Please Find Attached on Behalf of Andy Tickle, Head of Campaigns CPRE South Yorkshire, Representations on the Doncaster Local Plan Publication Draft 2019

From: CPRE Sent: 30 September 2019 07:36 To: Local Plan Subject: Doncaster Local Plan: Representations by CPRE South Yorkshire

Please find attached on behalf of Andy Tickle, Head of Campaigns CPRE South Yorkshire, representations on the Doncaster Local Plan Publication Draft 2019.

This representation relates to Chapters 4, 5, 7, 9, 10, 12, 14 and 1, aubmitted in the form of eight completed comment forms.

Please confirm receipt of this documentation.

We look forward to further involvement in the Local Plan process.

Andrew Wood Stride Works Ltd Planning, sustainability, project design & management 282 Springvale Road Sheffield S10 1LJ Ref: Doncaster

Local Plan

Publication Draft 2019 (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

Please respond by 6pm Monday 30 September 2019.

The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination.

Please email your completed form to us at

If you can’t use email, hard copies can be sent to: Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU.

All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan

This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations) Part A

Please complete in full. Please see the Privacy Statement at end of form.

1. Personal Details 2. Agent’s Details (if applicable) Title Dr

First Name Andy

Last Name Tickle Organisation CPRE South Yorkshire (where relevant) Address – line 1 37 Stafford Road

Address – line 2 Sheffield

Address – line 3

Postcode S2 2SF

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?

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

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.

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:

CPRE South Yorkshire

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.: 18-39 Paragraph: Policy Ref.: Chapter 4 Policies 2-6 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.

Chapter 4: Strategic Approach

Policy 2: Spatial Strategy and Settlement Hierarchy Not positively prepared to address the climate challenge Not justified by the available evidence of the need to address the climate challenge

NPPF Para 148 states that “The planning system should…shape places in ways that contribute to radical reductions in greenhouse gas emissions…” No Local Plan policy can be more important to place-shaping than the spatial strategy and settlement hierarchy. Policy 2 makes no reference at all to the climate challenge, when for the Plan to be sound it should feature strongly in the opening paragraph.

Policy 2 (5): Countryside Not positively prepared to ensure that new development is consistent with the rest of the settlement hierarchy; Unsound because there is no spatial strategy for the countryside.

The settlement hierarchy essentially defines ‘countryside’ as being land outside development limits, and that on that land ‘proposals for new development in the countryside, including those which support the rural economy, will be supported where in accordance with Policy 26’. Policy 26 is basically a development management policy. It is therefore worrying that, within this headline strategic policy, the majority of the text on development in the countryside is dedicated to the basis on which exceptions to that expectation of development could be made.

In other words, the Plan offers no spatial strategy for the countryside, other than to express where the characteristics of the countryside and the rural economy could be diluted or circumvented to enable ‘non-rural’ development. Considering that the majority of land in the Borough is in the countryside (some Green Belt, some not) this is an alarming omission.

Looking in detail at clauses A-E of Policy 2(5), they actually have the effect of creating an additional tier of the settlement hierarchy – sites which are outside all but the smaller, level 4 settlements, but which are not allocated in the Plan. The proposal is therefore that, in the absence of a 5-year borough-wide supply of housing land, development outside, but adjacent to, settlements will be supported so long as they accord with other policies in the Plan.

It is easy to see why this policy would be unacceptable in practice, and would also attract a great deal of attention from landowners seeking to extract value from their land. For example, let us suppose that a significant brownfield site in Balby was allocated in the Plan, and was envisaged to contribute to the 5-year land supply. If an applicant could demonstrate that site’s delivery would be delayed, and that this reduced the Borough’s land supply to slightly less than five years, that applicant could make a strong case that their greenfield site just outside say, Harlington, would be supported by Policy 2(5) – despite the fact that it would inevitably be providing housing for a very different sector of the market.

Therefore this policy creates a direct incentive for landowners and developers to talk down the 5-year land supply in order to gain planning permission in rural locations. This would undermine other policies in the Plan, including Policy 26, and would have a tendency to weaken the implementation of the spatial strategy and settlement hierarchy by enabling less sustainably-located development.

Policy 3: Level & Distribution of Growth Not positively prepared to decouple employment opportunities from dependence on road traffic, will therefore fail to address UK carbon budgets.

Not positively prepared because additional housing numbers above the Standard Methodology are not linked to sustainable development outcomes.

Policies 4 and 5: Employment

Table 4 shows that all the new employment allocations are concentrated on six sites, and the vast majority of that is on two sites, M18 J6 and RHADS Site 1. It is evident that, to quote Policy 3, these sites will be ‘attractive to market investment’, but:

 it is unclear how such spatially concentrated employment on peripheral sites away from town centres will ‘meet future employment needs’;  it is disingenuous to argue that these sites can be ‘accessed via a range of transport modes’, when self-evidently the overwhelming majority of employee journeys to those sites would be by car;  concentrating new employment on such road-hungry sites runs entirely counter to the likely pattern of development needed to address the climate challenge.

Para 4.31 compounds this problem by associating the potential for employment growth in the north of the Borough to a putative A1-A19 link road, for which no proposals are actually shown, but if these proposals do emerge towards the end of the plan period then clearly that employment land would not come on-stream until much nearer to the 2050 date for the UK to achieve net zero carbon.

In short, this is a 20th century economic vision based on Doncaster’s continuing obsession with building roads and peripheral employment sites, and it has no place in preparing the Borough for the realities of the mid 21st century that will be defined by how places respond to the challenges of climate change.

Policy 6: Housing

The basic principle of regarding the Standard Methodology figure as the lower end of a range for the housing requirement is broadly in line with our recommendations in response to the Homes & Settlements consultation last year. In that response, we took the position that any uplift above the standard figure should be associated with delivering specific outcomes, such as transforming affordable housing provision, delivering innovative zero carbon homes, self- build etc. This would also enable the market to be more segmented, recognising that volume housebuilders and other, more diverse providers have a complementary role in meeting housing need.

This would mean, for example, that a scheme to remodel and densify an under-used site for co-working units would be considered to contribute to the uplift, but not to the baseline.

Therefore our recommended approach is to regard the standard figure (unclear if this is 572 or 585) as the baseline target, and to use this as the basis for the 5-year land supply calculation. The Plan appears to have taken this approach, which we support.

However, the Plan has not made any provision to secure additional outcomes from exceeding the baseline figure, in terms of the better affordable provision, zero-carbon homes or market diversification that we have proposed. Were our recommended approach to be taken, it would enable the Plan to treat around 36% of new housing as providing specific opportunities for enhancing places, and to be able to set very high standards for that housing accordingly. Instead the range figure up to 920 is simply aimed towards supporting economic uplift, such that the generalised housing requirement is assumed to grow in proportion to any above-trend economic growth. This is a missed opportunity which will cause the Plan to fall short on delivering a range of planning outcomes beyond housing numbers, especially in design, housing mix and making efficient use of land.

Policy 6: Green Belt and paras 4.13 to 4.15 Not justified in light of evidence of the need to address urban sprawl to the east of Doncaster.

CPRE has consistently called for the completion of a Green Belt designation around Doncaster. The need for this is evidenced by the increasing risk of coalescence of settlements east of Doncaster, principally along the A18 where Edenthorpe (ie Doncaster main urban area), Dunsville, Dunscroft and Hatfield have all stretched towards each other in

recent years. This in turn has made it more difficult to direct large-scale development to regeneration areas including Hungerhill (Edenthorpe) and the Unity site at Hatfield-Stainforth.

Figure 2: Distribution of Centres Unsound because it fails to show the potential for rail connectedness of many settlements, with potential implications for the settlement hierarchy

The only rail route shown in Figure 2 is the East Coast Main Line. This means that relatively strong rail connectedness of the following settlements is not shown: Conisbrough, Mexborough, Bentley, Adwick-le-Street, Kirk Sandall, Hatfield-Stainforth, Thorne.

This is not simply an oversight of graphical representation. It allows the reader to consider the relationship between different centres in the Borough without visualising how they connect to each other by rail, and the potential implications of that for how those centres may be expected to provide services to their areas, and the levels of growth that may be appropriate there. For example, if a significant number of residents in a community are to be encouraged to use rail travel and reduce car dependency, then it is important to have enough local facilities situated along the walking routes from local stations to residential neighbourhoods; and there is also a need to facilitate higher residential densities in those areas to support the local facilities and rail patronage.

Our position on Policy 6 Housing Allocations, and paras 4.80 to 4.85 on land supply, should be seen in the context of our comments on Policy 3 above. That is to say, we do not find them unsound in themselves, but they would need to be modified to provide for our recommended approach to Policy 3.

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).

We recommend

Rewording the first paragraph of Policy 2 as follows:

Doncaster’s Spatial Strategy will focus on delivering development that is appropriate to the size and needs of individual settlements, and better equips those settlements to achieve the radical reductions in greenhouse gas emissions required by national policy. This development should meet the needs for new homes and jobs, regenerate places and communities, support necessary infrastructure, services and facilities, and enable transformative improvements to carbon efficiency and opportunities for active travel.

Please also see our comments on Chapter 9, wherein our recommendations for a sub-area approach may also affect the use of the settlement hierarchy.

Policy 2(5) amending to: provide a stronger spatial vision for the Borough’s countryside (see our comments on Chapter 9); specify that ‘small scale residential developments may be considered for permission if adjacent to a development limit in levels 1-3 above, where…’ delete clause E so that this policy is not triggered by the 5-year supply, and such sites are not assessed on the basis of their strategic contribution to housing land supply – since this should have been established by the Plan.

Policies 4 and 5: Employment

As we have consistently argued, Doncaster needs to provide evidence of how its economic growth ambitions are compatible with meeting future employment needs in a genuinely sustainable way. We are wholly unconvinced that a growth strategy focusing on road-based distribution and logistics is compatible with this, but if it is then the evidence must be provided to demonstrate it. Otherwise, the Plan is enabling a flawed growth strategy, and both must be revised.

Specifically, we consider that the focus on a small number of very large, peripheral sites needs to be replaced with a much finer-grain approach addressing the skills and needs of different communities across the Borough, accompanied by a plan to de-carbonise the employment patterns of the Borough.

Policy 6: Housing

We recommend setting a policy framework for the specific policy outcomes that new housebuilding at any rate exceeding 585 pa would be expected to deliver, and make clear that release of land to enable higher build rates would be conditional on clear proposals to implement that.

Figure 2: Distribution of Centres

Show the full rail network on Figure 2, and indicate how rail accessibility informs the provisions for different centres.

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:

To assist the Inspector by using our submitted representations to answer his/her questions, particularly in light of the evidence submitted by other representors and any other matters the Inspector may raise.

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

Your Andrew Wood pp Andy Tickle Date Signature 29/09/2019

Ref: Doncaster

Local Plan

Publication Draft 2019 (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

Please respond by 6pm Monday 30 September 2019.

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 Dr

First Name Andy

Last Name Tickle Organisation CPRE South Yorkshire (where relevant) Address – line 1 37 Stafford Road

Address – line 2 Sheffield

Address – line 3

Postcode S2 2SF

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on?

Do I have to use the response form?

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?

Question 3 (below) – What does ‘legally compliant’ mean?

Questions 4/5 (below) – What does ‘soundness’ mean?

 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?

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

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:

CPRE South Yorkshire

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.: 48 - 50 Paragraph: 5.33 – 5.35 Policy Ref.: Chapter 5: Policy 7 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.

The proposals for growth at the airport are unsustainable, unsound and unjustified.

1. Local planning authorities have a duty under Section 19 of the Planning and Compulsory Purchase Act 2004 (as amended) to ensure that plans ‘contribute to the mitigation of, and adaptation to, climate change’. There is no evidence of this approach towards Policy 7. This duty means that local plans should be based on evidence relating to the Climate Change Act targets (including identifying baseline carbon emissions data), and monitoring of plans in annual monitoring reports should demonstrate how development is contributing to meeting those targets. Doncaster Sheffield Airport’s (DSA) plan for transformational growth can only be supported in the context of a carbon pathway to net zero greenhouse gas emissions by 2050, with binding carbon targets. This pathway should include domestic and international aviation emissions and a commitment to amend the programme of interventions to meet those targets.

2. During development of this version of the Local Plan, climate change has developed into an existential threat and emergency. The October 2018 Special Report from the Intergovernmental Panel on Climate Change (IPCC) concluded that in order for warming to stay below 1.5°C, human-caused CO2 emissions must fall to net zero by 2050 or earlier2 which will require ‘rapid and far reaching transitions’ that are ‘unprecedented in scale…and imply deep emissions reductions in all sectors’. The Committee on Climate Change (CCC) published its response to the IPPC’s report3, and in June 2019 the Government accepted the Committee’s advice and amended the 2050 target under the Climate Change Act to require net-zero greenhouse gas emissions by that date.

3. DfT has yet to report on its 2018 consultation on the Future of UK airports 2050, a document that relied on aviation emissions increasing from 37.3MtCo2e in 2016 to 39.9Mt in 2050, or a 7% increase. However, in its 2019 progress report4 the CCC recommends the formal inclusion of aviation emissions in the Climate Change Act targets and a long term strategy for aviation that reflects net zero by 2050. In accepting the CCC advice on the IPCC report the Government stated that emissions should reach net-zero across the whole economy (i.e. including international aviation and shipping) and that the aim would be to reach net-zero emissions without recourse to international credits (or ‘offsets’), consistent with the Committee’s advice5. Consequently, although the Government does not have in place a framework for aviation carbon reduction, it is clearly its intent to develop one.

4. The current planning consent for the airport limits aircraft movements to 57,000 per annum with the airport having seen an average of 16,000 movements per annum over the last 3 years. It currently moves about 1million passengers per annum (mppa) and 7,000t of freight per annum6, although fully realised it could handle 25mppa and 250,000t of cargo7. The Interim Masterplan aims for increases of between 4mppa (core growth strategy) and 7mppa (high growth strategy) by 2037, and for between 70,000t and 170,000t of freight for the same respective scenarios. Both these appear unrealistic based on historical data for DSA (Doncaster Sheffield Airport). Since the airport opened in 2005 passenger numbers have largely remained below 1mppa and only rose above that figure in the last 3 years. Freight movements have fluctuated well below 1,000t per annum and in the last 3 years have fallen by nearly 25%. The emissions for freight transfer are always higher by air compared to road, let alone by rail or sea8.

2 October 2018. http://www.ipcc.ch/report/sr15/ 3 Net Zero The UK’s contribution to stopping global warming, Committee on Climate Change, May 2019 4 Reducing UK Emissions: 2019 Progress Report to Parliament, Committee on Climate Change July 2019 5 House of Commons Hansard (12 June 2019) Net Zero Emissions Target, Volume 661, Columns 673 and 682. 6 https://www.caa.co.uk/Data-and-analysis/UK-aviation-market/Airports/Datasets/UK-Airport-data/Airport-data-2018/ 7 Sheffield City Region Integrated Rail Plan, July 2019 8 The various emission factors for freight transfer KgCO2 per tonne km are that air freight is by far the highest; HGV freight on average emits less than a quarter of the least emitting air freight - so it would always be more carbon efficient to tranship freight S>N or N>S by road rather than air - but the most carbon efficient freight transport is by rail and ship – see DEFRA 2008 Guidelines to Defra’s GHG Conversion Factors: Methodology Paper for Transport Emission Factors, table 8 compared to table 26, and tables 28 & 31.

5. Transport is the one sector that has failed to meet its carbon budgets, with the sector’s emissions at the same level in 2016 as they were in 19909. Surface transport is the largest-emitting sector in the UK, accounting for 23% of UK emissions10 with cars accounting for the majority of them. Even with a shift to electric vehicles, the level of reduced car mileage needed to meet the UK carbon budget by 2030 is estimated to be between 20% and 60%, depending on the speed of the switch to electric vehicles and how fast the electricity powering them is decarbonised11. It is therefore imperative that traffic reduction is implemented urgently. The scale of the effort required has been shown by work done by the Tyndall Centre for both the West Yorkshire Combined Authority and Sheffield City Council12.

6. In that context both the Airport Surface Access Strategy and access to the housing and employment sites must be based on demand management of road capacity and development of sustainable alternative modes. NPPF para 103 requires significant development to be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. A robust approach should be taken towards travel to and from the site using the Institution of Mechanical Engineers’ Transport Hierarchy 201313, the Transport for New Homes Checklist 2019, and NPPF para 110. The proposal for improved access to the M18 would encourage journeys by car to both the airport and any new development. Demand management of traffic with investment in alternatives modes of travel and travel planning must be implemented.

7. The proposal for a southern link from the DSA station, creating a loop to allow ECML expresses to serve the airport cannot be justified based on the past history of the airport which suggests that neither the passenger nor the freight base exists to support it. A less ambitious intervention to create a station on the Lincoln line at DSA should be substituted.

8. The approach towards development at the airport refers to the requirement for a comprehensive Masterplan, which would include an up-to-date airport surface access strategy. At this current time the only document available to us is the 2018 Interim Consultation Report on the Masterplan 2018-2037 which was published by the airport owners and not subject to wider stakeholder involvement in its development. It is essential that the process for developing the masterplan is implemented.

9. Given the uncertainty surrounding the approach to climate change for both surface access and aviation, and DSA’s history there should be serious concerns about the implementation and delivery of Policy 7.

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

Amend opening sentence of Policy 7: Growth and investment at Doncaster Sheffield Airport (in areas defined on the Policies Map), will only be supported to enable its development and expansion in the context of a carbon reduction pathway to net zero by 2050, with binding targets, for the Borough and in line with the following principles:

7H) Access to the Airport must be shown to be compatible with an up to date Airport Surface Access Strategy (ASAS) to enable easy access through a range of travel modes, predominantly public transport, from the Borough, City Region and the wider region. Car parking for users of the airport will be limited in order to demand management travel by private

9 2016 UK Greenhouse Gas Emissions Final figures, BEIS, 2018, Table 6 10 Net Zero Technical Report Committee on Climate Change, May 2019, Figure 5.1 11 More than electric cars, FoE, May 2019 12 https://www.sheffield.gov.uk/content/dam/sheffield/docs/your-city-council/climate-change/Sheffield_Report_V1.3.1.pdf 13 https://www.imeche.org/policy-and-press/reports/detail/transport-hierarchy

car. There will be a presumption against provision of airport car parking in off-site locations outside the area of the airport growth plan.

Amend J) 3. by adding Travel to and from the site will be based on the sustainable travel hierarchy which promotes walking, cycling, public transport and car sharing in preference to single occupancy car use for movement of people, and encourages efficient and sustainable freight. Travel plans for both business and residential development will be required. (See our new proposed policy Transport Hierarchy)

The text to support this policy in paras 5.33-5.35 (including the second para 5.31) should be amended to remove the improved connection to the M18. Reference should be made to both the Transport Hierarchy and the Transport for New Homes Checklist in 5.31 (under transport) and/or para 5.34.

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

No, I do not wish to participate at the examination. I ☐ ☒ Yes, I wish to appear at would like my representation to be dealt with by the Examination. written representation.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations.

9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:

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

Your Andrew Wood pp Andy Tickle Date Signature 29/09/2019

Ref: Doncaster

Local Plan

Publication Draft 2019 (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

Please respond by 6pm Monday 30 September 2019.

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 Dr

First Name Andy

Last Name Tickle Organisation CPRE South Yorkshire (where relevant) Address – line 1 37 Stafford Road

Address – line 2 Sheffield

Address – line 3

Postcode S2 2SF

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on?

Do I have to use the response form?

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?

Question 3 (below) – What does ‘legally compliant’ mean?

Questions 4/5 (below) – What does ‘soundness’ mean?

 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?

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

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:

CPRE South Yorkshire

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.: 66 - 85 Paragraph: Chapter 7: New headline policy Policy Ref.: ‘Transport Hierarchy’ and Site Ref.: Policies 13, 14, 17, 18 and 22 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.

Chapter 7 is unsound as it does not meet the needs of the Borough to address climate change; nor take account of the evidence about climate change or of changing travel demand.

1. Local planning authorities have a duty under Section 19 of the Planning and Compulsory Purchase Act 2004 (as amended) to ensure that plans ‘contribute to the mitigation of, and adaptation to, climate change’. The duty means that local plans should be based on evidence relating to the Climate Change Act targets (including identifying baseline carbon emissions data), and monitoring of plans in annual monitoring reports should demonstrate how development is contributing to meeting those targets. There is no evidence of this approach in Chapter 7, which makes no mention of climate change. Strategically planned major change, where the location and overall form of development can have a major impact on travel, must be set within a carbon pathway to net zero 2050 with binding carbon targets for all modes.

2. During development of this version of the Local Plan climate change has developed into an existential threat and emergency. The October 2018 Special Report from the Intergovernmental Panel on Climate Change (IPCC) concluded that in order for warming to stay below 1.5°C, human-caused CO2 emissions must fall to net zero by 2050 or earlier2 which will require ‘rapid and far reaching transitions’ that are ‘unprecedented in scale…and imply deep emissions reductions in all sectors’. The Committee on Climate Change (CCC) published its response to the IPPC’s report3, and in June 2019 the Government accepted the Committee’s advice and amended the 2050 target under the Climate Change Act to require net-zero greenhouse gas emissions by that date.

3. Transport is the one sector that has failed to meet its carbon budgets, with the sector’s emissions at the same level in 2016 as they were in 19904. Surface transport is the largest-emitting sector in the UK, accounting for 23% of UK emissions5 with cars accounting for the majority of them. Even with a shift to electric vehicles, the level of reduced car mileage needed to meet the UK carbon budget by 2030 is estimated to be between 20% and 60%, depending on the speed of the switch to electric vehicles and how fast the electricity powering them is decarbonised6. It is therefore imperative that traffic reduction is implemented urgently. This will require a transformational change in the way people travel. The scale of the effort required has been shown by work done by the Tyndall Centre for both the West Yorkshire Combined Authority and Sheffield City Council7.

4. In order to reduce road vehicle miles for both passengers and freight, demand management of road capacity is essential, coupled with investment in high quality, affordable and accessible alternatives. Research by CPRE - Appendix A attached - (The End of the Road? Challenging the road building consensus, 2017, Sloman et al) has reinforced the futility of providing further road capacity. It not only induces substantial increases in traffic, over and above background growth, but also leads to congestion, air pollution and increases in carbon emissions. It reinforces a highly car-dependent pattern of land development, fails to benefit the economy and leads to long lasting adverse impacts on landscape and biodiversity. Travel demand is also reducing with 16% fewer trips than in 1996, 10% fewer miles travelled than in 2002 and 22 hours less time travelling than a decade ago8.

2 October 2018. http://www.ipcc.ch/report/sr15/ 3 Net Zero The UK’s contribution to stopping global warming, Committee on Climate Change, May 2019 4 2016 UK Greenhouse Gas Emissions Final figures, BEIS, 2018, Table 6 5 Net Zero Technical Report Committee on Climate Change, May 2019, Figure 5.1 6 More than electric cars, FoE, May 2019 7 https://www.sheffield.gov.uk/content/dam/sheffield/docs/your-city-council/climate-change/Sheffield_Report_V1.3.1.pdf 8 All Change? The Future of Travel and the Implications for Policy and Planning, The First Report of the Commission on Travel Demand, 2018

Therefore development proposals should be based on the Transport Hierarchy9 which prioritises walking, cycling, public transport, taxi, pool car, private car in that order. Such an approach can change transport behaviour, improve people’s health, reduce levels of physical activity and sedentary behaviour, and reduce air pollution and congestion. Policy 13 is not set within a carbon reduction pathway to 2050, nor is there any reference to the impacts of its proposals on climate change.

All of the proposals listed in Policy 13A) should be measures of last resort and only pursued if alternatives fail to provide the outcomes required.

A1, A3, A4 - We are particularly concerned about the pan northern route, part of which would cross the Peak District National Park. The proposal is against all policy, both nationally and locally, on strategic (motorway and trunk) road infrastructure in a National Park (NPPF para 172 and footnote 54; PDNPA Core Strategy 2011 Policies T1 and T2 and para 15.9).

Section 62 of the Environment Act 1995 places a general duty on statutory undertakers, such as Local Councils, to have regard to the purposes of National Parks when coming to decisions or carrying out their activities relating to or affecting land within the Parks. Although the Park is outside its area, Doncaster MBC has a duty under the Environment Act, which it has yet to demonstrate that it has met in its decision to promote the pan-northern route across the National Park.

Within South Yorkshire the pan-northern route and its components would have severe adverse impacts on some of the most sensitive landscapes, such as the Magnesian Limestone Ridge.

A2 - The A1-A19 link road would be adjacent to a railway line with a station at Adwick-le-Street. This is a prime example of where all new development could be car-free and rely on rail/bus connections. A5 - Congestion on the A1(M) motorway (capacity improvements) should be managed using demand management and smart motorway techniques. A6 - The Hatfield Link Road may be essential to link strategic development to the road network but all residential development could be car free with connectivity based on the rail station at Stainforth. A7 West Moor Link (A630).; A8. Improvements to M18; A9. Improved access to Doncaster-Sheffield Airport from M18; A10. M18 / A1(M) interchange improvements; A11. North Nottinghamshire to A631 are all road capacity improvements. Traffic should be demand managed, coupled with development of high quality, accessible and affordable public transport.

Some of these proposals (A1, A2, A3, A4, A5, A8, A10) fall within the scope of Transport for the North (TfN)’s Strategic Transport Plan 2019 Investment Programme10 to 2050. TfN is developing a carbon reduction pathway to net zero 2050 and has committed to amend its programme to meet this target (Strategic Transport Plan 2019, page 81). As TfN is the subnational transport body for the north and its remit covers Doncaster Borough, at least some of Doncaster’s proposals will be covered by the carbon reduction pathway. However, Doncaster should have its own pathway and make its own balances to achieve binding targets.

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

9 See Institution of Mechanical Engineers 10 https://transportforthenorth.com/wp-content/uploads/TfN-final-investment-programme-19-20.pdf

Insert as text before all policies a new opening to Chapter 7 Climate change is now an existential threat and emergency. In June 2019 the Government accepted the Committee on Climate Change’s advice and amended the 2050 target under the Climate Change Act to require net-zero greenhouse gas emissions by that date.

Transport is the one sector that has failed to meet its carbon budgets, with the sector’s emissions at the same level in 2016 as they were in 199011. Surface transport is the largest-emitting sector in the UK, accounting for 23% of UK emissions12 with cars accounting for the majority of them. Even with a shift to electric vehicles, the level of reduced car mileage needed to meet the UK carbon budget by 2030 is estimated to be between 20% and 60%, depending on the speed of the switch to electric vehicles and how fast the electricity powering them is decarbonised13. It is therefore imperative that traffic reduction is implemented urgently. This will require a transformational change in the way people travel.

In order to reduce road vehicle miles for both passengers and freight, demand management of road capacity is essential, coupled with investment in high quality, affordable and accessible alternatives. The futility of increasing road capacity has been shown over many years through extensive research. It not only induces substantial increases in traffic, over and above background growth, but also leads to congestion, air pollution and increases in carbon emissions. It reinforces a highly car-dependent pattern of land development, does not benefit the economy and leads to long lasting adverse impacts on landscape and biodiversity. Therefore increasing road capacity will be an option of last resort and demand for it will be managed.

The Transport Hierarchy14 which promotes walking, cycling, public transport and car sharing in that order of priority, in preference to single occupancy car use, for movement of people, and encourages efficient and sustainable freight, will be adopted for all planning and travel proposals in order to encourage more journeys to be made without a car. This would enable wider public policy goals for health and wellbeing, social inclusion, job opportunities, trade, access to services and sustainable places, which transport can support, to be achieved. The approach needs to be tailored to outcomes that are practical at the local level and to reflect particular areas of challenge such as travel in rural areas.

Taken from National Transport Strategy, 2016 Transport Scotland, page 26

Add a new first policy to chapter 7 ‘Transport Hierarchy’.

Measures to help travel needs meet Doncaster’s carbon reduction pathway to net zero 2050 will be based on reducing the need to travel and widening travel choices, as follows:

11 2016 UK Greenhouse Gas Emissions Final figures, BEIS, 2018, Table 6 12 Net Zero Technical Report Committee on Climate Change, May 2019, Figure 5.1 13 More than electric cars, FoE, May 2019 14 https://www.imeche.org/policy-and-press/reports/detail/transport-hierarchy

A) Patterns of development which reduce the need to travel and implement the sustainable transport hierarchy will be supported. B) Development must be supported by clear commitments to walking, cycling and public transport with mode- share targets in travel plans. C) Development must demonstrate best practices in sustainable transport, e.g. reducing travel through use of IT, Mobility as a Service (MaaS) and public transport, and promoting car clubs, cycle hire and home working solutions. D) Development will provide for car parking only in defined spaces or purpose-built bays on-street and be organised to avoid negative impacts on active travel and bus operation. The majority of car parking spaces will be communal (available to all residents, visitors and car club vehicles). Near to railway stations and strategic bus routes car-free development should be possible. E) Electric vehicle charging points will be provided. F) Development must make provision for public transport services that will operate 7 days a week and in the evenings from Day 1 of occupation. Provision of such services will be certain in the long term. The street layout will give priority to public transport over other traffic. Direct services to key destinations will be provided.

Policy 13: Strategic Transport Network Add new introductory text: Investment in transport infrastructure will all be assessed within the carbon reduction pathway to 2050 for the Borough and the programme will be amended to achieve carbon emissions targets for transport. Best use will be made of all transport infrastructure. Public transport by road or rail will be prioritized over road transport. Wherever possible freight should be conveyed by rail or water. Road capacity will be demand managed and any increase will be a measure of last resort, once all reasonable alternatives have been implemented and failed to achieve the desired outcomes. Proposals will be supported which:

Amend policy as follows: A) Delete all listed, except the Hatfield Link Road (?), and move A to the bottom of the policy. B) 1.Delete and replace with ‘a new railway station at DSA on the Lincoln line.’ D) 5. Delete ‘aviation and’

Policy 14: Promoting Sustainable Transport in New Developments Amend to fit with changes to Policy 13 B) 2nd para delete ‘capacity and’ B) 3rd para delete rest of sentence after ‘measures’

Policy 17: Cycling in Doncaster

B) Add new 6. ‘Cycle routes will be shorter than routes for cars wherever practicable.’ Add new 7 ‘Road space will be reallocated to cycling if segregated routes cannot be provided’

C)3. Add, in new development for employment provide changing and showering facilities;

Policy 18: Walking in Doncaster Add ‘provide alternative direct routes to local facilities and the town centre’

Policy 22: Telecommunications and Utilities infrastructure In F) after ‘visual’ add ‘and landscape’

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

No, I do not wish to participate at the examination. I ☐ ☒ Yes, I wish to appear at would like my representation to be dealt with by the Examination. written representation.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations.

9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:

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

Your Andrew Wood pp Andy Tickle Date Signature

29/09/2019

Ref: Doncaster

Local Plan

Publication Draft 2019 (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

Please respond by 6pm Monday 30 September 2019.

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 Dr

First Name Andy

Last Name Tickle Organisation CPRE South Yorkshire (where relevant) Address – line 1 37 Stafford Road

Address – line 2 Sheffield

Address – line 3

Postcode S2 2SF

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on?

Do I have to use the response form?

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?

Question 3 (below) – What does ‘legally compliant’ mean?

Questions 4/5 (below) – What does ‘soundness’ mean?

 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?

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

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:

CPRE South Yorkshire

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.: 94 - 98 Paragraph: Policy Ref.: Chapter 9: Policy 26 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.

Chapter 9: Countryside Unsound because the Plan is not positively prepared, ie to achieve any positive outcomes for the countryside.

The majority of land by area in Doncaster Borough remains rural. Para 2.6 of the Plan notes “Much of the Borough is rural in nature and includes areas of attractive landscape and features, such as limestone gorges, woodlands, country parks and lowland moorland. Over two-thirds of the Borough is in agricultural use, mainly in the eastern parts. Green Belt covers the western half of the Borough.”

Chapter 9 does not offer a spatial strategy for Doncaster’s countryside, and occupies just 4 of the 386 pages of the Plan. It is wholly unfit for purpose. Chapter 9 restricts itself to defining ‘Countryside’ as a policy designation, distinct from ‘Green Belt’ or from other levels of the settlement hierarchy. Whilst it is necessary and welcome to have a policy (Policy 26) outlining the development management framework for development in non-Green Belt countryside, that policy does not, in itself, warrant a chapter of the Plan. What is missing here is any articulation of the range of types, characteristics and needs of the Borough’s small villages, farming communities and the landscapes they sit within. Many of these are isolated by lack of amenities, lack of public transport and dependence on private cars for transport, but are nevertheless an intrinsic part of the Borough’s character and of its future.

By and large, it is immaterial to those communities and landscapes whether they fall within ‘Green Belt’ or ‘Countryside’ for policy purposes, except for the fact that within the Green Belt it is easier to protect against inappropriate development. Within neither policy designation is there any vision or policy for how they are to evolve. How will they be made fit for the low-carbon, low-car future that must inevitably happen if the UK’s legally-binding carbon targets are to be met? Or will these rural areas be excluded from that future through lack of planning?

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

We recommend:

The Plan should be comprehensively restructured, so that the Borough’s rural areas are not crudely cut off from settlements and then further sub-divided into ‘Green Belt’ and ‘Countryside’. Instead, we recommend a sub-area structure for the Plan, whereby settlements and their surrounding countryside can be understood and planned for in synergy with each other.

For example, we list below suggested sub-areas with identifiable characteristics (note that some of these (asterisked*) are currently defined within Doncaster Main Urban Area). This list is illustrative, not definitive, but is provided here to show that when groups of settlements are considered as sub-areas that also contain rural areas, landscapes and green infrastructure, it will be possible to plan for them in more interconnected ways. It is evident, for example, that some of these areas are affected differently by transport connectivity, flood risk and landscape character, and have different development needs and challenges.

Brodsworth-Hickleton-Marr-Barnburgh-Harlington-High Melton Mexborough-Conisbrough-Denaby-Edlington Wadworth-Tickhill-Bawtry Rossington Hayfield-Finningley-Blaxton-Auckley-Branton-Branton-Cantley* Armthorpe-Edenthorpe*-Kirk Sandall*-Barnby Dun Dunsville-Dunscroft-Hatfield-Stainforth-Hatfield Woodhouse Thorne-Moorends Kirk Bramwith-Braithwaite-Fishlake-Sykehouse-Moss-Fenwick Askern-Campsall-Norton Carcroft-Skellow-Adwick-Bentley* Scawthorpe*-Scawsby*-Cusworth-Sprotbrough

The Bradford Core Strategy Partial Review (Preferred Options) has an excellent sub-area approach which we suggest Doncaster looks to for good practice.

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

No, I do not wish to participate at the examination. I ☐ ☒ Yes, I wish to appear at would like my representation to be dealt with by the Examination. written representation.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations.

9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:

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

Your Andrew Wood pp Andy Tickle Date Signature

29/09/2019

Ref: Doncaster

Local Plan

Publication Draft 2019 (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

Please respond by 6pm Monday 30 September 2019.

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 Dr

First Name Andy

Last Name Tickle Organisation CPRE South Yorkshire (where relevant) Address – line 1 37 Stafford Road

Address – line 2 Sheffield

Address – line 3

Postcode S2 2SF

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on?

Do I have to use the response form?

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?

Question 3 (below) – What does ‘legally compliant’ mean?

Questions 4/5 (below) – What does ‘soundness’ mean?

 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?

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

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:

CPRE South Yorkshire

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.: Pages 99, 108, 111 and 116 Paragraph: Chapter 10: Policies 27, 30, 31 Policy Ref.: and 34 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 27: Green Infrastructure GI A) 4 asks development to consider tranquillity. This does not go far enough in interpreting NPPF 180a which requires ‘development to mitigate and reduce to a minimum potential adverse impacts resulting from noise from new development – and avoid noise giving rise to significant adverse impacts on health and the quality of life, and wildlife’.

Policies 30 and 31 Key sites and/or habitats should not be seen in isolation from the networks that link them. Giving sites and networks two separate policies fails to make explicit the absolute link that must be made between them. Making our proposed changes to Policies 30 and 31 would encompass that holistic approach, meet the Lawton Review’s principles (quoted in para 5.27) of ‘bigger, better, more and joined’ habitats and of the Government’s 2018 25-year Environment Plan’s proposals for Nature Recovery Network, and the NPPF paras 170(d) and 174, which consistently puts habitats and networks together. Policy 31 is weak and does not comply with NPPF paras 175-176.

Policy 34: Landscape A substantial revision of this policy is required in order to give landscape the importance it requires as the setting for all development and to reflect the European Landscape Convention. At present the explanatory text focuses only on policy not the importance of landscape to people and place.

Landscape is more than just scenery: it is the interaction between people and place; the bedrock upon which our society is built. Landscape gives meaning and value to the world around us, contributing to our sense of identity and quality of life. Landscape is both rural and urban, and includes both beautiful and everyday places, as well as those in need of restoration. Through it all ecosystem services are delivered.

Landscape makes connections between people, between people and places, and between society and its environment. Involving all of society in shaping and celebrating our landscape will address many challenges facing us today, including demographic and lifestyle changes, food and energy security, heritage and biodiversity conservation.

The European Landscape Convention was the world’s first treaty to focus specifically on Landscape and was ratified by the UK Government in 2007. Its commitments include integrating landscape into all relevant policies in spatial planning; identifying, assessing and monitoring landscapes, describing their character and analysing what contributes to, or detracts from, their quality and distinctiveness; involving all members of society in the protection, management and planning of landscapes: safeguarding their heritage value, enabling positive change and looking ahead to adapt and create the landscapes of the future.

NPPF paras 20(d), 127(c), 141, 149, 151, 170 (a & b), 171, and 180(b) require stronger protection of landscape and tranquil areas than the current policy.

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

Policy 27 The language of this policy needs amending to strengthen protection relating to tranquillity.

Policies 30 and 31 Policy 30 Ecological Networks should be part of Policy 31 Valuing Biodiversity and Geodiversity, creating one coherent policy. Delete Policy 30 and revise Policy 31 as follows.

Valuing Biodiversity and Geodiversity (Strategic Policy) Areas of high biodiversity and geodiversity value must be protected and enhanced. Enhancement measures will include increasing the total area of valuable habitat in the Borough, and linking up existing areas of high value habitat such as 'ecological stepping stone sites', ‘wildlife corridors’ and 'Nature Improvements Areas' to create coherent and continuous ecological networks. Ecological networks and connectivity are vitally important in sustaining sites and addressing the impacts of climate change. The overall aim is to work in partnership to deliver conservation gain at a landscape scale.

Proposals will only be supported which deliver a net gain for biodiversity and protect, create, maintain and enhance the Borough's ecological networks and sites through the following principles:

A) 1,2,4,5,6, unchanged A) 3. They protect restore enhance and provide appropriate buffers around wildlife and geological features, and aim to link these to, and enhance, the wider ecological networks. Existing habitat networks will be maintained and strengthened, and gaps will be bridged to create a coherent network A) 7. When creating new, or restoring existing, national and local priority habitats and networks all planting will be of native species;

B. Development proposals which may adversely affect the integrity of a site with one or more of the following international designations: i. Special Protection Areas (SPAs) ii. Special Areas of Conservation(SACs) iii. Ramsar site iv. Any potential Special Protection Areas (SPAs), Special Areas of Conservation(SACs) or proposed Ramsar site v. Sites identified, or required, as compensatory measures for adverse effects on European sites, candidate Special Protection Areas, possible Special Areas of Conservation, and listed or proposed Ramsar sites will not be permitted unless it has been demonstrated that there are no alternative solutions, there are imperative reasons of overriding public interest and that compensatory measures provide net gain to the habitats and species. The overall coherence of the network of the designations must be shown to be protected.

C. In order to ensure development does not negatively impact on nightjar populations, proposals located within 3km of Thorne and Hatfield Moors Special Protection Area, that impact habitats that nightjars may use for feeding on, will only be supported where they deliver a net gain in nightjar foraging habitat.

D. Development proposals which are likely to have an adverse impact on a Site of Special Scientific Interest (SSSI) will not normally be permitted. Where an adverse effect on the site’s notified special interest features is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest.

E. Development proposals which are likely to have a significant adverse impact on a site with one or more of the following local or regional designations, habitats or species will not be permitted except where the reasons for or benefits of the proposed development outweigh the impact of the development: i. Local Nature Reserves ii. Sites of Biological Importance (SBI) or Local Wildlife Sites iii. Regionally Important Geological and Geomorphological Sites (RIGGS) iv. Designated and/or important wildlife corridors and stepping stones

v. Nature Improvement Area vi. Habitats and species within the Doncaster Biodiversity Action Plan vii. National priority species and habitats (commonly known as ‘UK BAP priority habitats and species’) published for England under the requirements of Section 41 of the Natural Environment and Rural Communities Act 2006.

F. All development (including conversions and that on brownfield and greenfield sites) must aim to positively contribute to the conservation and enhancement of biodiversity and geodiversity and should not negatively affect these interests. When appropriate, conditions will be put in place to make sure appropriate monitoring is undertaken and make sure mitigation, compensation and offsetting is effective.

G. Development proposals that are likely to have a significant impact on a non-designated asset or a site valued by the local community identified in a Neighbourhood Plan or the Site Allocations and Development Policies documents will only be permitted where suitable mitigation and / or compensation is provided to address the adverse impacts of the proposed development, or where any residual harm following mitigation/compensation along with other harm, is clearly outweighed by the benefit of the development.

Policy 34 A substantial revision of policy 34: All development should conserve the landscape character and quality of the Borough and should where possible, enhance and effectively manage the historic, natural and man-made landscape features that contribute to local distinctiveness of both rural and urban landscapes. This will require a landscape scale approach to the proposed development, with associated policy requirements.

1. Understanding of the context, characteristics and significance of the development should be provided and informed by the Doncaster Landscape Character Assessment.

2. Development will be expected to: i. Incorporate appropriate landscaping which reflects the character of the area, including its historical, biodiversity and cultural character, and tranquillity through appropriate design and management; ii. Where appropriate, provide suitable and appropriate mitigation for the restoration of damaged landscape areas; iii. conserve the distinctive setting of, and relationship between, settlements and buildings and the landscape including important views; iv. Preserve and promote local distinctiveness and diversity; v. Avoid the loss of habitats of significant landscape importance and the pattern of woodland, forests, trees, field boundaries, vegetation and other features; where suitable mitigation measures are not achievable on site, then development should provide appropriate net biodiversity gain off site; vi. Protect and / or conserve the historical and ecological qualities of an area, and the special qualities of rivers, waterways, wetlands and their surroundings; and vii Protect the topography of the area including sensitive skylines, hillsides and geological features. viii Protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason; ix Consider cumulative impacts on landscape and visual amenity; x Where development proposals would result in a significant impact on the Borough’s landscape, consider alternative site selection; the scale, massing, design, form, layout, orientation and/ or operation of the development; and the incorporation of suitable mitigation measures.

3. Where development is considered to be acceptable in principle, measures will be sought to integrate it into the landscape character of the area by: i. Protecting, restoring and enhancing the character and appearance of the local area through suitable planting, landscape and / or woodland; ii. Making suitable provision for better public access to, and enjoyment of, local landscapes;

Landscape works shall be appropriate to the scale of the development in accordance with Policy 49 (Landscaping of New Developments) and may require consideration at a landscape scale.

The explanation below the policy also requires amending with the following paras before para 10.50: Landscape is more than just scenery: it is the interaction between people and place; the bedrock upon which our society is built. Landscape is both rural and urban, and includes both beautiful and everyday places, as well as those in need of restoration. Involving all of society in shaping and celebrating our landscape will address many challenges facing us today, including climate change, demographic and lifestyle changes, food and energy security, heritage and biodiversity conservation.

The European Landscape Convention was the world’s first treaty to focus specifically on landscape and was ratified by the UK Government in 2007. Its commitments include integrating landscape into all relevant policies in spatial planning; identifying, assessing and monitoring landscapes, describing their character and analysing what contributes to, or detracts from, their quality and distinctiveness; involving all members of society in the protection, management and planning of landscapes: safeguarding their heritage value, enabling positive change and looking ahead to adapt and create the landscapes of the future.

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

No, I do not wish to participate at the examination. I ☐ ☒ Yes, I wish to appear at would like my representation to be dealt with by the Examination. written representation.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations.

9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:

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

Your Andrew Wood pp Andy Tickle Date Signature 29/09/2019

Ref: Doncaster

Local Plan

Publication Draft 2019 (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

Please respond by 6pm Monday 30 September 2019.

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 Dr

First Name Andy

Last Name Tickle Organisation CPRE South Yorkshire (where relevant) Address – line 1 37 Stafford Road

Address – line 2 Sheffield

Address – line 3

Postcode S2 2SF

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on?

Do I have to use the response form?

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?

Question 3 (below) – What does ‘legally compliant’ mean?

Questions 4/5 (below) – What does ‘soundness’ mean?

 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?

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

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:

CPRE South Yorkshire

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.: 131 - 144 Paragraph: Policy Ref.: Chapter 12 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:

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.

Chapter 12: Design and the Built Environment Unsound because measures to incorporate low and zero-carbon design into buildings and places are not integrated or strategic.

The urgent need to embrace zero carbon as a feature of all new developments is not reflected in this chapter. The references to it in Clause 11 of Policies 43 and 45, and Policy 47(B) sit in some isolation from each other, and are treated as development management policies, whereas the role of design and placemaking in addressing climate change should in fact be a major strategic feature of the Plan if it is to be achieved.

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

We recommend: Adding an overall ‘design and placemaking for climate change response’ strategic policy, which refers to policies 42, 43, 45, 46, 47 as implementation policies, but also includes the importance of other characteristics, such as walkability, street trees, densities and mix of uses, and public transport connectivity, as crucial aspects of design and placemaking.

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

No, I do not wish to participate at the examination. I ☐ ☒ Yes, I wish to appear at would like my representation to be dealt with by the Examination. written representation.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations.

9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:

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

Your Andrew Wood pp Andy Tickle Date Signature

29/09/2019

Ref: Doncaster

Local Plan

Publication Draft 2019 (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

Please respond by 6pm Monday 30 September 2019.

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 Dr

First Name Andy

Last Name Tickle Organisation CPRE South Yorkshire (where relevant) Address – line 1 37 Stafford Road

Address – line 2 Sheffield

Address – line 3

Postcode S2 2SF

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on?

Do I have to use the response form?

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?

Question 3 (below) – What does ‘legally compliant’ mean?

Questions 4/5 (below) – What does ‘soundness’ mean?

 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?

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

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:

CPRE South Yorkshire

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.: 159-178 Paragraph: Chapter 14 Policy Ref.: Policies: 59, 60, 61, 62, 65 and Site Ref.: 66 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.

Chapter 14: Climate change, mineral resources and energy

Policy 59: Low carbon and renewable energy (strategic policy)

Unsound because:  Not positively prepared to address national carbon reduction targets; no low carbon/renewable energy (RE) generation targets set  Not justified in relation to the available evidence, notably the Committee on Climate Change’s report on meeting net carbon zero (May 2019)  Not effective: is unlikely to help deliver the radical carbon reductions necessary nor contribute sufficient low carbon energy, in part due to no targets/milestones being set; does not encourage or prioritise community energy schemes as a mechanism to address the concerns of affected local communities nor empower them to help shape their local energy response  Is not consistent with national targets (CCC five year carbon budgets) to radically reduce carbon emissions by 2035 The radical reductions in carbon emissions now required by the national policy to meet a net zero carbon target by 2050 will require the mass deployment of a wide range of low carbon solutions. In turn this will require the engaged consent of communities, enabled by participative decision-making and effective strategic spatial planning of renewable energy assets at local and supra-local levels.

To allow planning to deliver net carbon zero as a priority (and the proportionate reductions within the plan period, contributing to the carbon budgets set by the CCC), the Borough must set measurable targets for low carbon energy production (including renewables), based on a landscape capacity-led approach. This has been done for wind, although no targets have been set, but would need to be more comprehensive, including biomass, solar, hydro and a range of other options, based on the natural resources of the Borough.

It is unclear how proposals for large scale forestry (see A)1.) will meet the aspirations of this policy and this needs to be clarified.

Paragraph 14.13 states ‘In particular there is a significant opportunity for solar power schemes to be installed on the roofs of existing and planned large scale commercial and employment developments across the Borough’. Simple text encouragement to fit or retrofit onto commercial and employment developments is not sufficient – this must be mandated by complementary policies for new and existing developments within Policy 47: Design of Non-Residential, Commercial and Employment Developments (p.141).

Policy 60: Wind Energy Developments (Strategic Policy)

Unsound because:  Not positively prepared to address national carbon reduction targets; no generation targets set  Not justified in relation to the available evidence, notably the Committee on Climate Change’s report on meeting net carbon zero (May 2019)  Not effective: is unlikely to help deliver the radical carbon reductions necessary nor contribute sufficient low carbon energy, in part due to no targets/milestones being set; does not encourage or prioritise community energy schemes as a mechanism to address the concerns of affected local communities nor empower them to

help shape their local energy response; the Plan does not highlight the full range of landscape capacity types (or spatial areas) over the whole borough  Is not consistent with national targets (carbon budgets) to radically reduce carbon emissions by 2035 We also query, and require clarification of, the meaning of ‘directed towards’ the respective landscape capacity areas in 60 A) and B). Once applications are submitted, they will either be largely within or without the defined capacity areas. It is unclear what the burden on the scheme proposer is.

Text at 14.19 refers readers to Figure 13. We believe it is also necessary to reproduce the full Landscape Capacity for Windpower plan (Figure 10 in the 2006 ECUS study; shown at Appendix A in the supporting document Wind Energy Development Policy: Local Plan Evidence Base (DMBC, July 2019) to ensure clarity regarding the borough wide sensitivity analysis.

Policy 61: Protecting and Enhancing Doncaster’s Soil and Water Resources

Unsound because:  Not positively prepared in relation to identified need to store water (text at 14.32) but without related and specific proposals or policies  Not effective in fully integrating extensive forms of land-based energy generation schemes within the policy Supporting text (‘Explanation’) at 14.25 does not cover likely energy generation-related proposals (e.g. ground-mounted solar schemes: ‘solar farms’) and we suggest that explicit reference to such forms of development will add useful clarity. Text at 14.32 identifies ‘a need to store water within the landscape’ for the purposes of irrigation and protection of wetland habitats but does not offer policies (e.g. as to appropriate scale of storage) or spatial plans to plan for these positively.

Minerals Policy

Policy 62: Providing for and Safeguarding Mineral Resources (Strategic Policy)

Unsound because:  Is not consistent with national targets (carbon budgets) to radically reduce carbon emissions by 2035 Policy 62 (policy and supporting text/explanation) is not properly cognisant of the Government’s recently adopted/revised policy to meet a carbon net zero target by 2050 by overstating the need for oil and gas, which will not be consistent with future carbon budgets. The rationale for italicisation of part of explanatory text at 14.41 is unclear. We also suggest a change below to better reflect the reducing need for fossil fuels (imported or indigenous).

Policy 65: Providing for Energy Minerals (on-shore Gas and Oil (Hydrocarbons))

Unsound because:  Is not justified: it fails to take properly into account local constraints to development;  Is not effective: without suitable constraint-related policy criteria, there is a substantial risk that development will be inconsistent with the proper protection of rural areas of the Borough; Oil and gas exploration and production (especially for unconventional hydrocarbons, including use of hydraulic fracturing) have a related but different set of impacts from other minerals (aggregates and industrial minerals) and these need to be addressed by specific policies if such development is to be properly controlled and mitigated. We are unclear as to why ‘conventional and unconventional hydrocarbons (text in first sentence of 14.72) is italicised. Suggest change to plain (Roman) text.

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

Chapter 14: Climate change, mineral resources and energy

Policy 59: Low carbon and renewable energy (strategic policy) Alter pre-amble text: ‘We aim to increase the supply of low carbon and renewable energy generated in the Borough to at least xx GW installed capacity by 2035, to contribute to meeting the carbon reductions set out in national carbon budgets, and in accordance with the principles set out below:’

Add new policy criterion: A) 6. Community energy schemes where either local ownership (in part or whole) or significant community benefits are demonstrated. And amend: B) 1. are community owned (in part or whole) or have the engaged consent of communities have undertaken community engagement and demonstrate how they will deliver environmental, social and economic benefits;

Policy 60: Wind Energy Developments (Strategic Policy) Amend criterion: J) schemes are in full or part community ownership or have the engaged consent of communities following community engagement, and it can be demonstrated that the planning impacts identified by affected local communities have been fully addressed and therefore the proposal has their backing.

Policy 61: Protecting and Enhancing Doncaster’s Soil and Water Resources Amend text (third sentence) at 14.25 as follows: Proposals for other uses of agricultural land for purposes such as flood storage, and biomass planting schemes (e.g. reed bed creation) and energy generation (e.g. solar power) will be supported where they avoid the loss of high quality agricultural land.

Minerals Policy

Policy 62: Providing for and Safeguarding Mineral Resources (Strategic Policy) Amend text of 14.33, as follows: Minerals, such as sand and gravel, limestone and clay are essential to meeting society’s needs for economic growth and development. Others, such as gas and oil, are important in helping meet our needs for energy, although, as fossil fuels, they will need to be phased out to facilitate a rapid transition to a low carbon economy. Policy 62 to be amended as follows:

2. providing for sufficient industrial and energy minerals that balance both the economic and environmental benefits, taking into account the need to move to a low carbon economy; Criterion B) 5. of Policy 62 needs re-writing/clarifying so that it is plainer that ‘permitted’ refers to permitted development (i.e. under GDO) unless it has some other meaning?

Change last sentence of 14.41 to: Our approach to supporting the need for industrial and energy minerals will have regard to both the local economy and environment, including the need to phase out hydrocarbon use in line with national carbon budgets.

Policy 65: Providing for Energy Minerals (on-shore Gas and Oil (Hydrocarbons)) Remove current Policy 65 in its entirety and substitute the below:

Policy 65 Proposals for exploration and appraisal of hydrocarbons

Proposals for exploration and appraisal of onshore oil and gas will be permitted where they meet all of the following criteria: a. well sites and associated facilities are located in the least sensitive areas from which the target reservoir can be accessed; b. any adverse impacts can be avoided or mitigated to the satisfaction of the Mineral Planning Authority, with safeguards to protect highway, environmental and amenity interests put in place as necessary; c. it can be demonstrated that there would be no adverse impact on the underlying integrity of the geological structure or on groundwater or surface water regimes; d. an indication of the extent of the reservoir and the extent of the area of search within the reservoir is provided; e. exploration and appraisal operations are for an agreed, temporary length of time; f. well sites and associated facilities are restored at the earliest practicable opportunity if oil and gas is not found in economically viable volumes, or they are developed within an agreed time frame.

Policy 66 Proposals for production of hydrocarbons

Proposals for the production of hydrocarbons will be considered against the following criteria: a. Exploration and appraisal operations are for an agreed, temporary length of time. b. Extraction, processing, dispatch and transport facilities are sited, designed and operated to minimise environmental and amenity impacts and provide proportionate environmental enhancements. c. Any adverse impacts, both individual and cumulative can be avoided or mitigated to the satisfaction of the Mineral Planning Authority. d. Existing facilities are used for the development of any additional fields discovered unless the applicant satisfies the Mineral Planning Authority that this would not be feasible and any adverse impacts can be mitigated. e. Where a proposal uses existing production facilities, the integrity of the existing infrastructure can be demonstrated, having regard to local environmental factors. f. Developments for hydrocarbon production will be required to use pipelines. Where it can be demonstrated that this is not feasible, economically and/or environmentally, rail or road transport will be considered. Where road transportation is the only feasible option, it should be demonstrated that this would not give rise to unacceptable impacts on the environment or highway safety. g. The well site and all associated facilities are restored at the earliest practicable opportunity following the final cessation of hydrocarbon production. h. Where a proposal demonstrates that it will have a net zero impact on climate change.

Amend Explanation text as follows:

14.70. In line with national guidance ‘Petroleum Exploration and Development Licences’ and permitted hydrocarbon sites will be are shown on the Policies Map for information. Applications for the exploration, appraisal and development (including production) of on-shore gas and oil in licenced areas will be determined in line with National Policy, Guidance and Policies 65 and 66 above.

Add to explanatory text, insert at (new) 14.73 and retain current 14.73 text as 14.77 and renumber remaining text 14.78, (Peat and other minerals)14.79 and 14.80 :

14.73 If economic concentrations of hydrocarbons are found, the operator may seek to develop the field commercially. Small fields may be exploited using the existing exploration and appraisal wells where oil/gas can be stored on site, with tankers transporting the hydrocarbon off site. However, larger fields may require additional wellhead sites linked by pipelines.

14.74 Directional drilling, whereby a number of wells are drilled from a single location, may be used to minimise the number of sites required to exploit the field. Directional drilling is considered preferable to the creation of additional well sites. Above ground facilities including, potentially, a gathering station to provide a central facility to prepare the hydrocarbons for export, transport links, pipelines and offices may be required. Impacts similar to industrial development may be experienced, with pollution prevention being a potential long-term issue.

14.75 As there is likely to be some flexibility as to the location of extraction and processing facilities, they should be located to minimise adverse effects on landscape, nature conservation interests, residential amenity, historic environment and best and most versatile agricultural land.

14.76 Consideration will need to be given to the use of tree screens and appropriately managed areas around well sites or facilities in order to reduce visual impact. Additionally, where areas are sensitive ecologically, opportunities for habitat management should be explored.

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

No, I do not wish to participate at the examination. I ☐ ☒ Yes, I wish to appear at would like my representation to be dealt with by the Examination. written representation.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations.

9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:

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

Your Andrew Wood pp Andy Tickle Date Signature

29/09/2019

Ref: Doncaster

Local Plan

Publication Draft 2019 (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

Please respond by 6pm Monday 30 September 2019.

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 Dr

First Name Andy

Last Name Tickle Organisation CPRE South Yorkshire (where relevant) Address – line 1 37 Stafford Road

Address – line 2 Sheffield

Address – line 3

Postcode S2 2SF

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on?

Do I have to use the response form?

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?

Question 3 (below) – What does ‘legally compliant’ mean?

Questions 4/5 (below) – What does ‘soundness’ mean?

 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?

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

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:

CPRE South Yorkshire

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.: 186 - 250 Paragraph: Chapter 16 Housing: 940 Airport, 165 and 186 Skellow. Policy Ref.: Site Ref.: Employment: 001 Junction 6 M18, 441 Adwick, 941 Airport 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.

Chapter 16: Spatial Proposals

We object to the following proposed site allocations.

Site ref Location Objection Proposed Housing Allocations

940 Airport Would only be justifiable on basis of robust sustainability strategy with regard to new railway access and carbon reduction strategy.

165,186 Skellow Too peripheral to be sustainable.

Proposed Employment Allocations

001 Junction 6 M18, Thorne Along with the other two employment allocations we object to below, these three sites comprise the bulk of the new employment allocation in the Plan. Not only is the largest of the three, it is also the most peripheral, and its motorway location maximizes the risk that new jobs at this location will not be focused on local need in Thorne & Moorends, and indeed may also detract from take-up of employment sites within the Unity regeneration scheme. The site represents a wholly outmoded, unsustainable approach of road-dependent employment growth to which we object in principle.

441 Adwick Depends on the type of employment if it is to tackle local deprivation.

941 Airport Would only be justifiable on basis of robust sustainability strategy with regard to new railway access and carbon reduction strategy.

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)

Delete the proposed allocations for the reasons shown in our table above.

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

No, I do not wish to participate at the examination. I ☐ ☒ Yes, I wish to appear at would like my representation to be dealt with by the Examination. written representation.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations.

9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:

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

Your Andrew Wood pp Andy Tickle Date Signature

29/09/2019