Doncaster

Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

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

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

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

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

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

Title Mr Ms

First Name Alistair Clare

Last Name Maclean – Clark Plant

Organisation (where relevant)

360 Degree Media DLP Planning

Address – line 1 c/o agent Ground Floor

Address – line 2 2 Tenter Street

Address – line 3 Sheffield

Postcode S1 4BY

E-mail Address

Telephone Number

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

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

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

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

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

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

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

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

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

at the request of the Inspector, based on the matters and issues she/he identifies for examination.

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

or

Name / Organisation Name:

DLP Planning Ltd

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

Doncaster Local Plan Publication Draft ☒ Policies Map ☒

Sustainability Appraisal ☐ Habitats Regulations Assessment ☐

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

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

Page No.: Paragraph:

Policy Ref.: Policy 2 and 39 Site Ref.:

Policies Map: Green Belt and Parks and Gardens of Local Historic Interest: High Melton Hall Park.

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

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

Positively prepared ☒ Justified ☐

Effective ☒ Consistent with National Policy ☐

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

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

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

Please see the supporting letter submitted as part of this representation.

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

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

Please see the supporting letter submitted as part of this representation.

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

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

☒ Yes, I wish to appear at the Examination.

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

To support the presentations report and the Inspector’s understanding of the site.

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

Date 30/09/2019

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

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

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

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

Hard copies are available on request from:

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

or defamatory.

Local Plans Team Civic Office Waterdale Doncaster DN1 3BU

By email to: Dear Sir/Madam, Re: Publication of the Doncaster Local Plan (Regulation 19 Version) Consultation This Local Plan representation has been prepared by DLP Planning Ltd on behalf of 360 Degrees Media in response to the publication of the Doncaster Local Plan (Regulation 19) for consultation. This representation relates to the ‘Former Doncaster College Campus, High Melton’ and should be read alongside the response form that has also been completed and submitted in relation to the site. 360 Degrees Media are working alongside Doncaster Metropolitan Borough Council and Sheffield City Region to prepare proposals for a commercial film and media hub at the former Doncaster College site in High Melton. This entails the creation of film and TV studios, visual effects production facility (VFX), a film, TV and VFX training academy and hotel and events business. An element of residential development is proposed enabling development to support the wider scheme. 360 Degrees Media is focused on attracting a diverse range of new businesses to the High Melton site near Doncaster to create a unique digital ecosystem around the creative industries. Working closely with existing digital businesses in the region 360 aims to build a hub for new entrants to the industry as well as seasoned companies who can benefit from this ecosystem. In this way 360 aims, over the next 3-5 years, to build a sustainable network of companies that can support and attract larger businesses to relocate at High Melton and further expand the site as a hub for the creative and digital industries in South Yorkshire and nationally. The development has the potential to create around 6,700 new jobs in Doncaster within the film sector and its supply chain. Site and Context The site is circa 23ha in size and comprises the former Doncaster College Campus, which consists of a number of college buildings, a large car park, a number of listed buildings and open spaces. The site also encompasses the High Melton Golf Course. The southern portion of the site possesses a large band of mature trees.

Ref: MP.YK6202.3P Date: 30th September 2019

Fig.1: Aerial view of the site

The village of High Melton is located to the north/ north-east of the site. The site bounded by agricultural land to the west, east and south. The site is located within Flood Zone 1. Proposed Allocation The draft Local Plan document and Proposals Map currently shows the site washed over by Green Belt and included within a Parks and Gardens of Local Historic Interest area as indicated in Figure 2. This is despite the long established brownfield nature of the northern portion of the site which adjoins the High Melton Settlement boundary.

Fig. 2: Policies Map Extract

DLP Planning objects to the failure of the plan to designate the site for development. To ensure the soundness of the Local Plan the remainder of this letter sets out how the Plan should be modified to address soundness. Policy 2: Spatial Strategy and Settlement Hierarchy Policy 2 of the Publication Local Plan sets out that,

‘The openness and the permanence of Doncaster’s Green Belt will be preserved. The general extent of the Green Belt will be retained. Within the Green Belt, national planning policy will be applied including the presumption against inappropriate development except in very special circumstances’.

The former Doncaster College Site at High Melton is currently washed over by Green Belt. There is opportunity for the Development Plan to accurately reflect the future intentions for the site and it is considered that the site could be allocated under its own Special Policy Area within the Local Plan. Alternatively it could be identified as a major developed site in the Green Belt. We therefore object to the current designation of the site within the Green Belt with a view to making progress with Doncaster MBC (DMBC) and Sheffield City Region (SCR) in securing the redevelopment of the site, which would be assisted by a positive planning policy context. It is understood that great importance is attached to Green Belts, with the fundamental aim to prevent urban sprawl by keeping land permanently open and therefore Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. However, strategic policies within the Doncaster Local Plan should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period. In order to best facilitate the proposed investment at High Melton it is considered that an appropriate planning policy framework should reflect the proposals being prepared for the land, which are supported by DMBC and SCR due to their regional and national significance. In this instance the requirements of paragraph 137 of the National Planning Policy Framework (‘Framework’) can be demonstrated as having been met as the proposed allocation site is:

a) a brownfield site, currently vacant and underutilised; b) would be an efficient use of land based on its proposed development as a Creative

Media Industries Hub and Housing; and c) the development part of the High Melton Golf Course is essential in a single location in

order that a critical mass of expertise and facilities is provided in a single location. Dispersal over a wider range of neighbouring authorities would not be an appropriate means by which to deliver the development or the significant social and economic benefits that come from such a use and the environmental benefits of delivering regeneration of a brownfield site.

The proposed Special Policy Area allocation or Major Developed Site in the Green Belt designation performs poorly against the purposes of the Green Belt and is assessed against the five purposes (para 134 of the Framework) as follows;

a) the site does not act to check the unrestricted sprawl of large built-up area. High Melton is not a large built up area and the brownfield nature of the site demonstrates that development has extended beyond the settlement envelope limits in the past with that relationship now being well established;

b) the site is not, by virtue of its location, preventing neighbouring towns merging into one another. The nearest settlements are the village of Cadeby 1.2 km to the south and Sprotborough 2.4 km to the east. The development of this site will not reduce these

distances. This is not considered a material function of the land within the Green Belt in this instance;

c) to assist in safeguarding the countryside from encroachment is not a function in this

instance due to the brownfield nature of the site and that development has extended beyond the settlement envelope limits already. This has effectively established the nature of this area of land as being one of a major developed site in the Green Belt;

d) whilst there are listed buildings within the vicinity of the site and their setting is

protected, the Green Belt designation is not required to preserve the setting and special character of High Melton as a historic town. The listed building designations and Conservation Area boundaries and the protection afforded the setting of such heritage assets performs this function; and

e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban

land, release of the site from the Green Belt as part of a Special Policy Area designation would achieve this and allow appropriate redevelopment of a brownfield site.

The need to promote sustainable patterns of development should be taken into account in deciding to review the Green Belt in this location. The discussions between 360 Degree Media and the Council to date have demonstrated that this location is essential to the delivery of the Creative Media Hub. There would of course be the opportunity to mitigate the impact of the development as part of any further planning application, or indeed as a consequence of the decision to remove the land from the Green Belt through compensatory improvements to the environmental quality and accessibility of the site boundaries and wider retained open land as part of any proposed scheme. There is a significant opportunity to meet the economic investment objectives of the plan, as set out in Strategic Objective 2 and Policies 3, 4 and 5 of the Draft Plan for upskilling of work force through supporting development on this site. As previously noted, the land is not necessary to continue the function of the Green Belt in this location. The Green Belt boundaries can, through an appropriate process of development of the site proposals, be clearly set using physical features that are readily recognisable and are likely to be permanent beyond the plan period. Recommendation The site should be given its own Special Policy Area and the policies map updated to reflect this and with the Former Doncaster College Site removed from the Green Belt. Alternatively, the site should be reallocated as a ‘Major Developed Site within the Green Belt’ in order to ensure the policy is reflective of the Framework, which requires that strategic policies “make as much use as possible of suitable brownfield sites and underutilised land” (Paragraph 137). It is also recommended that to reflect this Special Policy Area, specific reference is made within the Green Belt section of Policy 2 to the redevelopment of this site for Creative Media Industries. Specific reference is made in Policy 3 to the site as an opportunity to secure investment in the Creative Industries: at Policy 4 reference is made to employment generation from Special Policy Area designation and articulated in Table 4 of the Local Plan. Justification The principle of the development of this site for Creative Media Industries, with an element of housing, has been subject to discussions with the Council who are supportive of the proposals due

to the significant skills and economic benefits that the development will have for the Borough and wider economic area. This new development opportunity has already been acknowledged in Table 1 of Page 12 of the Publication Local Plan, but it is recommended that acknowledgement is made within Policy 2 itself. Paragraph 134 of the National Planning Policy Framework sets out that Green Belt serves five purposes:

a) To check the unrestricted sprawl of large built-up areas; b) To prevent neighbouring towns merging into one another; c) To assist in safeguarding the countryside from encroachment; d) To preserve the setting and special character of historic towns; and e) To assist in urban regeneration, by encouraging the recycling of derelict and other urban

land. In respect to the proposed development of this and the five purposes of the Green Belt it is highlighted that the site will not result in the unrestricted sprawl of a large built-up area and will primarily result in the development of brownfield land. The site will not result in neighbouring towns merging into one another. The development will not encroach into the countryside any further than that of the existing built form and manicured landscape. The redevelopment of this site will help to secure the long-term future of the heritage assets on site and will be designed sensitively to respect the character of the historic parks and gardens. The development proposals for this site will assist in the regeneration of this site by redeveloping brownfield land. The site therefore performs poorly against the functions of the Green Belt and it should be allocated to reflect its previously developed nature and the forthcoming development proposals. A planning application is to be formally submitted imminently, and it is requested that the Policies Map and Policy 2 of the Local Plan are updated to reflect the nature of the emerging proposals, which have the benefit of support from the Sheffield City Region and Doncaster Metropolitan Borough Council. Policy 39 – Historic Parks and Gardens Policy 39 ‘Historic Parks and Gardens’ sets out that development affecting Historic Parks and Gardens will be assessed against the following principles:

a) Development proposals within, or affecting Doncaster’s nationally registered parks and gardens, and parks and gardens of local historic interest should preserve and, where appropriate, enhance the heritage significance of these parks and gardens.

b) Proposals affecting a historic park of local or national significance should not result in harm to the built or landscape features or key views or vistas which contribute to the significance of the historic park or garden, or which might prejudice future restoration.

c) Where proposals result in harm or substantial harm to the significance of a nationally designated historic park the proposal will be considered in relation to the extent of harm arising from the proposal, the relative significance of the historic park and garden, and any public benefits arising from the proposal. In the case of parks and gardens of local interest a balanced judgement will be taken weighing the scale of any harm against the significance of the park.

DLP query the need of Policy 39 given the protection to Heritage Assets set out in the National Planning Policy Framework. In respect of the proposed Special Policy Area of Major Developed Site in the Green Belt, any

future development proposals for the site will be sensitively designed in respect to the sites setting within High Melton Park and the High Melton Conservation Area. As part of any future planning application an assessment will be made of the developments impact on the significance of these heritage assets. Recommendation It is recommended that Policy 39 is removed from the Draft Local Plan. Summary DLP Planning have made representations on behalf of 360 Degrees Media for the allocation of land at the Former Doncaster College, High Melton to be allocated as a Special Policy Area to better reflect its brownfield nature and to support the development of this site for creative media industries, or at least to be designated as Major Developed Site in the Green Belt. The future development proposals for this site have been subject to discussion with Doncaster MBC and Sheffield City Region and are supported by these two bodies. The proposed development will have significant positive economic and skills benefit to the Borough and City Region, making the best use of previously developed land and securing the long term future of heritage assets located on the site. Should you require any further information regarding the site, please do not hesitate to contact me. Yours faithfully,

Clare Plant MRTPI AsssocRICs Director