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 Mrs
First Name Rhonda
Last Name Job Organisation Marr Parish Meeting (where relevant) Address – line 1 Grove Farm Bungalow
Address – line 2 Church Lane
Address – line 3 Marr
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’ (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:
Marr Parish Meeting
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): ☐ Please see JRP submission. Please see JRP submission.
2. To which part(s) of the document / map does your response relate?
Page No.: Paragraph: Policy Ref.: 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.
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 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:
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.
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 evidence in support of DMBC’s Chief Financial Officer recent statement ‘…. All of the unspent section 106 funding is earmarked for a range of developments including improving public open spaces which may include installing new play equipment and improving parks and woodland areas…’
Contrary to this, Marr Parish has experienced a different scenario over play equipment being removed from its park but not replaced. With DMBC claiming they have no funds available to replace or install new equipment the only recourse left to us, is to instead, look to source the play equipment through grant funding application.
As stated previously, Marr Parish welcomes DMBC’s aspirations to be a ‘greener’ Doncaster but based on historic evidence, we have little confidence in this ever being delivered or moving past an ‘aspiration’.
3. Infill
DMBC proposed significant changes to the Settlement Hierarchy with 28 previously ‘Defined Villages’ to be classified as ‘Smaller Greenbelt’ or ‘Washed over Greenbelt Villages’ with no’ Identified Development Limits’. The proposal listed Marr as one of these villages to be re- categorised and Marr Parish still welcomes and advocates for a change to ‘Smaller Greenbelt’ village.
Marr Parish fully supported the re-categorising of the 28 villages to ‘washed over green belt’ status, including our own village, provided the Council only permit Infill development in the small villages and hamlets in line with the stated policy and with the assurance that any application for such development which must be proportionate, sympathetic and in keeping with their character.
DMBC have stated that: 5.2.3 It is acknowledged that some sites within the existing settlement limits (infilling) of the ‘Defined Villages’ could still come forward and would be compliant with the settlement hierarchy as set out, but these are not being relied upon for the purposes of the Local Plan. Any such sites will be an additional supply of housing (windfalls). Due to the Local Plan not being reliant on this source of supply for housing allocations to meet the plan period’s housing target, they were not assessed any further. Since the ‘Call for Sites’ stage in autumn 2014, some of these sites could (and indeed have) come forward with a planning application in advance of the Local Plan e.g. existing UDP allocations, or land within designated Residential Policy Areas
We noted that the proposed settlement strategy did not direct housing to the smaller ‘washed over Green Belt’ villages (now Defined Villages) and DMBC have stated that they do not propose to allocate sites in these settlements within the proposed Local Plan, irrespective of the Green Belt status. We would therefore urge DMBC to remove any and all proposed development sites identified and included within the previous ‘Call-for-sites’ for our village as these should now be considered inappropriate and unsupported by both Marr Parish and DMBC. It is contrary to the settlement hierarchy, any development is ‘not relied’ upon to achieve DMBC’s housing target and development cannot be considered sustainable since it is well documented by DMBC - that development cannot be supported in villages which have no services whatsoever.
We do not support an allocation of housing distribution for Barnburgh & Harlington and Sprotbrough Village which have been categorised as ‘Defined Villages’. Sprotborough Village has already identified its housing needs and has created a Neighbourhood Plan. The Local Plan development proposals now conflict with this. Particular consideration must also be given to the impact of new dwellings proposed on land that floods at Barnburgh/Harlington.
Marr Parish acknowledges that DMBC has undertaken a detailed review of all Settlements and an assessment of local Services in these locations - including those services currently in Sprotbrough Village and Barnburgh/Harlington. The Local Plan asserts that some services exist in these rural villages however, it neither considers nor assesses service availability or accessibility. Services in both these villages are at capacity, with bus routes and local roads congested and oversubscribed schools. It is impossible to see how development here could be considered sustainable.
As such, we do not agree with the proposed development sites and scale of development identified within the Proposed Local Plan for these two Defined Villages.
Unacceptable levels of congestion continue to plague and impede vehicle movement on these and surrounding ‘B’ routes. This will be further compounded by the addition of a proposed 445 – 1000 new houses in Mexborough, huge development plans along the Dearne Valley Parkway which Barnsley Council propose to deliver through their own Local Plan – all of which will result in increased vehicle traffic on routes through and around the villages.
We strongly object to the inclusion of these new developments within the local plan, as they cannot be considered reasonable or sustainable.
4. Services
Marr Parish notes from previous consultation feedback, the “Homes and Settlements” proposal, Doncaster’s current population = 300,000. If, as the Draft Proposal suggests, 13,800 new homes will be added over the next 15 years and assuming two residents per new home, this translates to an additional 27,600 potential new residents – equating to a +9% increase on the current population.
We appreciate that a more detailed Settlement Review has been conducted along with services identified within each settlement area. We further note and agree with the decision that targeted development for new dwellings has been directed to areas where services are more prevalent and more readily available. However, even after consultation has been conducted with service providers, we remain unconvinced that the Local Plan has assessed or has made robust plans for, how it will adequately address the impact on such services. The Local Plan must ensure that the needs of the projected increase in population can be met by all current major providers and all other essential services e.g. schools, GP’s, Dentists, Public transport capacity and duration and Hospitals. It is our opinion that these services are critical to sustainability and should be further scrutinised. Without confidently outlining how this is to be delivered, any proposed Local Plan cannot be considered “sound, effective or robust” if we are unable to ensure that our services meet current and future needs.
There are several recent examples e.g. where a large new housing development in Woodlands has led to issues where there are no available school places at the local schools. This has resulted in children and parents having to travel significant distances to remote schools at Hooton Pagnell etc where even at this school there is no classroom availability and makeshift classrooms have been created in the main school hall. This cannot continue and it is most certainly not ‘effective or sound’ practice for a new Local Plan which has targeted a significant growth in housing. This also encourages more travelling than should be necessary and subsequently, is contrary to and is not in keeping with DMBC’s reduction of carbon emission Local Plan Policies.
We have further concerns regarding Doncaster Royal Infirmary, the main Hospital for the Borough and availability of service. Since it has been well publicised that the hospital has capacity issues and is struggling to maintain services for the current population, with suggestion that £millions of pounds of investment is required just to service the current volume of patients. Marr Parish maintain that additional investigation is needed to ensure provision of services can be provided for all existing as well as the projected new resident increase if the Local Plan is to be considered ‘sound’.
5. Social/Affordable Housing
The proposed Draft Plan did not provide an in-depth assessment or provide evidence to support the true need for Social housing. Social and Affordable housing were just “lumped in” within the annual projected target of 338 new homes required [which accounts for 37% of the total per annum] by the planned economic growth. It is Marr Parish Meetings view that Doncaster’s population has an increasing need for such housing which does not seem to be provided for nor is it prioritised within the Local Plan. This must be clarified, specific targets must be set to ensure that both developers and DMBC know what has to be delivered, in order to meet the future needs of the Borough.
Marr Parish also note that Section 106 Agreements, which allows DMBC to get money from developers in exchange for granting planning permissions for projects, has amassed a total of £5.7 million. It is our understanding that this Section 106 money was collected for the sole purpose and its intended use was for it to be spent on the communities who would be directly affected by the new development projects in their area. This money has been collected and earmarked for affordable housing, improvements to public open spaces like play parks, as well as, the provision for new school places to address the expected uptake in population from families and residents purchasing new houses in these developments.
We do not agree with the current policy, where this Section 106 money is accumulated to create a large fund, only then to be spent on a bigger project unrelated to the areas that have been impacted by new development. It is our understanding that this money was intended to be spent in areas where development has taken place and to off-set impacts of such development in those areas. It appears that this is not always the case. We further believe, at the outset of proposed development projects DMBC must have identified impacts and what these impacts would have on communities, hence, the request for contributions from developers towards addressing these, under Section 106 Agreements. We firmly believe that money collected from developers should benefit and be spent in the communities where development has taken place. Instead, it would appear that the majority of this 106 money is being ‘accumulated’ to provide finance for new affordable housing projects. This would suggest that DMBC is the only main beneficiary. Since, any new affordable houses will have been delivered through external finance and not from DMBC’s own budget but it also means, that DMBC will boost its own income from additional rates, revenue gained from these new homes. We acknowledge that affordable housing is needed but we do not accept that it is reasonable for these to be delivered at the expense or detriment of other communities and the new Local Plan Policies should ensure that 106 money is spent in the communities impacted by the development.
6. Elderly/Ageing Population
The majority of the “Homes and Settlement” Draft Proposal appears to concentrate on “how” the number of new homes required was determined along with “where and what quantity” DMBC propose to disperse this number throughout the Borough to meet varied demographic needs. However, Marr Parish believes that DMBC have omitted to robustly address our elderly population within this proposal.
In the Local Plan Reports DMBC state: ‘Like many parts of the country, Doncaster’s population is aging, with the 2015 Housing Needs Assessment predicting that the number of older people is set to increase by 36% between 2015 and 2032, whilst younger age groups are predicted to slightly decrease. This brings social and economic challenges for the borough.’
Currently the over 65 population accounts for 25% [75,600] of our 302,400 population but by 2032 this is expected to rise [an increase of almost 38,000] to 36% [113,148] of the 314,300. Marr Parish Meeting observes that this significant demographic group has not been properly addressed within the plan.
Marr Parish Meeting cannot condone this oversight, DMBC has an opportunity to rectify this oversight by delivering much needed private residential retirement developments aimed specifically at the needs of an ageing population where housing design and the provision of on- site services and support are fully integrated. In doing so, it is our view that such developments will provide suitable choice of accommodation and allow the elderly population to plan their future needs. This would release existing housing stock across the Borough – particularly within the rural communities – enabling residential areas where property demand is high but availability is limited, to become accessible to a wide and diverse range of new residents. .
DMBC has based its target for new dwellings on the future needs of families and younger people. However, since the report states: ‘…younger age groups are predicted to slightly decrease…’ the subsequent number of new houses apportioned to this age group appears skewed. We believe the future housing needs of the borough should be revised to better reflect the future changes in demographic age profiles.
In view of the issues outlined above, Marr Parish believe that in its present format, the proposed. Draft Local Plan, does not appear to be sufficiently robust and therefore is not “Fit for Purpose” as it does not meet the identified “Future Needs” of the Borough in this regard.
7. Renewable Energy
In the Local Plan proposals, Doncaster describes how it will strive to be a leader in Renewable Energy. Marr Parish believes this to be an admiral objective & is still one that it would like to support, however, it has major concerns on how DMBC are to achieve this status. Scarring the Greenbelt Landscape with Wind Turbines Solar Panel Farms is an issue we strongly object to. If DMBC are to deliver this objective then perhaps compulsory Solar instillations on all new builds could be the first step, followed by suitable large Roof Tops e.g: Industrial, Commercial & Agricultural buildings & large shed structures and a managed roll out of residential roof spaces. Thus utilising, existing, vast redundant acres of space. This would be fully aligned to the Borough’s Vision, Aims and Objectives. Until we maximise & exhaust the opportunities that currently exist, we cannot support any proposal to cover valuable Greenbelt or Agricultural Land.
8. Development Land Allocation
Marr Parish are in principle supportive of DMBC’s strategies provided existing redundant and brownfield sites are prioritised over Greenbelt locations and we do not believe, job creation can be considered ‘very special circumstances’.
We also agree with DMBC’s assessment of the A1(M), that no development should occur along this route until after the A1(M) has been upgraded, since it will restrict options for it to be widened and lead to further congestion.
Marr Parish reiterates its very strong opinion, that widening of the A1(M) should be to the east, since rural, Greenbelt Conservation villages are located too closely to the west.
In keeping with its economic growth proposals, as well as, being one of the 7 Economic Target Areas in the Sheffield City Region – Marr Parish fully support development of brownfield land along the M18
9. Economic Growth
Marr Parish note that DMBC have increased their new job target from 20,000 to 27,100 in the Local Plan, for the next 15 years. We consider another 7,100 is quite a significant increase and represents an uplift of 35% in new jobs projected against a background of economic uncertainty. We consider such an increase is optimistic and agree (as previously stated) with DMBC that an annual review should be carried out, to ensure that the borough’s new job creation meets with its new homes targets.
10. Transport Links & Infrastructure
Marr Parish Meeting understands how vital Transport Links are & how they can contribute to the prosperity of the Town, combined with the need to have an Infrastructure that supports growth and this is considered in our views and concerns.
1) Marr Parish note the feedback from the previous consultation, in that 77% of the responses “….supported the expansion of the A1/A1 (M) to a) improve connectivity and b) relieve congestion. However...many people are of the opinion that the impact on the Green Belt should be kept to a minimum and that improvements should not necessarily be a precursor to further development in the A1 corridor”.
Marr Parish unanimously agree with this view and support DMBC in their assessment that development along the A1(M) corridor is inappropriate,…’there are congestion problems along the A1(M) which currently limit the delivery of new large scale strategic employment sites…’ a decision supported by Highways England on the grounds of ‘capacity and safety concerns’.
2) Marr Parish support the proposed widening of the existing A1/A1 (M) but is completely opposed to the creation of a new build A1/A1 (M). However, where the A1/A1 (M) currently runs (from the northern boundary of the Borough to Marr) there is only a narrow band of Green Belt Land separating a number of rural villages and farms from this road. We acknowledge that some Green Belt land will potentially need to be utilised to enable road widening but this must be kept to a minimum. Marr Parish would not support the expansion of the A1/A1 (M) to the west or the creation of a “new” A1/A1 (M) on Green Belt land which as a result would create Green Belt land isolated within an old and new A1/A1 (M).
3) Marr Parish still firmly believe there is no requirement or public demand for a link road between the A19 and A1 (M) and therefore does not support it. We also noted from previous consultation feedback that this proposed initiative had by far the lowest support ‘and attracted a number of negative comments’. Highways England Route Strategy 2015 states: ‘….one of the priority issues is the capacity and safety concerns on the A1 between junctions 34 (Blyth) and Holmfield Interchange (M62)’. And they further state: ‘… and there is a lack of capacity to support growth…’ We support DMBC in their interpretation of Highways England when they state ‘…it is unlikely that extra traffic on the A1 (M) will be supported by Highways England….’
The proposed A19 link road to the A1 (M) will mean generating extra traffic onto this already congested stretch of the A1 (M). In light of overwhelming evidence against this proposal Marr Parish cannot understand why this link road remains in the Local Plan and we reaffirm our objection to this link road on these grounds.
There is more than sufficient access to the east of the Borough and beyond via the A1 to the M62 or M18 or via the existing A19 and as such we believe this scheme should not be included within the Full Local Plan Draft.
4) Marr Parish agrees with DMBC’s appraisal of the M18 that it has capacity for further growth. Along with 77% of respondents on previous consultation feedback, we also support development along this transport corridor and acknowledge that it is ‘of strategic importance for freight and logistics as it is a vital link to a number of strategic road network sections in SY as well as to the Humber ports….’ there are significant levels of growth which are focused along the M18 corridor and that it will need to be adapt to additional traffic flows created by corridor developments and increases in tonnage through the Humber ports…’. Development here has the ability to grow in line with demand and we note ‘Together with demand information which shows that large end users wish to be located along the M18 and congestion & access issues along the A1 (M), there is currently no exceptional circumstance justification for Greenbelt land to be allocated for employment use, and no Greenbelt sites will be proposed for allocation.’. As previously stated, we recognises the strategic importance of employment development along the M18 and the opportunity to deliver Lorry Parks on Brownfield and that in doing so, it will not consume any Greenbelt land, a policy which we fully support and endorse.
5) We support the dualling of the A630 Westmoor Link Road to improve access to Wheatley Hall Road / Kirk Sandall and potentially release the vast acreage of land and large number of underdeveloped brown field sites in this location for development.
6) We support the Hatfield Link road scheme to connect Hatfield/Stainforth to Junction 5 of the M18/Junction 1 of the M180 and unlocking 200ha of development land.
7) We remain encouraged by previous consultation feedback, in that ‘Clearly the A635 Bypass is the favoured scheme and has received a significant number of comments in support’. Supported by 66% of respondents, it received by far the strongest support for road schemes and similar to that of the A1 (M). With strong declared support and endorsement from Doncaster’s electorate, Marr Parish believes this Bypass should be included within the Full Local Plan Draft Proposal.
As Doncaster grows, there will be an increasing imperative to address the congested trunk roads in the West of the Borough. We firmly believe the much needed A635 by-pass must be a priority for delivery within the Local Plan. Previously, we believed The Local Plan demonstrated a preference for concentrating the majority of its trunk road development proposals towards the east. We consider this may now be corrected with the inclusion of this by-pass within the Local Plan. It is critical to improving accessibility and connectivity to neighbouring towns and boroughs in the Sheffield City Regional Council, as well as Wakefield, which are all only accessible via the west. We still maintain that improved transport links to these boroughs and towns will lead to greater development opportunities.
Within their Local Plan reports, DMBC further acknowledge that Sheffield City Region has cited the A635 as one of the ‘top 20 highways forecast to experience delays and could limit economic growth’. With such a poor endorsement, it is imperative that a rapid solution be implemented to address these issues. Doncaster cannot afford to lose the potential for economic growth if it is to meet its ambitious growth targets, as detailed within the draft Local Plan.
Currently all trunk roads to the west side of the Borough are congested and are in use 24/7 along the A635 and the A638. The latest figures for the A635 show 15% of vehicles thundering through Marr and Hickleton are HGV’s. Marr parish would like to see the upgrading of these trunk roads in the Finalised Local Plan Proposal to reduce traffic congestion, pollution and round-the-clock noise pollution in Hickleton, Marr and Hampole, and to improve access to Barnsley and Wakefield respectively. The Local Plan suggests a route for the by-pass, however, this has yet to be determined with external consultants presently carrying out an outline business case for a by-pass, including several route recommendations.This view is mirrored by 73% of the respondents who agreed with the statement ‘Greater emphasis should be given to managing traffic movements to reduce accidents and improve air quality’. DMBC proposes to develop thousands of homes near to and around the A635 e.g. at Brodsworth, Woodlands and Mexborough, added to this the thousands of homes projected to be built by Barnsley MBC within the vicinity of the A635, the resultant increase in vehicles along these routes will have a further detrimental and devastating impact on the safety of our roads, the environment and communities.
Within these, our village and residents continue to have very real, credible and valid concerns about the resulting impact that this pollution is having on their own health, their children’s and that of their elderly neighbours. DMBC stated over the last 2 years that the A635 exceeded DMBC’s own safety volume criteria, traffic volume has increased and resulting congestion is exacerbating already dangerous high levels of Air Pollution. Fumes from road vehicles have created poor Air Quality through both Marr and Hickleton, with NOx levels consistently above and in excess of 150% of the maximum permitted levels set by DEFRA. Air Quality levels at Hickleton are the second highest recorded in Doncaster. The volume of commuters travelling to and from Doncaster to Barnsley, means that congestion directly impacts other road transport routes which link into the A635 e.g. Scawsby, Barnburgh & Harlington, High Melton, Pickburn and Brodsworth. This cannot be allowed to continue.
Doncaster's ambitious growth plans, together with Barnsley’s development proposals and a congested A1, will only serve to exacerbate this situation. DMBC must prioritise and invest in the existing road/transport infrastructure before it proposes to invest in new link roads, if it is to meet its expected housing growth needs. As a result, the A635 bypass is now a “need to have” in the full Local Plan Draft Proposal. We support DMBC’s new Policies on Air Pollution, Noise Pollution, inclusive communities and road congestion and advocate that they are given equal weight in consideration of planning applications as previously these issues have been given very little regard.
8) We strongly oppose the current High Speed Phase 2b proposed rail route through Doncaster and South Yorkshire as well as a proposed rail junction at Clayton or a Dearne Valley Parkway Station.
9) We agree that rail links to the Airport would help to take traffic off the roads and aid congestion.
11. Planning Policy
We believe there needs to be a change in Planning Policy. It is essential that DMBC carry out full due diligence at proposed Development sites. They must instigate and invest in Traffic surveys in order to assess the individual and cumulative effects of any proposed development.
We believe it reasonable to expect prior independent surveys be carried out by DMBC and not by any proposed developers before any proposed sites can even be considered as potentially appropriate or suitable for development. It is vital that cumulative impacts from proposed developments are measured at the outset to establish what the compounding impact will have on neighbouring villages & communities and on already congested trunk /local transport routes. This must be done ahead of sites being designated as appropriate or they cannot to be considered truly sustainable.
It is our very strong view that DMBC must not allow individual site assessment to be undertaken and/or funded by developers, since all reports will be presumed as biased and prejudicial in their favour. Current Planning Policy dictates that individual developers finance impact assessment reports only specifically relating to their own proposed development plans. The Planning Committee can then only base their decision on an individual ‘case by case’ basis.
With many sites being proposed for development within the local plan, we have both a duty and an opportunity to address accumulative effects, thus preventing us from creating new problems or adding to problematic road congestion or increasing particulates leading to poor or worsening Air Quality. Awareness of the cumulative impacts means that we can stop these types of issues happening before they arise. This would be in keeping with DMBC’s Carbon Emissions and Green Policies.
When DMBC have completed the Local Plan, a list of all potential development sites will be created. It is our very firm view that such development sites are all independently assessed by DMBC but pre- financed by the developer. This would provide not only an independent assessment of each site but would highlight any accumulative effect of delivering multiple developments within areas. Developers must then work together to fund any remedial, preventative or mitigation measures resulting from their multiple developments. We believe this proposal is a reasonable and rational solution. If implemented, it gives the opportunity to address or prevent cumulative negative impacts created by DMBC’s extensive development plans within communities. We recommend this policy is reviewed and considered for implementation.
12. Mineral Extraction
Marr Parish considers that it is vital to assess the value of minerals before any development takes place and the impact on environment, landscape and local communities is fully understood. We agree with DMBC that no homes should be developed near potential Mineral sites which may hamper or prevent extraction. We think this is a sensible approach.
Whilst Marr Parish Meeting welcomes the opportunity to provide input into the development of the Local Plan, we are still extremely concerned that the process would seem to prioritise the demands and requirements of Developers and Landowners resulting in a plan driven by the commercial aspirations of private organisations and not by the residents of Doncaster. We further believe, if the right balance is not achieved, then the resulting Plan cannot be considered robust, effective, sound or fit for purpose nor in the best interest of the Borough nor its residents.
We ask that Marr Parish’s submission be included in the Doncaster Local Plan Consultation and we request that the content of our feedback is forwarded to the Inspector and that it will be carefully considered.
I would like to thank you once again, for the opportunity to engage in the process and for taking the time to read our contribution.
I would be grateful if you would confirm receipt and acknowledgement of our response by e-mail to:
Yours Sincerely
Mrs Rhonda Job Chairman Marr Parish Meeting
Grove Farm Bungalow Church lane, Marr Doncaster DN5 7AU