COMMENTS (REPRESENTATION) FORM€¦ · Last Name Peter Kelly, Graham White, Paul Pennington,...

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 Mr

First Name Matthew

Last Name Peter Kelly, Graham White, Paul

Pennington, Stewart Oades Good

Organisation (where relevant)

Pegasus Group

Address – line 1 The Pavilion

Address – line 2 Green Lane

Address – line 3 Garforth

Postcode LS25 2AF

E-mail Address

Telephone Number

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

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

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

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

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

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

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

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

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



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


https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

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

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

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

or

Name / Organisation Name:

Pegasus Group

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): ☒ Green Belt Phase 3 Report

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

Page No.: Paragraph:

Policy Ref.: Policy 2, 3 & Tickhill Housing Allocations

Site Ref.:

Policies Map:

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

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

Positively prepared ☒ Justified ☒

Effective ☒ Consistent with National Policy ☒

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

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

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

This comment form should be read in conjunction with the associated report.

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).

This comment form should be read in conjunction with the associated report.

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 provide a full explanation of our points and address issues raised by the Council, Inspector or other

participants.

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

Date 30/09/2019

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

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

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

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

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

or defamatory.


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

Pegasus Group Pavilion Court | Green Lane | Garforth | Leeds | LS25 2AF

T | www.pegasusgroup.co.uk | @pegasusgroup

Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester

Pegasus Group is a trading name of Pegasus Planning Group Limited [07277000] registered in England and Wales Registered Office: Pegasus House, Querns Business Centre, Whitworth Road, Cirencester, Gloucestershire, GL7 1RT

Page | 1

002.MG/P18-2216EC

30th September 2019

Local Plan Team

Civic Office

Waterdale

Doncaster

South Yorkshire

DN1 3BU

By email only:

Dear Sir/Madam,

Re: Publication Draft Doncaster Local Plan: Consultation Representation on behalf

of Peter Kelly, Graham White, Paul Pennington and Stewart Oades

Please find enclosed a representation prepared by Pegasus Group on behalf of Peter Kelly,

Graham White, Paul Pennington and Stewart Oades in relation to Land at Paper Mill Fields,

Tickhill. The representation considers the content within the Publication Draft of the

Doncaster Local Plan.

The representation should be read in conjunction with the accompanying representation

produced by Pegasus Group to the draft policies and proposed site informal consultation in

September 2018.

I would be grateful if you could confirm receipt of these submissions.

Yours faithfully,

Matthew Good

Director

Email:

cc. Stewart Oades

Page | 2

DONCASTER LOCAL PLAN

PUBLICATION DRAFT CONSULTATION (AUGUST – SEPTEMBER 2019)

LAND AT PAPER MILL FIELDS, TICKHILL FOR PETER KELLY, GRAHAM

WHITE, PAUL PENNINGTON AND STEWART OADES

1.0 Introduction

1.1 This representation is prepared by Pegasus Group on behalf of Peter Kelly, Graham

White, Paul Pennington and Stewart Oades in relation to Land at Paper Mill Fields,

Tickhill. The representation considers the content within the Publication Draft of the

Doncaster Local Plan.

1.2 In compiling this representation Pegasus Group have applied the four elements of

soundness referred to in the National Planning Policy Framework, which are;

positively prepared, justified, effective and consistent with national policy.

1.3 This representation should be read in conjunction with the accompanying

representation produced by Pegasus Group to the draft policies and proposed site

informal consultation in September 2018. That document promotes the site and

illustrates why is should be allocated for residential development. The purpose of this

submission is to focus on the matters within the Publication Draft only, mainly the

overall requirement and distribution of housing.

2.0 Our Vision for the Future

2.1 Our client is supportive of the vision which has been informed by the ambitions of

the City Region, its Strategic Economic Plan as well the Northern Powerhouse.

2.4 The economic aspirations of the Borough must be matched by a clear commitment

to deliver the area’s future housing needs as a minimum. Objective 9 of the Local

Plan seeks to; “ensure housing provision meets the housing need and aspirations by

increasing the provision of new homes for all to meet current and future needs and

create mixed and balanced communities.”

2.5 Unfortunately, the proposed policies and strategy within the Local Plan do not meet

this challenge. This clearly has implications for the soundness of the plan.

3.0 Policy 2: Spatial Strategy and Settlement Hierarchy

3.1 This policy is considered unsound as it is not justified or effective.

3.2 The policy seeks to distribute the majority of new development to the most

sustainable locations, these being the Main Urban Area of Doncaster, the 7 Main

Towns and the 10 Service Towns and Villages. This general principal is considered

appropriate and is supported. It is, however, important that this is sustainable and

deliverable.

3.3 Tickhill is identified as in the ‘Service Towns and Villages’ category. The identification

of Tickhill within the Service Town and Village tier is supported. It is a high performing

settlement and provides many primary services. It is well served by a district centre

Page | 3

containing local services and amenities, two primary schools and health care

provision.

3.4 In terms of new homes the policy seeks to deliver at least 50% within the ‘Main

Urban Area’ of Doncaster and 40% within the 7 ‘Main Towns’ with just 10% allocated

to the ‘Service Towns and Villages’. The lack of housing allocated to Service Towns

and Villages is disproportionately low and takes no account of the sustainability,

deliverability, development opportunities or affordable housing need within these

settlements.

4.0 Policy 3: Level and Distribution of Growth

4.1 The policy is not sound as it is not positively prepared, justified, consistent with

national policy or effective.

4.2 Policy 3 of the Publication Draft of the Local Plan sets a target for at least 920 (net)

new homes each year over the plan period 2015-2035 (18,400 homes in total) with

sufficient land allocated to deliver the housing requirement.

4.3 The proposed level of housing growth remains unchanged since the draft policies

consultation in 2018. Therefore, Pegasus continue to question whether this approach

to meeting the needs for new homes demonstrates that the Plan is positively

prepared and justified. 4.4 The PPG states the Government will be supportive of

authorities who wish to plan for growth. In addition, the PPG identifies other factors

which need to be considered when determining the housing requirement. These

include growth strategies, planned infrastructure, previous levels of delivery and

recent assessments of need such as Strategic Housing Market Assessments (SHMA)

where this suggests a higher need (PPG ID 2a-010). These are all important

considerations in the context of Doncaster. It is not considered that the housing

requirement within Doncaster adequately meets the economic aspirations of the area.

4.4 It should also be noted that between 2004/5 and 2017/18 housing delivery averaged

in excess of 1,000 net additional dwellings. Since the start of the plan period (2015)

average delivery rates have been higher at 1,140 net additional dwellings. Setting

the housing requirement lower than average levels of delivery over the previous 14

years and 220dpa lower than the plan period average, would be contrary to the ethos

of the NPPF and the Government’s continued desire to boost significantly the supply

and delivery of housing.

5.0 Land at Paper Mill Fields, Tickhill (Ref. 824)

5.1 Policy 3 identifies that just 165 dwellings should be provided within Tickhill. Given

our comments upon the housing requirement and distribution, above, this is not

considered a sound approach. This is further compounded by the Local Plan

identifying just one allocation for 74 dwellings. The Local Plan identifies that;

“The remainder of the settlement’s housing requirement of 165 new

dwellings (91 units) has therefore been made good through allocated supply

at the Doncaster Main Urban Area and some of the Main Towns in line with

Policy 3, which adds any unmet local housing need from settlements to the

economic-led housing growth uplift” (para. 16.237)

Page | 4

5.2 There is a clear need for development within Tickhill the Council’s approach to simply

redistributing this need to the Main Urban Area is not considered appropriate.

5.3 Whilst we do not object to the inclusion of the allocation in Tickhill (Site Ref: 1028,

Sunderland Street / Sunderland Farm Close, Tickhill) we do question whether it will

deliver the 74 dwellings envisaged. Our concerns arise from the proximity of the site

to the A1(M). As noted in the Local Plan site assessment (page 302) this will inevitably

require significant noise attenuation measures, we also suggest consideration of air

quality could be a factor. Given these issues the developable area is likely to be

reduced and hence the quantum of new dwellings will be affected.

5.4 Our previous representation was accompanied by a Site Promotion document which

explains why Paper Mill Fields (Site 824) represents a suitable location for new homes

in accordance with the strategic draft policy targeting growth to the settlement of

Tickhill. It also illustrates how development could be achieved on the site in a well-

designed manner, responding to site conditions and local characteristics, including

heritage setting considerations.

5.5 The Green Belt assessment identifies that exceptional circumstances for the release

of Green Belt are justified across Doncaster. Given the lack of housing proposed in

Tickhill and the lack of suitable alternatives we are strongly of the opinion that Land

at Paper Mill Fields should be allocated to meet the housing needs of Tickhill.

Page | 5

APPENDIX 1: INFORMAL CONSULTATION: DRAFT POLICIES &

PROPOSED SITES (SEPT 2018)

OCT 2018 | NB | P18-2216.002B

DONCASTER LOCAL PLAN INFORMAL CONSULTATION: DRAFT POLICIES & PROPOSED SITES (SEPT 2018)

REPRESENTATION FOR BANKS PROPERTY

Paper Mill Fields, Tickhill

Pegasus Group

Pavilion Court | Green Lane | Garforth | Leeds | LS25 2AF

T | W www.pegasuspg.co.uk


© Copyright Pegasus Planning Group Limited. The contents of this document must not be copied or reproduced in whole or in

part without the written consent of Pegasus Planning Group Limited.

Banks Doncaster Local Plan Representation - Tickhill

Oct 2018 | P18-2216.002B 1

EXECUTIVE SUMMARY

This representation is prepared by Pegasus Group on behalf of Banks Property in response

to the ‘Informal Consultation’ on the Draft Policies and Proposed Sites for the Doncaster

Local Plan.

The representation concerns land at Paper Mill Fields, Tickhill (LPA site ref. 824).

Within the Service Towns and Villages tier, Tickhill is a high performing settlement and

provides a large number of primary services. Tickhill is considered to be a sustainable

settlement suitable for new growth in the Borough, however the draft Local Plan does not

identify any new housing allocations. We strongly oppose the Council’s position that

sustainable and deliverable sites do not exist in Tickhill. The Council’s reasons for not

addressing local need at Tickhill in the draft Local Plan are not considered to be sound.

This representation is accompanied by a Site Promotion document which explains why

Paper Mills Field represents a suitable location for new homes in accordance with the

strategic draft policy targeting growth to the settlement of Tickhill. It also illustrates how

development could be achieved on the site in a well-designed manner, responding to site

conditions and local characteristics, including heritage setting considerations. This site

should not be ruled out for exclusion from the Green Belt and allocation for residential

development and is suitable for further consideration through the site selection process.

In order to be considered positively prepared and thus sound, the Plan must demonstrate

that housing need is being met as a minimum not a limit. The Plan must be aspirational

but deliverable to be positively prepared (NPPF, paragraph 16). The Local Plan target of

920 (net) new homes per annum is insufficient to realise job-led housing need in the

Borough. In order to be found sound, the Local Plan should be targeting higher growth.


Oct 2018 | P18-2216.002B 2

1. INTRODUCTION

1.1 This representation is prepared by Pegasus Group on behalf of Banks Property in

response to the ‘Informal Consultation’ on the Draft Policies and Proposed Sites for

the Doncaster Local Plan.

1.2 The comments in this representation relate to the Draft Policies, and in particular

meeting the need for new homes in Tickhill. A Housing Need Evidence Appraisal is

appended at Appendix A. This representation also considers the approach to growth

for Tickhill and the Proposed Sites at this location. This representation should be

read in conjunction with the accompanying Site Promotion Document prepared by

Banks Property (LPA Local Plan site ref. 824).

1.3 The representation considers the questions of soundness referred to in the National

Planning Policy Framework, which are; positively prepared, justified, effective and

consistent with national policy, and in respect of the relevant legal tests.

The Site (LPA Local Plan site ref. 824)

1.4 The site being promoted on behalf of Banks Group is approximately 8.5ha of land

immediately south of residential development on Lancaster Drive and Meadow

Drive, on the southern edge of the settlement of Tickhill.

Figure 1: Site Location Plan


Oct 2018 | P18-2216.002B 3

2. STATUTORY CONTEXT: SOUNDNESS AND THE LEGAL TESTS

2.1 The Doncaster Local Plan has been issued at informal draft stage for public

comment prior to being issued in Publication Draft.

2.2 Section 19(2) of the Planning & Compulsory Purchase Act 2004 provides that:

“(2) In preparing a development plan document or any other local development

document the local planning authority must have regard to –

(a) National policies and advice contained in guidance issued by the Secretary of

State….”

Section 20(5) then states:

“The purpose of an independent examination us to determine in respect of the

development plan document-

(a) Whether it satisfies the requirements of sections 19 and 24(1), regulations

under section 17(7) and any regulations under section 36 relating to the

preparation of development plan documents;

(b) Whether it is sound; and

(c) Whether the local planning authority complied with any duty imposed on the

authority by section 33 A in relation to its preparation”.

2.3 The NPPF outlines the Government’s policy in respect of plan making. The

transitional arrangements in the NPPF (2018) apply, and for Doncaster Local Plan

mean that the policies in the newly adopted Framework are applicable. NPPF

paragraph 35 provides the considerations which should be taken into account in

the process of examination of an emerging development plan. This states:

Plans are “sound” if they are:

• Positively prepared – the plan should be prepared based on a strategy

which, as a minimum, seeks to meet the area’s objectively assessed needs,

and is informed by agreements with other authorities, so that unmet needs

from neighbouring areas is accommodated where it is practical to do so and

consistent with achieving sustainable development;

• Justified – an appropriate strategy, taking into account the reasonable

alternatives, and based on proportionate evidence;


Oct 2018 | P18-2216.002B 4

• Effective – deliverable over the plan period, and based on effective joint

working on cross-boundary strategic matters that have been dealt with

rather than deferred, as evidenced by the statement of common ground;

and

• Consistent with national policy – enabling the delivery of sustainable

development in accordance with the policies in the Framework.

2.4 Regulation 8 (2) of the Town and Country Planning (Local Planning) Regulations

2012 require that “a local Plan or Supplementary Planning Document must contain

reasoned justification of the policies contained within it”.

2.5 Regulation 8 (4) of the Town and Country Planning (Local Planning) Regulations

2012 continues that the policies contained within a local plan must be consistent

with the adopted development plan.


Oct 2018 | P18-2216.002B 5

3 LOCAL PLAN VISION & OBJECTIVES

3.1 The vision for Doncaster in the draft Local Plan identifies that the Borough has

ambitious plans for the future.

3.2 The high-level vision set out in the draft Local Plan is welcomed, which aims for

Doncaster to be "a thriving place to learn, work, live and care” and support the

three objectives of the Local Plan, for Doncaster to have:

• A strong economy supporting progressive, healthy, safe and vibrant

communities.

• Full potential in employment, education and care.

• Prosperity and pride in Doncaster.

3.3 It should be the case that the Council set objectives for the Plan that provide a

positive framework for the future of the Borough; in a way that is aspirational but

deliverable. The economic aspirations of the Borough are clear in their intent to

expand existing and attract new business; become an important economic hub, a

University City and a leading centre in logistics, aviation, rail and civil engineering.

It is important that the economic aspirations of the Borough are matched by

ambition to meet and exceed, rather than just meet, the area’s housing needs

(Objective 9). Consideration of the synergies of housing and employment growth

are discussed further in Chapter 4.


Oct 2018 | P18-2216.002B 6

4. LOCAL PLAN DRAFT POLICIES & PROPOSED SITES

4.1 This chapter discusses the Draft Policies of the Local Plan relating to delivery of a

sufficient supply of homes, and also the Site Selection Results in relation to the

settlement of Tickhill.

Strategic Approach – Meeting the Need for New Homes

4.2 Policy 3 of the draft Local Plan sets a target for at least 920 (net) new homes each

year over the plan period 2015-2032 (15,640 homes in total) with sufficient land

allocated to deliver at least 15 years’ supply. We would question whether this

approach to meeting the need for new homes demonstrates that the Plan is

positively prepared and justified for the following reasons:

a) The Borough has a clear economic growth agenda – this is evident in the draft

Local Plan’s Vision and Objectives.

Doncaster forms a key part of Sheffield City Region and target metrics produced

independently for SCR LEP1 identify the need for jobs growth of 1.0% p.a. if the

City Region is to improve its performance relative to the UK. Given that

Doncaster has seen employment increase either at or above the levels

experienced by SCR since 1998, and in line with its positive growth aspirations,

it does not seem unreasonable to expect the Borough to align with the City

Region target and for jobs growth in the District to average 1.0% in the long-

term. The Local Plan Evidence Base study ‘Economic Forecasts and Housing

Needs Assessment. Peter Brett Associates, June 2018’ models job-lead housing

need at a 1,073 dpa target.

Long-term economic aspirations should be properly planned for within this land

use plan, to facilitate these aspirations becoming a reality. The impact of this

would be to increase housing requirements from the current OAN of 920dpa to

1,073dpa – an additional 153 homes per annum.

Further consideration of this matter is provided in the accompanying Housing

Need Evidence Appraisal at Appendix 3 of this representation.

1 Source: Target Metrics Sheffield City Region: Metro Dynamics, June 2017


Oct 2018 | P18-2216.002B 7

b) Affordability ratios in Doncaster have changed little over the past decade (5.21

– Source: 2017 Affordability Ratio Data), suggesting that the housing ladder

remains out of reach for a substantial part of the local population. Build rates

will therefore need to be high in the long-term to address this issue.



c) Housing completion data for the Borough for the five year period between 2004

and 2009 and for 2015-16 and 2016/17 shows that it is capable of delivering in

excess of 1,000 units per annum. The last local policy document to allocate land

for housing was the Unitary Development Plan in 1998 with the Core Strategy

in 2012 setting a housing target and spatial distribution without allocating

specific sites. The housing completions data demonstrates that despite not

releasing new land for residential development through the local plan process,

that outwith recession years, completions since 2004 are significantly higher

than the current OAN. Therefore, with the release of new housing land for the

first time in 20 years, forecasted completions would be even higher than historic

levels achieved and well in excess in 1,000 units per annum.

d) The Office for National Statistics has confirmed that they will be producing

variant projections, which are due to be published in early December 2018.

These variant projections will include higher formation rates for younger adults

(those aged 25 to 44 years), as evidence suggests that such households were

unable to form as freely as previous generations (due to high house prices, less

access to finance etc.). An increase in housing numbers in Doncaster will help

ensure that supply is able to meet demand – especially from younger adult who

move into the area.



4.3 The Plan should provide a sufficient range of allocated land to provide enough active

sites to allow delivery to be maintained at the required levels throughout the Plan

period. The draft Plan does not presently account for such a supply buffer that


Oct 2018 | P18-2216.002B 8

would deal with under-delivery from sites and provide sufficient flexibility for

unforeseen circumstances.

4.4 In order to be considered positively prepared and thus sound, the Plan must

demonstrate that housing need is being met as a minimum not a limit. The Plan

must be aspirational but deliverable to be positively prepared (NPPF, paragraph

16). The Local Plan target of 920 (net) new homes per annum is insufficient to

realise job-led housing need in the Borough. In order to be found sound, the Local

Plan should be targeting higher growth.

Hierarchy for Future Growth – Growth for Tickhill

Tickhill: Sustainable Location for Growth

4.5 The draft Local Plan at Policy 2 establishes a network and hierarchy of settlements

within the Borough. Setting out an overall strategy for the pattern of housing,

employment, retail and other commercial development within a Plan area is

considered to be a sound approach in accordance with paragraph 20 of the NPPF.

4.6 Policy 2 identifies Tickhill as a Service Town / Village. The policy defines such

settlements as having a good range of services meeting their own needs and the

local area.

4.7 Within the Service Towns and Villages tier, Tickhill is a high performing settlement

and provides a large number of primary services. It is well served by a district

centre containing local services and amenities, two primary schools and health care

provision.

4.8 Tickhill is considered to be a sustainable settlement suitable for new growth in the

Borough.

Tickhill: Level of Growth

4.9 Draft Local Plan Policy 2 specifies that “to maintain and enhance their role as service

towns and larger villages which provide housing, employment, retail, and key

services and facilities for the local area, these settlements will be a focus for


Oct 2018 | P18-2216.002B 9

accommodating an appropriate level of growth with priority given to renewing and

regenerating run-down neighbourhoods”.

4.10 The target for new homes in Tickhill is 165 units over the Plan period.

4.11 Earlier in this representation we provided commentary on the strategic approach

to meeting housing need at Borough-level. Economic evidence justifies a higher

housing requirement for Doncaster and the Borough should be positively preparing

its Plan to achieve this. In a scenario where the housing requirement were to

increase, such growth should be focussed in accordance with the Borough’s

strategic policies, appropriate to the size of individual settlements.

4.12 The Site Selection results for Tickhill identify that the residual housing target for

the settlement is at least 154 new units. This assumes an identified supply from

completion on small sites and existing permissions of 5+ units of 11 units (as of

April 2017). The Council consider these units to be specific, deliverable supply for

years one to five of the plan period.

4.13 When using residual housing targets based on identified sites within Plans, it is

necessary to ensure that these sites are deliverable by the terms of new definition

in the revised NPPF (NPPF Glossary, page 66). Where such sites are not capable of

being defined as deliverable they cannot be justified in the draft Local Plan as

forming current supply. We reserve the right to comment further on this point in

subsequent consultation on the Local Plan.

4.14 The Proposed Housing Site Allocation outcome for Tickhill is that there are no

suitable sites for growth. It has rejected 1,012 units on 11 sites because:

“it is not considered that the need to identify housing targets for local need at the

Service Towns/Villages justifies the use of such important Green Belt sites. In line

with previous consultation on the Local Plan (Homes & Settlements March 2016)

where insufficient sustainable and deliverable sites are identified through the site

selection process, the settlement’s undersupply is proposed to be made good

through adding to the economic-growth led allocation and found either at the Main

Urban Area or 7 Main Towns. At Tickhill’s case therefore, a further 154 dwellings

will need to be allocated elsewhere. However, it is acknowledged that subsequent

stages of the Local Plan process, in particular preferred sites consultation, will


Oct 2018 | P18-2216.002B 10

provide a further opportunity for site promoters to submit further site

representations that may provide solutions to the identified constraints, in

particular further consideration of defensible Green Belt boundaries or technical

access to site solutions, so this could change”.

4.15 We strongly oppose the position that sustainable and deliverable sites do not exist

in Tickhill. Further discussion of Green Belt Exceptional Circumstances and the

Green Belt Review of sites at Tickhill is provided in the following paragraphs. The

main access into the site off Lancaster Drive is established and is adopted highway

meeting all the required highways standards. Paper Mill Fields does not have any

access issues and the landscape assessment and indicative masterplan

demonstrate how clear defined long term Green Belt boundaries could be formed

on the west, east and southern boundaries. The current Green Belt boundary in

south east Tickhill follows rear garden fences and the allocation of Paper Mill Fields

has the ability to provide a much stronger and clearly defined long term Green Belt

boundary.

Green Belt

Exceptional Circumstances for Green Belt Review

4.16 The Local Plan Evidence Base ‘Green Belt Phase 3 Report Summary’ identifies that

there are known constraints on the supply of land at those settlements which form

strategic settlements in the draft Local Plan Policy 2 – a Strategic Policy. In doing

so, and in respect of NPPF paragraph 137, the Authority confirm that exceptional

circumstances exist to justify changes to Green Belt boundaries in this Local Plan,

and this approach is being taken at Service Town / Village in the Borough. However,

at the Service Town / Village of Tickhill, no Housing Sites are identified to meet the

settlement’s strategy need. This is not consistent with the development plan’s

strategy for meeting identified requirements for sustainable development through

re-defining its Green Belt boundary elsewhere in the Plan, contrary to NPPF

paragraph 139.

4.17 This lack of clarity and consistency is confirmed in the Proposed Housing Site

Allocation Summary which states that it will not necessarily be the case that sites

in Tickhill will continue to be unsuitable for Green Belt release, depending on the


Oct 2018 | P18-2216.002B 11

representations received during consultation. The reasons for not addressing local

need at Tickhill in the draft Local Plan are not considered to be sound.

4.18 It is necessary and justified to review the Green Belt boundary at the settlement

of Tickhill.

4.19 The Green Belt Phase 3 Report Summary notes that “just because a site has a

strong or moderately strong case for furthering the site through the site selection

process, does not mean its release from the Green Belt is justified, nor are sites

necessarily ruled out because they have a weak or moderately weak case” (para,

1.17). In this case, all sites have been ruled out because they have a Weak or

Moderately Weak case.

4.20 We reserve the right to comment further on this matter in subsequent stages of

the Plan’s preparation.

Tickhill: Green Belt Review

4.21 The Local Plan Evidence Base ‘Green Belt Phase 3 Report Summary’ confirms the

methodology for the assessments of Sites through the Green Belt Review. Each site

has been assessed in two ways: for the strength of the boundary, and against the

site’s contribution to the five purposes of the Green Belt (NPPF, para 134). The site

is then given an overall score through a ‘Strength of Case’ Matrix on the “strength

of case for continuing in the site selection process”. This could be strong,

moderately strong, moderate, moderately weak or weak case.

4.22 The site forming Site 824 – Land behind Lumley Drive – has been assessed as

having a Weak Case for inclusion in further site selection work.

4.23 The Green Belt Review (Stage 3) for Site 824 states that “the Proposed Green Belt

boundary is defined by a number of agricultural buildings in the north west; a

weakly defined field boundary in the west which is only delineated by occasional

low-lying scrubby hedges; the paper Mill Dike in the south which is lined with trees

to the south west and which is a less-defined shallow drainage ditch in the central

eastern section; and the boundary to the east is defined by a weakly defined field

boundary. The Proposed Green Belt boundaries are therefore considered to be


Oct 2018 | P18-2216.002B 12

mixed in strength: stronger to the south, but predominately west to the west, south

east and east.”

4.24 In respect of the purposes of the Green Belt, The Green Belt Review (Stage 3),

states that Site 824 strongly performs against local interpretation of the Green Belt

purposes: it performs weakly against the extent to which the Green Belt checks

unrestricted sprawl; weakly against the extent to which the Green Belt assists in

supporting regeneration; contains features that display a strong rural character;

and falls within a “largely essential” gap where the overall scale and openness of

the gap is important to maintaining separation; has a strong role in preserving the

setting and special character of the historic town.

4.25 The development of this parcel of land would not result in any substantive or

appreciable reduction in the separation between Tickhill and Harworth to the south

east. A well-designed scheme would allow for the creation of a new permanent and

defensible Green Belt boundary formed by an existing and enhanced vegetated

buffer at the boundary of the site. The Site Promotion document that accompanies

this representation provides a review of the site and a framework for development.

This includes woodland belt planting and green infrastructure to strengthen the

Green Belt boundary.

4.26 It is our position that this site should not be ruled out and is suitable for further

consideration through the site selection process.

Paper Mill Field, Tickhill (Site 824): Development Opportunity

4.27 This representation is accompanied by a Site Promotion document which explains

why Site 824 represents a suitable location for new homes in accordance with the

strategic draft policy targeting growth to the settlement of Tickhill. It also illustrates

how development could be achieved on the site in a well-designed manner,

responding to site conditions and local characteristics, including heritage setting

considerations.

4.28 The provision of new homes in this settlement will not only make an important

contribution to meeting the housing requirement for the Borough, as a minimum,


Oct 2018 | P18-2216.002B 13

but will also have local and Borough-wide economic benefits in terms of

construction impact and household expenditure once constructed.

4.29 We consider that Site 824 is a suitable site at Tickhill for housing growth to

contribute to the Borough’s growth and boost housing land supply. The site is

capable of delivering a range of type and tenure housing suitable for different

groups in the community with an indicative site capacity of 180 - 200 dwellings.

4.1 The indicative masterplan that has been prepared and included within the

promotional document is a considerate and sensitive response taking into account;

site visits, consideration of the local context and site opportunities and constraints.

The site represents a logical extension to the edge of the existing settlement, is

well contained, provides new public open space focused around existing footpath

links and also forming an appropriate offset from Tickhill Castle. The masterplan

also demonstrates how clear defined long term Green Belt boundaries would be

formed.

Figure 2: Indicative Masterplan (see Site Promotion Document)

4.2 We confirm that Site 824 is available now, that the promotion of the site is

supported by willing landowners, and that development on the site could be

delivered in a timely manner to contribute to the Borough’s supply.


Oct 2018 | P18-2216.002B 14

4.3 We reserve the right to comment further on proposed sites in Tickhill in subsequent

consultations on the draft Plan.


Oct 2018 | P18-2216.002B 15

APPENDIX A

HOUSING NEED EVIDENCE APPRAISAL

Pegasus Group Suite 4b | 113 Portland Street | Manchester | M1 6DW

T | W www.pegasusgroup.co.uk


© Copyright Pegasus Planning Group Limited. The contents of this document must not be copied or reproduced in whole or

in part without the written consent of Pegasus Planning Group Limited.

DONCASTER LOCAL PLAN INFORMAL CONSULTATION: DRAFT POLICIES & PROPOSED SITES (SEPT 2018) REPRESENTATION APPENDIX: HOUSING NEED EVIDENCE APPRAISAL

Date: October 2018

CONTENTS 1. INTRODUCTION .................................................................................. i 2. EXISTING EVDIENCE ON HOUSING NEED IN DONCASTER .................. ii 3. NEW DEMOGRAPHIC AND HOUSING MARKET INDICATOR DATA ........ v 4. EMPLOYMENT TRENDS IN DONCASTER ............................................xiii 5. ECONOMIC GROWTH ASSUMPTIONS ............................................... xvii 6. CONCLUSIONS.................................................................................. xix

Pegasus Group Representations Doncaster’s Local Plan – Consultation Draft

Page | i

1. INTRODUCTION

1.1 This report considers demographic and economic factors relevant to responding to the

Consultation Draft of the Doncaster Local Plan. It focuses on the evidence behind the

housing growth targets and economic growth rates in the Local Plan. This report has been

prepared on behalf of a number of Pegasus Group clients.

1.2 The comments within this report serve to highlight a number of aspects of the Local Plan

and its supporting evidence base that require revision or additional analysis to be

considered suitably robust.

1.3 From the outset, it should be noted that the high-level vison set out in the ‘Local Plan –

Vision and Objectives’ consultation document is welcomed, which aims for Doncaster to

be "a thriving place to learn, work, live and care” and support the three objectives of the

Local Plan, which are for Doncaster to have:

• A strong economy supporting progressive, healthy, safe and vibrant communities.

• Full potential in employment, education and care.

• Prosperity and pride.

1.4 This report is structured as follows:

• Section 2 provides a review of existing evidence on housing need in Doncaster.

• Section 3 analyses the most recent data on demographic trends and housing

market indicators, both of which impact on the requirement for new homes.

• Section 4 reviews past employment trends in Doncaster, along with selected

benchmark areas.

• Section 5 provides views on future economic growth in Doncaster and the extent

to which the Consultation Draft of the Local Plan fully reflects the growth potential

of the District.

• Section 6 presents overall conclusions from the analysis.


Page | ii

2. EXISTING EVDIENCE ON HOUSING NEED IN DONCASTER

Adopted Core Strategy

2.1 The Core Strategy for Doncaster, adopted in May 2012, set out a requirement for 1,230

dwellings per annum over a 15-year period up to 2028. This dwelling requirement was taken

from the subsequently revoked Yorkshire and Humber Regional Strategy.

Emerging Local Plan

2.2 The Consultation Draft of the Local Plan identifies a need for 920 dwellings per annum in

Doncaster up to 2032. This figure is based on analysis undertaken by the Council in

August 20151. More recent analysis of housing requirements in the District was produced

on behalf of the LPA by Peter Brett Associates in June 20182, and this forms part of the

evidence base for the Local Pan consultation. It is therefore helpful to consider what PBA’s

work says regarding future housing need in Doncaster.

2.3 In summary, PBA identifies three housing need requirements, with a range of 562-1,073

homes per annum:

• Demographic starting point, from the 2014-based official household projections:

562 net new dwellings per annum (dpa)

• Adjusted need, to match business-as-usual job forecast: 579 dpa

• Job-led housing need, to match the job growth aspiration of Sheffield City Region:

1,073 dpa.

2.4 The third figure, relating to job-led housing need, is particularly interesting because it

looks at how many homes will be needed in Doncaster if it is to help support the wider

Sheffield City Region (SCR) achieve its long-term economic growth aspirations. PBA

reference work undertaken by Metro Dynamics, which provides a series of metrics for the

City Region as a whole up to 2040. One of these metrics is for the area to see 1.0% jobs

growth per annum over the next 20+ year. Modelling this for Doncaster leads to the

1,073 dpa target. However, PBA argue that this is extremely ambitious and suggest using

a figure that is halfway between the lowest of the three requirement estimates (562 dpa)

and the highest (1,073). This would lead to an annual need for around 820 new homes

per annum and while this is closer to the OAN of 920, it is still significantly below the job-

1 Housing Need Assessment 2015 – Doncaster. Doncaster MBC, August 2015. 2 Economic Forecasts and Housing Needs Assessment. Peter Brett Associates, June 2018.


Page | iii

led estimate of 1,073 and indeed the higher dwelling figures endorsed by the five-year

housing land supply Inspector, although as identified above this is subject to challenge.

‘Planning for the Right Homes in the Right Places’

2.5 This consultation document was published in September 2017 on the back of

commitments set out within the White Paper ‘Fixing our Broken Housing Market’, which

included proposals to tackle the housing challenge, specifically to build more houses of

the type people want to live in, in the places they want to live in. The consultation paper

considered that the previous system for determining dwelling requirements was too

complex and that it led to a costly and time-consuming process that lacked transparency.

In response to this a standard approach was identified, based on three key principles, to

be simple, based on publicly available data and realistic.

2.6 The approach taken, as part of the original Standard Methodology, is essentially a top

down method to achieving a total number of homes nationally per annum. The targeted

figure was initially 266,000 homes per annum, which was an average of three different

sources of evidence. More recently, however, a higher figure of 300,000 homes per

annum has been targeted by the Government. As referred to later in this report,

however, the total number of homes achieved by the Standard Methodology using the

most recent household projections is significantly short of 266,000 and 300,000 and

closer to 215,000 homes per annum.

2.7 The methodology, in essence, takes the latest household projections (the average

between the first ten year period from the current year (now 2018 to 2028, although the

original methodology was based on a timeframe of 2016 and 2026)) as a starting point

or Local Plan requirement (if it was adopted within the last five years) and on top of that

applies an uplift based on affordability, which is an arbitrary calculation to generate

figures that are capped at 40% of the household projections or the Local Plan figure

(depending on its status and age).

2.8 More recently, the Revised NPPF has been published following a consultation exercise,

which provides the policy framework that the Standard Methodology fits within. The

Methodology has remained unchanged, except for clarity over the starting point etc. In

light of this, it is pertinent to consider the implications arising from the Standard

Methodology for Doncaster. Taking into account the above, when it was published in


Page | iv

September 2017, the assessment of housing need in the Borough was 585 dwellings per

annum.

Summary

2.9 When comparing the chronology of figures presented above, the dwelling requirements

for Doncaster have varied significantly, going from 1,230 in the adopted Local Plan and

Yorkshire and Humber RS, to 562 to 1,073 as set out in the PBA report and 585 in the

September 2017 Standard Methodology. The Consultation Draft Local Plan goes with a

different figure, with an OAN of 920dpa. It is interesting to note that the figures in excess

of 1,000 are predicated on achieving economic growth aspirations and others merely seek

to provide for growth projected from short-term demographic projections, which, as set

out in the next section, can be volatile. As further evidenced in Section 5, it is advised

that economic aspirations are properly planned for within a land use plan, to facilitate the

aspiration becoming a reality.


Page | v

3. NEW DEMOGRAPHIC AND HOUSING MARKET INDICATOR DATA

3.1 More recently, the 2016-based Subnational Household Projections have been published

as well as the 2017 affordability ratio data, both of which are considered in further detail

below – dealing with the latter first.

2017 Affordability Ratio Data

3.2 The more recent affordability ratio3 for Doncaster is 5.21, which is 0.14 higher than the

previous ratio and demonstrates that affordability in the Borough has worsened slightly.

In 2007 the ratio was 5.17, indicating that house prices in Doncaster over the last decade

have remained around five times the median local salary.

3.3 When comparing the affordability ratio data with other authorities in Yorkshire and the

Humber, Doncaster is one of the more affordable boroughs to live in the region. Harrogate

(10.36) and Hambleton (9.52) are the least affordable places. The average ratio for the

entire region is 5.90, which is closer to the figure for Doncaster. However, the fact that

the ratio in Doncaster has remained broadly the same over the last ten years means that

affordability still remains an issue for the area. Going back further, the affordability ratio

in the Borough has not been below 4 since 2003.

3.4 When comparing Yorkshire and the Humber to other regions, the most affordable region

to live is the North East, with an affordability ratio of 5.21. Unsurprisingly, London is the

least affordable and has a ratio of 12.36. Similar to Doncaster, Yorkshire and the

Humber’s ratio has stayed broadly the same over the last decade, indicating that housing

in the region has not become more affordable. The average price of a home is therefore

likely to remain unaffordable for many, especially for local employees on average

incomes.

2016-based Subnational Household Projections

3.5 The 2016-based Subnational Household Projections were published in September 2018.

This data is a key part of the Standard Methodology. When comparing the level of

projected growth with the earlier data set (2014 Based Subnational Household

Projections), which was 548 dwellings per annum between the period of 2016 and 2026,

3 Consistent with the original Standard Methodology consultation in 2017, the work-place based median affordability ratio has been used.


Page | vi

the more recent projection suggests that growth will be marginally lower at 531 dwellings

per annum for the same period. When looking at the period of 2018 to 2028, which is

the most up to date period that the Standard Methodology should be calculated from (as

set out in accompanying guidance to the Revised NPPF), the households per annum figure

is 532.

3.6 It should be noted that household projections are based on short-term past trends of

natural change and net migration (five years for internal migration and six years for

international migration). Further, it is acknowledged that there are additional

methodological changes, which may have impacted the change to the number of

households. Relevant factors are considered further below.

2016-based Subnational Population Projections

3.7 In order to further understand the differences between the different household projection

time series, it is necessary to consider the population projections, which are a key

component. Tables 3.1 and 3.2 show the population change in each of in the 2016 and

2014-based Subnational Household Projections respectively. Whilst the more recent

projections show a slower rate of household formation, the population projections show

the reverse. There is projected to be higher population growth in Doncaster, which is

contrary to what is happening in many other parts of the country. The slightly higher

rate of growth is projected in the more recent projections compared to the earlier data

set is quantified between 2016 and 2026, as a difference of around 900 people and,

between 2018 and 2028, as a difference of around 400 more people.

Table 3.1: 2016-based Subnational Population Projections by Five Year Age Group in Doncaster Age group 2016 2018 2026 2028 2016-26 2018-28 Age 0 - 4 18,667 18,040 16,709 16,501 -1,958 -1,539 Aged 5-9 19,549 19,672 17,844 17,623 -1,705 -2,049 Aged 10-14 17,199 18,421 19,268 18,656 2,069 235 Aged 15-19 16,767 15,851 18,696 18,789 1,929 2,938 Aged 20-24 17,341 16,595 14,785 15,718 -2,556 -877 Aged 25-29 20,915 20,590 17,264 16,492 -3,651 -4,098 Aged 30-34 20,577 20,920 19,910 19,177 -667 -1,743 Aged 35-39 18,233 19,668 21,407 21,258 3,174 1,590 Aged 40-44 18,653 17,364 20,505 20,843 1,852 3,479 Aged 45-49 21,524 20,781 18,110 19,416 -3,414 -1,365 Aged 50-54 22,431 22,159 18,521 17,247 -3,910 -4,912 Aged 55-59 20,549 21,249 21,223 20,504 674 -745 Aged 60-64 17,875 18,727 21,555 21,381 3,680 2,654 Aged 65-69 17,910 16,920 19,137 19,863 1,227 2,943 Aged 70-74 13,660 15,745 15,827 16,628 2,167 883 Aged 75-79 10,558 10,640 14,449 13,753 3,891 3,113


Page | vii

Aged 80-84 7,963 8,154 9,566 11,172 1,603 3,018 Aged 85-89 4,561 4,735 5,448 5,607 887 872 Aged 90+ 2,442 2,444 2,951 3,164 509 720 All Ages 307,374 308,675 313,175 313,792 5,801 5,117

Source: ONS

Table 3.2: 2014-based Subnational Population Projections by Five Year Age Group in Doncaster Age group 2016 2018 2026 2028 2016-26 2018-28 Age 0 - 4 18,400 17,800 17,100 16,900 -1,300 -900 Aged 5-9 19,400 19,400 17,800 17,700 -1,600 -1,700 Aged 10-14 17,100 18,100 18,500 18,000 1,400 -100 Aged 15-19 16,600 15,800 18,300 18,300 1,700 2,500 Aged 20-24 17,500 16,600 15,000 15,900 -2,500 -700 Aged 25-29 20,400 20,300 17,400 16,700 -3,000 -3,600 Aged 30-34 20,200 20,400 19,700 19,000 -500 -1,400 Aged 35-39 18,000 19,300 20,500 20,600 2,500 1,300 Aged 40-44 18,500 17,200 19,800 20,000 1,300 2,800 Aged 45-49 21,400 20,600 17,700 18,800 -3,700 -1,800 Aged 50-54 22,300 22,000 18,200 16,900 -4,100 -5,100 Aged 55-59 20,400 20,900 20,800 20,000 400 -900 Aged 60-64 17,800 18,600 21,100 20,900 3,300 2,300 Aged 65-69 17,800 16,800 18,700 19,300 900 2,500 Aged 70-74 13,600 15,700 15,700 16,400 2,100 700 Aged 75-79 10,600 10,700 14,500 13,800 3,900 3,100 Aged 80-84 7,900 8,200 9,800 11,400 1,900 3,200 Aged 85-89 4,600 4,800 5,800 6,000 1,200 1,200 Aged 90+ 2,500 2,600 3,500 3,900 1,000 1,300 All Ages 305,000 305,800 309,900 310,500 4,900 4,700

Source: ONS

3.8 When reviewing the differences in population profile over a ten-year period, it is evident

that the younger population is projected to contract and, in particular, the older/

retirement population is projected to grow. Such circumstances show the opposite of a

balanced and sustainable community, which is further evidence to suggest that Doncaster

should be planning for economic growth to expand opportunities for a younger population

to reside in the area.

3.9 It is next appropriate to consider the projected components of change, to understand

where the differences are occurring (i.e. due to differences in natural change and/ or

migration).

3.10 When comparing the data, it can be seen that natural change in the 2016-based

projections is expected to be lower as a result of a slightly lower birth rate (as reflected

in the declining population of age 0-4 in Table 3.1) and higher death rate (as reflected in

the reduced levels of people aged 85+). The latter is a nationally recurring trend.


Page | viii

However, net migration in the 2016-based projections is expected to be higher and this

looks to be the main factor in leading to the higher growth between the two sets of

projections. This may be as a result of existing efforts to achieve aspirational levels of

economic growth. A higher level of internal migration would raise the importance of

ensuring that housing supply in Doncaster is able to meet the needs of new residents.

3.11 There remains concern, however, over the sustainability of the Borough in light of:

declining natural change to the point where it reaches a plateau in 2028, declining internal

migration whereby 300 residents are anticipated to move out of the Borough, however,

a strong influx of international migration which reduces from 800 per annum in 2016 to

500 per annum in 2028. As highlighted above in respect of the population age profile,

there is concern that Borough will have an unbalanced population, due to a declining

younger population. Again, the aspiration to boost the economic position of the Borough

may well attract and encourage more young people and families to reside in the area,

providing more sustainable communities going forward.

Table 3.3: 2016-based Subnational Population Projections Components of Change in Doncaster (Figures in 1,000s)

Component 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 Population 307.4 307.9 308.7 309.4 310.2 310.8 311.4 311.9 312.4 312.8 313.2 313.5 313.8 Natural Change 0.3 0.4 0.3 0.3 0.3 0.2 0.2 0.2 0.1 0.1 0.0 0.0

Births 3.4 3.5 3.4 3.4 3.4 3.3 3.3 3.3 3.3 3.2 3.2 3.2

Deaths 3.2 3.1 3.1 3.1 3.1 3.1 3.1 3.1 3.1 3.2 3.2 3.2 All Migration Net 0.3 0.3 0.4 0.4 0.4 0.4 0.3 0.3 0.3 0.3 0.3 0.3

Internal Migration In 7.6 7.6 7.6 7.6 7.6 7.6 7.6 7.6 7.6 7.6 7.6 7.6

Internal Migration Out 8.1 8.0 7.9 7.9 7.9 7.8 7.9 7.9 7.9 7.9 7.9 7.9

International Migration In 1.5 1.5 1.4 1.4 1.3 1.3 1.2 1.2 1.2 1.2 1.2 1.2

International Migration Out 0.7 0.7 0.7 0.7 0.7 0.7 0.7 0.7 0.7 0.7 0.7 0.7

Cross-border Migration In 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

Cross-border Migration Out 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

Source: ONS

Table 3.4: 2014-based Subnational Population Projections Components of Change in Doncaster (Figures in 1,000s)

Component 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 Population 304.9 305.4 305.9 306.4 307.0 307.5 308.1 308.6 309.0 309.4 309.8 310.1 310.4 Natural Change 0.6 0.6 0.6 0.6 0.6 0.5 0.5 0.5 0.4 0.4 0.4 0.3 0.3

Births 3.5 3.5 3.5 3.5 3.5 3.4 3.4 3.4 3.4 3.4 3.3 3.3 3.3

Deaths 2.9 2.9 2.9 2.9 2.9 2.9 2.9 2.9 2.9 3.0 3.0 3.0 3.0 All Migration Net -0.2 -0.1 -0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0


Page | ix

Component 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 Internal Migration In 7.3 7.4 7.4 7.4 7.4 7.4 7.4 7.4 7.4 7.4 7.4 7.5 7.5

Internal Migration Out 8.0 7.9 7.9 7.8 7.7 7.7 7.7 7.7 7.7 7.7 7.7 7.8 7.8

International Migration In 1.1 1.1 1.1 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

International Migration Out 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6

Cross-border Migration In 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

Cross-border Migration Out 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4

Source: ONS

3.12 As highlighted above, the projections are based on short-term trends (five years for

internal migration and six years for international migration), it is appropriate to consider

the components of change that informed the different time series of projections. Table

3.5 sets out the estimated components of change since 2002. The final two rows

(highlighted in bold) summarise the data that was used as an input to the projections.

3.13 Interestingly and consistent with the estimates for the periods leading up to the projection

starting year, births in the most recent data series (2016-based) are lower and deaths

are higher, which has resulted in reduced levels of natural change. In terms of migration,

past trends of internal net migration are slightly lower in the period up to 2016 (this is

generally consistent as net internal migration has remained static in both the 2016 and

2014-based population projections) and international net migration is higher in the more

recent period informing the 2016 based population projections, hence the greater

proportion of international migration in the 2016 based population projection.

3.14 In terms of looking at trends over the longer term, for internal migration it is evident that

in response to the recession there was a significant outflow of people, more so than

before. Most recently, however, the mid-2017 estimate shows positive internal net

migration, which could be a future direction of travel that would not be picked up by the

most recent projections. In terms of international net migration, this has fluctuated

greatly with two years of very high international net migration in 2015 and 2016,

however, since in 2017 it has reduced.

3.15 Given the variation and fluctuation in migration levels (the changes are less varied for

natural change and follow a more gradual pattern), it is clear that population projections

can change significantly based on recent past trends. LPAs should, therefore, be mindful

that projections are self-fulfilling (as further referred to below) and consider other

important factors such as affordability and the housing needs arising from economic

growth aspirations.


Page | x

Table 3.5: Mid-Year Estimates Components of Change

Pop Start Births Deaths

Natural Change

Internal Net

Interna-tional

Net Other

Change Pop End

Mid 2002 286,900 3,184 3,099 85 -89 733 1,018 288,647

Mid 2003 288,647 3,232 3,139 93 22 309 1,040 290,111

Mid 2004 290,111 3,378 3,139 239 -425 288 637 290,850

Mid 2005 290,850 3,452 3,142 310 -522 556 980 292,174

Mid 2006 292,174 3,556 2,972 584 -875 1,140 967 293,990

Mid 2007 293,990 3,654 3,075 579 -413 924 1,135 296,215

Mid 2008 296,215 3,787 3,043 744 -706 1,090 1,045 298,388

Mid 2009 298,388 3,824 2,899 925 -710 445 1,136 300,184

Mid 2010 300,184 3,759 2,944 815 -1,079 319 1,060 301,299

Mid 2011 301,299 3,846 2,821 1,025 -1,020 516 648 302,468

Mid 2012 302,468 3,793 3,002 791 -1,003 314 350 302,920

Mid 2013 302,920 3,691 3,088 603 -341 417 94 303,693

Mid 2014 303,693 3,642 2,950 692 -749 694 68 304,398

Mid 2015 304,398 3,570 3,149 421 -757 1,346 88 305,496

Mid 2016 305,496 3,538 3,128 410 -58 1,451 75 307,374

Mid 2017 307,374 3,470 3,105 365 131 897 173 308,940

2016 4,197 18,542 15,010 3,532 -3,870 3,606 1,248 4,906

2014 5,305 18,913 14,754 4,159 -4,153 3,101 3,288 4,214

Source: ONS

3.16 The next factor to consider is whether there is any correlation between dwelling

completions and population growth in Doncaster. Analysis published by the Council in

June 2017 shows that there were 1,049 net additional housing completions in the

Borough in 2016/174. Data published by the Ministry of Housing, Communities & Local

Government (MHCLG) provides net completions data going back to 2001/02 and Table

3.6 presents this information.

3.17 Looking at the rate of delivery across the period, fluctuations are evident. Net completions

for the two most recent periods of 2015/6 and 2016/17 are above 1,000, higher than the

current OAN of 920 dwellings per annum. Interestingly, this corresponds with the two

years of significant net international migration, which shows there is demand for housing

in the Borough. Prior to this, however, net completions were well below this figure

between 2009 and 2015, despite there being a Regional Strategy and subsequently a

Core Strategy dwelling requirement of 1,230. It is anticipated that this was not achieved

due to the impact of the recession, which has possibly resulted in more people leaving

the Borough (see internal migration figures) to find homes elsewhere.

4 Residential Land Availability Report 2016/17. Doncaster MBC, June 2017.


Page | xi

3.18 In 2001/02 and 2003/04, Doncaster actually experienced a reduction in dwelling stock

due to a number of demolitions/losses.

Table 3.6: Doncaster’s Net Housing Completions, 2001-175

Year Net Housing Completions6 2001-02 -335 2002-03 1,745 2003-04 -2,285 2004-05 1,426 2005-06 1,380 2006-07 1,285 2007-08 1,414 2008-09 1,709 2009-10 506 2010-11 817 2011-12 457 2012-13 316 2013-14 654 2014-15 792 2015-16 1,162 2016-17 1,049

Source: MHCLG Live Table 122 & Doncaster MBC

3.19 When examining the dwelling completions, it is clear that the economic downturn in

2009/09, has had an impact on housing delivery in the Borough with completions

significantly reducing. It is worthwhile noting, however, that whilst the dwelling

completions were reduced in this period, they remained at a reasonable level, which

shows resilience and continued market demand for homes. This is a further indicator

that there remains a strong need for homes, which should not be overlooked.

3.20 A further indicator of housing market pressure is whether there is a sufficient proportion

of vacant housing stock in the market to provide flexibility for renovations, transactions

etc. A rate of 3% has previously been identified as an appropriate level of vacancies to

maintain. The Government maintains a statistical data set of live tables recording such

data. The number of vacancies at October 2017 was 4,138, which represents 3.1% of

the total housing stock (135,250), meaning Doncaster is right on the threshold of what

is considered to be an appropriate level of vacant stock.

5 The 2011/12, 2012/13, 2013/14, 2014/15, 2015/16 and 2016/17 figures are provisional and subject to scheduled revisions pending the release of future census dwelling stock data. 6 Figures highlighted in red are imputed


Page | xii

Summary

3.21 Based on the data and commentary above, the low levels of housing delivery (possibly

as a consequence of the recession and other factors) in previous years has resulted in

increasing levels of negative net internal migration, which has then informed the

population and household projections. Such trends may not be desirable to repeat.

Indeed, as set out above in the analysis, there is concern that unsustainable and

unbalanced communities may result. Accordingly, it is important to consider other factors

such as affordability and economic aspirations (as explored in the following section),

when creating successful and sustainable communities.


Page | xiii

4. EMPLOYMENT TRENDS IN DONCASTER

4.1 When considering the extent to which the current OAN provides a realistic level of new

housing provision, it is helpful to look at past employment trends in Doncaster, as housing

need will be driven to a large extent by changes in the labour market. This section

analyses the latest jobs data published by the Office for National Statistics (ONS). It

focuses on Doncaster, along with the benchmark areas of Sheffield City Region (SCR)

Local Enterprise Partnership, Yorkshire & the Humber and Great Britain7. Sheffield City

Region LEP covers the following local authority areas: Barnsley; Doncaster; Rotherham;

Sheffield; Bassetlaw; Bolsover; Chesterfield; Derbyshire Dales; and North East

Derbyshire.

Employment Trends

Total Employment

4.2 ONS data allow for long-term analysis of past trends in employment going back to 1998.

As a result of changes to the methodology used in producing the data, it is not possible

to look at trends over a continuous period. The following timeframes have been analysed

to allow for this fact:

• 1998-2008: Jobs data published as part of the Annual Business Inquiry (ABI) by

ONS).

• 2009-2015: Jobs data published as part of the Business Register & Employment

Survey (BRES) by ONS, which replaced the ABI.

• 2015-2017: Jobs data published by ONS as part of the BRES.

4.3 Table 4.1 shows jobs in Doncaster between 1998 and 2008, along with the benchmark

areas. The main points to note are:

• Doncaster saw total employment increase by around 10,000 from 1998-2008,

equating to annual growth of 0.9%. This was in line with the level of growth seen

in SCR, Yorkshire & the Humber and Great Britain.

• In absolute terms, the 10,000 new jobs in Doncaster between 1998 and 2008 was

the third highest figure at a district level in SCR – behind only Sheffield (24,000)

and Rotherham (18,000). Employment decreased in three of the nine districts in

7 Sheffield City Region LEP covers the following local authority areas: Barnsley; Doncaster; Rotherham; Sheffield; Bassetlaw; Bolsover; Chesterfield; Derbyshire Dales; and North East Derbyshire


Page | xiv

SCR: Barnsley (which lost 3,000 jobs over the 10-year period at a rate of 0.4%

per annum); Bassetlaw (2,000 jobs – 0.5% per annum); and Chesterfield (2,000

jobs, 0.4% per annum).

Table 4.1: Jobs Change by District in Sheffield City Region, 1998-2008

Total Employment 1998 2008 Absolute Change

% Annual Change

Barnsley 72,000 69,000 -3,000 -0.4% Doncaster 106,000 116,000 10,000 0.9% Rotherham 81,000 99,000 18,000 2.0% Sheffield 224,000 248,000 24,000 1.0% Bassetlaw 45,000 43,000 -2,000 -0.5% Bolsover 17,000 26,000 9,000 4.3% Chesterfield 50,000 48,000 -2,000 -0.4% Derbyshire Dales 32,000 34,000 2,000 0.6% North East Derbyshire 26,000 26,000 - - Sheffield City Region 652,000 710,000 58,000 0.9% Yorkshire and The Humber 2,050,000 2,232,000 182,000 0.9%

Great Britain 24,355,000 26,677,000 2,322,000 0.9% Source: Annual Business Inquiry Note: Figures may not sum due to rounding

4.4 Table 4.2 shows the jobs change in Doncaster and the selected benchmark areas between

2009 and 2015. The main points to note are:

• Employment in Doncaster increased by approximately 7,000 between 2009 and

2015, representing annual growth of 1.0%. This was higher than SCR (0.5% per

annum) and Yorkshire & the Humber (0.4% p.a.) and in line with national growth.

• In absolute terms, the 7,000 new jobs in Doncaster between 2009 and 2015 in

SCR was the second highest figure at a district level – with only Bolsover (10,000)

ahead of it.


Page | xv



% Annual Change

Barnsley 75,000 78,000 3,000 0.7% Doncaster 117,000 124,000 7,000 1.0% Rotherham 100,000 102,000 2,000 0.3% Sheffield 254,000 255,000 1,000 0.1% Bassetlaw 48,000 50,000 2,000 0.7% Bolsover 26,000 36,000 10,000 5.6% Chesterfield 48,000 51,000 3,000 1.0% Derbyshire Dales 39,000 33,000 -6,000 -2.7% North East Derbyshire 29,000 29,000 - - Sheffield City Region 730,000 750,000 20,000 0.5% Yorkshire and The Humber 2,329,000 2,392,000 63,000 0.4%

Great Britain 27,858,000 29,548,000 1,690,000 1.0% Source: Business Register & Employment Survey Note: Figures may not sum due to rounding

4.5 Table 4.3 shows employment change in Doncaster between 2015 and 2017, again split

by district, alongside regional, national and LEP benchmarks. Employment in Doncaster

increased by 1,000 jobs from 2015-17, which is equivalent to 0.4% growth per annum.

This was in line with growth seen across SCR LEP, but below that of Yorkshire & the

Humber (1.0% p.a.) and Great Britain (1.3% p.a.).

4.6 At a district level in SCR LEP, Sheffield saw the largest absolute increase in jobs between

2015 and 2017, with employment increasing by 8,000 (1.5%). Rotherham, Bolsover and

North East Derbyshire all experienced job losses over the two-year period – of 2,000

(1.0%); 5,000 (7.2%); and 1,000 (1.7%) respectively.



% Annual Change

Barnsley 79,000 80,000 1,000 0.6% Doncaster 125,000 126,000 1,000 0.4% Rotherham 104,000 102,000 -2,000 -1.0% Sheffield 257,000 265,000 8,000 1.5% Bassetlaw 51,000 51,000 - - Bolsover 36,000 31,000 -5,000 -7.2% Chesterfield 51,000 51,000 - - Derbyshire Dales 33,000 36,000 3,000 4.4% North East Derbyshire 29,000 28,000 -1,000 -1.7%

Sheffield City Region 764,000 770,000 6,000 0.4%

Yorkshire and The Humber 2,415,000 2,463,000 255,000 1.0%

Great Britain 29,819,000 30,593,000 2,633,500 1.3% Source: Business Register & Employment Survey Note: Figures may not sum due to rounding


Page | xvi

Summary

4.7 Employment in Doncaster has been on a positive trajectory since 1998, with job numbers

increasing over each of the three timeframes discussed in this section. Growth over the

period 2009-15 was particularly strong and while it fell back between 2015 and 2017,

Doncaster has still seen employment increase either at or above the levels experienced

by Sheffield City Region since 1998. The next section looks at why this is such an

important finding.


Page | xvii

5. ECONOMIC GROWTH ASSUMPTIONS

5.1 As noted in section two, one of the main documents underpinning the Consultation Draft

of the Doncaster Local Plan is PBA’s June 2018 report8, which looks at housing and

economic development needs for the period up to 2032. The analysis includes forecasts

of employment and this section reviews the forecasts to assess the extent to which they

fully reflect the economic growth potential of Doncaster.

Employment Growth Scenarios

5.2 The Employment Forecasts and Housing Needs Assessment uses local economic forecasts

produced by Experian to analyse two scenarios for future growth in Doncaster:

Baseline ‘business-as-usual’ Scenario

5.3 This scenario was calculated using the standard (or baseline) forecast from Experian

(December 2017). The forecasting model takes account of the macroeconomic context,

the area’s mix of industries and services (industrial structure) and its past performance

compared to the UK and the region. It also takes account of future population change,

which it assumes will be as shown in the latest official projection, which at the time of

analysis was the 2014-based Sub-National Population Projections (SNPP 2014).

5.4 The baseline scenario forecasts jobs growth of 13,800 in Doncaster between 2015-2032

(from 134,000 to 147,800), equating to 812 additional jobs per annum – an annual

growth rate of 0.6%.

Planned Growth Scenario

5.5 This scenario takes into account emerging targets associated with the latest refresh of

the Sheffield City Region (SCR) Strategic Economic Plan (SEP). The emerging SCR targets

are the work of the consultancy Metro Dynamics and have been provided in a ‘Target

Metrics’ report9, which forecasts employment growth over the plan period in SCR of

132,600 (7,800 jobs per annum) – an annual jobs growth of 1.0%.

5.6 The Planned Growth Scenario applies the same 1.0% annual growth rate to Doncaster in

and forecasts growth in the Borough of 24,200 jobs between 2015 and 2032, which

equates to 1,424 jobs per annum. The impact of this higher level of growth is that

housing requirements in Doncaster increase to 1,073 dwellings per annum according to

PBA.

8 Housing Forecasts and Housing Needs Assessment: Peter Brett Associates, June 2018. 9 Target Metrics Sheffield City Region: Metro Dynamics, June 2017.


Page | xviii

Jobs-Led Growth in Doncaster

5.7 Considering the fact that Doncaster has seen employment increase either at or above the

levels experienced by SCR since 1998, it is argued that the Planned Growth Scenario

better reflects the economic growth potential of the Borough. With the City Region aiming

for long-term annual jobs growth of 1.0%, Doncaster needs to show the same level of

ambition and be aiming for this level of growth in its labour market. As noted by Metro

Dynamics in its Target Metrics Report10:

“We believe these targets will push Sheffield City Region to further improve its economy…

they are attainable, yet challenging. They will ensure that SCR continues to move

forward, creating an economy that works for all its citizens. But they are targets, rather

than predictions. They require significant policy interventions and economic investments

to achieve them. All of them are set higher than what we believe would occur without

changes, and are meant to encourage action towards them”.

5.8 This would help build on the growth seen in the area since 1998 and would also better

reflect sub-regional objectives. Other areas have set considerably higher targets, such as

the West Midlands Combined Authority, which is aiming for 1.3% annual jobs growth up

to 2030 as part of its Strategic Economic Plan. This was pre-Brexit, however, and the

growth target may have been lowered since. An annual growth rate of 1.0% would ensure

that Doncaster isn’t left behind by other parts of the country. With increased jobs growth

comes a higher demand for homes and as noted by PBA, the Planned Growth Scenario

will see the annual requirement for housing increase to 1,073 – above the current OAN

of 920dpa.

10 Target Metrics Sheffield City Region: Metro Dynamics, June 2017.


Page | xix

6. CONCLUSIONS

6.1 The analysis presented in this report raises a number of important points when

responding to the Consultation Draft of the Doncaster Local Plan. Firstly, the information

discussed in sections two and three shows that numerous housing targets have been

calculated for the Borough. The Consultation Draft of the Local Plan opts to continue with

the OAN figure of 920dpa. Doncaster has surpassed this target in the last two years and

seen more than 1,000 new homes built in both 2015/16 and 2016/17. Prior to this the

number of net completions on an annual basis was consistently below 900, but the two

most recent timeframes show that the Borough is able to deliver at least 1,000 dwellings

on annual basis.

6.2 Compared with other parts of the country, Doncaster is more affordable to live, however

affordability ratios have changed little over the past decade, suggesting that the housing

ladder remains out of reach for a substantial part of the local population. Build rates will

therefore need to remain high in the long-term to address this issue and it does not seem

unreasonable to expect Doncaster to see annual housing completions surpass 1,000 on

a consistent basis.

6.3 As set out earlier in the report, the household projections are self-fulfilling and heavily

influenced by recent changes to circumstances (such as the recent economic down turn

and recovery). It is, therefore, important that other factors and aspirations are

considered alongside the household projections and Standard Method calculations.

6.4 The Office for National Statistics has confirmed that they will be producing variant

projections, which are due to be published in early December 2018. These variant

projections will include higher formation rates for younger adults (those aged 25 to 44

years), as evidence suggests that such households were unable to form as freely as

previous generations (due to high house prices, less access to finance etc.). An increase

in housing numbers in Doncaster will help ensure that supply is able to meet demand –

especially from younger adult households that form and/ or may move into the area.

6.5 Secondly, the analysis presented in sections four and five raises the question of whether

Doncaster should be aiming for higher long-term growth in employment. Doncaster forms

a key part of Sheffield City Region and target metrics produced independently for SCR

LEP identify the need for jobs growth of 1.0% p.a. if the City Region is to improve its

performance relative to the UK. Given that Doncaster has seen employment increase

either at or above the levels experienced by SCR since 1998, it does not seem

unreasonable to therefore expect it to align with the City Region target and for jobs


Page | xx

growth in the Borough to average 1.0% in the long-term. The impact of this would be to

increase requirements from the current OAN of 920dpa to 1,073dpa – an additional 153

homes per annum.

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