Ref: Doncaster

Local Plan

Publication Draft 2019 (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 and Mrs Mr

First Name James

Last Name Hardy Rawlings Organisation Countryside Properties PLC (where relevant) Address – line 1 3200 Century Way

Address – line 2 Thorpe Park

Address – line 3 Leeds

Postcode LS15 8ZB

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:

Countryside Properties on behalf of Mr and Mrs Hardy

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

Doncaster Local Plan Publication Draft ☒ Policies Map ☒ Sustainability Appraisal ☒ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☐

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

Page No.: Paragraph: Policy Ref.: 2, 3, 6 Site Ref.: 139 Policies Map:

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

4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6)

5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☒ Justified ☒

Effective ☒ Consistent with National Policy ☒

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

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

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

Please see attached the Representations to the Doncaster Local Plan 2015-20135 Publication Version (September 2019) for full comment.

Site Name: Land North of Wath Road, Site reference: 139 Size: 18.6ha Site Capacity: 400 dwellings

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 attached representations for full comments.

We strongly recommend Site 139, land north of Wath Road, Mexborough be included as a housing allocation for 400 units. This in turn will assist in Doncaster delivering its required housing target for Mexborough.

Benefits of Site 139 as a housing allocation:

o Allows Mexborough to meet their housing target as identified in Core Strategy and Local Plan o Residential development in a sustainable location o Provision of circa 400 homes with a portion of affordable housing o Maintain the distance between settlements through design o Retention of the core shape and form of the settlement o An urban extension that would not significantly harm the character and appearance of the surrounding countryside or the rural setting of the settlement. o Exceptional circumstances have been demonstrated o Urban extension consistent with national policy. o Deliverable within the Plan Period. o Economic benefits and economic led housing growth Available

The site is within sole family ownership. Terms have been agreed between the owners and Countryside properties to continue promoting the land for residential uses.

Suitable

The emerging Local Plan requires additional housing in Mexborough. Mexborough currently has a shortfall in quantum allocated and is a settlement that is recognized to be constrained. Site 139 as a residential allocation offers a sustainable urban extension location within Mexborough that would bring in line the allocation numbers with the Core Strategy and national policy.

Deliverable

The site is deliverable in the short, medium and long term. Countryside Properties have agreed an option agreement on the land should the land be allocated for residential development; the site would come forward within the plan period as demonstrated below.

Plan Period Years 1-5 Years 6-10 Years 11-15 Total Houses Delivered 100 150 150 400

The Site is considered to provide a solution to the acuteness and intensity of housing that is required in Doncaster, Mexborough specifically in this instance. There are constraints on the supply and availability of other land whereas Site 139 has clearly been shown to be available, deliverable and suitable. The site should be released from the Green Belt, as it has been demonstrated that through design, there is no further coalescence of settlements. The delivery of 400 houses, which will include a proportion of affordable housing will assist in driving the economic led housing within Mexborough in a highly sustainable location.

For the Local plan to meet its aims and objectives, a sufficient amount of housing needs to be allocated to Mexborough. This should be achieved by the removal of Site 139 from the Green belt. Moreover, the site should be a Housing Allocation, which will support the Council in meeting its aims and objectives.

In respect of alternatives;

“There is a complete lack of landowner representations for any land to the north of Mexborough, so deliverability of a northern extension cannot be justified which only leaves the western urban extension option. Given the site performs well through sustainability appraisal, and mitigation identified for any negative effects, on balance it is considered the benefits of allocating the site as a sustainable urban extension to one of the borough’s largest Main Towns outweighs the Green Belt Review Phase 3 findings and exceptional circumstances can be demonstrated.”

Doncaster Local Plan, Draft Policies & Proposed Sites (2018)

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 ☐ ☒ Yes, I wish to appear at would like my representation to be dealt with by the Examination. written representation.

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:

Housing delivery in Mexborough

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

Date Your 30/09/2019 Signature

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.

Representations to the Doncaster Local Plan 2015-2035 Publication Version (September 2019)

Site Name: Land North of Wath Road, Mexborough Site reference: 139 Size: 18.6ha Indicative Capacity: 400 dwellings

Prepared on behalf of Mr and Mrs Hardy

September 2019 Executive Summary

Land North of Wath Road, Mexborough (Site 139) proposes a Western Urban Extension to Mexborough and is considered to provide a solution to the acuteness and intensity of housing that is required in Doncaster, Mexborough specifically in this instance. There are constraints on the supply and availability of other land in the settlement, whereas Site 139 has clearly been shown to be available, deliverable and suitable to deliver 400 homes. The site would be brought forward in two phases. Phase 1 would be the northern section of the site (250 dwellings), and Phase 2, the southern portion of the site (150 dwellings). The site should be released from the Green Belt, as it has been demonstrated that through design, there is no further coalescence of settlements and exceptional circumstances demonstrated. The delivery of 400 houses, which will include a proportion of affordable housing will assist in driving the economic led housing within Mexborough in a highly sustainable location.

For the Local plan to meet its aims and objectives, a sufficient amount of housing needs to be allocated to Mexborough. This should be achieved by the removal of Site 139 from the Green belt. Moreover, the site should be a Housing Allocation, which will support the Council in meeting its aims and objectives.

In respect of the alternatives;

“There is a complete lack of landowner representations for any land to the north of Mexborough, so deliverability of a northern extension cannot be justified which only leaves the western urban extension option. Given the site performs well through sustainability appraisal, and mitigation identified for any negative effects, on balance it is considered the benefits of allocating the site as a sustainable urban extension to one of the borough’s largest Main Towns outweighs the Green Belt Review Phase 3 findings and exceptional circumstances can be demonstrated.”

Source: Doncaster Draft Policies & Proposed Sites (2018)

Introduction

These representations are in response to the Doncaster Local Plan 2015-2035 Publication Version on behalf of Mr & Mrs Hardy. The consultation is between August and 30th September 2019.

This representation is regarding the Land off Wath Road, Mexborough (site Reference 139). The site is referred to as Site 139 throughout this report. A site plan is attached to this representation.

Site and Surroundings

The site is an irregularly shaped agricultural field to the west of Mexborough contained by a well- defined western boundary. The site has an undulating topography. To the north of the site is open countryside and Lousy Busk Lane (a track); to the east is Mexborough Highwoods Primary School and Mexborough School, as well residential properties along Manvers Road and Highwoods Road. To the south-east of the site there is Mexborough West junction, Manvers Road Playground, Wath Road Skate Park, and a public footpath which connects the existing neighbourhood to the A6023, Wath Road. To the west there is a railway line and beyond that there is a Business Park and Dearne Valley College.

Mexborough and its surrounding settlements (, Swinton and Adwick upon Dearne) have a combination of visual or physical gaps that currently exist and perceived separations between the settlements. These are accomplished in different ways, whether it be the green field physical gap between Mexborough and Adwick upon Dearne or the differing levels created by the topography and transport links with Wath upon Dearne and Swinton.

Timeline of allocations

Stage Date Status Call for Sites December 2014 Submitted as an available site for housing Local Plan Consultation - Draft September/October 2018 Proposed Housing Site (418 Policies and Proposed Sites dwellings) Local Plan Consultation – August/September 2019 Green Belt Publication Draft Policies and Proposed Sites

This representation is to promote Site 139 (Land to the north of Wath Road) for Residential development and a housing allocation in the Doncaster local Plan 2015-2035.

This representation is set out in the following structure:

o Comments on Policy 2, 3 and 6 of the Local Plan publication Draft o Green Belt Assessment o Conclusion

Appendix 1 - Indicative Layout plan

Appendix 2 - Comparative Sustainability Assessment

Appendix 3 – Extract from Local Plan Consultation - Draft Policies and Proposed Sites

Appendix 4 – Previous Representations submitted.

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

This policy sets out the proportion of homes that will be completed in the ‘Main Urban Area’, ‘Main Towns’ and the ‘Service Towns and Larger Villages’. We support that the distribution of sites will follow a logical hierarchical approach, provide an appropriate development pattern and support sustainable development within all market areas.

As per paragraph 2.14 of the Publication Draft Local Plan, Mexborough and Thorne are the largest centres outside of Doncaster and provide a wide range of services (e.g. shops, banks, building societies, libraries and restaurants) serving a wide catchment area.

We support that 40% of the housing should go to Main Towns, with particular focus to the most sustainable settlements which include Mexborough. This is echoed in the policy ‘Housing allocations and mixed-use allocations to meet local needs housing growth are distributed on a pro-rata basis to the most sustainable and deliverable urban and urban extension sites and, in accordance with a sequential approach to flood risk, to these settlements.’

Site 139 is a deliverable and suitable site that can contribute to the local housing growth via an urban extension in one of the most sustainable settlements in Doncaster. The Local Plan should be ‘prepared with the objective of contributing to the achievement of sustainable development,’ which can be achieved through the allocation of Site 139 for residential development.

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

The distribution of housing throughout the district is set out initially in Core Strategy Policy CS2 (adopted 2012) Table 1: Settlement Hierarchy. Mexborough was identified as a principle town that should accommodate between 646 to 923 dwellings. This was then amended in the Draft Local plan in 2018, when a range of 475 to 1140 was proposed in Mexborough. This has been further amended within the Doncaster Local Plan Publication Version, which states a housing delivery target of 475 – 985 during the Plan period.

“Housing allocations and mixed-use allocations to accommodate economic-led housing growth are directed to the most sustainable and deliverable urban and urban extension sites in the Doncaster Main Urban Area and Main Towns in accordance with the growth ranges set out in Policy 3 and in accordance with a sequential approach to flood risk.”

Allocations Allocations Local Plan with without target planning planning Allocated Settlement Shortfall/Surplus (Publication permission permission Total Version) (as at 1st (as at 1st April 2018) April 2018) A shortfall of Mexborough 475-985 268 202 470 between 5 and 515

With Mexborough being one of the most sustainable settlements in Doncaster, it should be positively planned to deliver a high quantum of housing. The council’s allocations to aim for the lower quantum of housing in Mexborough is strongly objected to, as this would not meet the requirements of the settlement given its sustainability and role to deliver housing in Doncaster and for the Council to meet their aims and objectives.

Site 139 will assist in driving economic led housing growth in Mexborough, which the Council identifies as one of the most sustainable urban areas within the district. As stated in the site Doncaster Draft Policies & Proposed Sites (2018), paragraph 9.1.23 ‘Permissions and the above additional allocations provides a settlement allocation of 532 dwellings against a target of 475 – 1,040 which, although provides for the full local need target, goes little towards providing the economic-growth led housing for one of the largest Main Towns outside of Doncaster.’ The Site allows for an urban extension in a highly sustainable area which is in Flood Zone 1.

As per the NPPF, paragraph 11, The Presumption in favour of sustainable development, for Plan Making means that:

a) plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;

It is considered that the Plan, in relation to Mexborough, does not positively seek opportunities to meet the development needs of their area, and is therefore not consistent with National Policy, and thus not sound.

Policy 6: Housing Allocations (Strategic Policy)

The housing allocations are shown in Table H1(F): Allocations with planning permission (as at 1st April 2018), Table H2(F): Allocations without planning permission (as at 1st April 2018), and Table H3(C): Reserve Development Sites.

The proposed allocated total results in a minimum shortfall of housing between 5 and of 515 dwellings. This is based on all the sites listed within the tables delivering their full quantum of housing. It is clearly evident that the allocations in the Plan for Mexborough are not positively prepared, justified, effective or consistent with national policy and thus, not sound.

In accordance with national Policy when identifying land for homes, policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability. The Local plan as it stands does not achieve this in Mexborough. The inclusion of Site 139 would assist in making the plan sound in relation to Mexborough as demonstrated in the table below, the inclusion of Site 139 would result in the allocated housing numbers meeting both the Core Strategy Requirement, and the Local plan requirement.

Allocations Allocations without Local with planning planning Allocated Settlement Plan permission Shortfall/Surplus permission Total target (as at 1st April (as at 1st 2018) April 2018) 475 – 202 + 400 470 + 400 Mexborough 268 870 (+395 or -115) 985 602 870

Identifying land for homes

The NPPF states at paragraph 67 that Strategic ‘policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability. Planning policies should identify a supply of:

a) specific, deliverable sites for years 1-5 of the plan period; and

b) specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan.

The consultation undertook by Doncaster Council in October 2018 when proposing housing sites, in reference to Site 139 which was at the time a proposed housing site, stated:

“Although land to the south-west is not at risk of flooding, this is the edge of the DMBC borough boundary and beyond it lays a large area of employment uses at Swinton (Rotherham MBC). There is a complete lack of landowner representations for any land to the north of Mexborough, so deliverability of a northern extension cannot be justified which only leaves the western urban extension option. Given the site performs well through sustainability appraisal, and mitigation identified for any negative effects, on balance it is considered the benefits of allocating the site as a sustainable urban extension to one of the borough’s largest Main Towns outweighs the Green Belt Review Phase 3 findings and exceptional circumstances can be demonstrated.”

As the Council have acknowledged previously, this site offers a very suitable, deliverable and available urban extension for Mexborough. The inclusion of the site as a Housing Allocation would significantly assist Doncaster in housing delivery throughout the plan period.

Safeguarded Sites in Mexborough

There are a number of urban sites (mainly in the Doncaster Main Urban Area and Mexborough) where deliverability issues (mainly associated with addressing flood risk mitigation and/or directly impacted by the safeguarding route of HS2 and unstable land) have prevented them coming forward and where their development in the plan period cannot at this time be demonstrated. Site 154 is an example of where deliverability, suitability and availability are all seriously questioned. Whereas, Site 139 has demonstrated that it can come forward and deliver housing in an area that is otherwise constrained.

There are three reserve development sites within Mexborough that have an indicative capacity of 242 dwellings. The inclusion of the proposed reserved development sites over the inclusion of Site 139 is not considered to be sound.

Site 139 significantly outscores site 154 in the Sustainability Appraisal undertaken by the Council. When applying a scoring system of -2 to 2 relative to – to ++, Site 154 was the most unsustainable site within Mexborough. The sustainability of the site is positively highlighted within the Councils Sustainability Appraisal. Site 139 scores higher than 154 in the following areas:

o Distance to bus stops o Distance to cycle network o Access to secondary school o Access to GP surgery o Not being located on unstable land o Fibre broadband coverage o Biodiversity The comparison of sustainability of the two sites is appended to this representation.

Paragraph 72 of the NPPF states ‘The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities.’ The NPPF then goes on to list criterion that such developments should meet:

a) consider the opportunities presented by existing or planned investment in infrastructure, the area’s economic potential and the scope for net environmental gains;

b) ensure that their size and location will support a sustainable community, with sufficient access to services and employment opportunities within the development itself (without expecting an unrealistic level of self-containment), or in larger towns to which there is good access;

c) set clear expectations for the quality of the development and how this can be maintained (such as by following Garden City principles), and ensure that a variety of homes to meet the needs of different groups in the community will be provided;

d) make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites, and identify opportunities for supporting rapid implementation (such as through joint ventures or locally-led development corporations); and

e) consider whether it is appropriate to establish Green Belt around or adjoining new developments of significant size.

It is considered that the allocation for residential development on Site 139 would align with the NPPF and achieve a well located and designed urban extension to Mexborough that is deliverable, sustainable and suitable.

As current, the Publication Local Plan housing allocations within Mexborough, does not meet any of the following criteria and is therefore not sound:

Positively prepared – providing 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 need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;

Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

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 this Framework.

We strongly recommend that the Council identifies Site 139 as a Housing Allocation in order for the Council to meet its housing requirement within Mexborough and to achieve the criteria listed above.

Site 139 – Land north of Wath Road, Mexborough - Green Belt Assessment

An assessment of Site 139 against the five Green belt Criteria is as below:

a) to check the unrestricted sprawl of large built-up areas;

The site does not result in unrestricted sprawl of a large built up area. As noted within the Green Belt Review undertaken by Doncaster Council, the site is not considered to have a role in checking the unrestricted sprawl of a Large Built Up Area. The site meets this criterion.

b) to prevent neighbouring towns merging into one another;

The approach that would be taken, as demonstrated on the attached plan, is the built form of the proposed site and the existing built form will be no closer than currently exists. The site will not negatively impact on the visual or physical gap that currently exists. Nor would it result in the reduction of perceived separation between settlements. An existing physical and visual gap already exists due to the change in topography and the levels that exist between the two areas. The nearby settlement of Wath upon Dearne is situated 1.6km away. However, the built form of the commercial and industrial area extends towards Mexborough. The built form of the industrial area is currently just 240 metres from the existing built form. This would be maintained, and the Green Belt boundary could be well defined through the design of the development and the advanced planting that is currently being undertaken.

c) to assist in safeguarding the countryside from encroachment;

The area is characterised by residential to the east, Adwick Business Park to the south and south west and countryside to the north and west. The site would not negatively impact on the wetland structure. Development in this location would not have a negative impact on the physical landform as it would look to retain the settlement shape and would be designed in a manner to not have an adverse effect upon the landscape therefore the site meets this criterion.

d) to preserve the setting and special character of historic towns; and

The proposed site does not influence the preservation of the setting and special character of historic towns. Therefore, the site meets this criterion and there is no conflict.

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

The site has a moderate role in encouraging the recycling of derelict and other urban land. The opportunity to recycle derelict land in Mexborough has been included within the Plan as safeguarded land. The safeguarded land is safeguarded in relation to HS2. The housing requirement of Mexborough requires more land than that is available through only derelict sites. Moreover, the constraints of Mexborough further restrict this. The site should be released from the Green Belt as it is required to meet the housing requirements for Mexborough as exceptional circumstances can be demonstrated as stated in the Councils Doncaster Local Plan Site Selection Methodology Part 3.

Conclusion

Mexborough is not receiving the quantum of housing required to make the Plan sound. As stands, the permissions and the additional allocations provides a settlement allocation of 470 dwellings against a target of 475 – 985 which, although provides for the full local need target, ‘goes little towards providing the economic-growth led housing for one of the largest Main Towns outside of Doncaster.’ The west urban extension site allows for an urban extension in a highly sustainable area which is of low flood risk.

We strongly recommend Site 139, land north of Wath Road, Mexborough, be released from the Green Belt and be included as a housing allocation for 400 units. This in turn will assist in Doncaster delivering its required housing target for Mexborough.

Benefits of Site 139 as a housing allocation:

o Allows Mexborough to meet their housing target as identified in Core Strategy without exporting part of the requirement to Doncaster Main Urban Area. o Residential development in a sustainable location o Provision of circa 400 homes with a portion of affordable housing o Maintain the distance between settlements through design o Retention of the core shape and form of the settlement o An urban extension that would not significantly harm the character and appearance of the surrounding countryside or the rural setting of the settlement o Exceptional circumstances have been demonstrated o Urban extension consistent with national policy o Deliverable within the Plan Period o Economic Growth Led Housing

Available

The site is within sole family ownership. Terms have been agreed between the owners and Countryside Properties to continue promoting the land for residential uses.

Suitable

The emerging Local Plan requires additional housing in Mexborough. Mexborough currently has a shortfall in quantum allocated and is a settlement that is recognized to be constrained. Site 139 as a residential allocation offers a sustainable urban extension location within Mexborough that would bring in line the allocation numbers with the Core Strategy.

Deliverable

The site is deliverable in the short, medium and long term. Countryside Properties have agreed an option agreement on the land should the land be allocated for residential development; the site would come forward within the plan period as demonstrated below.

Plan Period Years 1-5 Years 6-10 Years 11-15 Total Houses Delivered 100 150 150 400

The Site is considered to provide a solution to the acuteness and intensity of housing that is required in Doncaster, Mexborough specifically in this instance. There are constraints on the supply and availability of other land whereas Site 139 has clearly been shown to be available, deliverable and suitable. The site should be released from the Green Belt, as it has been demonstrated that through design, there is no further coalescence of settlements. The delivery of 400 houses, which will include a proportion of affordable housing will assist in driving the economic led housing within Mexborough in a highly sustainable location.

For the Local plan to meet its aims and objectives, a sufficient amount of housing needs to be allocated to Mexborough. This should be achieved by the removal of Site 139 from the Green Belt. Moreover, the site should be a Housing Allocation, which will support the Council in meeting its aims and objectives.

In respect of the alternatives;

“There is a complete lack of landowner representations for any land to the north of Mexborough, so deliverability of a northern extension cannot be justified which only leaves the western urban extension option. Given the site performs well through sustainability appraisal, and mitigation identified for any negative effects, on balance it is considered the benefits of allocating the site as a sustainable urban extension to one of the borough’s largest Main Towns outweighs the Green Belt Review Phase 3 findings and exceptional circumstances can be demonstrated.”

Doncaster Local Plan, Draft Policies & Proposed Sites (2018)

Appendix 1 – Indicative Layout Plan

N

Proposed residential development blocks

Indicative Public Open Space

Indicative primary loop road

Principle vehicular access

Potential emergency vehicle access

Existing Public Right of Landscape buffer to Green Belt Way

Potential pedestrian links

Public Open Space

Wath Road, Mexborough Indicative Layout: SK02 Sept 2019 Partnerships Yorkshire Aeris, 3200 Century Way, Thorpe Park, Leeds, LS15

Appendix 2 – Sustainability Appraisal Comparison with Reserved Site 154.

139: Land north of Wath 139: Land north of Wath 154: Land to the north Road, Mexborough Road, Mexborough west of Pastures Road (amended Score)

SA Rating Score SA Rating Score SA Rating (amended)Score 1 - Maintain and increase A) Local economy (maintain and strengthen) Doncaster’s growth and 0 0 0 0 0 0 prosperity and diversify its B) Diversify the economic base n/a 0 n/a 0 n/a 0 ₋₋ -2 2 - Reinforce and support A) Support community identity n/a 0 n/a 0 n/a 0 ₋ -1 community identity and B) Pride n/a 0 n/a 0 n/a 0 0 0 i & ii) Will the site promote the use of public transport? (Train) ₋ -1 ₋ -1 ₋ -1 ₊ 1 A) Accessibility to places i & ii) Will the site promote the use of public transport? (Bus) ₊ 1 0 0 ₊ 1 ₊₊ 2 3 - Improve accessibility to iii) Will the site promote cycling? ₊ 1 0 0 ₊ 1 places and services, both within and outside of the i) Will the site be accessible to an existing centre? ₋ -1 ₋ -1 ₋ -1 borough ii) Will the site be accessible to a primary school? ₊ 1 ₊ 1 ₊ 1 B) Accessibility to services iii) Will the site be accessible to a secondary school? ₊ 1 0 0 ₊ 1 iv) Will the site be accessible to a GP Surgery? ₊ 1 0 0 ₊ 1 4 - Ensure resources are A) Energy resources n/a 0 n/a 0 n/a 0 available and efficiently B) Minerals and construction n/a 0 n/a 0 n/a 0 used to sustain C) Efficient use of waste n/a 0 n/a 0 n/a 0 5 - Provide affordable, good A) Affordability ₊₊ 2 ₊₊ 2 ₊₊ 2 quality housing that is B) Quality n/a 0 n/a 0 n/a 0 available to everyone, C) Mix and range of homes n/a 0 n/a 0 n/a 0 including vulnerable and D) Availability 0 0 0 0 0 0 6 - Reduce social exclusion A) Social exclusion n/a 0 n/a 0 n/a 0 and disadvantage B) Social disadvantage n/a 0 n/a 0 n/a 0 7 - Make places that are safe, A) Attractive and distinctive places n/a 0 n/a 0 n/a 0 attractive, culturally B) Safety and security ₊ 1 ₊ 1 ₊ 1 i) Will the site enable the reuse of previously developed land and/or buildings? 0 0 0 0 0 0

A) Land and buildings ii) Will the site bring back into effective use areas on known contaminated land? 0 0 ₊ 1 0 0 iii) Will the site avoid known areas of landfill sites? ₋ -1 ₋ -1 ₋ -1 8 - Renew and reuse existing iv) Will the site avoid known areas of unstable land? 0 0 ₋₋ -2 0 0 buildings, land and i) Will the site have an impact on the Strategic Road Network? ₊ 1 ₊ 1 ₊ 1 infrastructure ii) Will the site have access to fibre broadband? ₊ 1 0 0 ₊ 1 B) Infrastructure iii) Will any additional demand for primary school places be likely from the site? ₊ 1 ₊ 1 ₊ 1

iv) Will any additional demand for secondary school places be likely from the site? ₊ 1 ₊ 1 ₊ 1 9 - Improve the health and A) Health ₋ -1 0 0 ₊ +1 well-being of the borough’s B) Well-being n/a 0 n/a 0 n/a 0 10 - Provide education and A) Education n/a 0 n/a 0 n/a 0 training provision to build B) Skills and training n/a 0 n/a 0 n/a 0 i) Will the site be at risk of flooding from main rivers/the sea? ₊ 1 ₊ 1 ₊ 1 ii) Will the site be at risk from surface water flooding? ₊ 1 ₊ 1 ₊ 1 iii) If the site is at risk of flooding from main rivers/the sea, does it benefit from A) Flood risk 11 - Manage and adapt to being within an area of existing defences? ₊ 1 ₊ 1 ₊ 1 climate change iv) If the site is at risk of flooding from main rivers/the sea, is it within an EA flood warning/alert area? ₊ 1 ₊ 1 ₊ 1 B) Greenhouse gas emissions n/a 0 n/a 0 n/a 0 C) Water supply and drainage n/a 0 n/a 0 n/a 0 12 - Protect, increase and A) Biodiversity (habitats and species) 0 0 ₋ -1 0 0 enhance the natural B) Landscape 0 0 0 0 0 0 13 - Protect, conserve and A) Historic places 0 0 0 0 0 0 enhance the historic and B) Cultural heritage 0 0 0 0 0 0 i) Will the site impact on mineral resource? ₋ -1 ₋ -1 ₋ -1 14 - Protect and enhance soil, A) Land and soil ii) Will the site impact on best and most versatile agricultural land? 67-74 ? 0 ? 0 ? 0 air and water quality ii) Will the site impact on best and most versatile agricultural land? 1988 ? 0 ₋ -1 ? 0 (watercourses and ground i) Will the site impact on groundwater? 0 0 0 0 0 0 water) B) Water ii) Will the site impact on surface water bodies? 0 0 0 0 0 0 C) Air i) Will the site impact on air quality? 0 0 0 0 0 0 TOTAL SCORE 11 4 12

Appendix 3: Doncaster Local Plan, Draft Policies & Proposed Sites (Mexborough Extract) (2018)

Where are new homes in Mexborough being proposed through the emerging Doncaster Local HS2 Safeguarding Route - The route of HS2 is now a safeguarded route under direction of the Secretary of Plan? State for Transport as of November 2016. The advice in the safeguarding guidance for Council’s preparing a Local Plan is that the area safeguarded by the Safeguarding Directions should be taken into account. Local Plans should state that the Safeguarding Directions have been made by the Secretary of State for Transport. They are not proposals of the LPA and the routes in question will not be determined through the local plan process.

How many planning permissions already exist that will contribute towards the Towns’ housing need?

Some sites have already been built/approved for housing at the settlement as at the base date of the Local Plan (1st April 2015) and will contribute towards Mexborough’ housing requirement range of 465-1,040 new homes therefore. The largest of these sites (i.e. sites which could provide at least 5+ new homes) are identified as green outline sites on the map and summarised below in Table 1; these sites are proposed to be allocated. National policy states that planning permissions are assumed to be deliverable sites unless clear evidence to the contrary.

There are also some smaller sites which have been built over the first 2 years of the plan period (1st April 2015- 31st March 2017) which are also being included in the overall numbers for Mexborough (but not shown on the map/summary table as they are too small to allocate). In summary, 364 of the 465-1,040 new homes have already been built or have planning permission already granted as at 1st April 2017.

How much more housing needs to be identified at Mexborough?

Given the supply of new housing from completions on small sites and existing permissions 5+ units (364 new homes) is below the bottom of the growth range target/requirement, there is a need to find further sites for at least 101 new homes, or up to 676 new homes if the top of the growth range is to be met at the town.

What sites have been put forward to provide this additional housing by landowners/developers and which are being proposed to be supported/rejected through the local plan?

There are a further 8 sites at Mexborough that have been considered through the site selection methodology process and shown on the map. A very brief summary of each, including why the site is either being proposed (identified on the map via an orange outline) or rejected (shown with a red outline) as a new housing site in the emerging local plan is provided in Table 2.

Are there any other sites being proposed for housing at the settlement?

At the time of writing, all of the sites submitted for consideration as housing sites at Mexborough How many new homes are being proposed? have been assessed through the site selection process and there are no ‘late’ sites on file awaiting to be incorporated into The emerging Doncaster Local Plan, and its supporting evidence base, has identified Mexborough as one of 7 Main the process. Towns in the borough. The Homes & Settlements consultation (March 2016) proposed a housing allocation range to the Where can I find more information about the site selection process? town of 465 – 1,024 new homes over the plan period to 2032. The latest, and most up-to-date evidence base, now proposes a slightly different range/ target for Mexborough of 475 – 1,040 new homes during this same timeframe. This document provides a very brief summary of the evidence base that has informed the decisions on whether sites should be supported or rejected. Further information and detail therefore can be seen through the Site Selection What are the main physical and policy constraints to growth at the Town of Mexborough? Methodology & Results Report published alongside this consultation and available to view via: Flood Risk – National policy states areas at risk of flooding should be avoided where possible. According to the www.doncaster.gov.uk/localplan Council’s Strategic Flood Risk Assessment (November 2015) a large part of the surrounding land at Mexborough I want to let the Council know now what I think about these proposals. How can I do this? to the north, east and south, is at high risk of flooding (Flood Risk Zone 3). However, the maps do not take account of the presence of flood defences and how they may reduce flood risk to the Town. Other sources of This engagement stage runs until Friday 26th October 2018. You can provide your comments and feedback to us via flood risk, such as surface water flooding, must also be considered. completing the Local Plan Draft Policies & Proposed Sites response form available to download via the following web-link: www.doncaster.gov.uk/localplan The response form provides all the relevant information for how you can return your Green Belt – National policy only allows land to be taken out of the Green Belt in exceptional circumstances, for comments to us or how you should contact us if you have any queries in respect to this stage, or any aspect of the example if the homes target for the borough or a specific town could not otherwise be sustainably achieved. emerging Doncaster Local Plan. Mexborough is surrounded by a tightly drawn Green Belt identified on the map via the green shading, except to the south-east where the settlement meets its neighbouring Main Town of Conisbrough-Denaby and to the south– west where the borough boundary runs along the settlement edge (beyond which is Green Belt). Please note, these are the current boundaries as per the Unitary Development Plan and will need to be reviewed as part of the Doncaster Local Plan. Table 1: Completions & Existing Planning Permissions for new homes at Mexborough from merging, and a moderately strong role in Completions on small sites (1st April 2015- 31st March 2017 on sites of less than 5 units) Number of encouraging the recycling of derelict and other urban new homes land. The site is considered to have a moderate role in 43 safeguarding the countryside from encroachment and a Site Ref: Site Name/Address: weak role in preserving the setting and special 632 North Gate Working Men’s Club, North Gate, Mexborough 6 character of historic towns. The sustainability appraisal 687 The Embankment, Leach Lane Industrial Estate, Leach Lane, Mexborough 24 identifies significant positive effects for affordability 704 Land Adjacent 166 Wath Road, Mexborough 14 given the size of the site is likely to trigger a large 790 Red Lion Hotel, 41 Bank Street, Mexborough 16 affordable housing contribution. Other effects are 839 Mexborough Power Station, Mexborough 67* mostly positive or neutral. The sites location to the train 850 Land at Alagu Close, Off Highwoods Road, Mexborough 9 station and Mexborough Town centre are identified as 894 Former Nurses Home, Cemetery Road, Mexborough 9 911 Mexborough Congregational Church, garden Street, Mexborough 7 being negative due to the distance but could be 912 51 Market Street, Mexborough 5 mitigated through a Transport Assessment and Travel 922 Garage Site, Maple Road, Mexborough 5 Plan and it is noted the site is located on a high 678/927 Pastures Road, Mexborough 146 frequency bus network. Negative effects on loss of 960 The Highwoods, Elm Road, Mexborough 13 open space (informal open space at the southern end Total new homes identified 364 of the site identified through the Green Space Audit as Manvers Road/Park – reference 586) could be *This development is directly on the route for the HS2 line which has now been safeguarded through a direction from the mitigated through either this part of the site being Secretary of State. The majority of the site has been built out over years with a remaining capacity on site at the start of undeveloped and/or new open space being provided as the plan period of 106 dwellings, of which a further 67 have been completed in the first 2 years of the plan period, leaving part of the development which would be required a remaining 39 units as at 1st April 2017. No further completions have occured however during the 2017/18 monnitoring anyway given the size of the site. Whether or not the period. Latest reports suggest that 16 homes will need to be demolished due to being directly on the route. As such, no site contains best and most versatile agricultural land further units have been assumed from the remaining site capacity towards the settlement’s housing supply post April could be confirmed through on-site survey and then 2017. potentially a soil management plan were the survey to show the site is grade 3a agricultural land as at present Table 2: Proposed & Rejected Housing Sites these effects are uncertain. In conclusion, although the importance of the Green Belt in this location is Site Site Name/ Address: Potential Proposed to be supported or rejected through the acknowledged, there are no other options for the Ref: Number of emerging local plan? settlement to deliver significant new housing and the new homes settlement is surrounded by Green Belt. The HS2 068 Former Coal Depot, 82 Rejected Housing Site – the site would lead to Safeguarding route further constrains growth to the Pastures Road, inappropriate development in an area of high flood risk east, and beyond this are areas of high flood risk Mexborough (Flood Risk Zone 3) so the site fails the flood risk including the functional flood plain. The same flood risk sequential test. constraints are found to the south-east/south of 139 Land North of Wath 418 Proposed Housing Site - Large urban extension site Mexborough. Although land to the south-west is not at Road, Mexborough circa 18.6 hectares in size to the west of the settlement. risk of flooding, this is the edge of the DMBC borough The site is currently in agricultural use and is greenfield boundary and beyond it lays a large area of therefore and could accommodate 418 dwellings. To employment uses at Swinton (Rotherham MBC). There the north is open countryside and Lousy Busk Lane (a is a complete lack of landowner representations for any track); to the east is Mexborough Highwoods Primary land to the north of Mexborough, so deliverability of a School and Mexborough School, as well residential northern extension cannot be justified which only leaves uses. To the south-east of the site there is Mexborough the western urban extension option. Given the site West junction, a recreation ground, and a public performs well through sustainability appraisal, and footpath which connects the existing neighbourhood to mitigation identified for any negative effects, on balance the A6023, Wath Road. To the west there is a railway it is considered the benefits of allocating the site as a line and beyond that there is Adwick Business Park. sustainable urban extension to one of the borough’s The Phase 3 Green Belt Review concludes that were largest Main Towns outweighs the Green Belt Review the site to be removed from the Green Belt, the Phase 3 findings and exceptional circumstances can be boundary would be defined by Wath Road (A6023) in demonstrated. the south west, a field boundary in the west, a field 154 Land to the North 489 Rejected Housing Site – Large urban extension site boundary supported by occasional mature trees in the West of Pastures extending to 21.8 hectares to the north-east of the north west and a weakly defined field boundary in the Road, Mexborough settlement. The site is currently in agricultural use and north east. Aside from the A6023 which accounts for a is greenfield therefore and capable of accommodating very small proportion of the outer boundary, the Green 489 dwellings. To the west and south of the site are Belt boundary is considered to be weakly defined, existing residential uses. There is open weakly recognizable and unlikely to be permeant. The countryside/agricultural land to the north and north- Green Belt in this location is connected to the South east. A new housing development is currently under Yorkshire Green Belt, but is not considered to have a construction to the south-east of the site (Pastures role in checking unrestricted sprawl of a large built up Road). A small part of the site adjacent to Clayfield area. However, the General Area is considered to have Avenue is a current UDP Housing Allocation which has a strong role in preventing the neighbouring town of not yet been developed, to the east of this is a larger Wath Upon Dearne (Rotherham MBC) and Mexborough area of the site which is currently designated as Open Space Policy Area, so these parts are not in the Green development high risk area due to the legacy of coal Belt. The remainder of the site to the north and north- mining in the area. The site would need to undertake a west is the part that is designated Green Belt. Although Coal Mining Risk Assessment to identify site specific this site has a stronger Green Belt case for further site coal mining risks and an appropriate mitigation strategy selection, relative to Green Belt site reference 139 (plus to show that the site can be made safe and stable for a large part of this site is non-Green Belt anyway given the development that is proposed. The site’s proximity its current Housing/Open Space allocation in the UDP), to the canal leads to potential for pollution to this the site lies directly on the route of HS2 and this is now surface water body but this can be mitigated through a safeguarded route under direction of the Secretary of best practice construction techniques. State for Transport as of November 2016. The advice in 379 Garden Street, 15 Proposed Housing Site - The site is 0.5 hectares and is the safeguarding guidance for Council’s preparing a Mexborough located just north of Mexborough's town centre and Local Plan is that the area safeguarded by the currently in use as a surface car park consisting largely Safeguarding Directions should be taken into account. of hard standing and is therefore brownfield. The site is Where a Safeguarded Direction is taken into account in capable of accommodating 15 dwellings. There are a Local Plan, it should be represented on the policies existing residential uses to the west and north of the map (in accordance with Regulation 9 of the Town and site and commercial/retail uses to the south and east of Country Planning (Local Planning) () the site. The site is an existing UDP Housing Allocation Regulations 2012 as amended). Adding information that has not yet been developed. Although the site is about the extent of the safeguarded area on the identified in the Green Space Audit as amenity housing Proposals Map is helpful for those considering public open space, the majority of the site is currently in development in the area, however it is important to note use for car parking. The site performs strongly through that the requirements of the Safeguarding Directions the sustainability appraisal stage with entirely positive apply, in the circumstances described above, or neutral effects with the exception of significant regardless of whether the safeguarded area is identified negative effects on unstable land due to the site being on the Proposals Map or not. Local Plans should state located in a development high risk area due to the that the Safeguarding Directions have been made by legacy of coal mining in the area. The site would need the Secretary of State for Transport. They are not to undertake a Coal Mining Risk Assessment to identify proposals of the LPA and the routes in question will not site specific coal mining risks and an appropriate be determined through the development plan process. mitigation strategy to show that the site can be made They will be considered in Parliament under hybrid Bill safe and stable for the development that is proposed. procedures, which will provide appropriate opportunities 412 Willow Drive, 25 Proposed Housing Site - The site is an open space for petitions to be made to Parliament by those directly Mexborough which is circa 0.7 hectares in size and greenfield affected by the scheme. Prior to the HS2 Safeguarding therefore. The site could accommodate 25 dwellings. Direction, this site would be a logical expansion for There are existing residential uses to the north and Mexborough given part of the site is non-Green Belt west of the site and allotments/further open and the remainder that is has a stronger case for space/sports pitches to the east and south. The site is release compared to site reference 139 based on the currently allocated for Housing in the UDP but has not findings from the Phase 3 Green Belt Review. The site yet been developed. The site performs strongly through also makes sense in urban form given the Pastures the sustainability appraisal stage with entirely positive Road development under construction to the east (site or neutral effects with the exception of significant reference 731). However, site reference 139 does negative effects on unstable land due to the site being perform stronger through sustainability appraisal located in a development high risk area due to the compared to this site. legacy of coal mining in the area. The site would need 155 Site A, Leach Lane 16 Proposed Housing Site - The site is 0.6 hectares in size to undertake a Coal Mining Risk Assessment to identify Industrial Estate, and previously contained an industrial estate although site specific coal mining risks and an appropriate Mexborough all buildings have since been demolished and the site is mitigation strategy to show that the site can be made cleared. The site is brownfield and capable of safe and stable for the development that is proposed. accommodating 16 dwellings. To the north of the site is 414 Windhill, Whinhill 112 Proposed Housing Site - The site is 3.3 hectares and the A6023 (Greens Way) with Mexborough's town Avenue, Mexborough consists of former housing stock that has been centre beyond. Station Road adjoins the site to the west demolished and cleared. The site is brownfield which leads directly to Mexborough Train Station. therefore and capable of accommodating 112 Beyond Station Road there are various dwellings. There are existing residential uses on all four industrial/commercial buildings. The sides of the site. The site performs strongly through Navigation Canal runs adjacent to the south of the site sustainability appraisal with significant positive effects and further cleared former industrial land is located to on affordability, market failure, and, re-use of land and the east of the site. The site is currently designated as buildings. Other effects are mainly positive or neutral. Employment Policy Area in the UDP but there are no Significant negative effects on unstable land due to the active uses on the site and previous buildings relating site being located in a development high risk area due to historical employment use have been demolished. to the legacy of coal mining in the area would need to The site performs strongly through sustainability be addressed through undertaking a Coal Mining Risk appraisal with mainly positive and neutral effects. Assessment to identify site specific coal mining risks Significant negative effects in relation to unstable land and an appropriate mitigation strategy to show that the are found due to the site being located in a site can be made safe and stable for the development that is proposed. 834 Pitt Street, 82 Rejected Housing Site – The site is 2.9 hectares and Mexborough consists of open space and sports pitches and is greenfield therefore. The site could accommodate 82 dwellings. There are residential uses to the north, east and west of the site with further open space to the south. The site performs strongly through the sustainability appraisal stage with entirely positive or neutral effects, with the exception of significant negative effects on unstable land and negative effects for the loss of an existing open space. Although the site would be a sustainable housing site, the site is currently public open space which is being proposed to be retained through the Local Plan

Table 3: Proposed Housing Site Allocation Summary Total potential of 1,223 additional new homes (Table 2) Total new homes 586 proposed to be supported (Table 2) Total new homes 637 proposed to be rejected (Table 2) How does this Requirement = 475-1,040 new homes compare to the Completions & Existing Planning Permissions = 364 new homes (Table 1) settlement’s housing Proposed Housing Allocations = 586 new homes (Table 2) requirement? Total Housing Identified = 950 new homes (+475 new homes compared to the bottom of the target range, or 44 new homes below the top of the range)

Appendix 4: Previous Representations submitted.