little weight whilst it is out to consultation, it is prudent to be mindful of the implications arising from it in respect of under delivery should the proposed delivery targets and penalties come to fruition.