Comments (Representation) Form

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

First Name Neil

Last Name Westwick Organisation Theakston Estates Limited Lichfields (where relevant) Address – line 1 c/o agent The St Nicholas Building

Address – line 2 St Nicholas Street

Address – line 3 Newcastle upon Tyne

Postcode NE1 1RF

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:

Theakston Estates Limited

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.: Chapter 3 – pages 14 to 16 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.

We respond on behalf of our client, Theakston Estates Ltd (Theakston Estates), in relation to land at Scawsby Lane, Scawsby (ref 436) which is located within the Main Urban Area (MUA).

We welcome the Council’s ambitious strategy, which ties in with the Sheffield City Growth Plan, for Doncaster to “become an important economic hub”. Given Doncaster’s location in proximity to Doncaster Sheffield Airport, the East Coast Mainline and the strategic road network, there is a clear opportunity for Doncaster to become a leading centre in logistics, aviation, rail and civil engineering which is recognised in the vision.

Investment and growth in transport infrastructure is a key component of the Northern Powerhouse initiative to make the cities of the north a powerhouse for the UK economy once more. Capitalising upon its excellent road and rail links, and the international connectivity offered by Robin Hood Airport, Doncaster has become an important logistics hub. Similarly, the financial and business sectors have grown significantly, alongside a focus on creative and digital industries, further diversifying and strengthening Doncaster’s economy.

The outlook for Doncaster, in this context, is extremely positive with the Borough forecast to experience significant economic and population growth in the future.

There are 20 draft objectives proposed to realise this vision including 9, 10 and 11 relating to homes and communities. Objectives 9 and 10 require that “housing provision meets the housing need and aspirations by increasing the provision of new homes for all to meet current and future needs” and to “focus new homes primarily within the main urban area of Doncaster”.

Theakston Estates agrees with the approach to focus the delivery of new housing in the main urban area (MUA) as this is clearly the most appropriate and sustainable location for growth. However, as set out in our other responses (including those to draft Policies 2, 3 and 16), the plan does not currently meet these objectives as there is a clear shortfall of sites identified in the MUA. Furthermore, the draft Plan is currently seeking that at least 50% of new homes is delivered in the MUA; however, the ‘Doncaster Council Core Strategy 2011-2028’ (adopted May 2012) seeks a higher figure of closer to 64% in the MUA.

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).

To ensure a sound Plan through ensuring that its strategy is consistent with the Plan’s vision and objectives, additional sites need to be identified and allocated within the Main Urban Area. This is discussed in response to Policies 2, 3 and 6.

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:

The issues are complex and require further debate during Public Examination of the Local Plan.

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

Your Date

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.

Part B

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

Name / Organisation Name:

Theakston Estates Limited

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

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

Page No.: Paragraph: Policy Ref.: Policy 2 – Spatial Strategy and Site Ref.: Settlement Hierarchy 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.

Draft Policy 2 sets out the Council’s spatial strategy and settlement hierarchy and states that new development will be focused in and around existing urban areas (primarily the MUA, the main towns and services towns and villages. This policy continues by stating that “at least 50% of new homes will go to the ‘Main Urban Area’” (Theakston Estates emphasis).

Theakston Estates agrees with the approach to focus the majority of housing delivery in the MUA. However, this is a significant dilution the amount of housing which was previously directed to the MUA, and endorsed by the Inspector, in the adopted Core Strategy which is up to 64% (Table 1). The supporting text states:

“The South Yorkshire sub-regional centres (e.g. Doncaster) play an important part in driving economic growth but their ability to do this is hampered by a dispersed settlement pattern and unless this issue is resolved South Yorkshire will not be able to transform its economy and environment and address the problems of social disadvantage and exclusion.” (para. 3.10).

“The policy seeks to distribute growth and regeneration where it would do most good in terms of supporting prosperous and sustainable communities by improving the economic performance of towns, promoting regeneration and tackling deprivation. It seeks to achieve a balance between a focus on Doncaster and sufficient growth and regeneration in the outlying towns.” (para. 3.12)

The Inspector’s ‘Report to Doncaster Metropolitan Borough Council’ (26 March 2012) stated in relation to the Core Strategy distribution focusing on the MUA that:

“In this way, the Core Strategy seeks to change the pattern of development to ensure better access to services and especially public transport. This is a vital aspect of sustainable development.” (para. 35) (Lichfields emphasis)

Importantly, with regard to the Doncaster MUA, the Inspector’s Report concludes that the “assets, challenges and potential of the town require a figure at or very near the top of that range.” (para. 15) (Lichfields emphasis). As such, it is clear that the Inspector considered that the housing requirement for the MUA should be around 64%.

Theakston Estates submits that the proportion of development in the MUA should follow the Core Strategy (i.e. 64% of new homes within the MUA). This would alleviate pressure on less sustainable settlements and would focus new development in the most accessible locations, which, as the Inspector advised in his report, is a vital aspect of sustainable development. Increasing the number of new homes delivered in the MUA would also make a most significant contribution towards driving forward the economic growth of Doncaster as an important sub-regional centre in South Yorkshire.

With regard to the settlement hierarchy, Theaston Estates agrees with the recognition in draft Policy 2 that to strengthen the role and to meet the growth objectives and regeneration needs, Doncaster MUA “will be the main focus for development in the Borough, including housing, retail, leisure, cultural, office and other employment development.”

Furthermore, there has been a substantial shortfall of completions in the MUA over the last 4 years, with an average of 42.7% being in this area. The number of completions in the MUA compared with the total for the Borough are provided in the following table:

Year MUA Borough Total 2014/15 308 881 2015/16 459 1,025 2016/17 555 1,049 2017/18 426 1,137 1,748 4,092 Source: Doncaster’s Residential Lane Availability Reports

Taking the above into account, there is an identified need to achieve a step change and allocate more homes within the MUA ahead of the requirement. Otherwise the Plan will fail to achieve its objective and policy requirement to deliver the majority of new homes in this area.

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

To ensure a sound Local Plan, Theakston Estates submits that the proportion of development in the MUA should follow the Core Strategy which directs up to 64% of new homes to the MUA. This approach would alleviate pressure on less sustainable settlements and would ensure that new development is directed to a location that will have the maximum benefits in terms of driving economic growth forward in Doncaster an as important sub-regional centre.

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:

The issues are complex and require further debate during Public Examination of the Local Plan.

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

Your Date

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

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

Part B

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

Name / Organisation Name:

Theakston Estates Limited

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

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

Page No.: Paragraph: Policy Ref.: Policy 3 and Chapter 16 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 ☒

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.

Policy 3 (Level and Distribution of Growth)

Policy 3 identifies the need to deliver 18,400 new homes in the period 2015 to 2035 (920 per annum), with sufficient land allocated to deliver 15 years’ supply of housing (13,230, or 882 dpa once supply in the years 2015 to 2018 is deducted from the overall requirement). However, 2019 to 2035 is 17 years, not 15 years and hence the Plan is 2 years short.

Theakston Estates consider that this is a significant change since the Draft Plan for informal consultation. Policy 3 has shifted from stating that the 920 dpa is a minimum figure (‘at least’), to stating that the housing requirement is a range from the Local Housing Need (585 dpa) to 920 dpa. Theakston Estates does not feel that this policy is sound as it does not support a positively prepared plan which is supportive of boosting significantly the supply of housing. We consider it important that the wording in Policy 3 should state that the 920dpa is a minimum and reflect the wording in the Draft Plan for informal consultation where the 920 dpa was stated as ‘at least 920 dpa’.

Notwithstanding the above, the 920 dpa identified in Policy 3 is not evidenced within the ‘Economic Forecasts and Housing Needs Assessment’ (June 2018) (prepared by PBA) and it is unclear upon which evidence the 920 dpa figure is based. The PBA report states that in order to support the job-led scenario which supports the economic ambition of Doncaster and the Sheffield City Region over the plan period, 1,073 dpa would be required. This level of future housing is needed to support the jobs-led scenario over the plan period and to help drive forward economic growth across the Borough. Indeed, paragraph 2.9 of the draft Plan states that Doncaster is reasserting itself as a major economic centre within northern England, whilst the vision advises that by 2035 Doncaster will be a more important economic hub with a stronger, more balanced and productive economy. The draft Plan’s vision is informed by the ambitions of the City Region, its Strategic Economic Plan as well as the Northern Powerhouse ambitions. To enable the Plan’s vision to be achieved, it is most important that the Council’s Plan is positively prepared and that it’s housing requirement is aspirational but deliverable, in accordance with the National Planning Policy Framework (NPPF) (February 2019, but updated June 2019) (para. 16).

Furthermore, an annual housing requirement of 1,073 dwellings is more aligned with housing delivery in recent years. The annual Doncaster Residential Land Availability Reports show average net completions over the last 3 years of 1,070. It is anticipated that this could rise when the net delivery figures for 2018/19 are published.

Table 1 Doncaster Past Net Housing Delivery Year Net no. of Homes 2015/16 1,025 2016/17 1,049 2017/18 1,137 2018/19 1,327* Source: Residential Land Availability Reports *number to be confirmed but current Council estimate based on methodology used in RLA

The PPG at paragraph ID :2a-010 is clear that the government remains committed to ensuring more homes are built and support authorities who want to plan for additional growth and as such the standard method is a minimum starting point in determining the number of homes needed in an area. The PPG goes on to identify the circumstances where it may be appropriate to consider whether actual housing need is higher than the standard method. These include where:

• Growth strategies are in place such as Housing Deals; • Strategic infrastructure improvements are identified; and • Previous levels of housing delivery are significantly greater than the standard method.

The PPG is clear that in these situations authorities will need to take this into account when identifying future needs. Doncaster’s Publication Local Plan does identify a housing requirement as a range, of which the upper end is above the standard method, trends in past delivery and the aspiration to support an economic led future for Doncaster suggest that in order to plan positively for the future it would be more appropriate for the housing requirement in Doncaster to be set at the 1,073 dpa to ensure that the vision can be achieved.

Accordingly, Theakston Estates considers that there is a need to increase the housing requirement identified in Policy 3 to state at least 1,073 dpa, in line with the Council’s own evidence, if the vision for the plan is to be achieved. The minimum housing requirement for the MUA should also be increased to reflect this update.

Finally, Policy 3 should make it clear that the number of homes per annum is a net figure. The Draft Plan which was issued for informal consultation in October 2018 explicitly stated that the annual requirement was a net figure; however, it is not clear whether the annual requirement in the Publication Plan is a ‘net’ or ‘gross’ figure.

Delivery in the Doncaster Main Urban Area

As discussed in response to draft Policy 2, Theakston Estates considers that the delivery of ‘at least 50% of the Borough’s Total Housing’ in the MUA is a significant dilution to the 64% of housing which was previously directed to the MUA, and endorsed by the Inspector, in the adopted Core Strategy.

To ensure a sound Local Plan, Theakston Estates contends that the proportion of development in the MUA must accord with the Core Strategy which would alleviate pressure on less sustainable settlements and would drive forward economic growth in the Doncaster, an important sub-regional centre.

Reserve Development Sites

Paragraph 4.43 discusses the approach to the “Reserve Development Sites”. The Council considers that these are potentially suitable urban sites (mainly in the Doncaster MUA and Mexborough) but where deliverability issues (mainly associated with flood risk mitigation and / or directly impact by the safeguarding route of HS2) have prevented them coming forward and where their development in the plan period cannot at this time be demonstrated. This paragraph continues by stating that if they came forward within the plan period they would be additional to the allocations.

Theakston Estates has fundamental concerns regarding the approach to the “Reserve Development Sites” given their constraints, especially given that some of these sites are subject to flood risk and that alternative sites are available, such as land at Scawsby Lane (ref 436), that are not at risk of flooding. As these sites are not deliverable / developable they should have no status in the Plan. Please see the response to draft Policy 6 for details of the concerns and how the approach conflicts with the NPPF.

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).

To ensure a sound Plan, Theakston Estates contends that the housing requirement identified in Policy 3 must be increased to state at least 1,073 dpa, in line with the Council’s own evidence provided in the ‘Economic Forecasts and Housing Needs Assessment’ (June 2018) (prepared by PBA). Otherwise, the housing requirement would not have been underpinned by a relevant and up-to-date evidence and hence the Plan would not be sound, contrary to the NPPF (February, 2019) (paragraphs 31 and 35).

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:

The issues are complex and require further debate during Public Examination of the Local Plan.

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

Your Date 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

Part B

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

Name / Organisation Name:

Theakston Estates Limited

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 6 and assessment of site Policy Ref.: 436 in the Sustainability Site Ref.: 436 Appraisal Policies Map in relation to Policies Map: Green Belt

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 ☒

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.

Plan Period

The plan period runs from 2015 to 2035; however, the plan period for land supply runs from 2018 and, in the case of housing only runs until 2033 (Table 5). This is an unnecessary complication and must be revised to ensure the plan period and supply period run from the same dates. At the current time, the Plan is not considered to be sound because it fails to provide an appropriate strategy in relation to housing supply, contrary to the NPPF (para. 35).

Housing Trajectory

The Housing Trajectory set out in Figure 3 confirms that the requirement of 920dpa will not be reached in the final 9 years of the plan period and 550dpa (Standard Method Requirement) will not be achieved for 7 years of the plan period. Indeed, the trajectory drops off to approximately 100 dwellings in the final year. This approach would have the following significant and fundamental harmful issues:

• Failure to meet annual housing requirement – the OAN should be a minimum figure to be achieved on an annual basis – this is acknowledged within Appendix 12 of the draft Local Plan which confirms that net dwelling completions will be monitored each year against a target of 920dpa – although as advised in response to Policy 3, the annual requirement should be 1,073 dpa rather than 920pda, in accordance with the Council’s own evidence contained within the PBA report. The Council should therefore be making provision for the delivery of 1,073 dwellings each year throughout the plan period. The Council’s proposal to exceed 1,000dpa in the earlier years of the plan does not justify the significant decline in delivery proposed in later years. • Significant Adverse Practical/Economic Effects – the differentiation between the levels of growth sought at the start of the plan period and those in the later years will have significant adverse economic impacts for Doncaster. The dramatic shift from higher levels of provision to under- provision will lead to a significant drop in job availability within the construction industry and a significant decline in economic input from the house building industry in Doncaster in the later years of the plan. The housing delivery strategy must therefore be revised to ensure it sustains growth across the plan period and does not lead to a decline in Doncaster’s economy in the later years of the plan.

It would be inappropriate for the Council to simply redistribute the housing delivery across the trajectory because this would affect delivery and artificially suppress demand, which would be an unsound approach. Importantly, sites with planning permission have a combined capacity of 9,318 dwellings (draft Plan para. 4.73) and hence it would now be impossible for the council to redistribute and control when these sites are delivered. It is contended that additional sites should be allocated, for the reasons provided elsewhere in Theakston Estates’ representation, and that the housing trajectory should be amended to show the delivery of more new homes from 2026/27 onwards.

Based on the position as outlined above, the strategy for delivery of housing in Doncaster is not positively prepared and fails to support growth, and hence the Plan is not sound. It is clear therefore that the delivery strategy must be revised and the Council must allocate additional sites for housing, in addition to those currently proposed.

Delivery in the Main Urban Area

Theakston Estates does not consider that the Plan is sound because the distribution of the sites identified does not align with the strategy in draft Policy 3 to direct “at least 50% of new homes” to the MUA. Indeed, there would be a shortfall against this figure.

Policy 6 provides details of the sites with planning permission and the allocations which will deliver the housing requirement provided in Policy 3.

Delivery between 2015 - 2018

Between 2015 – 2018 the following has been delivered:

Settlement 1st April 2015 – 31st 1st April 2016 – 31st 1st April 2017 – 31st Total March 2016 (net) March 2017 (net) March 2018 (net) Main Urban Area 459 (44.8%) 555 (52.9%) 426 (37.5%) 1,440 (44.8%) Borough Total 1,025 1,049 1,137 3,211

A copy of the summary tables containing these figures is appended to this representation.

Despite the requirement of Policy 3 for at least 50% of new homes to go in the MUA, between April 2015 to March 2018, only 44.8% of new homes have been delivered in this area. As such there is already an under delivery against the requirement for at least 50% of new homes to be delivered in the MUA.

Furthermore, Table 5 advises that the net completions for the first 3 years is 3,400. However, the actual figure (based on the figures contained in the Council’s Residential Land Availability Reports) is 3,211. There has therefore been 189 fewer completions than the figures provided in Table 5.

Housing Allocations in the MUA

The allocation for the next 15 years in the MUA is 7,211 dwellings or 7,441 by the end of the plan period (2035) (para. 16.22). Table H1(B) also identifies that a further 151 dwellings will come forward beyond the plan period.

Table 5 identifies that the Allocations plan period supply from Tables H1 and H2 total 16,115. However, the Allocations plan period supply in the MUA is 7,411 which is 46% of the allocations supply, this is less that the requirement that at least 50% of the total is delivered in the MUA. Indeed, 50% of 16,115 is 8,058 (not 7,411) and hence there is a need to allocate at least 647 more dwellings in this area using the current Plan figures.

Summary

Taking into account the sites that have been delivered between 2015 – 2018 and the allocations up to the end of the plan, it is clear that less than 50% of new homes will be delivered in the MUA.

Taking into account the above, as well as Theaskton Estates response to Policies 2 and 3, the housing requirement should be 1,073 dpa to reflect the evidence base and 64% of new homes should be delivered in the MUA.

Queries

Table 5 advises that there are 585 units with permission as at 1/4/2018 that are not included in the allocation supply. These consist of sites of 5+ units in the Defined Villages and those of 1-4 units throughout the borough. It is not clear how many of these units are located in the MUA. Paragraph 4.74 advises that these sites will help to address the additional 2 years of the plan period requirement. However, if these sites have planning permission, it is likely that the majority of these units will be delivered over the next few years and will not help to address the additional 2 years of the plan period requirement.

Policy 3 and paragraph 16.20 provide a target that at least 50% of the Borough total, or 6,805 – 7,315 new houses, are allocated to the MUA. However, it is not clear how these figures have been calculated, as 50% of the overall requirement of 18,400 (between 2015 – 2035) is 9,200, whilst 50% of 13,230 (between 2018 – 2033) is 6,615.

The first sentence within paragraph 4.77 refers to the first 15 year period of the plan (2018-2035). However, the period 2018 – 2035 is 17 years rather than 15 years.

The approach within the Plan is very confusing as references are made to the Plan running to both 2033 and 2035. This should be clarified and it should be made clear that the Plan period runs to 2035.

Reserve Development Sites

Paragraph 4.82 advises that the Reserve Development Sites have a capacity of 1,483, whilst Table H3(A) identifies that of these 749 dwellings lie within the MUA. Paragraph 4.82 states that:

“These are sites where there is currently doubt about whether they could be developed in the plan period, due to HS2 Safeguarding Route, and / or where allocations cannot be justified in accordance with a sequential approach to addressing flood risk”.

This paragraph this goes on to advise that new applications will be approved where flood risk sequential and exceptions tests and / or other development requirements can be satisfactorily addressed. It is also stated that any completions on these sites will contribute to meeting the plan period housing requirement but have not been factored into the housing supply.

Our client has fundamental concerns about the inclusion of the Reserved Development Sites in the Plan. On one hand, paragraph 4.82 advises that there is doubt that the sites can be developed and whether allocations can be justified, whilst at the same time this paragraph goes on to support the principle of development on these sites during the plan period, provided sequential and exception tests can be passed. Paragraph 16.22 advises that the “Reserve Development Sites are generally sites that failed the Sequential Test at plan-making stage so any future development proposals on these sites still need to demonstrate a successful pass of the Sequential Test of part of any future application.” As these sites are not deliverable / developable they should have no status in the Plan.

The NPPF is clear that:

“Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future)”. (para. 155) (Lichfields emphasis)

“Development should not be allocated or permitted if there are reasonable available sites appropriate for the proposed development in areas with a lower risk of flooding” (para. 158). (Lichfields emphasis)

In this case, there is an alternative site (Land at Scawsby Lane (ref: 436)) that is developable and deliverable and which lies within flood zone 1. Importantly, removing a site from the Green Belt is a sound approach rather than delivering new housing in flood zones 2 or 3. This is because the Green Belt is a planning policy designation rather than a physical constraint whereby a built development could have serious safety issues.

Our client submits that the Land at Scawsby Lane is a logical and sustainable location to deliver new housing. It was previously proposed for housing but was rejected on archaeological grounds (the archaeological issues have now been addressed). Given the availability of this site, it is not considered the sequential test could be passed for any Reserved Development Sites in the MUA. The merits of this site are discussed below.

Land at Scawsby Lane (ref. 436)

Theakston Estates considers that their land at Scawsby Lane (ref. 436) should be removed from the Green Belt and allocated for residential development within the Plan and on the Policies Map. This is a logical and sustainable location to deliver new housing and it would make an important contribution towards meeting the housing need in the MUA.

The site extends to around 39 ha and is bound to the north by Green Lane and the Roman Ridge; to the east by existing development off Emley Drive; to the south by Barnsley Road (A635); and to the west by Scawsby Lane. Land to the west of Scawsby Lane is also within our client’s control and is a proposed community parkland which would be delivered as part of the residential development. It is considered that the site could deliver approximately 800 new homes.

The site has been assessed in the Doncaster HELAA Update 2017-2018 as being Suitable (but with national policy constraints or physical constraints), Available and Deliverable/Developable with an overall timeframe of 6-10 years. Subject to appropriate consents, our client is confident that delivery could be secured within years 1-5 and have been approached directly by a number of national and regional house builders. The extract from the HELAA Housing Map is provided below.

As the site has been identified as a deliverable and developable site, our client has sought to understand any concerns for developing the site and have responded accordingly. In doing so, we have considered the

assessments of the site in the various evidence base documents, including those in the Sustainability Appraisal (August 2019); Green Belt Review; Site Selection and Results report; Heritage Impact Assessment and Archaeological Scoping Assessment. These findings from these assessments are briefly summarised below.

The various assessments conclude that there are archaeological constraints to developing the site which relate mainly to the likely presence of a deserted medieval village to the south of the site. There are also heritage considerations due to the presence of the Roman Ridge (Scheduled Monument) to the north and the grade II listed Tudor Cottage and Scawsby Hall to the south.

This representation responds to the concerns identified by the Council.

Green Belt Review

We have also considered the Council’s Green Belt Review (Stage 3 Green Belt sites Re-appraisal – 9 May 2017) which concludes that the site has a “Moderate Case for inclusion in further site selection work”.

Sustainability Appraisal and Housing & Employment Site Selection Methodology & Results Report

The Sustainability Appraisal (August 2019) concludes that:

“it is noted that this is a very large site where there would be scope for sensitive site layout and design of a scheme that could avoid areas of archaeological significance whilst still delivering an extension with significant capacity. In conclusion, although the site has been identified as performing the same through the Green Belt Review Phase 3 as other sites at the settlement which are being proposed for allocation, there are sites that perform slightly better through the Sustainability Appraisal and sufficient allocations now identified.” (Lichfields emphasis)

This assessment indicates that the site has been rejected on the basis of the Sustainability Appraisal. It is recognised that the Sustainability Appraisal has assessed a site capacity of 969 homes, whilst our client is proposing a development of approximately 800 homes on this site, which is a smaller site than that assessed in the Sustainability Appraisal. Theakston Estates therefore requests that the Council reassess this site. Indeed, Theaskton Estates submitted a representation in response to the ‘Doncaster Local Plan Information Consultation: Draft Policies and Proposed Sites’ consultation in October 2018 where further details were provided, including the proposed indicative masterplan and an archaeological report. However, it does not appear that these representations have been considered by the Council in the updated “Sustainability Appraisal of the Doncaster Local Plan 2015-2033: Publication Version” (August 2019).

The “Doncaster Local Plan – Housing & Employment Site Selection Methodology & Results Report” (Publication Version, June 2019) has proposed sites at Alverley Lane, Balby (site ref. 115) and Land adjacent to 163 Sheffield Road, Warmsworth (site ref: 003) for housing. These sites currently lie within the Green Belt. A comparison of the scores given to these sites in the 2019 Sustainability Appraisal against the score of Land at Scawsby Lane (site ref. 436) is provided in the following table. :

Site Ref. Site Name Positive Score Negative Score Overall Score 115 Alverley Lane, Balby 15 7 8 003 Land adjacent to 163 14 7 7 Sheffield Road, Warmsworth 436 Land at Scawsby Lane 13 8 5

Archaeology and Heritage

In response to the constraints identified, we append a report by Northern Archaeological Associates Ltd (NAA) dated October 2018 which assesses the archaeological constraints and identifies mitigation measures to limit the impact of developing the site. This report was submitted with the representations in October 2018.

In terms of the Roman Ridge Scheduled Monument, NAA’s assessment considers that the section adjacent to the site represents a relatively short section of a much larger monument. The Roman Ridge is generally 1-2m in height and approximately 10m in width and is primarily comprised by a tarmac route with grass verge and/or mixed shrub and tree hedgerow on each side. Therefore, the main character of this section of Roman Road is that of an enclosed corridor contained by hedgerows which retains a sense of rural character and limits views of built development.

NAA’s assessment considers that the development of the site whould have no physical impact on the Scheduled Monument and that any impact upon its setting can be limited through an appropriately designed scheme. The recommended mitigation measures include:

. Reinforcing planting along those sections of the route where hedgerows are either missing or low; . Applying a buffer zones of at least 10m between the Roman Road and the development line which is consistent with the existing development to the south east of the site; and . Incorporating accessible open space into this buffer zone with access links to the Roman Road.

Additionally, interpretation and knowledge panels could also be provided to enhance and further local understanding of the Roman Ridge. Application of the above would enable access and better appreciation of the Scheduled Monument, providing a new public benefit to a section which is not currently publically accessible.

NAA’s assessment also considered the potential earthwork remains of the deserted medieval village (DMV) and a review of the LiDAR imagery indicates that these remains are likely to be present in the southern field which is under pasture. The LiDAR imagery indicates that in the southern field the remains are likely to be a combination of crofts and tots, road and ridge and furrow. Any cropmarks which have been indicated are common across this part of South Yorkshire and are not considered to be a constraint to development.

NAA’s recommended mitigation strategy is to exclude the southern field from the development, given the reasonable survival of the DMV, and retain this as an area of publicly accessible open space within the development. The development should also minimise tree planting, drainage infrastructure and other works which could result in ground disturbance. The suggested mitigation would mean that this area would form an attractive green corridor along Barnsley Road, creating new opportunities to link paths through the development, community parkland and to the north and onto the Roman Ridge bridleway. This would enhance permeability and access between existing public footpaths and the various heritage and community assets in the area.

Lichfields has considered the potential impact of the development on above ground heritage assets. Tudor Cottage (Listed Grade II) dates from the second quarter of the nineteenth century. The cottage faces across Scawsby Lane to the ancillary farm buildings associated with Scawsby Hall. It is likely that it was built as farm accommodation (possibly for a farm manager). It does not appear to have been associated with any particular neighbouring buildings or land use with its strongest association being with the building to the south of Barnsley Road.

Scawsby Hall (Listed Grade II) is a mid-seventeenth-century farmhouse set back from Barnsley Road behind a sizeable front garden and is associated with a number of ancillary buildings now converted from farm use to a pub and restaurant.

By retaining the southern fields as public open space, Scawsby Hall and Tudor Cottage will both be separated from proposed development. The wider site to the north of these heritage assets does not contribute to the significance of these listing buildings and, therefore, developing this part of the site will not harm their significance.

It is therefore concluded that through careful masterplanning an acceptable scheme can be delivered that is sensitive to the historic environment. As such, archaeology and heritage are not issues that preclude the wider site development and Theakston Estates contend that the negative score in the Sustainability Appraisal against ‘Heritage Impacts’ should be amended to a neutral observation.

Pollution to Surface Water Bodies

The Sustainability Appraisal, at Table 8.3, also identifies potential significant negative effects relating to “Pollution to Surface Water Bodies”. Other elements of the Sustainability Appraisal do not reference this effect. Therefore, as stated in the Theakston Estate representations in October 2018, it is suspected that there is an error with the assessment as it is unclear how the development would result in pollution to surface water bodies. Furthermore, the only water body identified on the Environment Agency’s map would be located in the southern field which is to be excluded from the development. There is a field drain which runs through the site in an west to east direction however this is dry for the majority of the year. In addition, any concerns would be dealt with at the planning application stage and the required mitigation measures would be secured by planning conditions. The assessment should be amended to a neutral observation.

Indicative Masterplan

We have attached an indicative masterplan for the site, which includes an indicative layout for the site east of Scawsby Lane which could deliver around 800 houses together with a new school and other community shops and facilities. The proposals also include a community parkland to the west of the Scawsby Lane. The indicative masterplan was discussed in the representations submitted to the Council in October 2018.

As detailed in the Council’s Settlement Background Paper (2018), “there is a deficiency in open space (be it formal, informal, allotments, public parks, woodlands and nature conservation areas)” and that additional housing delivery “without improving existing open spaces or delivering new open space, must be avoided to prevent this from worsening”. The paper also states that “sport and recreation activity is below the national average, with the borough facing relatively high levels of obesity and ill health”.

The community parkland on adjacent land to the west of Scawby Lane will include new sports facilities; a woodland play area and trails; allotments and new habitats for wildlife. This represents a significant benefit and aligns with the NPPF (February 2019) which states that plans:

“should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land”. (Lichfields’ emphasis) (para. 138)

This would directly support efforts to address the current issues relating to open space deficiencies and obesity rates identified in the Settlement Background Paper. It also responds directly to the Local Plan objectives including no. 13 which seeks to “provide new or improved health, sport and recreational facilities and green infrastructure to create quality communities and address deficits in provision”.

As part of the proposals to east of Scawsby Lane, the masterplan includes provision for a new school and community hub with shops and facilities. As shown on the plan, the proposals could also deliver additional education benefits by providing land for playing fields or car parking to support the operation of existing schools located to the south of Barnsley Road.

These recommendations identified in the assessments by NAA and Lichfields have been also been incorporated into the indicative masterplan. The masterplan clearly demonstrates how the southern field can be retained as public open space which would limit any impact of the development on the DMV archaeological remains whilst also maintaining the setting to the nearby Grade II Listed buildings. The proposed access road into the development would be taken from Barnsley Road, although its exact route will be informed by further archaeological investigation to limit any impact on below ground remains. Along the northern boundary, the Roman Ridge would not be affected by the development and the proposed masterplan incorporates a buffer zone together with additional landscaping to limit any impacts to its setting. Notwithstanding this, the assessments by Lichfields and NAA recommend that links to the Roman Ridge are included to enable the historic route to contribute further to the network of pedestrian and cycle access.

Overall, whilst the locality has a number of heritage assets associated with it, the masterplan demonstrates that consistency with the conservation and enjoyment of the historic environment. The heritage assets will be incorporated into the wider proposals in a way which is consistent with their conservation, which contributes to the distinctiveness of the area and which allows them to contribute to the wider benefits to the proposals.

Re-Assessment of the Land at Scawsby Lane

To ensure a sound Plan, Theakston Estates request that the Council re-assesses the site within their Sustainability Statement and take the following into account.

The negative scores against ‘heritage impacts’ and ‘pollution to surface water bodies’ should be changed to a neutral score in light of the information provided earlier in this representation. These two changes would amend the total negative score to 8 and the overall score to 7, which is the same overall score as site reference 003.

Importantly, in light of the proposals shown on the indicative masterplan, the Sustainability Appraisal scoring should be amended as follows: - ‘Access to Existing Centre’ should be changed from a negative to a positive score given that the proposals include the provision of community shops and other facilities; - ‘Biodiversity - should be changed from a negative to a positive score given that the proposals include the provision of extensive wildlife habitats which will deliver a substantial net gain; and - ‘Access to Public Open Space’ should be changed from a single to a double positive score given that a most extensive area of community parkland is proposed on adjacent land which is likely to include new sports facilities, a woodland play area and trails, allotments and wildlife habitats.

Taking into account these changes, together with the above in relation to heritage impacts and water pollution, the sustainability score should be amended to a positive score of 14 and a negative score of 5. This provides a total score of 9, which is higher than the other two Green Belt sites which are proposed to be removed from the Green Belt and allocated for housing. The scoring in the Sustainability Appraisal is therefore wrong and the Plan has been based on false evidence, contrary to the NPPF.

Summary

Scawsby Lane (ref. 436) is a logical and sustainable location to deliver housing growth and our client requests that it is allocated in the Plan and on the Policies Map for housing development.

The provision of additional community facilities on the site together with the proposed community woodland on land to the west of Scawsby Lane means that this is the only site which can deliver a substantial package of benefits in line with paragraph 138 of the NPPF (February 2019).

The overall development package has a higher sustainability score that the other two Green Belt sites which have been assessed through the Sustainability Appraisal are proposed to be allocated for housing. The scoring in the Sustainability Appraisal is therefore wrong and the Plan has been based on false evidence, contrary to the NPPF.

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

As explained in response to question 6, the strategy for the delivery of housing in Doncaster has not been positively prepared and fails to support growth. To ensure a sound plan that is consistent with the NPPF (February 2019) (para. 35), the delivery strategy must be revised and additional sites for housing must be allocated, in addition to those currently proposed, to ensure that a minimum annual delivery figure of 920 dwellings can be achieved every year (notwithstanding Theakston Estates’ response to Policy 3 regarding the need to increase the housing requirement to at least 1,073 dpa).

Importantly, it is critical that additional sites are identified within the MUA to ensure that the housing allocations in this area reflect the requirement of Policy 2 which is to deliver at least 50% of new homes in the MUA (notwithstanding Theakston Estates’ response to Policy 2 that this figure should be 64%).

The approach to including the Reserve Development Sites in the Plan is fundamentally flawed and cannot be justified, especially given that some of these sites are subject to flood risk. As these sites are not deliverable / developable they should have no status in the Plan. To ensure a sound Plan that provides the most appropriate strategy and accords with the NPPF (paragraphs 35, 155 and 158), references to these sites must be removed and other less constrained and more suitable sites should be allocated.

The Land at Scawsby Lane is a logical and sustainable location to deliver new housing and as such should be allocated for this use within the Plan and on the Policies Map. This site was previously proposed for housing but was rejected on archaeological grounds. However, as demonstrated in response question 6, this matter has now been addressed and the site is available, deliverable and developable for a residential development. Importantly, the Council’s scoring of the site in the Sustainability Appraisal is incorrect any re- assessment will identify that it performs better than the two Green Belt sites which are proposed for housing.

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:

The issues are complex and require further debate during Public Examination of the Local Plan.

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

Your Date

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

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

Part B

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

Name / Organisation Name:

Theakston Estates Limited

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

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

Page No.: Paragraph: Policy Ref.: Chapters 1, 5, 7, 12, 14 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 ☒

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.

Throughout the draft Local Plan various references are made to Supplementary Planning Documents (SPDs). For example, paragraph 5.30 advises that in developing masterplans and design codes, applicants ‘must adhere to’ other relevant Local Plan policies and SPDs, whilst paragraph 7.52 states that ‘developers will be expected to provide walking provision in line with the relevant SPD’.

On the Council’s ‘Supplementary Planning Documents’ page of the website, it is stated that the SPDs have been produced to provide further guidance about the implementation of specific planning policies and that they are material considerations. It is therefore not the intention that the guidance within the SPDs must be applied rigidly and that they must be adhered. This would result in an onerous and inflexible approach. Theakston Estates is concerned that the Local Plan is being used to give greater weight to the SPDs that was their original intention. Furthermore, it is considered to be inappropriate to reference an SPD in the Local Plan in advance of the SPD being prepared.

It is therefore requested that reference to the SPDs are either deleted or the supporting text is amended to make it clear that the SPDs provide guidance.

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

As explained in response to question 6, it is requested that reference to the SPDs are either deleted or the supporting text is amended to make it clear that the SPDs provide guidance. This will ensure that the Plan is positively prepared and provides the most appropriate strategy through not being overly onerous.

We suggest that where reference is made to SPDs at paragraphs 5.30, 7.21, 7.47, 7.52, 7.54, 12.24, that the text is amended to state that ‘developers should take into account the guidance provided within the SPD’.

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:

The issues are complex and require further debate during Public Examination of the Local Plan.

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

Your Date

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

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

Part B

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

Name / Organisation Name:

Theakston Estates Limited

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

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

Page No.: Paragraph: Policy Ref.: Chapter 16: Doncaster MUA 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 ☒

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 Theakston Estates’ response to Policies 2, 3 and 6 in relation to the housing requirement, housing supply, development in the Main Urban Area and the approach to the reserve development sites.

(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:

The issues are complex and require further debate during Public Examination of the Local Plan.

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

Your Date

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

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

NAA DONCASTER LOCAL PLAN CONSULTATION

ARCHAEOLOGY REPRESENTATION REPORT

Northern Archaeological Associates Ltd Marwood House Harmire Enterprise Park Barnard Castle Co. Durham DL12 8BN t: e: w: www.naaheritage.com ALLOCATION SITE 436: LAND EAST OF SCAWSBY LANE

SCAWSBY LEYS, LAND WEST OF SCAWSBY LANE

DONCASTER, SOUTH YORKSHIRE

prepared for

Lichfields

Project No.: 1479 on behalf of Text: Mary Fraser Theakston Estates Illustrations: Cath Chisman

NAA 18/94 October 2018 NAA Northern Archaeological www.naaheritage.com Marwood House Associates Harmire Enterprise Park Barnard Castle Co. Durham DL12 8BN

QUALITYQUALITYQUALITY ASSURANCE

Project Number 1479

Report Number 18-94

Manager Mary Fraser

Draft Mary Fraser

Graphics Cath Chisman

Edit Frederick Foulds

Authorised Frederick Foulds

Issue 1 18/10/2018

Issue 2 25/10/2018

Issue 3 26/10/2018

DisclaimerDisclaimerDisclaimer This document has been prepared in good faith on the basis of information available at the date of publication without any independent verification for the exclusive use and benefit of the named client and for the sole purpose for which it is provided. Northern Archaeological Associates does not guarantee the accuracy, reliability, completeness, or currency of the content of this document nor its usefulness in achieving any purpose. This document is not intended to nor should it be relied upon by any third party. Northern Archaeological Associates accepts no responsibility nor liability should this document be used for any alternative purpose other than for which it is intended nor to any third party. Northern Archaeological Associates will not be liable for any loss, damage, cost, or expense incurred or arising by reason of any person using or relying on information in this document.

Author Mary Fraser Illustrations Cath Chisman

Client Lichfields Location Allocation Site 436: Land east of Scawsby Lane; Scawsby Leys, Land west of Scawsby Lane District Doncaster

DONCASTER LOCAL PLAN CONSULTATION ALLOCATION SITE 436: LAND EAST OF SCAWSBSCAWSBYY LANE, DONCASTER SCAWSBY LEYS, LAND WWESTEST OF SCAWSBY LANE ARCHAEOLOGY REPRESENREPRESENTATIONTATIONTATIONTATION

TABLE OF CONTENTS

1.0 Introduction 1 2.0 Policy context 2 3.0 Key constraints 5 4.0 Roman Ridge Roman road 6 5.0 South Field: Scawsby deserted medieval village 17 6.0 North and middle field: iron age to roman cropmarks 24 7.0 Scawsby Leys 25 8.0 Summary and conclusion 26 References 29

LIST OF FIGURES

Figure 1: site location. Figure 2: designated heritage assets. Figure 3: non-designated archaeological sites. Figure 4: archaeology sensitive areas to be excluded from development (OS map). Figure 5: archaeology sensitive areas to be excluded from development (Google Earth). Figure 6: LiDAR mapping.

LIST OF PLATES

Plate 1: Vulcan Court bridleway access point, showing height of agger. Plate 2: view north-west along the top of the Roman Ridge bridleway from Vulcan Court access point. Plate 3: view south-east along the boundary between the Scheduled Monument and Site 436. Plate 4: view north-west along the boundary between the Scheduled Monument and Site 436. Plate 5: Layden Drive. View north along the line of the Roman Ridge where buffer zone has been enclosed into rear garden areas. Land east and west of Scawsby Lane, Doncaster: Archaeology Representation Report

Plate 6: Vulcan Court development. View south along the line of the Roman Ridge with open views and access. Plate 7: view north along Roman Road, with houses along Layden Drive on the left. Plate 8: view south along Roman Ridge, with Vulcan Court to the right. Plate 9: view north along Roman Ridge, with new development off Emley Drive on the left and Site 436 beyond. Plate 10: view south along the Roman Ridge at its junction with Green Lane. The modern bungalow is shielded from view along the road corridor by a combination of hedgerow and trees. Plate 11: view west from the Roman Ridge across Site 436 towards Tudor Cottage and Scawsby Hall. Plate 12: panoramic view south along Roman Ridge, with Site 436 on the right. Plate 13: view west from Ryedale Walk across the eastern extent of the DMV earthworks in the southern pasture field. Plate 14: View north along eastern boundary of southern pasture field with Ryedale Walk and modern housing to the east Plate 15: panoramic view east along Barnsley Road, with Tudor Cottage and southern pasture field on the left and Scawsby Mill and Scawsby Hall on the right. Plate 16: panoramic view east along Barnsley Road, with Scawsby Hall and Scawsby Mill on south side of road. Plate 17: views east and west showing parts of footpath network through 20th-century housing estate lying to east (top) and the DMV earthworks beyond metal fence to the west (bottom). Plate 18: existing gateway from the southern field onto Barnsley Road.

DONCASTER LOCAL PLAN CONSULTATION ALLOCATION SITE 436: LAND EAST OF SCAWSBSCAWSBYY LANE, DONCASTER SCAWSBY LEYS, LAND WWESTEST OF SCAWSBY LANE ARCHAEOLOGY REPRESENREPRESENTATIONTATIONTATIONTATION

1.01.01.0 IIINTRODUCTIONINTRODUCTION

1.1 Doncaster Council is consulting on an emerging Local Plan. This report has been prepared in support of a submission by Lichfields, on behalf of Theakston Estates, that requests Doncaster Council to reconsider their position in relation to Site 436 Land at Scawsby Lane (Map 10) and allocate the site for residential development. Archaeological constraints related to both designated and non-designated sites have been cited as being one of the key considerations for not allocating the site.

1.2 A detailed assessment of the archaeological constraints relating to this site is set out in the sustainability appraisal report Archaeology Scoping Study of Site Allocations for Doncaster Local Plan, Appendix Part 6 (ArcHeritage 2017). This appraisal has identified Site 436 as having a major archaeological constraint on allocation due to potential for impact on the following three sites:

• Roman Ridge Roman Road, a Scheduled Monument (ID 1003672; SMR 03039/01); • earthwork remains of Scawsby deserted medieval village (DMV) (SMR 00452/01); and • cropmark features relating to a probable Iron Age to Roman enclosure, trackway and field system (SMR 04935)

1.3 Northern Archaeological Associates Ltd (NAA) has been engaged to review the evidence base for rejection on archaeological grounds and to advise Lichfields whether it would be possible to effectively mitigate the archaeological impacts of developing the site, such that any harm can be avoided or reduced to less than substantial. As part of this review, a site visit was undertaken on 11 October 2018.

1.4 This report sets out the results of the review findings and recommendations for potential mitigation. The Council is requested to take these into account when balancing the impact on both designated and non-designated archaeology sites

against the public benefit of residential development (NPPF para. 196 and 197; MHCLG 2018).

2.02.02.0 POLICY CONTEXT

2.1 The legal and main planning context relevant to the allocation of this site for residential development within the emerging Local Plan comprise:

• the Ancient Monument and Archaeological Areas Act 1979; and • the National Planning Policy Framework (NPPF) (MHCLG 2018).

Ancient Monument and Archaeological Areas Act 1979

2.2 The Ancient Monument and Archaeological Areas Act 1979 sets out the statutory regime for the protection of scheduled monuments. Once a monument is scheduled, any works to it, and flooding and tipping operations that might affect it, require scheduled monument consent from the Secretary of State.

2.3 The Act makes no provision to protect the setting of a scheduled monument.

National Planning Policy Framework (NPPF)

2.4 The NPPF sets out the Government’s planning policies for England and how these are expected to be applied. At the heart of the National Planning Policy Framework is a presumption in favour of sustainable development (para. 11). Achieving sustainable development means that the planning system has three overarching objectives (economic, social and environmental). These objectives are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives) (para. 8). The environmental objective is to contribute to protecting and enhancing our natural, built and historic environment (para. 8c).

2.5 Paragraph 9 states that the three objectives should be delivered through the preparation and implementation of plans and the application of the policies in the NPPF; they are not criteria against which every decision can or should be judged. Planning policies and decisions should play an active role in guiding development towards sustainable solutions, but in doing so should take local circumstances in account, to reflect the character, needs and opportunities of each area.

2.6 The preparation and review of all Plan policies should be underpinned by relevant and up-to-date evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals (para. 31).

2.7 Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, wherever possible, alternative options that reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).

2.8 Paragraph 54 states that local planning authorities should consider whether otherwise unacceptable development could be made acceptable through the use of conditions or planning obligations. Planning obligations should only be used where it is not possible to address unacceptable impacts through a planning condition.

2.9 Policy 12Policy 12 addresses the importance of good design of new structures and features in relations to the pre-existing environment. Paragraph 127 requires that any development be ‘sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change.’

2.10 Policy 16: Conserving and enhancing the histhistoricoric environment sets out the framework for local planning authorities to make informed decisions on developments that affect heritage assets. Paragraphs 184–202 set out the information requirements and policy principles in relation to heritage assets. The following are of particular relevance to consideration of the allocation of Site 436.

2.11 Paragraph 185 states that Plans should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. This strategy should take into account:

a) the desirability of sustaining and enhancing the significance of heritage assets, and putting them to viable uses consistent with their conservation;

b) the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; c) the desirability of new development making a positive contribution to local character and distinctiveness; and d) opportunities to draw on the contribution made by the historic environment to the character of a place.

2.12 Local planning authorities should identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting the setting of a heritage asset), taking account of the available evidence and any necessary expertise. They should take this into account when considering the impact of a proposal on a heritage asset, to avoid or minimise any conflict between the heritage asset’s conservation and any aspect of the proposal (para. 190).

2.13 Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation (para. 189).

2.14 When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance (para. 193).

2.15 Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification (para. 194). Substantial harm to or loss of:

a) grade II listed buildings, or grade II registered parks or gardens, should be exceptional; and b) assets of the highest significance, notably scheduled monuments, protected wreck sites, registered battlefields, Grade I and II* listed buildings, Grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.

2.16 Where a proposed development will lead to substantial harm to (or total loss of significance of) a designated heritage asset, local planning authorities should refuse

consent unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss (para. 195).

2.17 Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use (para. 196).

2.18 The effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that directly or indirectly affect non-designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset (para. 197).

2.19 Local planning authorities should require developers to record and advance understanding of the significance of any heritage assets to be lost (wholly or in part) in a manner proportionate to their importance and the impact, and to make this evidence (and any archive generated) publicly accessible. However, the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted (para. 199).

2.20 Local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites, and within the setting of heritage assets, to enhance or better reveal their significance. Proposals that preserve those elements of the setting that make a positive contribution to the asset (or which better reveal its significance) should be treated favourably (para. 200).

3.03.03.0 KEY CONSTRAINTS

3.1 Allocation Site 436 lies on the north side of the busy Barnsley Road and to the east of Scawsby Lane. It comprises three fields each with different archaeological constraints (Figs 2 and 3):

North and middle fields: under arable cultivation

• Roman Ridge Roman Road (ID 1003672)1003672). The Roman road is demarcated by the bridleway that runs along the northern boundary of Site 436. This section of the road is designated as a Scheduled Monument; therefore, impact on setting and

potential for physical impact on the road or associated remains will be a significant consideration. • Cropmarks record enclosure, trackway and field boundaries (SMR 04935)04935). These are indicative of Iron Age to Roman settlement and agricultural remains being present throughout both the north and middle fields. These remains are unscheduled and according to the Archaeological Scoping Assessment, are of local to regional importance, depending on nature and state of survival.

South field: underunderunder pasturepasturepasture

• This field contains the earthwork remains of Scawsby deserted medieval village (SMR 00452/01), which may have historic associations with the 17th-century Grade II listed Scawsby Hall on the south side of Barnsley Road.

3.2 Scawsby Leys is a large arable field (blue boundary) to the west of Scawsby Lane and opposite Allocation Site 436. If Site 436 were to be developed, it is proposed that this area could provide an area of Community Parkland. There are no recorded archaeological constraints, but the area has potential for unrecorded Iron Age to Roman remains, and possibly medieval remains associated with Scawsby DMV.

4.04.04.0 ROMANROMANROMAN RRRIDGERIDGE RRROMANROMAN RRROADROAD

Description

4.1 The Roman Ridge Roman Road runs along the northern boundary of Site 436 and is currently used as a bridleway. The road formed part of the major military route from Lincoln (Lindum) to York (Eboracum) via Doncaster (Danum) and Castleford (Lagenium) and is detailed in the Antonine Itinerary.

4.2 This affected section is therefore a single, relatively short section of a much larger monument with variability of survival and several different scheduled sections along its route. The extent of the Scheduled Monument, of which this section forms a part, is shown on Figure 2. It is approximately 2.5km in length and runs south from Highfields across Green Lane to the southern edge of Broad Axe field. The potential continuation of the route south-east towards Doncaster is shown on Figure 2 (Site 1165931).

4.3 Development within Site 436 has potential to impact on a 465m section of the 1.2km length of Roman Road that runs south from Green Lane to Broad Axe field. This

section is a well-defined ‘green lane’ and is used as a bridleway, although there is no signage to indicate its Roman origins.

4.4 In landscape terms, the Roman Ridge forms a significant containment feature (Enplan 2016) and will have formed a key boundary and communication route through the area for at least the last 1600 years.

FormFormForm

4.5 Throughout the length of the section south from Green Lane, the Roman road survives as a very distinct agger (embankment) 1–2m in height and approximately 10m in width (Plate 1). The bridleway runs along the top of the agger and is demarcated by a central tarmac strip with rough grass verge to either side that is bordered by a mixed shrub and tree hedgerow, which forms a vegetative lined corridor (Plate 2).

Plate 1: Vulcan Court bridleway access point, showing height of agger.

Plate 2: view north-west along the top of the Roman Ridge bridleway from Vulcan Court access point.

4.6 For the majority of its length alongside Site 436, the upper part of the agger embankment is covered by trees or shrubs, while the lower slope is under grass, forming a distinct sharp edge between the Roman road and the ploughed field (Plates 3 and 4).

4.7 South-east from Site 436, the Roman Ridge runs alongside modern housing estates— Layden Drive and Vulcan Court—and school grounds. The agger continues throughout this section and the vegetation covers the majority of the embankment slopes. Along the Layden Drive section, the south-western edge of the agger borders a fence that encloses rear gardens (Plate 5). Through the Vulcan Court section, it borders public open space (Plate 6), which then transitions into school playing fields (Fig. 5).

4.8 There is agricultural land alongside the north-east side of the road corridor with views of Scawthorpe settlement in the background (Fig. 2).

4.9 There does not appear to be any visible signs of flanking roadside ditches, although they could survive below-ground and been infilled either as a result of ploughing or vegetative growth.

Plate 3: view south-east along the boundary between the Scheduled Monument and Site 436.

Plate 4: view north-west along the boundary between the Scheduled Monument and Site 436.

Plate 5: Layden Drive. View north along the line of the Roman Ridge where buffer zone has been enclosed into rear garden areas.

Plate 6: Vulcan Court development. View south along the line of the Roman Ridge with open views and access.

CharacterCharacterCharacter and settingsettingsetting

4.10 This scheduled section of Roman road is well-preserved and forms a key feature within the landscape. It retains its intended use as a communication route and its consequential role as a significant boundary feature.

4.11 The main character of the section of Roman road running south from Green Lane is that of a raised, straight-sectioned, vegetative embankment running across the landscape. When walking along the top of the agger, its character is that of an enclosed ‘green lane’ corridor, with the eye contained by the hedgerows and carried along the tarmac bridleway. The tarmac strip gives a slightly modern, rather than historic, feel to the route, although it makes the lane very accessible.

4.12 This hedge-lined corridor prevents or limits views of both the surrounding agricultural land and the built environment, including the adjacent housing estates at the south- east end of the bridleway (Plates 7, 8 and 9) and of the bungalow at its junction with Green Lane (Plate 10). It helps create a sense of rural character and enclosure, which contributes to the setting of the Roman Ridge and the creation of a tranquil context for users of the bridleway.

Plate 7: view north along Roman Road, with houses along Layden Drive on the left.

Plate 8: view south along Roman Ridge, with Vulcan Court to the right.

Plate 9: view north along Roman Ridge, with new development off Emley Drive on the left and Site 436 beyond.

Plate 10: view south along the Roman Ridge at its junction with Green Lane. The modern bungalow is shielded from view along the road corridor by a combination of hedgerow and trees.

4.13 There are several intermittent sections of missing or low hedgerow on both sides of the Roman Ridge corridor, examples of which are shown on Plates 11 and 12. These mainly occur beyond the built-up areas. Where they occur along the boundary with Site 436, they have resulted in opening up elevated views across the north and middle fields of Site 436, south-west towards Scawbsy Hall, Tudor Cottage and other built development along the Barnsley Road corridor. Along the north-east boundary, these breaks allow views across agricultural land to the built development at Scawthorpe. These are, however, dynamic open views that quickly close again as walkers progress along the bridleway and hedgerow height and density are restored.

4.14 Whilst these intermittent open views contribute to the sense of walking out from a built environment into the countryside and thus reinforce the rural setting of the monument and enjoyment of the walk along the Roman Ridge, they are not critical to how the heritage asset its experienced and our understanding and appreciation of its significance.

Plate 11: view west from the Roman Ridge across Site 436 towards Tudor Cottage and Scawsby Hall.

Plate 12: panoramic view south along Roman Ridge, with Site 436 on the right.

Physical ImpactImpactImpact

4.15 Development within Site 436 should have no physical impact on the Scheduled Monument. The scheduled area is tightly contained and appears to broadly reflect the agger corridor (Fig. 2). Within Site 436, the bottom edge of the agger slope is clearly defined by the grass strip, which slopes down to the ploughed edge of the field (Plates 3 and 4). Geophysical survey would determine if there are any associated features extending beyond the scheduled area that should be avoided, such as flanking side ditches.

Impact on SettingSettingSetting

4.16 Development would occupy agricultural land immediately adjacent to the scheduled Roman road and will alter the setting of this section of monument from a rural landscape character to a built environment. This change in contextual setting of the monument will potentially affect its prominence in the landscape and, in visual terms, potentially reduce its role as a significant landscape boundary and containment feature.

4.17 As there is no public access across Site 436, the effects of this impact would mainly be apparent for users of the bridleway and in distant views of the monument from Scawsby Lane and Barnsley Road.

4.18 This extension of existing built environment alongside the Roman Ridge corridor would mean that users would lose that sense of emerging out from built environment into rural countryside. This would have less of an impact on those sections of the route where dense hedgerows contain views out across the landscape. It would, however, result in a change in view along those intermittent sections of the Roman Ridge with missing or low hedgerows.

4.19 The way in which we experience an asset in its setting is also influenced by other environmental factors, such as noise from other land uses in the vicinity, and therefore the proximity of new development to the monument will be a consideration.

PotentialPotentialPotential mitigationmitigationmitigation

4.20 A scheduled monument is considered by the NPPF to be a heritage asset of the highest significance (para. 194b). When considering the impact of a proposed development on the significance of a designated heritage asset, the NPPF requires the local authority to give great weight to the asset’s conservation, irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance (para 193). The more important the asset, the greater the weight should be, and any harm should require clear and convincing justification (para. 194).

4.21 The degree of harm to the setting of the monument and people’s enjoyment of the bridleway along the Roman Ridge depends on the extent to which the affects of this change in contextual setting could be reduced through design and mitigation.

4.22 Measures to consider that could help reduce the effects of this change include:

• Geophysical survey along the corridor adjacent to the monument to determine whether there is any sub-surface archaeological remains which should be protected from development. If appropriate, trial trenching may also be required to fully determine the nature, extent and significance of survey anomalies (NPPF para. 189). • Reinforce planting along those sections of the Roman Ridge along the boundary with Site 436 where hedgerows are either missing or low. This would help contain views to along the line of the Roman Road, which would be in keeping with the overall character of the monument along this section of road (Scheduled Monument Consent would be required). • Build in a buffer zone along the length of the Roman Ridge, within which no development would take place. The width of this would need some consideration but at a minimum it should be 10m from the edge of the scheduled area as shown on Figures 4 and 5. This would be similar to the stand-off width between the Roman Ridge and the housing at the south-east end of the scheduled area. This buffer zone would ensure that there are no physical impacts on the scheduled monument and help retain a green context for the immediate setting of the monument and its prominence as a key feature within the landscape. • Incorporating this buffer zone into accessible public space would enable access along the south-west edge of the Roman Ridge and better appreciation of the monument, than incorporating it into rear gardens (Plates 5 and 6). This would provide a new public benefit, as along this section, the monument is not currently publicly accessible, other than along the bridleway and it is difficult to fully appreciate the form and height of the agger embankment from this angle. • Consider incorporating a new pedestrian access point onto the Roman Ridge bridleway from within the development and look at how this access point could be incorporated into an attractive and accessible open public space. • Consider how a new access point onto the Roman Ridge bridleway could be incorporated into a new footpath network linking Scawsby DMV, the new Community Parkland, Scawsby Mill public house and Scawsby Hall Nurseries (see section on Scawsby DMV below). • Consider alignment of roads and properties within vicinity of Roman Ridge and how they relate to the monument.

Significance of impactimpactimpact

4.23 Any physical impact to the scheduled Roman road can be avoided through a combination of evaluation and the incorporation of a buffer zone along the edge of the monument.

4.24 It is acknowledged that the development would cause some harm to the setting of the Roman road through the development of housing, the need for access roads and reduction of its rural setting.

4.25 Development would also have the potential to deliver some positive benefits by improving public access to the monument and new links to the Roman road and other heritage assets within the vicinity, and thus would provide an opportunity to better reveal the significance of both the Road road and these other assets (NPPF, para 200).

4.26 By use of appropriate design and mitigation (10m buffer zone, landscaping, sensitive design layout, public open space and links), it is considered that the degree of harm to the significance of the monument would be less than substantial in terms of the NPPF.

4.27 Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, the NPPF states that this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use (para. 196).

5.05.05.0 SSSOUTHSOUTH FFFIELD:FIELD: SSSCAWSBYSCAWSBY DESERTEDDESERTEDDESERTED MEDIEVAL VILLAGE

DescriptionDescriptionDescription

5.1 The southern field is under pasture and contains the earthwork remains of the deserted medieval village (DMV) of Scawsby. LiDAR imagery indicates that these remains are likely to be a combination of crofts and tofts, road and ridge and furrow (Fig. 6). From ground level, the earthworks are visible within the field as a slightly undulating landscape but are not particularly well defined (Plate 13).

5.2 The area has not been cultivated in recent years and the earthworks suggest that below-ground preservation of archaeological remains is likely to be high. According to the Archaeological Scoping Assessment Report, the site is considered of regional importance (ArcHeritage 2017).

Plate 13: view west from Ryedale Walk across the eastern extent of the DMV earthworks in the southern pasture field.

5.3 LiDAR imagery suggests that the associated remains are likely to extend north into the middle arable field, possibly west into the south-east corner of Scawsby Leys, and to

the south of Barnsley Road. Remains in these arable fields will have been truncated by ploughing and are unlikely to be as well preserved as those in the southern pasture field.

Plate 14: View north along eastern boundary of southern pasture field with Ryedale Walk and modern housing to the east

5.4 The field is set in a slight dell below the level of Barnsley Road. It is contained by mature hedgerow along its northern boundary with the middle arable field and along its southern boundary with Barnsley Road as far as Tudor Cottage, where it changes to stone wall. To the east, a green metal fence separates the field from Ryedale Walk public footpath and the 20th-century housing estate beyond (Plate 14). Along its western boundary, the field is bounded by buildings and Scawsby Lane. Scawsby Leys, the area proposed for Community Parkland, lies immediately opposite on the west side of Scawsby Lane.

5.5 Tudor Cottage, a Grade II listed building, is inset into the field towards the western end (Plate 15). Scawsby Mill and the 17th-century Grade II listed Scawsby Hall, lie on the south side of Barnsley Road and opposite the western end of the field (Fig. 2; Plate 16).

Plate 15: panoramic view east along Barnsley Road, with Tudor Cottage and southern pasture field on the left and Scawsby Mill and Scawsby Hall on the right.

Plate 16: panoramic view east along Barnsley Road, with Scawsby Hall and Scawsby Mill on south side of road.

Recommended mitigationmitigationmitigation

5.6 Given the reasonable survival of the DMV earthworks and the high potential for well- preserved below ground remains, it is recommended that the southern field as shown on Figures 4 and 5 should be excluded from development and retained as an area of green open space within any development proposals.

5.7 Any ground disturbance (landscaping, tree planting, drainage, infrastructure, etc.) that would cause damage to below ground archaeological remains should be avoided where possible. Where limited, localised ground disturbance is unavoidable, then a programme of evaluation (geophysical survey and, if appropriate, trial trenching) should be undertaken. This should aim to ensure that impact on the most significant remains is avoided and to provide the basis for agreeing an appropriate programme of investigation to mitigate any harm or loss to the medieval remains (NPPF, para. 189 and 199).

5.8 The area offers opportunities to create an attractive green corridor along the northern edge of the Barnsley Road corridor. Pedestrian access through this corridor could create a link between the existing footpath network through the 20th-century housing estate to the east (Plate 17) and the proposed community parkland at Scawsby Leys, as well as footpath links to Scawsby Mill public house and Scawsby Hall Nurseries to the south of Barnsley Road; there is an existing gateway from the field on to Barnsley Road just west of Tudor Cottage (Plate 18). It would also offer opportunities to link into

paths through the new development to the north and onto the Roman Ridge bridleway. This would improve permeability and access along this busy road corridor zone and create new opportunities for connectivity into existing public footpaths and links between the various heritage assets within this area.

Plate 17: views east and west showing parts of footpath network through 20th-century housing estate lying to east (top) and the DMV earthworks beyond metal fence to the west (bottom).

Plate 18: existing gateway from the southern field onto Barnsley Road.

5.9 The DMV earthworks are unlikely to meet criteria for scheduling. Therefore, there would be a strong argument that, by designating the area as green space, development of Site 436 would offer the potential beneficial impact of providing for the long-term protection of these remains from ploughing. It could also contribute to protecting and enhancing the setting of the listed buildings to the south.

5.10 Further beneficial impacts could be achieved through improving public awareness and understanding of the heritage assets within this area. This would partly be achieved through any improved physical connectivity between Scawsby DMV, Scawsby Hall, Scawsby Mill, Tudor Cottage and the Roman Ridge Roman Road. It could be further enhanced by building in some level of community involvement during the investigations of the Iron Age to Roman remains within fields to the north and dissemination of information about the heritage assets within the area through a combination of on-site interpretation boards, footpath leaflets, parish website, community talks on heritage work being undertaken in support of the development, visits to local schools, etc. (NPPF, para. 200).

6.06.06.0 NNNORTHNORTH AND MIDDLE FIELFIELD:D: IRON AGE TO ROMANROMANROMAN CROPMARKS

DescriptionDescriptionDescription

6.1 Cropmarks recorded within Site 436 and surrounding areas by the Historic England Magnesian Limestone Aerial Photographic Mapping Project are shown on Figure 3. These record a probable Iron Age to Roman settlement enclosure, trackway and fragmentary field boundaries within the northern field of Site 436 to the south of the Roman Ridge Roman Road. The trackway appears to extend southwards into the middle field.

6.2 Given the extensive nature of the Iron Age to Roman cropmark landscapes recorded elsewhere across the Magnesian Limestone, there is potential that similar remains could be present throughout Site 436, including underlying the medieval village earthworks and possibly westwards into Scawsby Leys. However, evaluation undertaken in advance of the new development on land adjacent to Emley Drive, immediately adjacent to the south side of the Roman Ridge and the north-east corner of the site (Plate 9), did not identify any archaeological remains (ArcHeritage Archaeological Scoping Assessment Event ESY 525). This suggests that, as indicated by the cropmark evidence, density will be variable.

6.3 Modern cultivation will have caused some truncation of sub-surface deposits but, as stated within the Archaeological Scoping Assessment (ArcHeritage 2017), the potential for survival of buried archaeology below the plough zone is likely to be moderate to high. Settlement, burial and industrial remains are likely to be considered of regional importance, whilst most sections of trackways and field boundaries would probably be of local importance.

Potential impactimpactimpact

6.4 Development within the north and middle fields will impact on the below ground archaeological remains relating to this Iron Age to Roman landscape and result in their damage or destruction.

MitigationMitigationMitigation

6.5 It is considered that the presence of the cropmarks in Site 436 should not represent an absolute constraint on development. As can be seen from Figure 3, similar cropmark features have been recorded across much of the Magnesian Limestone and, as with many similar sites on the Magnesian Limestone, this impact could be effectively dealt with through a staged programme of archaeological investigation.

6.6 This would comprise a pre-determination evaluation (geophysical survey and possible trial trenching) to determine the density, nature and significance of remains (NPPF, para. 189). The results of this work would be taken into account during development design to enable the opportunity to design out sensitive or significant impacts where feasible, and to agree a programme of investigation in advance of, or during, development where impact is unavoidable. If appropriate, these proposals could be set out in a Heritage Design Brief submitted as part of a planning application and secured through condition.

6.7 This approach would be in compliance with NPPF paras 189, 197, 199, 54.

7.07.07.0 SSSCAWSBYSCAWSBY LLLEYSLEYSEYSEYS

7.1 Scawsby Leys is a large, open field to the west of Scawsby Lane and is under arable cultivation (Plate 19).

Plate 19: panoramic view of Scawsby Leys taken from southern end of Scawsby Lane.

7.2 Although there are no recorded cropmarks within Scawsby Leys, given the density of Iron Age to Roman settlement across the Magnesian Limestone, there is likely to be concern that the area has the potential for unrecorded remains of this period (Figure 2).

7.3 There is also potential that remains associated with Scawsby deserted medieval village could extend into the south-eastern corner of the site. There are, however, no visible survival of any earthworks on LiDAR imagery, so if remains do extend into this area, they are likely to have been subject to plough damage.

7.4 If development of this area as Community Parkland will result in ground disturbance below the depth of existing plough zone through landscaping, drainage, tree planting, infrastructure, etc., then it is likely that pre-determination evaluation through geophysical survey, and possibly trial trenching, would be required. As with the arable fields to the east of Scawsby Lane, the aim will be to better determine potential impact and appropriate mitigation through design or investigation.

7.5 If Iron Age to Roman remains or medieval village remains are present within this field, they are likely to be of regional or local importance depending on their state of preservation and whether or not they are settlement related. In a worst-case scenario, impact could be effectively mitigated through a combination of avoidance of impact and archaeological investigation. The potential for the presence of archaeology should therefore not constitute an absolute constraint on development of this area as Community Parkland.

7.6 There are no other recorded archaeological constraints associated with Scawsby Leys.

8.08.08.0 SSSUMMARYSUMMARYUMMARYUMMARY AND CONCLUSION

8.1 Residential development of land to the east of Scawsby Lane will impact on:

• Roman Ridge Roman Road, a Scheduled Monument; • Scawsby deserted medieval village earthworks, a non-designated site of regional importance; and • the probable remains of Iron Age to Roman enclosure, trackway and fieldsystem, which are non-designated cropmark features of probable regional or local importance.

8.2 Physical impact on the Roman Road can be avoided through use of a sufficient buffer of undeveloped land along the entire length of the monument within Site 436.

8.3 It is acknowledged that the development would cause some harm to the setting of the Roman road through the development of housing, the need for access roads and reduction of its rural setting but that this would constitute less than substantial harm to the significance of the monument. It is also considered that development would offer opportunities for public benefit through enabling improved public engagement with, and access to, the monument.

8.4 It is considered that the degree of harm to the setting of the Roman road could be reduced and offset by adoption of the following types of mitigation:

• incorporation of a sufficient buffer of undeveloped land alongside the edge of the monument both to avoid any physical impact on the monument and to protect its immediate setting. It is suggested that a minimum 10m corridor may be sufficient and would be consistent with the development to the south; • reinforcement of hedgerow planting along the Roman Ridge corridor to create a continuous enclosed route and thus restrict views of the new built environment from the bridleway; • through incorporation of the Roman road as a key feature into areas of open space, and the creation of new access routes both onto the bridleway and alongside the monument, development would offer opportunities to embrace the monument by using it to help shape design, contribute towards creating a sense of place and to reinforce its role as a significant routeway and boundary within the landscape; and • improving public access to the monument and incorporating new links with other heritage assets within the vicinity would help better reveal the significance of these assets and offer opportunities for improved public engagement, awareness and understanding.

8.5 Taking into account the proposed mitigation it is considered that the degree of harm to the significance of the monument would be less than substantial in terms of the NPPF and that this harm should be weighed against the public benefits that would arise as a result of embracing the monument as a key feature within the development design and improving public access.

8.6 It is considered that retention of the earthwork remains of Scawsby deserted medieval village as green open space with links to other heritage assets in the vicinity would constitute a positive public benefit.

8.7 Impact on any non-designated sub-surface Iron Age to Roman remains or medieval settlement remains within the two arable fields and Scawsby Leys, can be satisfactorily mitigated through a staged programme of archaeological investigation, recording and publication and secured through condition. The results of such investigations would contribute to an improved understanding of settlement and landscape development over the last 2,000 years, and thus be of public benefit in terms of making a positive contribution to the developing research framework for South Yorkshire Archaeology.

8.8 Overall it is considered that development would cause less than substantial harm to the three heritage assets affected by the allocation and that it offers potential for significant public benefit in terms of opportunities to better reveal their significance. With appropriate design and mitigation, development would be able to meet the requirements of statutory duty and comply with NPPF, paras 127, 193, 196, 197, 199 and 200.

REFERENCES

ArcHeritage (2017) Archaeology Scoping Study of Site Allocations for Doncaster Local Plan. Sheffield: ArcHeritage.

Enplan (2016) Land at Scawsby Lane, Doncaster. Consultation Response to Arup’s Stage 1 Green Belt Review for Doncaster Metropolitan Borough Council.

Ministry of Housing, Communities and Local Government (MHCLG) (2018) National Planning Policy Framework. London: HMSO.

0 5km

scale 1:250,000 @ A4

407

406 Site 436 proposed residential proposed development community parkland

405

404

0 1km

© Crown copyright 2018 OS AL 100005557 scale 1:25,000 @ A4 453 454 © NAA 2018 Scawsby Lane, Doncaster: site location Figure 1 © Crown copyright 2018 OS AL 100005557. You are permitted to use this data solely to enable you to respond to, or interact with, the organisation that provided you with the data. You are not permitted to copy, N sub-licence, distribute or sell any of this data to third parties in any form.

407

1013654 1013653

Brodsworth Hall

406

1003672

Site 436 proposed proposed residential community development 1151492 Marr parkland

1192644 1192626 1151640 1151641 1314778 1314759

1165931 1192634 1151681

1191542

405

KEY Scheduled Monument Listed Building Registered Park or Garden Conservation Area 1019080 1151602 Roman road 1314798 1314779 1286477 site boundary Cusworth Hall 0 500m 1314799 1240554 1421398 1km search area scale 1:12,500 @ A3 453 454 455 © NAA 2018 Scawsby Lane, Doncaster: designated heritage assets Figure 2 © Crown copyright 2018 OS AL 100005557. You are permitted to use this data solely to enable you to respond to, or interact with, the 1437121 organisation that provided you with the data. You are not permitted to copy, N sub-licence, distribute or sell any of this data to third parties in any form.

407 1434742

55792

55786 1437184

1437038

1434742 1437184 1437184

1434619

406

1437184

1437038

55804 SMR 04935

Site 436 1437129 proposed 1437129 proposed residential 1374811 community development parkland 1437202 SMR 00452/01

1437073 1174935

405 1431754

1025781

1431746

KEY DMV earthworks cropmark

railway 1317500 1432207 ridge and furrow 56022 site boundary 0 500m 1km search area scale 1:12,500 @ A3 453 454 455 © NAA 2018 Scawsby Lane, Doncaster: non-designated archaeological sites Figure 3 KEY N archaeology sensitive area

406

Site 436 proposed residential development

proposed community parkland

405

0 250m

© Crown copyright 2018 OS AL 100005557 453 454 scale 1:8000 @ A4 © NAA 2018 Scawsby Lane, Doncaster: archaeology sensitive areas to be excluded from development Figure 4 KEY N archaeology sensitive area

Site 436 proposed residential development

proposed community parkland

0 250m

Site 436 proposed proposed community residential parkland development

Scawsby Medieval village earthworks

0 200m

scale 1:6250 @ A4 Based on data Published by the Environment Agency and Licensed under OGL Open Government Licence © Environment Agency Copyright and/or database right 2015. All rights reserved © NAA 2018 Scawsby Lane, Doncaster: LiDAR mapping Figure 6 6 9

14 7

1 15 5 11

12 13 3

2 16 4

1.1 New housing development set within existing 10.10 New buffer planting provides wildlife route topography and ‘bowl’ ways across site, linking Scawsby Leys Hill Roman Ridge 2.2 New school, community hub, shops and community facilities 11.11 New community garden space

3.3 Main road to reflect urban boulevard character to foster 12.12 New sports provision integration with adjoining urban areas 1313. Sport pavilion, tennis courts/MUGA 4.4 Main bus route through site 1414. Woodland play area 5.5 Existing field margins reinforced and planted with broad leaf English hardwood and hedgerows 1515. Allotments

6.6 Circa 50m of buffer planting to create a strong 1616. Southern field retained as public open space boundary to the site to avoid disturbance to potential remains of the deserted medieval village 7.7 Public open space will allow for a buffer zone to the Roman Ridge 1717. Sustainable Urban Drainage System incorporated to manage surface water and 8.8 Improved pedestrian links with potential connections to deliver ecological benefits the Roman Ridge 1818. Potential car parking for Ridgewood School 9.9 Robust planting to community parkland boundaries