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)
Mrs
Title
Rhonda
First Name Last Name
Job Marr Parish Meeting
Organisation
(where relevant)
Grove Farm Bungalow Church Lane Marr
Address – line 1 Address – line 2 Address – line 3 Postcode
DN5 7AU
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’(seebelow).
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?
- be
- Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would
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:
Marr Parish Meeting
1. To which document does your response relate? (Please tick all that apply) Doncaster Local Plan Publication Draft Sustainability Appraisal
☒☒☐
Policies Map
☒☐☐
Habitats Regulations Assessment
- Topic Paper? If so, which one(s):
- Other Document(s)? If so, which one(s):
Please see JRP submission.
Please see JRP submission.
2. To which part(s) of the document / map does your response relate?
- Page No.:
- Paragraph:
Site Ref.:
Policy 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 Effective
☐☒
Justified
☐☐
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.
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).
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
the Examination.
☒
☐ would like my representation to be dealt with by 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:
Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session.
Date
Your
Signature
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.
Date: 30/09/2019
Local Plans Team Civic Office, Waterdale Doncaster, DN1 3BU
Marr Parish Meeting Response to the Consultation on the proposed Local Plan for Doncaster 2015-2035
Dear Madam, Marr Parish Meeting would like to fully participate in the Local Plan Consultation for Doncaster. Following our most recent Parish meeting and on the resident’s feedback we have previously reviewed the Draft proposal on Homes and Settlements and the accompanying Green Belt Reviews, Sustainability Appraisal along with the Feedback from previous consultations. Reference has also been made to the various accompanying evidence based Reports and the amended Vision, Aims and Objectives and consideration has been given to the Local Plan in its entirety, including the Appendices, HELAA, Settlement Background Paper, Settlement Audit, Local Plan Evidence Base, Doncaster Infrastructure Strategy, Green Belt Topic Paper, Green Belt Stage 3 Site Summaries, Section 106 Monitoring Report, and NPPF March 2019. Based on available documents the Marr Residents have requested that I, on their behalf, formally register their contribution to the Inspector on the updated
proposals for Doncaster’s Local Plan.
Marr Parish Meeting agreed that its response could be better conveyed through a written submission. We would like to congratulate the Council on their in-depth analysis and acknowledge the work and effort of DMBC staff in collating these reports, with special recognition to the Planning Department for their time and effort in collating these reports. We would also like to pass on our personal thanks to the Planning Officers for their assistance in explaining how the proposals within the Local Plan may affect our Parish. This was very much appreciated and their proactive response encouraged a belief
that our resident’s views were important and would be carefully considered.
We appreciate the extended deadline for contributions, as once again, time scheduling of the consultation process has been conducted during holiday periods. However, due to the vast number of reports that have only recently been made available, together with the very short consultation period, this has meant it has been an onerous task for the Parish to assimilate and review the information from the numerous and lengthy documents in order to form its opinion and give credible feedback. We would like to suggest and reiterate once again, that for future consultations, Reports are made publically available when they are completed in a timelier manner rather than, in this instance, all reports generated over the two years being released all at once. This would greatly assist local Parishes.
The Joint Rural Parishes are to submit a more detailed feedback on the Local Plan on our behalf, all of which Marr Parish Meeting fully supports and endorses.
1. Greenbelt Land
Marr Parish Meeting note the overwhelming and very strong response to previous consultations
where over 75% of the responses supported “The Borough’s overall housing and employment
needs should be met outside the Green Belt as far as possible so as to help protect the Green Belt”.
Marr Parish Meeting unanimously support this view and would like to see this strong opinion reflected in the Full Local Plan Draft.
We further support previous Consultation Feedback: there were a significant number of responders who supported the use of Brown Field sites in preference to Green Belt for
employment and development. This mirrors our very strong opinion, that it is crucial that the Green Belt bands between Doncaster, Wakefield, Barnsley and Rotherham are not eroded. It is our very strong opinion that Brownfield and existing redundant sites are prioritised over Greenbelt for development.
Based on the Greenbelt reviews, Marr Parish are still unclear which sites /if any are to be proposed for development for new homes or job creation, or which sites are being considered, with a view to be taken out of Greenbelt. Interactive Maps have been provided, however they are unwieldy and not easily negotiated, feedback which we have already fed back to DMBC representatives. We believe more clarity is needed on these site locations.
We maintain that affordable housing is not only needed and must be delivered within the Local Plan, however we do not believe that the Rural Communities can deliver the supporting services that will be needed e.g. public transport, health and Employment support etc .Even if
development of this nature could be considered ‘very special circumstances’ under Greenbelt
policies, we do not believe affordable housing in these locations could ever be sustainable. Affordable housing needs can only be realistically met within urban locations. We would again reiterate that our rural community maintains its view - that development in the small villages and hamlets must be proportionate, sympathetic and in keeping with their character to maintain our rural identities.
Marr Parish strongly supports and would welcome the new proposed planning policies, where growth is directed to larger and more sustainable settlements and also those policies which seek to continually protect our rural communities and identities. Marr Parish fully supported being
designated as a ‘Smaller Greenbelt Village’ with ‘no Identified Development Limits’ in the last 2018
consultation for the Local Plan. However, having consulted with communities to change their designation, which gained overwhelming support, DMBC have now withdrawn their intention and it will now no longer apply. Marr Parish maintains, that having completed a full review of the Greenbelt, with the sole purpose for this to act as a catalyst for changes to the Greenbelt for
Doncaster, DMBC then proposed a change to designate of some of the villages to ‘Smaller
Greenbelt Villages’. However, although several other changes to the Greenbelt are now to be
adopted within the Local Plan, the designation to ‘Smaller Greenbelt Villages‘ has now been
abandoned. With overwhelming support in favour of these new designations, Marr Parish advocate for this to be reinstated in the final version of the Local Plan.
We maintain, Greenbelt and Agricultural land are a very precious resource which must be protected. Marr Parish continues to object to proposals for additional Greenbelt land to be ‘safeguarded’. We do not believe that development necessitates the use of Greenbelt land but no more land should be taken out of Greenbelt than is vital. Land that will not be used for
development ‘over the life of the plan’, does not in our opinion mean that Safeguard land can be considered vital and as such, it cannot be considered ‘very special circumstances’. We strongly
object to Greenbelt land being safeguarded and insist that it should remain Green Belt Land within the Local Plan.
2. Housing Stock
For several years, Doncaster has suffered from an oversupplied property market and a reducing volume of Homebuyers in a financial position to purchase.
Marr Parish continues to recognise and acknowledge that if Doncaster is to flourish there could be a need for additional, sustainable housing stock but this must not be delivered “at all costs” or to the detriment of existing Rural Communities nor at the expense of Green Belt Land.
However, as Doncaster has approx. 4,281 vacant houses around the Borough, Marr Parish Meeting would urge DMBC to use The National Policy Framework which places the obligation on
Local Authorities with “compulsory purchase powers” to “bring back into residential use” vacant
houses and disused buildings. Historically, DMBC have been reticent to purse this obligation. Subsequently, for the new Plan to be considered ‘effective and sound’ this must now be considered a priority within the new emerging Local Plan with a commitment from DMBC and a transparent Policy for Doncaster.
We further believe that at 31% (as a minimum) of the 13,800 new homes that the “Homes and Settlements” document proposes, that this would deliver much needed Affordable/Social homes
in the Borough without the need to take land out of Green Belt to build even more new homes when such properties currently exist. We urge DMBC to ascertain how much housing stock is currently vacant within the Borough before making a commitment to significant investment in developing new housing stock to meet any potential future demands.
We advocate that this approach fully aligns to and delivers Affordable/Starter homes with
sustainability and in keeping with DMBC’s green policies and obligations.
Marr Parish note that in the draft Homes and Settlements proposal, the current total households for the Borough totals 130,165 and the draft still proposes an additional 13,800 new homes over the next 15 years.
DMBC’s latest proposals remain at 920 new dwellings per year, 585 to accommodate population rise within the borough and an additional 335 allocated for economic growth across the borough. DMBC project that 15,640 new dwellings will be required to meet demand over a 17 year period between 2017 – 2035.
In previous consultations we raised concerns over the targeted increase and the number of projected new dwellings within the draft Local Plan. We understand the rationale and the basis on which this target has been established, however, our concerns still remain the same since this still constitutes an increase of +10% on the total available housing stock across the borough, a borough which has one of the worst performing housing markets in the UK. Marr Parish agree with DMBC’s proposal to objectively evaluate and measure the number of new jobs and homes annually. We believe, plan delivery means they are co-dependant on one another and this must be implemented to ensure they achieve an equally balanced delivery for economic growth.
Marr Parish Meeting welcome DMBC’s aspirations to be a “greener” Doncaster and that the Draft Proposal will ensure that developers set aside 10% of land for “green spaces”. We believe that this
could have a positive influence on reducing obesity and improving health and wellbeing for the whole community.
In every community, Parks and green spaces are important amenities, however due to restricted budgets DMBC have stated over the last few years that they have little/ no funding available to provide new or replacement play equipment. Instead play equipment has had to be sourced through grant funding applications, as is the case in point with Marr Park. We are not aware of