This shows the various document referred to within the rep for 05197.

The documents have been given different Appendix numbers as shown below:

Site Our Ref Document Title Selection Site 001 Site 441 Policy 3 Policy 4 Accessibility Technical Note by Sanderson Appendix Appendix A Associates Appendix 1 1 1 x Appendix 1 A1M/A19 Technical Note by Sanderson Appendix Appendix B Associates x x 2 x 1a Technical Note by Fore C Consulting Appendix 2 x x x Appendix 2 Flood Risk report by Appendix Appendix D Fairhurst Appendix 3 2 3 x Appendix 3 (Commercial Review/Assessment of Employment Site Options) Dove Haigh Appendix Appendix E Phillips Appendix 4 3 x 2 Appendix 4 F Vision document Appendix 5 x x x Appendix 5 G Revised SA Scores Appendix 6 x x x x Inspectors Letter - withdrawn Doncaster H Sites and Policies DPD Appendix 7 x x x x Updated Masterplan for West Moor Park I East x x x x Appendix 6 Hatch Regeneris Review of employment Appendix J Land Evidence x x x 1 x

Prepared on behalf of

Blue Anchor Leisure Ltd

West Moor Park East (Site Ref 937/1031)

Technical Note Relative Accessibility

West Moor Park East (Site Ref 937/1031)

Disclaimer

The methodology adopted and the sources of information used by Sanderson Associates (Consulting Engineers) Ltd in providing its services are outlined within this Report.

Any information provided by third parties and referred to herein has not been checked or verified by Sanderson Associates (Consulting Engineers) Ltd, unless otherwise expressly stated within this report.

This report was checked and approved on the 27th September 2019 and the Report is therefore valid on this date, circumstances, regulations and professional standards do change which could subsequently affect the validity of this Report.

Copyright

All intellectual property rights in or arising out of or in connection with this report are owned by Sanderson Associates (Consulting Engineers) Ltd. The report has been prepared for Blue Anchor Leisure Ltd (the ‘Client’) who has a licence to copy and use this report only for the purposes for which it was provided. The licence to use and copy this report is subject to other terms and conditions agreed between Sanderson Associates (Consulting Engineers) Ltd and the Client.

This document cannot be assigned or transferred to any third party and no third party may rely upon this document without the express written agreement of both Sanderson Associates (Consulting Engineers) Ltd and the Client.

Report Ref: 11193/AND/001/02 September 2019

Author: Adam Darwin

Checked & Approved: Tracy Hargreaves Date: 27th September 2019

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 2 September 2019

West Moor Park East (Site Ref 937/1031)

Contents Page No

1 Introduction ...... 5

2 Methodology of Sustainability Appraisal ...... 7

3 Minimise Travel to Work Distances ...... 14

4 West Moor Park East (Site Ref. 937/1031) ...... 16

5 Thorne North (Site Ref 001)...... 21

6 Balby Carr Bank, Balby (Site Ref 92) ...... 27

7 Land at Carcroft Common, Carcroft (Site Ref 441) ...... 30

8 Site A, East of Bankwood Lane, Rossington (Site Ref. 878/1032) ...... 36

9 Site 2, Land East Of Poplars Farm, Hurst Lane, Auckley (Site Ref. 941) ...... 39

10 Summary and conclusions ...... 42

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 3 September 2019

West Moor Park East (Site Ref 937/1031)

Appendices

APPENDIX A Reasons for Allocation/Rejection of Selected Employment sites

APPENDIX B 8km Travel Distance (Isodistance) Maps

APPENDIX C Residential sites incorporated in population assessments

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 4 September 2019

West Moor Park East (Site Ref 937/1031)

1 Introduction

1.1 Sanderson Associates (Consulting Engineers) Ltd have been appointed by Blue Anchor Leisure Ltd to provide transportation and highways advice to support a proposed allocation of land for employment at West Moor Park East, Holme Wood Lane, Armthorpe (Local Plan Site References 937/1031), which is located to the east of Junction 4 of the M18. The site has currently been rejected as an employment site allocation in the Draft Doncaster Local Plan.

1.2 A total of 6 employment sites that do not currently benefit from planning permission have been allocated for employment within the Draft Local Plan. The reasons for allocating these sites are set out within the ‘Housing & Employment Site Selection Methodology & Results Report Publication Version - June 2019’. These together with the reasons for rejecting the West Moor Park East site are summarised in the table included at Appendix A.

1.3 One of the reasons for rejecting the West Moor Park East site is that the Council have concluded that other sites such as Site 001 (Thorne North) are preferable for sustainability reasons, with the Council stating for the West Moor Park East site:

‘The site is to the east of the M18 and more isolated than other options that are available across the borough. There are other options directly adjacent to the main urban area and main towns which offer better opportunities for securing sustainable development such as long term public transport access.’.

1.4 Blue Anchor Leisure Ltd do not agree with the Councils findings. Therefore, they have instructed Sanderson Associates to review the proposed employment site allocations and the Sustainability Appraisal (SA) undertaken by the Council for these sites, to consider whether the conclusions that have been drawn are correct.

1.5 Following a review of the Councils Sustainability Appraisal Methodology, concerns are raised that the assessment approach does not adequately assess the relative accessibility of the sites, which has contributed towards the West Moor Park East site not being selected. These concerns are set out in Section 2 of this report.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 5 September 2019

West Moor Park East (Site Ref 937/1031)

1.6 Following Sanderson Associates review of the 6 employment site allocations that do not currently benefit from planning permission, a number of issues relating to the assessments have been identified that are considered to be material to the site selection process. As such, Section 5 – 9 of this report highlight points relating to accessibility matters that have been identified in relations to sites 001, 92, 441, 878/1032 and 841 (no comments are provided in relation to site 258 as the scoring for this site is considered to be reasonable).

1.7 Comments have also been made about accessibility matters relating to the West Moor Park East site in Section 4, to allow a comparison of the relative accessibility to be made. Attention should also be drawn to the further Technical Note entitled ‘Review of Allocation Justification’ dated 27th September 2019 (Version 1.1), which has been produced by Fore Consulting in support of the West Moor Park East site and addresses the concerns that have been raised by the Council about the site, with further supporting information provided in relation to the high frequency bus service that can be delivered for the site and includes a full response in relation to highway capacity matters.

1.8 As set out in Section 2 of this report, concerns are raised that the site selection process has not fully taken into account one of the key objectives of local and national transport planning policy related to the need to minimise travel to work distances (Identified as a detailed decision making criteria relating to Sustainability Appraisal No. 3 – Improving accessibility to places, services, both within and outside of the borough). Therefore, Section 3 of this report includes further information regarding the population sizes within the vicinity of the sites, who would be available to work at the employment sites and contribute to minimising travel to work distances.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 6 September 2019

West Moor Park East (Site Ref 937/1031)

2 Methodology of Sustainability Appraisal

2.1 Introduction

2.1.1 As confirmed in the ‘Doncaster Local Plan - Housing & Employment Site Selection Methodology & Results Report - Publication Version - June 2019’ The Sustainability Appraisal (SA) is a tool designed to assess, predict and monitor the effects of the Doncaster Council’s Local Plan. The SA aims to ensure that decisions are made in accordance with the principles of sustainable development and seeks to integrate social, economic and environmental considerations from the outset.

2.1.2 The Site Selection Methodology and Results report outlines that sites were assessed using current baseline information, which does not take account of how a site could be improved through provision of new infrastructure, services, mitigation that may be justified through site-specific planning conditions and obligations. The report states that in reviewing and updating the SA of sites since the 2018 consultation, site survey and assessment evidence provided by landowners/developers and their agents has been incorporated into the process. Where robust evidence was provided, then some SA scores were revised in light of this to give a ‘post-mitigation’ score. However, this was only applied for criteria and findings specific to the site. More generic development mitigation and requirements through policies such as those relating to section 106 contributions (e.g. contributions to public transport/highway improvements) were expected for most sites; and as such has not been taken into account.

2.1.3 However, this means the SA methodology dismisses some mitigation measures as ‘generic development mitigation’ which undervalues the wider benefits potentially associated with specific mitigation measures attached to allocation sites. This is evident in the scoring for West Moor Park East site. Either the material submitted to the Council last year in relation to accessibility improvement for that site has failed to be taken into account as specific material or classified as generic and failed to be taken into account for that reason. Either way, there is no indication that it has factored into the Councils process of site selection, which has led the process into error.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 7 September 2019

West Moor Park East (Site Ref 937/1031)

2.1.4 Through discussions with the main bus operator within Doncaster, it was highlighted in submissions to the previous draft plan that the existing No. 15 bus service could feasibly be extended to directly serve the site West Moor Park East site. This extension would provide a direct bus service between a significant employment site and a substantial population catchment across the Doncaster district (estimated in previous supporting site information to be approximately 20,860 people and 9,258 households along the bus route), including areas south west of the town centre at Balby, Hexthorpe and Edlington. In terms of the current SA, this appears to be considered a generic mitigation measure related to a section 106 contribution; however, it represents a much wider benefit to the population of Doncaster district in terms of access to employment, which is omitted from the SA.

2.1.5 The SA approach effectively assumes that other sites could also offer similar bus enhancements. However, this is not the case, as providing a new or diverted high frequency bus service would not be feasible in more isolated locations; and even if one could be funded by a development through a S106 contribution in the short term (typically 5 years), these services may not be sustainable in the longer term. The feasibility of extending worthwhile and effective services on a long term self- funding basis is a key factor for the SA to take into account and it has not done so.

2.1.6 It is also noted that some of the other SA methodology factors related to transportation and highway matters only provide a very high level assessment of the sites; and does not take into account the quality of the facilities that are available. This means that the scoring for individual sites is misleading. Therefore, comments relating to each of the SA methodology factors related to accessibility matters are including in the following sections 2.2 – 2.4. There are serious concerns that the SA has not allowed a proper assessment of choices about reasonable alternatives on a valid and sound basis.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 8 September 2019

West Moor Park East (Site Ref 937/1031)

2.2 Sustainability Appraisal (SA) No. 3A – Accessibility to places

2.2.1 SA Appraisal No. 3 relates to improving accessibility to places and services, both within and outside of the borough, with SA Sub-objective 3A relating to accessibility to places. The detailed decision-making criteria emphasises that providing access to sustainable forms of transport is vital to reduce the individuals need to use the private car for their everyday journeys (to shop, to work etc.). In turn it can have a significant impact on reducing congestion, improving local air quality and increasing public transport patronage. The detailed decision making criteria for SA Appraisal No. 3A are set out as follows:

 Ensure places can be accessed via public transport;  Encourage a modal shift;  Minimise Travel to Work Distances;  Has footpath access where possible;  Have adequate parking facilities;  Has road access where possible;  Facilitate links between urban and rural areas.

2.2.2 For Employment Site Proposals, SA Appraisal No. 3A is then split into 3 assessment criteria, relating to access by train (3Ai), bus (3Aii) and bicycle (3Aiii). These assessment criteria are then scored based on the following guidance methodology:

SA No. 3ai - Distance to train station + Site is within 800m of a train station; 0 Site is located 800m - 1.2km of a train station; - Site is located over 1.2km from a train station;

SA No. 3aii - Distance to Bus Stop (SYPTE Core Network)

+ Site is within 400m of a bus stop on the high frequency network; 0 Site is located 400m - 800m of a bus stop on the high frequency network; - Site is located over 800m of a bus stop on the high frequency network;

SA No. 3aiii - Access to cycle network

+ Site is within 100m of the identified cycle network; 0 Site is beyond 100m of the identified cycle network;

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 9 September 2019

West Moor Park East (Site Ref 937/1031)

2.2.3 Whilst it is considered that at a high level the approach taken is reasonable, it is not complete and there are some specific concerns with the scoring methodology that are detailed below:

 Whilst the approach to measuring a walking distance to a Train Station is considered appropriate, the methodology of using an ‘as the crow flies’ distance from the site boundary for walking journeys to the Train Station is considered to be misleading, as there are sites that have been given a 0 score (eg site 001), which in fact are beyond a 1.2km walking distance, so are unlikely to be accessible for most people on foot. Furthermore, for large sites, whilst some of the site area may be within walking distance, a large proportion of the site may not. Also the quality of the pedestrian/cycle routes to the train stations and the facilities/services available at the station are not taken into consideration, which the development would not feasibly be able to upgrade as part of ‘generic development mitigation’ measures. Furthermore, a simple distance to train station does not in itself provide clarity that the train will serve people that are likely seek to work in the employment site in question.  Similarly, whilst measuring a walking distance to a bus stop is considered appropriate, the methodology of using an ‘as the crow flies’ distance from the site boundary for walking journeys to a bus stop is again considered to be misleading. Also the quality of the bus services that are available has not been taken into account evenly across all of the site; and as stated in paragraphs 2.1.3 – 2.1.5, the assessment methodology does not take in account whether evidence has been provided that demonstrates a development could provide improvements that would allow it to be served by a high frequency bus service, which would not be feasible for all sites. Had this been the case, then the score for the West Moor Park East site would have increased from a - score to a + score. As with trains, the attractiveness of the service (times, frequency and duration of travel) to the greatest population that is able to use the service can be as important a factor as the distance to the closest bus stop. With distance to a bus stop having to take account of future viable service stops as well as current stops.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 10 September 2019

West Moor Park East (Site Ref 937/1031)

 With regard to the assessment methodology for considering bicycle accessibility, this approach is considered to be flawed, as it is too simplistic and takes no account of the quality of the cycle facilities that are available on the local network. Instead it simply relates to any route that may be shown on Doncaster Cycle Map (2013) within the immediate vicinity of the sites, which includes advisory routes that have no specific cycling provision and may not be of good quality (eg it includes routes where cyclists are required to dismount over long distances, which in reality are unlikely to promote cycling). Therefore, it is considered that a more qualitative approach to cycle accessibility would have been more appropriate.

2.2.4 In light of the above, it is considered that a more thorough assessment of accessibly by train, bus and bicycle is needed. With this in mind, Sections 4 - 9 of this report highlight points that need attention in relation to the West Moor Park East site and 5 of the 6 proposed Employment Site Allocations, where comments are considered to have a bearing on their SA scores.

2.2.5 In addition to the concerns regarding the SA No. 3A assessment criteria, it is considered that none of the assessment criteria adequately assesses one of the key SA decision making criteria that seeks to minimise travel to work distances. It is clear that the location of the sites and proximity to the nearby residential population will be a major influencing factoring on the ability of a development to minimise travel to work distances. Therefore, Section 3 of this report considers this matter further in relation to West Moor Park East site and the 4 proposed Employment Site Allocations that are located outside of central Doncaster, to determine the local populations that exist within close proximity of these sites, who would be able to travel in a sustainable manner (eg by walking, cycling, public transport or through a short car journey).

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 11 September 2019

West Moor Park East (Site Ref 937/1031)

2.3 Sustainability Appraisal (SA) No. 3B – Accessibility to places

2.3.1 SA Sub-objective 3B relates to accessibility to places from the proposed allocated sites. The detailed decision making criteria for SA Appraisal No. 3B are set out as follows:

 Facilitate access to services and facilities such as health, education, open spaces and shops etc.  New development should be close to services;  Facilitate transport of freight by sustainable means;  Minimise the need to travel.

2.3.2 For Employment Site Proposals, SA Appraisal No. 3B is only assessed by a single assessment criteria, which is scored based on the following guidance methodology:

Section 3B) Accessibility to services + Site lies within 400m of a town, district, local centre or neighbourhood shopping parade; 0 Site is located 400m - 800m of a town, district, local centre or neighbourhood shopping parade; - Site is located over 800m of a town, district, local centre or neighbourhood shopping parade;

2.3.3 The above assessment criteria is not particularly relevant for employment sites. Whilst it is clearly important for residential developments to be well located near to a variety of services, this is far less important for employment sites, where the main services that are required frequently for staff are catering facilities required at lunch times. However, as all of the proposed employment sites are relatively large in scale, it is likely that these developments would be able to cater for their staff requirements through the provision of canteens and other on-site facilities. Therefore, it is considered that this element of the SA Appraisal methodology is flawed and should be given little weight in the employment site selection process.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 12 September 2019

West Moor Park East (Site Ref 937/1031)

2.3.4 Furthermore, this approach is likely to skew employment site locations to residential areas and other areas where there are high numbers of vulnerable road users (eg pedestrian and cyclists), which is not necessarily desirable in terms of the developments impact on highway safety and amenity etc.

2.4 Sustainability Appraisal (SA) No. 8B – Renew and reuse existing building, land and infrastructure - Highways Capacity

2.4.1 The scoring methodology for SA Sub-objective 8B relates to assessment work undertaken by Highways England in assessing the impact of all option sites on the strategic road network, identifying where mitigation will be required. This assessment was undertaken in 2015, and provides a very 'high level' assessment of the potential impacts on the key junctions on the trunk road network only. It is not up to date and is being reviewed. The 2015 work is not a proper basis for an SA assessment in these circumstances.

2.4.2 No quantitative or qualitative assessment of the impact of the allocations on the local network has been undertaken as part of the evidence base at this stage. Therefore, it is considered that the definition of this scoring criteria is too narrow and provides an insufficient basis upon which to consider operation of the highway network and access to the employment sites. For instance, only traffic impacts at motorway junctions are considered (not fully and not in an up to date manner); and no account appears to be taken of impact on local roads. Moreover, the wider SA methodology does not appear to take into account the suitability of existing local roads to accommodate increased traffic flows associated with employment development; and in particular freight movement (one of the detailed decision making criteria mentioned for SA No. 3B).

2.4.3 In light of the above, brief comments have been made in Sections 4-9 of this report, regarding access issues relating to the employment sites, which it is considered should have been taken into account in the SA.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 13 September 2019

West Moor Park East (Site Ref 937/1031)

3 Minimise Travel to Work Distances

3.1 As mentioned at paragraph 2.2.5, concern is raised that the site selection process has not fully taken into account one of the key objectives of local and national transport planning policy related to the need to minimise travel to work distances (Identified as a detailed decision making criteria relating to SA No. 3), as it is clear that the location of the employment sites and their proximity to the nearby residential population will be a major influencing factoring on the ability of a development to minimise travel to work distances.

3.2 In light of the above, this section includes an assessment of the residential populations that exist within the locality surrounding the West Moor Park East site, compared to the other proposed employment site allocations that are located away from Doncaster town centre. The proposed employment sites at Balby Carr Bank (Site ref 092) and Potteric Carr Road (Site ref 258) have been excluded from this assessment given their central location in close proximity to Doncaster town centre, which clearly makes them accessible to a large residential population.

3.3 To consider the local residential population that exists within close proximity of the sites, 8km travel distance (isodistance) boundaries have been produced for the West Moor Park East site and the remaining 4 employment site allocations located away from Doncaster Town Centre. An 8km/5mile isodistance has been chosen, as this represents a distance that commuters would reasonably be able to travel in a sustainable manner (eg by walking, cycling, public transport; or through a short car journey as a driver or car sharer). Isodistances have been chosen rather than isochrones, as they are considered to be the best way to compare the sites, as isochrones would vary considerably by mode and time/day of journey.

3.4 The isodistance boundaries for each site are included in Appendix B. These boundaries have then be used to calculate the existing residential population and number of households using census data (LSOA dataset). Data has then been obtained from the draft Local Plan regarding all residential site allocations (both with and without planning permission), so that this can be incorporated into the assessment to determine the likely populations over the Local Plan period. Details

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 14 September 2019

West Moor Park East (Site Ref 937/1031)

of the residential sites that have been included within each isodistance boundary are summarised in Appendix C. For the purposes of this assessment, an occupancy rate of 2.3 people per household has been utilised, which corresponds to the existing residential population data.

3.5 Based on this assessment, the estimated residential population within the 8km isodistances are shown in the following table:

Population within 8km Travel Distance Existing Proposed Total Site Ref. Location Population Households Population Households Population Households 937 West Moor Park East 77,500 33,500 9,405 4,089 86,905 37,589 001 Thorne North 29,000 12,200 2,493 1,084 31,493 13,284 441 Carcroft 83,000 36,200 7,390 3,213 90,390 39,413 878/1032 Rossington 70,300 30,800 14,472 6,292 84,772 37,092 941 Poplar Farm 55,200 23,900 12,271 5,335 67,471 29,235

3.6 As can be seen from the above, based on the existing and proposed residential populations, the West Moor Park East site is ranked second of the five sites, with a similar population to Site 441 (Carcroft). Therefore, it is concluded that the site is well located to a large residential population, which will allow development at the site to contribute to minimising travel to work distances, before any regard is taken of bus improvements. This is contrary to the conclusions reached by the Council, which suggests that the West Moor Park East site is isolated and that other sites offer better opportunities for securing sustainable development.

3.7 It is also noted that one of the reasons that the Council have stated for selecting Site 878/1032 at Rossington is that it is close to a large population. However, as can be seen from the above, even taking into account planned housing growth in the area, there would be a larger residential population in close proximity to the West Moor Park East site.

3.8 Most important of all, the sites at Thorne and Poplar Farm are not at all well located for the workforce population, with Thorne having roughly a third of the local population compared to West Moor Park East.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 15 September 2019

West Moor Park East (Site Ref 937/1031)

4 West Moor Park East (Site Ref. 937/1031)

4.1 Introduction

4.1.1 One of the reasons for rejecting the West Moor Park East site was that the Council have concluded that other sites are preferable for sustainability reasons, with the Council stating for the West Moor Park East site that:

‘The site is to the east of the M18 and more isolated than other options that are available across the borough. There are other options directly adjacent to the main urban area and main towns which offer better opportunities for securing sustainable development such as long term public transport access.’.

4.1.2 The current accessibility scoring undertaken by the Council for the West Moor Park East site is shown in the following table:

3A(ii) Distance to Site 3A(i) Distance 3A(iii) Distance to Bus Stop (SYPTE Reference to Train Station Cycle Network Core Network) 937/1031 - - 0

4.2 Train Station Accessibility

4.2.1 There are no train stations within 1.2km of the site. Therefore, the - score is not considered to be unreasonable. However the relevance of distance to a train station as a simple scoring exercise has to be questioned. As stated in Section 2 of this report, a train service will not necessarily provide a good and convenient means of accessing an employment site for a high proportion of the population, dependent very much on the location of stops and routes.

4.2.2 High frequency bus services are often more easily able to provide an attractive means of transport to a large population compared to a somewhat remote train station. In the case of this site (see Section 4.3) bus services would be provided to serve the site, which would provide a direct connection to Doncaster Train Station (taking less than 45minutes), where a wide range of train services are available to serve the development. Therefore, whilst the site could not be given a high score in relation to train accessibility, the site would be accessible by train using a combined public transport journey.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 16 September 2019

West Moor Park East (Site Ref 937/1031)

4.2.3 The consequence of not being near a local train station is therefore not of great weight. The SA does not allow this to be properly factored in and this is a failing of it. Instead, it is suggested that the SA should have taken into account of whether a site is accessibly by high quality public transport provision in general, rather than scoring these modes separately, with greater weight applied to bus provision as it is likely to be more accessible to a greater proportion of the Doncaster population.

4.3 Bus Accessibility

4.3.1 As confirmed in the Accessibility Comparison document previously produced by Fore Consulting and in their latest Technical Note entitled ‘Review of Allocation Justification’ dated 27th September 2019 (Version 1.1), discussions have been held with First South Yorkshire (as main operator of bus services in the Doncaster District), who have confirmed that it will be feasible to serve the site by public transport by extending the existing No. 15 service from Clay Lane at Wheatley to the site.

4.3.2 The No. 15 service provides a direct service to Doncaster Town Centre along the A630 and would provide access to a significant proportion of the Doncaster borough. Based on the Fore Consulting assessment, this service alone would provide direct access to a population of approximately 20,860 people and 9,258 households along the route. Furthermore, there are also a number of proposed major housing site allocations along this bus route that would further increase the population that could access the site by the No. 15 bus service; and who would benefit from it’s extension. The No. 15 service also links directly with the Doncaster Frenchgate Interchange, where links to further bus and rail services can be accessed.

4.3.3 As confirmed by First South Yorkshire, they would be willing to extend the No. 15 service to the site, so that it would provide a high frequency service between 0700- 1900hrs Mondays-Saturday (with further extension possible if deemed necessary), which would provide 4 bus services per hour at peak times and 3 service per hour during inter-peak periods. They have also confirmed that following the initial 5 year funding period that would be required from the development, they envisage that the service would become self-funding. This is a critical point, as other sites that

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 17 September 2019

West Moor Park East (Site Ref 937/1031)

could fund a bus service for a short time, when funding is stopped, the bus service will naturally be inferior. Finally, First South Yorkshire have noted that additional measures to improve the sites accessibility by bus could be achieved, to improve links to the site from the Armthorpe area.

4.3.4 In light of the above, it is clear that the site could be made highly accessible by bus through realistic improvements to the existing bus network, which would be sustainable in the long term. Therefore, it is concluded that the Councils current score for SA Sub-category No. 3Aii - Distance to Bus Stop (SYPTE Core Network) is too low and the score should be amended to a + score.

4.3.5 Therefore, it is concluded that the most appropriate approach to assessing public transport accessibility in the SA would be to allow sites with good bus accessibility, to make irrelevant the lack of a local train station.

4.4 Cycle Accessibility

4.4.1 Based on a review of the Doncaster Cycle Map (2013), there are no identified cycle routes located within 100m of the site. Therefore, in strict accordance with the Councils scoring guidance the 0 score that has been given is correct.

4.4.2 However, as stated at paragraph 2.2.3, it is considered that the scoring methodology for cycle accessibility is too simplistic to provide an accurate assessment of how accessible the site could be for cyclists.

4.4.3 As confirmed in Section 3 of this report, based on an 8km isodistance from the site, (which is generally accepted as a reasonable cycling distance for commuting journeys - see Cycling England, ‘Integrating Cycling into Development Proposals’ 2009), there would be a large residential population of approximately 77,500 people (which is expected to increase to circa 86,900 people with future housing growth) that would be within easy cycling distance of the site, with areas such as Wheatley Hill, Intake, Armthorpe, Hatfield, Blaxton, Bessacarr, Edenthorpe, Kirk Sandall, Dunsville and significant parts of the Doncaster Main Urban Area being accessible by cycle.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 18 September 2019

West Moor Park East (Site Ref 937/1031)

4.4.4 Therefore, whilst the 0 score that has been given to the site for cycle accessibility is technically correct in accordance with the Councils scoring criteria, in practice the location of the site, which is within easy cycling distance of a large residential population, is likely to make cycling a popular choice for people employed at the site.

4.5 Site Access

4.5.1 Fore Consulting Limited have been advising our client of the likely access requirements for the site; and have provided various information in support of the site allocation. This includes further detailed assessment information contained in their Technical Note entitled ‘Review of Allocation Justification’ dated 27th September 2019 (Version 1.1). This work has concluded that highway infrastructure improvements can be delivered along Holme Wood Lane that have scope to deliver a safe and efficient access to the site, which does not form a barrier to the future allocation of the site. These improvements would allow the development to be integrated well into the existing local and strategic highway network at the M18 junction 4; and would allow freight movement to take place via the strategic highway network in a sustainable manner, with minimal impact on the local resident population by virtue of the sites location.

4.5.2 The proposed highway infrastructure would include continuous pedestrian links that would connect to the wider highway network on the A630 to the west. It is also noted that improvements are proposed by the Council to the west of the site along the A630 road corridor, which it is understood will include cycle facility upgrades alongside highway capacity improvements. Therefore, in future the cycling facilities on the local highway network are likely to be improved, which the development may be able to link into as part of the development process.

4.5.3 Therefore, it is concluded that appropriate high quality access arrangements can be delivered at the West Moor Park East site.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 19 September 2019

West Moor Park East (Site Ref 937/1031)

4.6 Summary and conclusions

4.6.1 Based on the information contained in this section, the following conclusions can be drawn:

 Due to the bus enhancements that can be delivered at the site, a + score for bus accessibility is warranted; and a negative score for access to a train station should be ‘not applicable’ (N/A), as the high frequency bus access makes that of limited relevance, with public transport access overall being good;  Whilst there are currently no cycling facilities within the vicinity of the site, cycle links are likely to be improved in future along the A630 road corridor, which the development would be able to link into. Therefore, this in combination with the large residential population that will live within close proximity of the site is likely to make cycling a popular choice for people employed at the site;  Appropriate high quality road access can be delivered at the West Moor Park East site, which would provide direct access to the strategic highway network that will allow sustainable access for the movement of freight.  There is a large residential population within vicinity of the site, which will help to minimise travel to work distances.

4.6.2 Therefore, based on this more qualitative approach to accessibility, it is considered that the site accessibility scoring for the site should be as follows:

Ability to Site Train Bus Cycle Road Access minimise travel to Reference Accessibility Accessibility Accessibility work distances 937/1031 N/A + 0 + +

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 20 September 2019

West Moor Park East (Site Ref 937/1031)

5 Thorne North (Site Ref 001)

5.1 Introduction

5.1.1 One of the reasons for proposing to allocate the Thorne North site that has been stated by the Council is that in their view the site:

‘…scores similarly to the other sites through the Sustainability Appraisal process.’

5.1.2 Therefore, based on the Council conclusions for the West Moor Park East site that other site options offer better opportunities for securing sustainable development, such as long term public transport access, Sanderson Associates have reviewed the accessibility issues relating to the Thorne North site, to determine whether this conclusion is justified. This review has been based on a comparison of the current SA scoring criteria and the more qualitative assessment approach undertaken for the West Moor Park East site set out in Section 4 of this report.

5.1.3 The current accessibility scoring undertaken by the Council for the Thorne North site is shown in the following table:

3A(ii) Distance to Site 3A(i) Distance 3A(iii) Distance to Bus Stop (SYPTE Reference to Train Station Cycle Network Core Network) 001 0 - +

5.2 Train Station Accessibility

5.2.1 The nearest train station to the site is at Thorne North. The station is located 1.23km from the site, based on the shortest walking route to the site, as shown on the following Figure 5.1:

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 21 September 2019

West Moor Park East (Site Ref 937/1031)

Figure 5.1 – Shortest walking route from site to Train Station

5.2.2 The walking route has been measured from the southwest corner of the site. However, in practice, pedestrians would not be able to safely cross from the site to the existing footway on the west side of the A614 Selby Road at this point, due to the presence of a bend on the A614 to the south that restricts pedestrian visibility. Therefore, in practice, pedestrian access to the site is likely to be further to the north, which would further increase the walking distance to the station. The quality of the route to the station is also considered to be poor (narrow, unlit, with poor crossing provision), which would require significant upgrade along it’s length to create a suitable and attractive route to the site.

5.2.3 The walking route has also been measured to the nearest pedestrian entrance to the train station, which is located on it’s northwest side. However, this is a stepped access only, which would be inaccessible for cyclists and some pedestrians, who would instead need to access the station via the ramped route a 100m further to the east, which would again increase the distance to the station from the site.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 22 September 2019

West Moor Park East (Site Ref 937/1031)

5.2.4 The Train station is served by an hourly train service that operates between Hull and Sheffield, via Doncaster. Between Doncaster and Thorne North, the service stops at Kirk Sandall and Hatfield & Stainforth only. Therefore, even if future occupiers of the Thorne North site were willing to walk or cycle to the train station, the available services are limited and are unlikely to be a viable option for most people; and as previously stated, will not necessarily provide a good and convenient means of accessing an employment site for a high proportion of the population, dependent very much on the location of stops and routes.

5.2.5 Therefore, it is concluded that the current 0 score that has been provided by the Council in relation to Train accessibility is incorrect and the score should be amended to a – score, by virtue of the stations remoteness alone, notwithstanding the limited services the train station provides.

5.3 Bus Accessibility

5.3.1 The site is located over 800m from a bus stop. Therefore, the - score currently provided for bus accessibility is considered to be correct.

5.3.2 It is noted that a number of planning application have been submitted for the site (Applications No. 15/02252/OUTM & 16/02136/OUTM), which suggest that bus service improvements may be provided for the site, which could involve the diversion of the No. 87 bus service. However, based on a review of the available information on the planning portal relating to the pending planning application, it is understood that no details have been provided to confirm what, if any, bus service improvements would be delivered. Furthermore, it is noted that in the SYPTE consultation response to planning application no. 15/02252/OUTM, it was confirmed that whilst a further diversion of bus service No. 87 (that currently diverts to The Range on Mount Pleasant Road twice per day) may be feasible, this service is not commercially viable and would require long term funding from the development. As such, the long term viability of any bus service that may be rerouted to serve the site is not secure.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 23 September 2019

West Moor Park East (Site Ref 937/1031)

5.3.3 It is also noted that the No.87 bus service that the applicant has suggested may be diverted is made up of 3 bus routes (87, 87a and 87b) that serve different routes between Thorne and Doncaster. Therefore, the prospect of diverting multiple routes is unlikely and casts further doubt on whether a high frequency bus service could be provided for the development.

5.3.4 Therefore, it is concluded that without evidence to the contrary, even with development S106 funding, the site would not be served by a high quality bus service; and therefore the - score is considered to be correct for this site. This is particularly so in the context for the need for a service to be self-funding when any developer subsidy is finished.

5.4 Cycle Accessibility

5.4.1 Based on a review of the Doncaster Cycle Map (2013), there are no dedicated cycle routes or facilities within 100m of the site. However, there is an advisory cycle route shown on Ferry Road, which is accessed from the opposite side of the A614 Selby Road, along the site frontage. Therefore, the + score currently provided based on the Councils assessment approach is technically correct according to their SA approach, but this is too blunt a tool to make a proper assessment.

5.4.2 It is noted that the Ferry Road route has only been included on the cycle map as it is a lightly trafficked route; and in practice does not represent a high quality cycle route (there are no footway or cycleway provision along this route, it is unlit and is subject to a 60mph speed limit). Therefore, the availability of this route is unlikely to encourage high numbers of cyclists to the site.

5.4.3 It is also noted that the matter of cycling accessibility has been considered by the applicant in relation to the planning application that has been submitted at the site. In the ‘Technical Note – Response to Highways England and Doncaster Council and Doncaster Council’ dated 23rd December 2016, it was stated that:

‘….cyclists would be required to use the Selby Road carriageway to reach the development. Given that the road is subject to the national speed limit, it is unlikely that it will represent an attractive route for all cyclists.’

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 24 September 2019

West Moor Park East (Site Ref 937/1031)

5.4.4 Sanderson Associates agree with the above conclusion.

5.4.5 Therefore, it is considered that whilst the + score that has currently been provided is technically correct based on the Councils scoring methodology, this is only by virtue of the simplistic assessment approach that has been used; and in reality a neutral 0 score would be more appropriate.

5.5 Site Access

5.5.1 The site has a long frontage on to Selby Road and North Common Road. Therefore, it is likely that a suitable vehicle access to the site could be achieved. However, pedestrian and cycle access to the site is currently poor and would require significant improvement to cater for the development, which may not be viable (full improvements to pedestrian infrastructure along Selby Road are not currently proposed as part of the pending planning application). Given the sites location close to M18 junction 6, good access to the strategic highway network would be available.

5.5.2 In light of the above, it is considered that subject to significant levels of off-site improvement, it appears possible to provide adequate access arrangements for the site. However, these arrangements would be in no way superior to those suggested for West Moor Park East site.

5.6 Summary and conclusions

5.6.1 Based on the information contained in this report, the following conclusions can be drawn:

 The 0 score that has given by the Council in relation to train accessibility is considered to be incorrect, as the station is beyond 1.2km from the site. The walking route to the station is also poor, with narrow unlit footways; and the train station only provides a limit frequency service (1 per hour). Therefore, it is concluded that a - score is appropriate for train accessibility.  The existing - score that has been given by the Council in relation to bus accessibility is considered to be correct, given that it does not appear feasible to provide a high frequency bus service at the site; and even if it was, it is

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 25 September 2019

West Moor Park East (Site Ref 937/1031)

unlikely to be sustainable in the long term once development funding has ceased.  In terms of cycle accessibility, there are no good quality facilities within the vicinity of the site; and the unlit/high speed nature of Selby Road is unlikely to make access to the site by cycle an attractive option (as confirmed by the applicant in correspondence relating to the pending planning application). Therefore, it is concluded that the site should not be scored any higher than the West Moor Park East site in terms of cycle accessibility.  Subject to significant levels of off-site improvement, it appears possible to provide adequate access arrangements for the site. However, these arrangements would be in no way superior to those suggested for the West Moor Park East site.  As detailed in Section 3, there will be a significantly smaller residential population (around a third) within close proximity of the site, compared to the West Moor Park East site. Therefore, the ability of the site to help minimise travel to work distances will be significantly less and should be scored accordingly.

5.6.2 Therefore, based on this more qualitative approach, it is considered that the accessibility scoring for the site should be as follows:

Ability to Site Train Bus Cycle Road Access minimise travel to Reference Accessibility Accessibility Accessibility work distances 001 - - 0 + -

5.6.3 It is concluded that in accessibility terms, the Thorne North site does not offer better opportunities for securing sustainable development than the West Moor Park East site; and in fact is likely to be inferior due to the limited residential population in the local area.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 26 September 2019

West Moor Park East (Site Ref 937/1031)

6 Balby Carr Bank, Balby (Site Ref 92)

6.1 Introduction

6.1.1 One of the reasons for proposing to allocate the Balby Carr Bank site that has been stated by the Council is that in their view the site:

‘…has good links locally and is close to a large population.’

6.1.2 Whilst it is agreed that given the sites central Doncaster location next to a large residential population, this should allow the development to minimise travel to work distances, it is considered that the Councils SA scoring in relation to bus accessibility is incorrect. It is also considered that whilst the site’s close proximity to a residential area is a positive in accessibility terms, the impact of development traffic (particularly HGV’s) is a negative point that has not currently been considered in the SA.

6.1.3 The current scoring undertaken by the Council for the Balby Carr Bank site is shown in the following table:

3A(ii) Distance to Site 3A(i) Distance 3A(iii) Distance to Bus Stop (SYPTE Reference to Train Station Cycle Network Core Network) 92 - + 0

6.1.4 As the site is located in excess of 1.2km from Doncaster Train Station and as there are no dedicated cycling facilities available on the local network, it is considered that the Councils scoring on these matters is correct and no further comments are provided on these matters.

6.2 Bus Accessibility

6.2.1 There are bus services that operate along Balby Carr Bank. However, these services operate at a frequency of 1 bus every 2 hours, which is not a high frequency service. Whilst there are other frequent bus services that are available to the west on the A630 Balby Road bus corridor, the nearest stops are approximately 700m from the site. Therefore, these stops are likely to be less attractive to staff at the site; and in accordance with the Councils scoring criteria, the site should be given a reduced 0 score on this basis, although the range and

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 27 September 2019

West Moor Park East (Site Ref 937/1031)

frequency of bus services via Balby Road is such that a positive score may have been justified if a more qualitative assessment had been undertaken.

6.3 Site Access

6.3.1 Whilst a suitable access may be possible onto Balby Carr Road; and road access to the east is reasonable, access to the west towards the A630 through the residential area is not considered suitable for significant increases in traffic. Additional traffic to the west of the site is likely to cause problems for existing residents, including increased rat-running by light vehicles along Belmont Avenue and Carr View Avenue, which currently have HGV bans to discourage HGV’s from rat running along these routes.

6.3.2 In light of the above, it is considered that there are vehicular access constraints at the site that do not exist at the West Moor Park East site.

6.4 Summary and conclusions

6.4.1 Based on the information contained in this report, the following conclusions can be drawn:

 The existing + score that has given by the Council in relation to bus accessibility is considered to be incorrect, given that high frequency bus services are located approximate 700m from the site. Therefore, a 0 score should have been applied in accordance with the Councils scoring criteria, albeit the range and frequency of bus services via Balby Road is such that a positive score may be justified if a more qualitative assessment had been undertaken.  Given the sites central Doncaster location next to a large residential population, this should allow the development to help minimise travel to work distances. However, development traffic is likely to have a negative impact on nearby residents to the west of the site.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 28 September 2019

West Moor Park East (Site Ref 937/1031)

6.4.2 Therefore, based on this more qualitative approach, it is considered that the accessibility scoring for the site should be as follows:

Ability to Site Train Bus Cycle Road Access minimise travel to Reference Accessibility Accessibility Accessibility work distances 92 - 0/+ 0 0 +

6.4.3 It is concluded that in accessibility terms, the Balby Carr Bank site does not offer any benefits to the West Moor Park East site; and that road access to the site is inferior to the West Moor Park East site.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 29 September 2019

West Moor Park East (Site Ref 937/1031)

7 Land at Carcroft Common, Carcroft (Site Ref 441)

7.1.1 One of the reasons for proposing to allocate the Carcroft site that has been stated by the Council is that in their view the site:

‘…scores similarly to the other sites through the Sustainability Appraisal process.’

7.1.2 Therefore, based on the Council conclusions for the West Moor Park East site that other site options offer better opportunities for securing sustainable development, such as long term public transport access, Sanderson Associates have reviewed the accessibility issues relating to the Carcroft site, to determine whether this conclusion is justified.

7.1.3 The current accessibility scoring undertaken by the Council for the Carcroft site is shown in the following table:

3A(ii) Distance to Site 3A(i) Distance 3A(iii) Distance to Bus Stop (SYPTE Reference to Train Station Cycle Network Core Network) 441 0 + +

7.2 Train Station Accessibility

7.2.1 The nearest train station to the proposed site is Adwick, which provides two services per hour to Doncaster and an hourly service to Leeds and Sheffield.

7.2.2 There are two options for accessing the train station on foot, one via Bentley Moor Lane, which is approximately a 1.6km walk from the site. An alternative option would be via Adwick Lane, which is a shorter walk of approximately 1km from the southwest corner of the site. However, access via Adwick Lane would only be possible if the southern part of the site were delivered first (which is unlikely in phasing terms); and a pedestrian route were provided through the site that linked to Bentley Moor Road. Should this link be provided, the walking distance to the northern half of the site to the station would still be at least 1.5km.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 30 September 2019

West Moor Park East (Site Ref 937/1031)

7.2.3 Although there is street lighting provided along Bentley Moor Road, the existing footways on both sides are narrow. The footway that links Bentley Moor Road to the train station along the B1220 is also narrow. Along the potential route to the train station via Adwick Lane, no street lighting is available, which would make the route unattractive. Therefore, it is considered that the 0 score given by the Council is appropriate based on the required walking distances and the quality of the routes, which would require significant improvements to the existing footway connections to encourage staff and visitors to travel to the site using rail.

7.3 Bus Accessibility

7.3.1 The closest bus stops to the site are located on Doncaster Road, which are within a 400m walking distance of the site. The bus stop is served by three main services, which are the 405, 408 and 409 services that run half-hourly Monday to Saturday. The services provide access to Doncaster town centre, Pontefract, Selby and villages north of the main urban area.

7.3.2 Whilst access to the bus stops is available by existing footways, these footways are narrow and there is a lack of safe crossing facilities on Doncaster Road, which would need to be upgraded by the development.

7.3.3 There is an additional bus service (No. 412) on Doncaster Road that provides access to Carcroft. However, this only runs very infrequently (3 services during weekdays). Therefore, the current bus accessibility to the immediate residential population is inadequate. Given that one of the reasons for the Council proposing to allocate the site is that it will benefit the local community, this lack of bus access to Carcroft is a constraint that the development would need to rectify.

7.3.4 Therefore, it is concluded that without evidence to confirm that a high frequency bus service to the local community could be provided for the site and sustained in the long term, the + score that has currently been given by the Council for bus accessibility is incorrect and should be adjusted to a 0 score.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 31 September 2019

West Moor Park East (Site Ref 937/1031)

7.4 Cycle Accessibility

7.4.1 Based on a review of the Doncaster Cycle Map (2013), there are no dedicated cycle routes or facilities within 100m of the site. However, there is an advisory cycle route on Adwick Lane along the southern site boundary.

7.4.2 However, Adwick Lane has no dedicated cycling facilities, is unlit and is subject to a 60mph speed limit. Therefore, the availability of this route is unlikely to encourage high numbers of cyclists to the site.

7.4.3 As such, is considered that whilst the + score that has currently been provided is technically correct in accordance with the Councils scoring methodology, this is only by virtue of the simplistic assessment approach that has been used; and in reality a neutral 0 score would be more appropriate.

7.5 Site Access

7.5.1 Whilst suitable accesses may be possible onto Bentley Moor Lane, access to the wider highway network is constrained, as acknowledged by the Council in their site assessment. Without delivery of the A1M to A19 link road, which the Council acknowledge is at the ‘aspirational’ stage and not a committed scheme, access to the site from the wider area is not ideal, particularly for the movement of goods. In particular, access to the A1 is problematic, with HGV traffic needing to travel via Carcroft, where the highway network is constrained (particularly at the signalised crossroads in the centre of Carcroft) and where HGV traffic would have a significant impact on the residential population on route to the A1.

7.5.2 Based on the limited information relating to the A1 to A19 link contained with Local Plan documentation, it is clear that the delivery of the new link cannot be relied upon; and there are significant barriers to it’s delivery during the Local Plan period, if at all.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 32 September 2019

West Moor Park East (Site Ref 937/1031)

7.5.3 This is confirmed in the ‘South Pennines: Strategic Development Corridor - Strategic Program Outline Case, March 2019’ document produced by Transport for the North, which in reference to the Trans Pennine Link (to which the A1 to A19 forms a part of) states:

‘6.19 The transport interventions shown are indicative at this stage. They are based on the level of evidence currently available at this very early stage of assessment. For many of the Reference Case schemes there remains a critical requirement to continue with the development of cases and to secure funding and TfN will work with partners to try and achieve that. It should also be pointed out that many of these interventions require further development and a positive funding decision before they can be delivered.’

6.20 Delivery of these draft transport interventions should not be relied upon for planning and development purposes.’

7.5.4 Therefore, the very fact of, let alone the timescales for the delivery of the A1-A19 link are clearly a significant unknown. There will be a need for key decisions to be taken about priorities and funding, other schemes elsewhere will be competing for funds and even when high level decisions are taken they are susceptible to being reviewed. Beyond this there will be a need for technical work and compulsory purchase. The time it would take to undertake the necessary studies, prepare business cases (in conjunction with the wider South Pennines: Strategic Development Corridor program), secure funding and then proceed to the implementation stages (including significant CPO procedures) are likely to take it’s implementation beyond the Local Plan period if it happens at all, as was the case for the previous Doncaster UDP where the scheme was also mooted but not progressed. There is insufficient certainty of delivery and certainly in the plan period for the plan to make decisions based upon this infrastructure being in place. As the ‘South Pennines: Strategic Development Corridor - Strategic Program Outline Case, March 2019’ states ‘Delivery of these draft transport interventions should not be relied upon for planning and development purposes.’

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 33 September 2019

West Moor Park East (Site Ref 937/1031)

7.5.5 In light of the above, it is considered that there are significant vehicular access constraints that do not exist at the West Moor Park East site.

7.6 Summary and conclusions

7.6.1 Based on the information contained in this report, the following conclusions can be drawn:

 The 0 score that has given by the Council in relation to train accessibility is considered to be technically correct for the southern half of the site. However, the northern half of the site would be beyond 1.5km of the train station (even if a new link to Adwick Lane were provided through the southern site); and wider improvements to the footway network would be needed to provide a good quality route to the train station.  Without evidence to confirm that a high frequency bus service to the local community could be provided for the site, which is sustainable in the long term, the + score that has currently been given by the Council for bus accessibility is incorrect and should be adjusted to a 0 score.  In terms of cycle accessibility, there are no good quality cycling facilities within the vicinity of the site; and the unlit/high speed nature of Adwick Lane is unlikely to make access to the site by cycle an attractive option. Therefore, a 0 score would be more appropriate, without significant development mitigation.  As acknowledged by the Council, road access via the local network is constrained; and is inferior to the West Moor Park East site.  As detailed in Section 3, there will be a similar residential population (around 4% more) within close proximity of the site compared to the West Moor Park East site. Therefore, the ability of the site to help minimise travel to work distances will be similar to the West Moor Park East site and the sites should be scored similarly in this regard.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 34 September 2019

West Moor Park East (Site Ref 937/1031)

7.6.2 Therefore, based on this more qualitative approach, it is considered that the accessibility scoring for the site should be as follows:

Ability to Site Train Bus Cycle Road Access minimise travel to Reference Accessibility Accessibility Accessibility work distances 441 0 0 0 0 +

7.6.3 It is concluded that in accessibility terms, the Carcroft site is similar in accessibility terms to the West Moor Park East site. However, road access to the site is inferior to the West Moor Park East site.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 35 September 2019

West Moor Park East (Site Ref 937/1031)

8 Site A, East of Bankwood Lane, Rossington (Site Ref. 878/1032)

8.1 Introduction

8.1.1 One of the reasons for proposing to allocate the Bankwood Lane site that has been stated by the Council is that in their view the site:

‘…has good links both locally to a wider area via Great Yorkshire Way. It is close to a large population.

8.1.2 Whilst it is agreed that given the sites location next to a large (and growing) residential population, this should allow the development to minimise travel to work distances, it is considered that the Councils SA scoring in relation to bus accessibility is incorrect. It is also considered that whilst the site’s close proximity to a residential is a positive in accessibility terms, the impact of development traffic (particularly HGV’s) is a negative point that has not currently been considered in the SA.

8.1.3 The current scoring undertaken by the Council for the Bankwood Lane site is shown in the following table:

3A(ii) Distance to Site 3A(i) Distance 3A(iii) Distance to Bus Stop (SYPTE Reference to Train Station Cycle Network Core Network) 878/1032 - + 0

8.1.4 As the site is located in excess of 1.2km from a Train Station and as no dedicated cycling facilities are available on the local network, it is considered that the Councils scoring in relation to these modes is correct and no further comments are provided on these matters. Similarly there are high frequency bus services that operate on West End Lane that are accessible within a reasonable walk of the site (albeit over the 400m threshold for journeys towards Doncaster). Therefore, again the Council scoring for bus access is considered broadly appropriate and no additional comments are provided on these matters.

8.1.5 In light of the above, only comments regarding access to the site are made in the subsequent paragraphs.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 36 September 2019

West Moor Park East (Site Ref 937/1031)

8.2 Site Access

8.2.1 Access to the site is gained via Bankwood Lane, which for it’s initial section is a residential road, where on-street parking occurs near to the junction with West End Lane. Additional traffic on Bankwood Lane is likely to cause problems for existing residents; and it may be necessary to introduce parking restrictions to prevent this parking causing development traffic (including HGV’s) blocking back on West End Lane, which would be detrimental to existing residents.

8.2.2 Access to the strategic highway network is gained to the west via West End Lane, which links to Great Yorkshire Way and then on to junction 3 of the M18. Whilst the route could accommodate HGV traffic, the route passes through a major new housing development and so is likely to have a negative impact on these residents. Similarly, road access to the east is also via the residential area of Rossington and would have similar negative impacts.

8.2.3 In light of the above, it is considered that there are vehicular access constraints at the Rossington site that do not exist at the West Moor Park East site.

8.3 Summary and conclusions

8.3.1 Based on the information contained in this report, the following conclusions can be drawn:

 There are vehicular access constraints for the Rossington site that do not exist at the West Moor Park East site, which make the vehicular access arrangements superior at the West Moor Park East site;  As detailed in Section 3, there will be a similar residential population (around 2% less) within close proximity of the site compared to the West Moor Park East site. Therefore, the ability of the site to help minimise travel to work distances will be similar to the West Moor Park East site and the sites should be scored similarly in this regard.  As with the West Moor Park East site, due to the high frequency bus services that are available for the site, a negative score for access to a train station should be 'not applicable' (N/A), as the high frequency bus access makes train station accessibility of limited relevance.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 37 September 2019

West Moor Park East (Site Ref 937/1031)

8.3.2 Therefore, based on this more qualitative approach, it is considered that the accessibility scoring for the site should be as follows:

Ability to Site Train Bus Cycle Road Access minimise travel to Reference Accessibility Accessibility Accessibility work distances 878/1032 N/A + 0 0 +

8.3.3 It is concluded that in accessibility terms, the Rossington site does not offer any benefits to the West Moor Park East site; and that road access to the site is inferior to the West Moor Park East site.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 38 September 2019

West Moor Park East (Site Ref 937/1031)

9 Site 2, Land East Of Poplars Farm, Hurst Lane, Auckley (Site Ref. 941)

9.1 Introduction

9.1.1 The current scoring undertaken by the Council for the Poplar Farm site is shown in the following table:

3A(ii) Distance to Site 3A(i) Distance 3A(iii) Distance to Bus Stop (SYPTE Reference to Train Station Cycle Network Core Network) 941 - + 0

9.1.2 As the site is currently located in excess of 1.2km from a Train Station and cycling facilities are limited on the local network, it is considered that the Councils scoring on these modes is broadly correct and no further comments are provided on these matters.

9.1.3 In light of the above, only comments regarding bus accessibility, site access arrangements and general accessibly are made in the subsequent paragraphs. As there is a pending planning application at the site, reference has been made to the supporting transport information and comments made by the Local Highway Authority.

9.2 Bus Accessibility

9.2.1 5 no. bus services currently pass near to the site along the A638 Great North Road, which in total provide approximately 2-4 services per hour at peak times. However, as these services operate to a number of destinations they do not represent a high frequency service. This is confirmed in the Local Highway Authority consultation responses to the pending planning application, where the highways officer has commented that the services are not regarded as high frequency.

9.2.2 As confirmed in the in the Transport Assessment produced in support of the pending planning application, the walking distance to the stops that are located on the A638 close to the junction with High Common Lane are approximately 500m from the proposed site access junction. This walking distance is likely to increase following development as the bus stops will need to be relocated away from the

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 39 September 2019

West Moor Park East (Site Ref 937/1031)

junction due to the roundabout that is proposed to serve the site (and the adjacent resident site). Therefore, based on the Councils scoring criteria, the sites bus accessibility should have been given a 0 score.

9.2.3 The supporting Transport Assessment also suggests that additional bus services can be accessed at the nearby Airport Terminal. However, they have also confirmed that these stops are at least 900m walk from the site. Therefore, in reality these stops would not be accessible to most staff and visitors at the development; and the prospect of these services being diverted to the site would seem remote, as airport customers would not wish to be rerouted via an employment site.

9.3 Site Access

9.3.1 As previously stated, in the pending planning application, a roundabout access has been proposed on to the A638 Great North Road to serve the site. However, it does not appear that this arrangement has been agreed with the Council as yet, who have requested further information regarding it’s geometry and a Road Safety Audit before commenting further. Based on our initial review of the design, it appears that there are elements of it’s geometry that may not be compliant with standard. Therefore, to achieve a compliant design, additional land take may be required, included the triangular land located southwest of High Common Lane and east of the A638, which is beyond the application site boundary. As such, there are potential physical constraints that may prevent a high quality access being delivered at the site that do not exist at the West Moor Park East site.

9.4 Summary and conclusions

9.4.1 Based on the information contained in this report, the following conclusions can be drawn:

 Due to the current lack of high frequency bus services and the walking distance to the bus stops, which are in excess of 400m, the bus accessibility score should be reduced to a 0 score.  Whilst adequate access to the site may be achievable, this has not currently been demonstrated for the site as part of the pending planning application.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 40 September 2019

West Moor Park East (Site Ref 937/1031)

 As detailed in Section 3, there will be a smaller residential population (around 22% less) within close proximity of the site, compared to the West Moor Park East site. Therefore, the ability of the site to help minimise travel to work distances will be less and should be scored accordingly.

9.4.2 Therefore, based on this more qualitative approach, it is considered that the accessibility scoring for the site should be as follows:

Ability to Site Train Bus Cycle Road Access minimise travel to Reference Accessibility Accessibility Accessibility work distances 941 - 0 0 0/+ 0

9.4.3 It is concluded that in accessibility terms, the Poplars Farm site does not offer better opportunities for securing sustainable development than the West Moor Park East site; and in fact it is likely to be inferior due to the smaller residential population in the local area. Furthermore high quality access to the site has not currently been demonstrated and may not be achievable.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 41 September 2019

West Moor Park East (Site Ref 937/1031)

10 Summary and conclusions

10.1 As detailed in Section 2, the Council’s SA scoring in relation to accessibility matters only provide a very high level assessment of the sites; and does not take into account the quality of the facilities that are available, or that could be made available and sustained in the long term (eg long term self-sustaining bus services, as could be provided for the West Moor Park East site). This means that the Council’s SA scoring for individual sites is misleading. As such, this report provides a more qualitative assessment of accessibility matters, which provides a more accurate and detailed approach.

10.2 Based on the information contained in this report, the following conclusions can be drawn regarding the West Moor Park East site:

 Due to the bus enhancements that can be delivered at the site, a + score for bus accessibility is warranted; and a negative score for access to a train station should be ‘not applicable’ (N/A), as the high frequency and quality bus service that would be available makes that of limited relevance, with public transport access overall being good.  There is a large residential population within vicinity of the site, which will help to minimise travel to work distances. This is contrary to the conclusions reached by the Council, who suggest that the West Moor Park East site is isolated and that other sites offer better opportunities for securing sustainable development, which is not the case, particular in view that the sites at Thorne North and Poplar Farm that are not at all well located for the workforce population, with Thorne North having roughly a third of the local population compared to West Moor Park East.  Appropriate high quality road access can be delivered at the West Moor Park East site, which would provide direct access to the strategic highway network that will allow sustainable access for the movement of freight.  Whilst there are currently no dedicated cycling facilities within the vicinity of the site, cycle links are likely to be improved in future along the A630 road corridor that the development would be able to link into, which could help further encourage the large residential population that will live within close proximity of the site to travel by cycle.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 42 September 2019

West Moor Park East (Site Ref 937/1031)

10.3 Based on the more accurate and detailed approach to assessing accessibility matters that is contained within this report, it is considered that the site accessibility scoring for the West Moor Park East site and the other five proposed employment site allocations that have been assessed should be as follows:

Ability to Train Bus Cycle minimise Site Road Access Accessibility Accessibility Accessibility travel to work distances 937/1031 N/A + 0 + + West Moor Park East 001 - - 0 + - Thorne North 092 - 0/+ 0 0 + Balby Carr Bank 441 0 0 0 0 + Carcroft Common 878/1032 N/A + 0 0 + Rossington 941 - 0 0 0/+ 0 Poplars Farm

10.4 A summary of our findings in relation to each of the sites is as follows:

 Site 001 Thorne North - It is considered that in accessibility terms, the Thorne North site does not offer better opportunities for securing sustainable development than the West Moor Park East site; and in fact it is inferior due to the limited residential population in the local area and the long term prospects for self-sustaining public transport access.  Site 092 Balby Carr Bank, Site 441 Carcroft and Site 878/1032 Rossington - It is considered that in accessibility terms, these sites do not offer any benefits to the West Moor Park East site; and that road access to these sites is inferior to the West Moor Park East site.  Site 941 Poplars Farm - It is considered that in accessibility terms, the site does not offer better opportunities for securing sustainable development than the West Moor Park East site; and in fact it is inferior due to the smaller residential population in the local area.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 43 September 2019

West Moor Park East (Site Ref 937/1031)

10.5 In conclusion, it is considered that the Council reasons to not allocate the West Moor Park East site on accessibility grounds are incorrect, as the site compares favourably with all of the Councils preferred employment site allocations that we have assessed; and their SA approach and methodology does not include all of the relevant factors, includes irrelevant factors and mis-scores sites against the factors that are used, which has not allowed the Council to undertake a proper assessment of accessibility on a valid and sound basis.

Technical Note Relative Accessibility Report Ref: 11193/AND/001/02 44 September 2019

West Moor Park East (Site Ref 937/1031)

APPENDIX A Reasons for Allocation/Rejection of Selected Employment sites

Site Ref Site Name Gross site Area (ha) Reason for site being rejected/Reason for allocation 937/ 1031* West Moor Park East, Holme Wood Lane, Armthorpe 62 / 78.73 As with all the potential sites, this site fails the flood risk sequential test as it is within Flood Zone 3. It scores similarly to the other sites through the Sustainability Appraisal process. It is currently within Countryside Policy Area as designated by the UDP Proposals Map. The majority of the site is within the Armthorpe Neighbourhood Plan as Countryside Policy Protection Area (as included in the Core Strategy in Policy CS3). Armthorpe Parish Council were given the opportunity to consider potential employment sites during the preparation of the Neighbourhood Plan, and as a result of that process there is already a substantial amount of employment land within the Parish boundary. The site is to the east of the M18 and more isolated than other options that are available across the borough. There are other options directly adjacent to the main urban area and main towns which offer better opportunities for securing sustainable development such as long term public transport access. There are also concerns over vehicular access from Junction 4. The allocation of this site would exceed the supply of employment land for this plan period. Sites other than this one have been chosen for allocation in order to provide a balanced distribution of employment land across the Borough. 001 Junction 6 M18, Thorne North 73.63 As with all the potential sites in the M18 Corridor, this site fails the flood risk sequential test as it is within Flood Zone 3. It also scores similarly to the other sites through the Sustainability Appraisal process. It is currently designated as Countryside Policy Area by the UDP Proposals Map. Core Strategy Policy CS3: Countryside also applies as it continues to protect the countryside to the east of the borough through Countryside Protection Policy Area. It provides an excellent job creation opportunity in the north of the borough and it will complement the successful existing industrial estates to the north of Thorne. There is an outline planning application pending for employment uses. The site has support through the Informal Consultation on the Local Plan which took place in September – October 2018 (see Draft Policies and Proposed Sites Consultation Summary for further information). The Doncaster Employment Land Review suggests that if allocated 50% of the site could be developed in the plan period (36.8ha). Due to the extension of the plan period this would now equate to 70% of the site could be developed in the plan period. The majority of development could be for B8 and some for B2 (85/25% split).

92 Balby Carr Bank, Balby 11.25 This site is within an existing well used successful employment site within the Main Urban Area and therefore helps to provide additional land in that location. It has good links locally and is close to a large population. 258 Plot 1 Lakeside, Potteric Carr Road 8.48 This site is within an existing employment area within the Main Urban Area and therefore helps to provide land next to a well-used employment area which has good links locally and is close to a large population. 441 Land at Carcroft Common, 49.28 As with all the potential sites, this site fails the flood risk sequential test as it is within Flood Zone 3. It scores similarly to the other sites through the Sustainability Appraisal process. It is Carcroft a reserve employment site within the Unitary Development Plan and is therefore not within the Green Belt. There is a requirement the development to incorporate flood mitigation measures. There is a wider aspiration for the construction of a Trans-Pennine link from Manchester to Hull which this site will benefit from. The construction of the A1M to A19 link road will also form part of that new link. The site is within an area of high deprivation and job opportunities on this site would be greatly beneficial to the north of the borough. It will also help to re-address the balance of private sector investment which has been spent in the south of the borough. Due to the current infrastructure constraints it is considered that approximately 25% of the site (12 ha) would come forward before the end of the plan period. The majority of development will be for B8 and some for B2 (70/30% split). 878/1032 Site A, East of Bankwood Lane, 17.68 This site is within an existing well used successful employment site within Rossington and therefore helps to provide additional land in that location. It has good links both locally to a Rossington (former site ref 878) wider area via Great Yorkshire Way. It is close to a large population. 941* Site 2, Land East Of Poplars Farm, 68.54 This site is currently within the Countryside Policy Area as designated by the UDP Proposals Map. Hurst Lane, Auckley, Core Strategy Policy CS3: Countryside also applies as it continues to protect the countryside to the east of the borough through Countryside Protection Policy Area. The site benefits from being in Flood Zone 1. The inclusion of this site reflects the importance of Doncaster Sheffield Airport and the support for it within the Sheffield City Region Strategic Economic Plan (which lists the airport as one of the seven spatial priorities for the region) The airport is viewed as a catalyst for business development, inward investment and job creation. The site is supported by improved access through the Great Yorkshire Way. There is clear developer intention to develop this site. It is considered that the whole site (68 ha) would come forward before the end of the plan period. The majority of development will be for B8 (60/40% split). The SA scores show that there are archaeology issues which will need to be addressed. West Moor Park East (Site Ref 937/1031)

APPENDIX B 8km Travel Distance (Isodistance) Maps

West Moor Park East (Site Ref 937/1031)

APPENDIX C Residential sites incorporated in population assessments

Residential sites incorporated in population assessments

Site 001, there are 1084 new homes allocated/permitted, which are made up of the following allocations:

 Thorne: 588, 805, 807, 846, 889, 949, 951, 952, 958, 962, 988, 994, 1069, 081/343, 133, 396, 501, 510, 795  Stainforth: 794 and 857

Site 441, there are 3,213 new homes allocated/permitted, which are made up of the following allocations:

 Adwick: 648, 898, 944, 961, 991, 1073, 1080, 460  Carcroft: 1076, 165/186  Bentley: 972, 1059, 926, 1077, 1075, 979  Askern: 569, 628, 723, 796, 925, 954, 955, 956, 1066, 041, 195, 374  Doncaster: 712, 838, 897, 902, 906, 921, 923, 959, 967, 981, 983, 986, 993, 1070, 1071, 1074, 1084, 1085, 1091, 1092, 1093, 1094

Site 878/1032, there are 6,292 new homes allocated/permitted, which are made up of the following allocations:

 Airport: 223, 837, 940  Balby: 111, 115, 148, 164/430, 646, 990, 1046, 1052, 1081  Bessacarr: 843  Cantley: 350/407  Doncaster: 833 (39)  Lakeside: 261, 262, 797, 953  Rossington: 247, 662, 1056  Woodfield: 836

Site 937/1031, there are 4,089 new homes allocated/permitted, which are made up of the following allocations:

 Armthorpe: 241, 250, 602, 914, 915, 945, 947, 977, 1057, 1058, 1079, 1083, ANP3  Auckley: 223  Barnby Dun: 147  Bessacar: 843, 164/430  Cantley: 350/407  Edenthorpe: 255, 792  Hatfield: 170, 784, 890, 946, 970, 1068, 1090  Kirk Sandall: 544/943, 555  Wheatley: 432/391, 981, 984, 1086

Site 941, there are 5,335 new homes allocated/permitted, which are made up of the following allocations:

 Auckley: 223, 837, 940  Bawtry: 499, 950, 966, 982  Bessacar: 164/430, 1106  Rossington: 247, 662, 1056  Balby: 148, 836  Doncaster: 833  Finningley: 789, 965, 1078  Lakeside: 261, 261, 262, 953

/

Technical Note

Project: West Moor Park East Project No: 11193

Subject: A1 - A19 Link – Summary Note

Prepared by: Adam Darwin Date: 30/09/19

In the ‘Doncaster Local Plan 2015-2035 Publication Version – June 2019’ it states at pages 32-33 (point 4.31):

‘As well as supporting the M18 corridor, it is necessary that land in the north of Doncaster is allocated to ensure regeneration is spread across the Borough. Land in the north of Doncaster tends to have low value and poor accessibility as well as flood risk issues. Proposals for an A1 to A19 link road will unlock this potential by providing improved access to the A1(M). However, this will be towards the end of the plan period when there are clearer proposals for A1 improvements and funding for an A1-A19 link. Once these highway links are in place there are considerable prospects for the north of Doncaster including land at Carcroft Common of 54ha.’

It goes on to state at page 68 (Table 7 - North Doncaster A1-A19 link):

‘The scheme will provide a link road from the A1 to the A19 at Bentley Moor Lane, north of Toll Bar. The existing link between the A1 and A19 via Skellow does not have sufficient spare capacity to accommodate the additional traffic arising from proposed growth opportunities in the wider area. The link road will help boost regeneration and economic development in Doncaster’s northern communities which have higher levels of deprivation. In particular, it is hoped that the improved access to the A1 will help release the long term potential of the Carcroft employment area and help to enable the development of land at Carcroft Common.’

Based on the above, it apparent that the A1-A19 Link road scheme needs to be in place before any development can take place at Carcroft and is at the very early stages of conception, which is further acknowledge in the Councils reason for allocating the Carcroft Common site (Site Ref. 441), which highlights the proposal will form part of:

‘..a wider aspiration for the construction of a Trans-Pennine link from Manchester to Hull’.

To gain an update on the proposed Trans-Pennine link, reference has been made to the ‘South Pennines: Strategic Development Corridor - Strategic Program Outline Case, March 2019’ document produced by Transport for the North.

Figure 25 on page 85 (attached to the rear of this note) shows an indicative line for the A1-A19 link. However, there is very little additional information about the proposal (which forms part of the ‘Southern Pennines SDC Road Reference Case and SOP Proposals’) other than the general information contained at paragraphs 6.19-6.20, which states:

‘6.19 The transport interventions shown are indicative at this stage. They are based on the level of evidence currently available at this very early stage of assessment. For many of the Reference Case schemes there remains a critical requirement to continue with the development of cases and to secure funding and TfN will work with partners to try and achieve that. It should also be pointed out that many of these interventions require further development and a positive funding decision before they can be delivered.’

Technical Note

6.20 Delivery of these draft transport interventions should not be relied upon for planning and development purposes.’

In light of the above, it is clear that the delivery of the new A1-A19 cannot be relied upon; and there are significant barriers to the delivery of the scheme during the Local Plan period, as the proposal has not yet reached the Strategic Road Study stage, unlike the ‘The Trans Pennine Tunnel Study’ that is currently being developed.

The very fact of, let alone the timescales for the delivery of the A1-A19 link are clearly a significant unknown. There will be a need for key decisions to be taken about priorities and funding, other schemes elsewhere will be competing for funds and even when high level decisions are taken they are susceptible to being reviewed. Beyond this there will be a need for technical work and compulsory purchase. The time it would take to undertake the necessary studies, prepare business cases (in conjunction with the wider South Pennines: Strategic Development Corridor program), secure funding and then proceed to the implementation stages (including significant CPO procedures) are likely to take it’s implementation beyond the Local Plan period if it happens at all, as was the case for the previous Doncaster UDP where the scheme was also mooted but not progressed. There is insufficient certainty of delivery and certainly in the plan period for the plan to make decisions based upon this infrastructure being in place. As the ‘South Pennines: Strategic Development Corridor - Strategic Program Outline Case, March 2019’ states "Delivery of these draft transport interventions should not be relied upon for planning and development purposes.’

Page 2 of 2

Southern Pennines: Strategic Development Corridor SPOC

Figure 25: Southern Pennines SDC Road Reference Case and SOP Proposals

March 2019 | 85

Blue Anchor Leisure Limited West Moor Park East

Technical Note: Review of Allocation Justification

27 September 2019 Version 1.1 Issue

1 Introduction

Fore Consulting Limited (Fore) has been commissioned to provide transport and highways advice to support a proposed allocation of land east of Junction 4 of the M18 for approximately 2,301,000 sq. ft of employment use warehousing, known as West Moor Park East, through the Doncaster Metropolitan Borough Council (DMBC) emerging Local Plan. A Transport and Access Appraisal report was submitted to DMBC as part of a representation in respect of the proposed allocation in 2018.

In preparing the report, Fore initiated dialogue with Highways England and their technical advisors, including various meetings to discuss the potential impacts of the proposed allocation development on Junction 4 of the M18 motorway as part of the Strategic Road Network (SRN). The assessment work that was undertaken has identified that the junction can accommodate the traffic associated with the proposals, and any local mitigation that is necessary at Junction 4 can be delivered through land under control of the site promoter, the precise form of which can be determined as part of a future planning application. In summary there are no barriers in transport/highways terms to the site being brought forward for development as part of a future employment allocation.

A Publication Draft version of the emerging Local Plan was published by DMBC in August 2019 for consultation up to 30 September 2019. The West Moor Park East site is not allocated for employment in the draft plan, and a number of reasons were highlighted in the accompanying justification set out in the ‘Housing & Employment Site Selection Methodology and Results’ report (dated June 2019, reference Table 9.28, site 937 / 1031).

This technical note has been prepared directly in response to the justification presented by DMBC, which is not considered to fairly reflect or fully represent the technical position in transport/highways terms for the proposed allocation site.

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2 Accessibility

DMBC Comment

“The site is to the east of the M18 and more isolated than other options that are available across the borough. There are other options directly adjacent to the main urban area and main towns which offer better opportunities for securing sustainable development such as long term public transport access.”

Fore Response

A comparison of the relative accessibility of West Moor Park East to several nearby allocated sites has been undertaken by a separate consultant and should be referenced alongside this document.

Discussions with First Group (as the main operator of bus services in Doncaster) were undertaken as part of the appraisal work submitted previously. First Group confirmed in principle that the development can be readily served by extending existing bus services. A letter from First Group confirming this is provided at Appendix A.

The proposed extension to the number 15 service would deliver a 15 minute bus service at peak times and a 20 minute service interpeak, this will operate from Clay Lane at Wheatley to the allocation site. Travel time from the allocation site to Clay Lane is expected to be less than 15 minutes given that no intermediate bus stops are proposed, and the extension is approximately 3 miles in distance. From Clay Lane to Doncaster town centre, journey time is approximately 20 minutes which indicates total journey time from the allocation site to Doncaster town centre is predicted to be less than 45 minutes in total.

The bus route extension will provide additional connectivity for a significant proportion of the Doncaster borough including Armthorpe, Wheatley, central Doncaster and Hexthorpe, Balby and Edlington in the south west. With extensive commercial development emerging along the A18 and A1630, delivering improved public transport connectivity to employment sites along this corridor will offer residents wider employment opportunities. Residents in Armthorpe will benefit from improved public transport connectivity into Doncaster town centre, where the option to interchange with a range of services is available.

The promoter of the site is committed to provide public transport links as part of any development on the allocation site, and these would be considered in detail at the planning application stage. The information provided above demonstrates that there is willingness on behalf of the main bus operator to provide a future service that will provide benefit to a wider area across north Doncaster. The lack of existing access to a bus service should not therefore represent a barrier to the allocation of the site for employment uses.

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3 Vehicular Access

DMBC Comment

“There are also concerns over vehicular access from Junction 4.”

Fore Response

The nature of any concerns over vehicular access are not specified by DMBC in their response, with no details provided. Through work undertaken as part of the 2018 representation and to date, access to the proposed allocation site has been considered in detail. The promoter is able to demonstrate that a safe and satisfactory access to the allocation site can be achieved and delivered through land under their control. This point has been covered and demonstrated in the representations provided. The technical work undertaken by Fore is to a sufficient level of detail to demonstrate that vehicular access is not a barrier to the site coming forwards for development, and the details of this can be secured by DMBC through a future planning process.

The key points are set out in the following sections.

3.1 Access to the Allocation Site

Potential access arrangements were identified as part of the Transport and Access Appraisal submitted to DMBC in 2018. The works comprise the widening of Holme Wood Lane which is an adopted public highway to 7.3m between Junction 4 of the M18 and the proposed access point. The works that are likely to be necessary would be accommodated within land that is either adopted public highway or on land that is controlled by the promoter. As such, works anticipated to be required on Holme Wood Lane are readily deliverable by the promoter and the details of this can be secured by DMBC through a future planning process.

There are options for achieving a safe and satisfactory vehicular access to the site from Holme Wood Lane, which can be delivered through a future masterplan process. An indicative access arrangement is demonstrated in Appendix B. Following an initial feasibility assessment, this access arrangement is considered to be deliverable and would operate safely and efficiently. The precise access solution can be optimised further through discussions with DMBC as highway authority, and this can all be controlled by them through a future planning application.

Based on adopted public highway information obtained from Doncaster Council, it is clear that the embankments and verge on the north side of Holme Wood Lane form part of the adopted highway. The necessary widening of Holme Wood lane, along with any other mitigation required, can therefore feasibly be achieved within the extent of land

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controlled by the promoter and the adopted highway, without land controlled by third parties.

The information set out above indicates there is scope to deliver a safe and efficient access to the site which does not form a barrier to the future allocation of the site.

3.2 M18 Junction 4

It is understood that Highways England are currently assessing the cumulative impact of the Local Plan on the Strategic Road Network. However, based on the work previously submitted and also subsequent discussions and correspondence with Highways England and their technical advisors, it is understood that:

• There are some existing operational issues at Junction 4, but these issues are associated with capacity constraints elsewhere on the local network. These constraints specifically result in queuing back from roundabouts on the A630 West Moor Link Road at certain times, affecting Junction 4 (rather than a specific issue with the Junction 4 roundabout itself). It is understood that the West Moor Link improvement scheme that is being delivered through the SCRIF process (the first phase of which is under construction at the time of writing) would resolve the existing queuing issues on the A630 West Moor Link.

• The scope of any necessary works at Junction 4 to accommodate development on the allocation site is capable of being delivered. The inclusion of land directly adjacent M18 Junction 4 to the north east within the proposed allocation boundary would further assist the ability to mitigate the cumulative impact of the Local Plan, should this be confirmed as necessary through Highways England’s cumulative assessment study.

3.2.1 Impact on the Highway Network

Given the likely changes in traffic flows associated with the allocation, further detailed assessment of the key junctions on the local network will need to be undertaken, and this will be addressed at the planning application stage.

However, given that vehicular access will be taken from Junction 4 of the M18, an initial capacity assessment of the junction has been undertaken at this early stage given its importance to the operation of the strategic road network. The capacity assessment has been undertaken based on the following assumptions:

• For the purposes of this assessment, the full development is considered.

• Weekday peak hours are assessed, as they are anticipated to represent the worst- case combination of existing and allocation-related traffic flows. The surveyed traffic data indicates that the weekday peak hours on the existing highway network are

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07.00 to 08.00 in the morning, and 16.00-17.00 in the afternoon. In terms of development traffic, peak hours identified from the trip rates and resulting trip generation have been assumed. As such, the assessment is considered to be robust.

• A future assessment year of 2035 has been assumed, which corresponds to the period covered by the Council’s emerging local plan.

• Traffic growth has been considered based upon a series of planned and committed development proposals in Armthorpe and sites with planning permission as of the beginning of 2018. The developments considered are as follows:

▪ Wheatley Hall Lane – residential, commercial, retail, leisure and healthcare uses. ▪ Parkside Industrial Estate – 23,204 sqm commercial use. ▪ Land at Hungerhill Lane – 542 residential dwellings. ▪ Athelstane Crescent – 65 residential dwellings. ▪ Land to east of Mere Lane – 650 residential dwellings. ▪ Land at north west of Hatfield Lane – 400 residential dwellings ▪ Hatfield Lane – 400 residential dwellings. ▪ Land west of Barton Lane - 185 residential dwellings. ▪ Hatfield Road – 22,300 sqm (B8). ▪ West Moor Park extension – 3,531 sqm (B1) and 80,634 sqm (B8).

Development proposals expected to generate less than 30 two-way trips have been discounted as their impacts are considered to be limited. Such impacts are unlikely to be represent a significant impact on the operation of the junction.

• The following scenarios have been assessed:

▪ 2018 Base: representing the operation of the existing junction layout, based on traffic flows surveyed at Junction 4 on Tuesday 11 September 2018. ▪ 2035 Do Minimum: representing the future year situation, without the proposed development taking place. The scenario includes the surveyed peak hour traffic flows at the M18 Junction 4, plus the committed development flows. For the purposes of this scenario, dualling of the A630 West Moor Link west of Junction 4 of the M18 is assumed to have been implemented. ▪ 2035 With Development: representing the situation with proposed development in place. The traffic flows are derived by adding the Development Traffic Flows to the 2035 Do Minimum Traffic Flows. This scenario assumes dualling of the

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A630 West Moor Link, and also incorporates changes to Junction 4 necessary to accommodate the development (briefly, widening of Holme Wood Lane and associated changes to the approach to Junction 4).

3.2.2 Capacity Assessment – M18 Junction 4

A Junctions9 model of the site access priority junctions has been developed. The Junctions9 program calculates the Ratio of Flow to Capacity (RFC) and maximum queue experienced by all vehicles on each arm. The RFC is an indicator of the likely performance of a turning movement at a junction under a given set of traffic flows. Due to site-to-site variation, there may be a standard error in the prediction on the entry capacity by ±15%. An RFC value of 1.0 is considered to represent the absolute capacity threshold.

The full modelling results are presented in Appendix C and summarised in Table 1 .

Table 1: Capacity Assessment – M18 Junction 4 2035 With West 2018 Base Year 2035 Do Minimum Moor Park East Existing Layout + Existing Layout + Existing Layout Scenario Link West Moor Link West Moor Link

Queue Queue Queue RFC RFC RFC (PCU) (PCU) (PCU)

M18 Southbound 1.1 0.52 2.6 0.72 7.8 0.90 Exit Slip Road

Holme Wood Lane 0.1 0.05 0.1 0.07 0.5 0.33 AM Peak Hour M18 Northbound 0.6 0.38 1.2 0.55 2.8 0.74 Exit Slip Road

A630 6.8 0.88 2.3 0.70 4.2 0.81

M18 Southbound 0.9 0.48 2.0 0.67 2.6 0.73 Exit Slip Road

Holme Wood Lane 0.1 0.06 0.1 0.08 0.9 0.48 PM Peak Hour M18 Northbound 0.7 0.40 1.6 0.61 2.9 0.75 Exit Slip Road

A630 3.3 0.77 1.5 0.61 1.9 0.66

The assessment demonstrates that the Junction 4 layout would satisfactorily accommodate traffic associated with West Moor Park East. A small number of links would operate with a modelled RFC at or just higher than 0.85; including the southbound M18 exit slip road and

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the A630 West Moor Link approach during the AM peak hour. However, if necessary, a minor improvement scheme to mitigate impacts could be developed and delivered if this was demonstrated to be required following full assessment through the planning process. As referenced above, as the necessary land to improve the Junction 4 layout is under control of the scheme promoter, the scope of mitigation potentially required does not form a barrier to allocation of the site.

In all cases the RFC would be lower than the absolute capacity threshold of 1.0 and associated queues on the slip road would be accommodated satisfactorily on the slip road without extending back to the running lanes of the motorway. Similarly, the modelled queue on the A630 West Moor Link approach is not of a scale that would extend back to upstream junctions.

It should be noted that no allowance has been made to account for traffic associated with the existing uses of the site for the purposes of this assessment; the modelling can therefore be considered extremely robust.

On this basis, it is considered that traffic associated with the West Moor Park East development as proposed, plus planned and committed development can be satisfactorily accommodated at Junction 4 of the M18.

3.3 Wider Local Road Network Operation

It is understood that following publication of the draft Local Plan, DMBC have commissioned strategic modelling of the local highway network. Although the published evidence base includes an assessment of the impact of the local plan on the highway network around Doncaster, the document was produced by the Highways Agency (now Highways England) in 2015, and provides a very ‘high level’ assessment of the potential impacts on the key junctions on the trunk road network only. As such, it cannot be relied upon for the purposes of considering vehicular access to the allocation site or, in turn, the impact of individual allocation sites on the local highway network. As highlighted above, Highways England are undertaking cumulative assessment of the impact of the Local Plan on the trunk road network around Doncaster.

3.4 Road Safety

Detailed assessment of recent road safety records, and collision history was undertaken in preparing the submitted transport and access appraisal report. Since the submission, accident data has been reviewed and no additional incidents have been identified. This confirmed that there is no pattern of accidents which suggests a specific existing road safety issue (at M18 Junction 4 or elsewhere along the A630 corridor in the vicinity) that would need to be addressed to safely and efficiently accommodate the proposed allocation.

7 Blue Anchor Leisure Limited 3132 ▪ West Moor Park East ▪ Technical Note: Review of Allocation Justification 27 September 2019 ▪ Version 1.1 ▪ Issue

Details of road traffic collisions (RTCs) recorded on the highway network in the vicinity of the site (including slip roads and merging / diverging areas at Junction 4) were obtained from Doncaster Council for the period between 1 January 2013 and 15 August 2018. This has been examined to determine whether there is a history of collisions that is attributable to the existing highway geometry. Accident data is presented in Appendix D.

• M18 slip roads: a total of three RTCs were recorded over the period; one on the southbound exit slip road, one on the northbound exit slip road, and one on the northbound entry slip road respectively. Two collisions occurred in similar circumstances, with drivers following too close to the vehicle in front resulting in collisions. The other incident occurred as a result of a motorcyclist losing control while pulling over to stop due to illness.

• Junction 4 roundabout circulatory; one RTC was recorded involving two vehicles colliding, causing injuries of slight severity. This was a result of the driver of a vehicle changing lanes suddenly to continue on the roundabout rather than towards the southbound entry slip road.

• A630 West Moor Link; a total of four RTCs were recorded during the period. One RTC resulted in serious injuries, as a result of a driver losing control of their vehicle due to wet road conditions, and veering into the path of oncoming traffic. As a result of the car veering, another vehicle swerved to avoid a head on collision which led the two vehicles to collide together and also into the rear of a parked HGV. The remaining RTCs resulted in injuries of slight severity. One incident involved a vehicle skidding on diesel deposited in the road, resulting in a collision with another vehicle. Another incident resulted from a driver failing to look properly, causing them to collide with a van driving in front. The third incident involved one vehicle colliding in to the rear of another, due to careless driving.

Since the transport access and appraisal report was submitted in 2018, a review of accident data has been carried out and there remains no pattern of accidents recorded. Overall, there is no pattern of accidents that suggests that substandard road layout, inadequate or masked signs, or poor/defective road surfaces were significant contributory factors in any of the RTCs recorded. All appear to be isolated, one-off events, typically arising through driver error or behaviour. On this basis it is considered there are no specific site-related causal factors that would need to be addressed to safely and efficiently accommodate the development proposals. Road safety is therefore demonstrably not a barrier to the allocation site coming forwards for development.

8 Blue Anchor Leisure Limited 3132 ▪ West Moor Park East ▪ Technical Note: Review of Allocation Justification 27 September 2019 ▪ Version 1.1 ▪ Issue

4 Summary

Based on the assessment undertaken to date, it is considered that the West Moor Park East allocation site can be accessed safely and efficiently. It is accepted that local improvements to the existing Holme Wood Lane as well as the layout and operation of Junction 4 of the M18 will be required to support the allocation. Such improvements are wholly deliverable within existing public highway or land controlled by the promoter and should not represent a barrier to allocation of the site.

The basis of the statement “there are concerns over vehicular access from Junction 4” from DMBC in the justification for not allocating the site is not clear. It appears that no quantitative analysis has been undertaken to support the draft allocations at this stage. There is no specific evidence of an existing issue at Junction 4 that is not capable of being mitigated (either by the promoter, or ongoing committed improvement schemes), and DMBC is currently delivering the West Moor Link Road that improves access on the western side of the junction. On this basis and as demonstrated in the representations made, the stated concerns do not seem to be reasonable or justifiable.

9

Appendix A

Allan Riggall Commercial Director First South Yorkshire Ltd Olive Grove Depot Sheffield S2 3GA

Fore Consulting Limited 2nd Floor Queens House Bus 34 Wellington Street Leeds LS1 2DE

11th October 2018

Dear Sir / Madam,

Reference: West Moor Park East Development I can confirm that following discussions with Fore Consulting Limited, First South Yorkshire Ltd in principal is willing to make changes to the commercial bus network to ensure that the proposed development at junction 4 of the M18 is sufficiently served by bus. We feel the best course of action to serve the site is to extend service 15 which currently terminates at Clay Lane approximately 3 miles away. The proposed extension would deliver a 15 minute bus service at peak times and a 20 minute service interpeak. The proposal could operate between 07:00 and 19:00 Monday to Saturday. We are willing to do this for a sum of £150,000 per annum + inflation for a duration of 5 years from the service commencement date. Additional operation outside of the hours quoted is available at the cost of £32 per hour. We are also willing to look at wider schemes to improve links between the site and Armthorpe. This will require further work at the appropriate stage to confirm the details of what this will look like and the resource needed, but at this stage we anticipate that such an improvement will be feasible We feel the proposal ensures that the site is well served by public transport and based on current information available and experience, we envisage the service would be self- sustaining after the 5 years funding ceases. A full review of this would be taken towards the end of the term. Yours sincerely

Allan Riggall Head of Commercial First South Yorkshire

Appendix B

THIS DRAWING IS THE PROPERTY OF FORE CONSULTING C REGISTERED IN ENGLAND NO 7291952 COPYRIGHT RESERVED DO NOT SCALE 3rd PARTY LAND N O T E S

BOUNDARY 1. PRELIMINARY LAYOUT SUBJECT TO FULL TOPOGRAPHICAL SURVEY & DETAILED DESIGN INCLUDING CDM COMPLIANCE, STATUTORY UNDERTAKERS SEARCH, DIVERSION REQUIREMENTS, HIGHWAY DRAINAGE PROVISION, LAND AVAILABILITY AND LOCAL AUTHORITY APPROVAL.

2. THIS DRAWING IS TO BE READ IN CONJUNCTION WITH ALL ARCHITECTS, ENGINEERS & SPECIALISTS DRAWINGS AND SPECIFICATIONS. TIE INTO MASTERPLAN 13010 6150 Meadpark

4480 1300 3600 6470 1330 1330 2870

FTA DESIGN ARTICULATED VEHICLE (1998) 3rd PARTY LAND BOUNDARY TIE INTO EXISTING OVERALL LENGTH 16.480M OVERALL WIDTH 2.550M OVERALL BODY HEIGHT 3.870M MIN BODY GROUND CLEARANCE 0.515M MAX TRACK WIDTH 2.470M LOCK TO LOCK TIME 3.00S KERB TO KERB TURNING RADIUS 6.550M

2.4M X 70M VISIBILITY SPLAY

2.4M X 90M VISIBILITY SPLAY

NEW 2.0m FOOTWAY TO BE PROVIDED CONNECTING INTERNAL SITE LAYOUT TO EXISTING PEDESTRIAN TIE INTO M18 J4 INFRASTRUCTURE TO THE WEST HOLME WOOD LANE CARRIAGEWAY TO WIDENED TO 7.3m BETWEEN ACCESS & M18 JUNTION 4

GENERAL ARRANGEMENT 1:500

FTA Design Articulated Vehicle (1998) 7.300

2.000 REV DESCRIPTION DATE BY

CLIENT: R6.000 BLUE ANCHOR LEISURE

PROJECT COMPOUND CURVE WEST MOOR PARK EAST

2.000

DRAWING TITLE

3.650 POSSIBLE VEHICLE ACCESS ARRANGEMENTS

P R E L I M I N A R Y

Fore Consulting Limited 2nd Floor, Queens House 34 Wellington Street Leeds LS1 2DE 3.650 0113 2460204 FTA Design Articulated Vehicle (1998) www.foreconsulting.co.uk Drawn by Checked by Date Scale Format PJ PI 2018 AS SHOWN A1

Job Number Drawing Number Revision GEOMETRIC LAYOUT 1:200 AUTOTRACK 1:250 3132 3132 SK001 01 -

Appendix C

Generated on 24/09/2019 13:02:51 using Junctions 9 (9.5.0.6896)

Junctions 9 ARCADY 9 - Roundabout Module Version: 9.5.0.6896 © Copyright TRL Limited, 2018 For sales and distribution information, program advice and maintenance, contact TRL: www.trlsoftware.co.uk The users of this computer program for the solution of an engineering problem are in no way relieved of their responsibility for the correctness of the solution

Filename: 01 J4 M18 Base Flows Only.j9 Path: X:\Jobs\3132 Blue Anchor Leisure\Junctions 9\2018-10-22 Updated Floorspace Report generation date: 24/09/2019 13:01:13

»Existing Layout - 2018 Base Flows, AM »Existing Layout - 2018 Base Flows, PM

Summary of junction performance

AM PM Queue (PCU) Delay (s) RFC LOS Queue (PCU) Delay (s) RFC LOS Existing Layout - 2018 Base Flows

Arm 1 1.1 4.17 0.52 A 0.9 3.64 0.48 A Arm 2 0.1 4.39 0.05 A 0.1 4.05 0.06 A Arm 3 0.6 3.75 0.38 A 0.7 3.88 0.40 A Arm 4 6.8 18.08 0.88 C 3.3 9.71 0.77 A

There are warnings associated with one or more model runs - see the 'Data Errors and Warnings' tables for each Analysis or Demand Set.

Values shown are the highest values encountered over all time segments. Delay is the maximum value of average delay per arriving vehicle.

File summary

File Description

Title Location Site number Date 24/09/2018 Version Status (new file) Identifier Client Jobnumber Enumerator WEEZY\Modelling Description

Units Distance units Speed units Traffic units input Traffic units results Flow units Average delay units Total delay units Rate of delay units m kph PCU PCU perHour s -Min perMin

Analysis Options Vehicle length Calculate Queue Calculate detailed queueing Calculate residual RFC Average Delay Queue threshold (m) Percentiles delay capacity Threshold threshold (s) (PCU) 5.75 0.85 36.00 20.00

1 Generated on 24/09/2019 13:02:51 using Junctions 9 (9.5.0.6896)

Demand Set Summary ID Scenario name Time Period name Traffic profile type Start time (HH:mm) Finish time (HH:mm) Time segment length (min) Run automatically D1 2018 Base Flows AM ONE HOUR 08:00 09:30 15 ü D2 2018 Base Flows PM ONE HOUR 16:00 17:30 15 ü

Analysis Set Details ID Name Include in report Network flow scaling factor (%) Network capacity scaling factor (%) A1 Existing Layout ü 100.000 100.000

2 Generated on 24/09/2019 13:02:51 using Junctions 9 (9.5.0.6896)

Existing Layout - 2018 Base Flows, AM

Data Errors and Warnings Severity Area Item Description Arm 1 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 2 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 3 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 4 - Roundabout Warning Geometry Effective flare length is over 30m, which is outside the normal range. Treat capacities with increasing caution. Geometry Arm 4 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout HV% is zero for all movements / time segments. Vehicle Mix matrix should be completed whether working in Warning Vehicle Mix PCUs or Vehs. If HV% at the junction is genuinely zero, please ignore this warning.

Junction Network

Junctions Junction Name Junction type Use circulating lanes Arm order Junction Delay (s) Junction LOS 1 untitled Standard Roundabout 1, 2, 3, 4 10.71 B

Junction Network Options Driving side Lighting Left Normal/unknown

Arms

Arms Arm Name Description 1 M18 Northbound 2 Holme Wood Lane 3 M18 Southbound 4 A630

Roundabout Geometry V - Approach road half- E - Entry width l' - Effective flare R - Entry radius D - Inscribed circle PHI - Conflict (entry) Exit Arm width (m) (m) length (m) (m) diameter (m) angle (deg) only 1 6.50 6.50 0.0 126.8 160.0 15.0 2 2.85 5.50 20.0 57.5 160.0 17.1 3 6.40 6.40 0.0 57.3 160.0 23.4 4 3.15 6.84 39.0 27.6 160.0 62.2

Slope / Intercept / Capacity

Roundabout Slope and Intercept used in model Arm Final slope Final intercept (PCU/hr) 1 0.528 2153 2 0.439 1537 3 0.505 2046 4 0.416 1635

The slope and intercept shown above include any corrections and adjustments.

3 Generated on 24/09/2019 13:02:51 using Junctions 9 (9.5.0.6896)

Traffic Demand

Demand Set Details ID Scenario name Time Period name Traffic profile type Start time (HH:mm) Finish time (HH:mm) Time segment length (min) Run automatically D1 2018 Base Flows AM ONE HOUR 08:00 09:30 15 ü

Vehicle mix varies over turn Vehicle mix varies over entry Vehicle mix source PCU Factor for a HV (PCU) ü ü HV Percentages 2.00

Demand overview (Traffic) Arm Linked arm Profile type Use O-D data Average Demand (PCU/hr) Scaling Factor (%) 1 ONE HOUR ü 858 100.000 2 ONE HOUR ü 39 100.000 3 ONE HOUR ü 531 100.000 4 ONE HOUR ü 1296 100.000

Origin-Destination Data Demand (PCU/hr) To 1 2 3 4 1 0 5 0 853 From 2 6 1 10 22 3 2 22 0 507 4 724 30 524 18

Vehicle Mix Heavy Vehicle Percentages To 1 2 3 4 1 0 0 0 0 From 2 0 0 0 0 3 0 0 0 0 4 0 0 0 0

Results

Results Summary for whole modelled period Average Demand Total Junction Arm Max RFC Max Delay (s) Max Queue (PCU) Max LOS (PCU/hr) Arrivals (PCU) 1 0.52 4.17 1.1 A 787 1181 2 0.05 4.39 0.1 A 36 54 3 0.38 3.75 0.6 A 487 731 4 0.88 18.08 6.8 C 1189 1784

4 Generated on 24/09/2019 13:02:51 using Junctions 9 (9.5.0.6896)

Main Results for each time segment

08:00 - 08:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 646 161 445 1918 0.337 644 548 0.0 0.5 2.820 A 2 29 7 1046 1078 0.027 29 43 0.0 0.0 3.433 A 3 400 100 675 1704 0.235 399 400 0.0 0.3 2.754 A 4 976 244 23 1625 0.600 970 1051 0.0 1.5 5.447 A

08:15 - 08:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 771 193 533 1872 0.412 771 656 0.5 0.7 3.268 A 2 35 9 1252 987 0.036 35 52 0.0 0.0 3.780 A 3 477 119 808 1637 0.292 477 478 0.3 0.4 3.102 A 4 1165 291 28 1623 0.718 1161 1257 1.5 2.5 7.726 A

08:30 - 08:45 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 945 236 648 1811 0.522 943 797 0.7 1.1 4.141 A 2 43 11 1528 866 0.050 43 63 0.0 0.1 4.374 A 3 585 146 989 1546 0.378 584 582 0.4 0.6 3.737 A 4 1427 357 34 1620 0.881 1411 1539 2.5 6.4 16.094 C

08:45 - 09:00 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 945 236 654 1808 0.523 945 805 1.1 1.1 4.171 A 2 43 11 1535 863 0.050 43 64 0.1 0.1 4.391 A 3 585 146 991 1545 0.378 585 587 0.6 0.6 3.747 A 4 1427 357 34 1620 0.881 1425 1541 6.4 6.8 18.075 C

09:00 - 09:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 771 193 542 1867 0.413 773 667 1.1 0.7 3.294 A 2 35 9 1263 982 0.036 35 53 0.1 0.0 3.800 A 3 477 119 811 1636 0.292 478 487 0.6 0.4 3.112 A 4 1165 291 28 1623 0.718 1182 1261 6.8 2.6 8.455 A

09:15 - 09:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 646 161 450 1915 0.337 647 554 0.7 0.5 2.838 A 2 29 7 1053 1074 0.027 29 44 0.0 0.0 3.446 A 3 400 100 678 1703 0.235 400 404 0.4 0.3 2.763 A 4 976 244 23 1625 0.600 980 1055 2.6 1.5 5.620 A

5 Generated on 24/09/2019 13:02:51 using Junctions 9 (9.5.0.6896)

Existing Layout - 2018 Base Flows, PM

Data Errors and Warnings Severity Area Item Description Arm 1 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 2 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 3 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 4 - Roundabout Warning Geometry Effective flare length is over 30m, which is outside the normal range. Treat capacities with increasing caution. Geometry Arm 4 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout HV% is zero for all movements / time segments. Vehicle Mix matrix should be completed whether working in Warning Vehicle Mix PCUs or Vehs. If HV% at the junction is genuinely zero, please ignore this warning.

Junction Network

Junctions Junction Name Junction type Use circulating lanes Arm order Junction Delay (s) Junction LOS 1 untitled Standard Roundabout 1, 2, 3, 4 6.37 A

Junction Network Options Driving side Lighting Left Normal/unknown

Traffic Demand

Demand Set Details ID Scenario name Time Period name Traffic profile type Start time (HH:mm) Finish time (HH:mm) Time segment length (min) Run automatically D2 2018 Base Flows PM ONE HOUR 16:00 17:30 15 ü

Vehicle mix varies over turn Vehicle mix varies over entry Vehicle mix source PCU Factor for a HV (PCU) ü ü HV Percentages 2.00

Demand overview (Traffic) Arm Linked arm Profile type Use O-D data Average Demand (PCU/hr) Scaling Factor (%) 1 ONE HOUR ü 832 100.000 2 ONE HOUR ü 49 100.000 3 ONE HOUR ü 569 100.000 4 ONE HOUR ü 1135 100.000

Origin-Destination Data Demand (PCU/hr) To 1 2 3 4 1 0 4 0 828 From 2 15 2 16 16 3 2 14 0 553 4 723 12 376 24

6 Generated on 24/09/2019 13:02:51 using Junctions 9 (9.5.0.6896)

Vehicle Mix Heavy Vehicle Percentages To 1 2 3 4 1 0 0 0 0 From 2 0 0 0 0 3 0 0 0 0 4 0 0 0 0

Results

Results Summary for whole modelled period Average Demand Total Junction Arm Max RFC Max Delay (s) Max Queue (PCU) Max LOS (PCU/hr) Arrivals (PCU) 1 0.48 3.64 0.9 A 763 1145 2 0.06 4.05 0.1 A 45 67 3 0.40 3.88 0.7 A 522 783 4 0.77 9.71 3.3 A 1041 1562

Main Results for each time segment

16:00 - 16:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 626 157 321 1984 0.316 625 554 0.0 0.5 2.645 A 2 37 9 921 1132 0.033 37 24 0.0 0.0 3.285 A 3 428 107 664 1710 0.251 427 294 0.0 0.3 2.803 A 4 854 214 25 1624 0.526 850 1067 0.0 1.1 4.625 A

16:15 - 16:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 748 187 384 1950 0.384 747 664 0.5 0.6 2.991 A 2 44 11 1103 1053 0.042 44 29 0.0 0.0 3.568 A 3 512 128 795 1644 0.311 511 352 0.3 0.4 3.175 A 4 1020 255 30 1622 0.629 1018 1276 1.1 1.7 5.935 A

16:30 - 16:45 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 916 229 469 1905 0.481 915 811 0.6 0.9 3.629 A 2 54 13 1349 945 0.057 54 35 0.0 0.1 4.042 A 3 626 157 973 1554 0.403 626 429 0.4 0.7 3.874 A 4 1250 312 36 1619 0.772 1243 1562 1.7 3.2 9.414 A

7 Generated on 24/09/2019 13:02:51 using Junctions 9 (9.5.0.6896)

16:45 - 17:00 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 916 229 471 1904 0.481 916 815 0.9 0.9 3.641 A 2 54 13 1352 943 0.057 54 35 0.1 0.1 4.048 A 3 626 157 974 1553 0.403 626 432 0.7 0.7 3.883 A 4 1250 312 36 1619 0.772 1249 1565 3.2 3.3 9.707 A

17:00 - 17:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 748 187 387 1949 0.384 749 669 0.9 0.6 3.005 A 2 44 11 1107 1050 0.042 44 29 0.1 0.0 3.579 A 3 512 128 797 1643 0.311 512 355 0.7 0.5 3.185 A 4 1020 255 30 1622 0.629 1027 1280 3.3 1.7 6.108 A

17:15 - 17:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 626 157 323 1982 0.316 627 559 0.6 0.5 2.656 A 2 37 9 926 1130 0.033 37 24 0.0 0.0 3.292 A 3 428 107 667 1709 0.251 429 296 0.5 0.3 2.815 A 4 854 214 25 1624 0.526 857 1071 1.7 1.1 4.707 A

8 Generated on 24/09/2019 13:43:02 using Junctions 9 (9.5.0.6896)

Junctions 9 ARCADY 9 - Roundabout Module Version: 9.5.0.6896 © Copyright TRL Limited, 2018 For sales and distribution information, program advice and maintenance, contact TRL: www.trlsoftware.co.uk The users of this computer program for the solution of an engineering problem are in no way relieved of their responsibility for the correctness of the solution

Filename: 02 J4 M18 With West Moor Link.j9 Path: X:\Jobs\3132 Blue Anchor Leisure\Junctions 9\2019-09-19 Updated 2019 Models Report generation date: 24/09/2019 13:42:27

»Existing Layout & West Moor Link - 2035 Do Min, AM »Existing Layout & West Moor Link - 2035 Do Min, PM

Summary of junction performance

AM PM Queue (PCU) Delay (s) RFC LOS Queue (PCU) Delay (s) RFC LOS Existing Layout & West Moor Link - 2035 Do Min

Arm 1 2.6 7.85 0.72 A 2.0 6.00 0.67 A Arm 2 0.1 6.15 0.07 A 0.1 5.31 0.08 A Arm 3 1.2 5.65 0.55 A 1.6 6.57 0.61 A Arm 4 2.3 4.24 0.70 A 1.5 3.25 0.61 A

There are warnings associated with one or more model runs - see the 'Data Errors and Warnings' tables for each Analysis or Demand Set.

Values shown are the highest values encountered over all time segments. Delay is the maximum value of average delay per arriving vehicle.

File summary

File Description

Title Location Site number Date 24/09/2018 Version Status (new file) Identifier Client Jobnumber Enumerator WEEZY\Modelling Description

Units Distance units Speed units Traffic units input Traffic units results Flow units Average delay units Total delay units Rate of delay units m kph PCU PCU perHour s -Min perMin

Analysis Options Vehicle length Calculate Queue Calculate detailed queueing Calculate residual RFC Average Delay Queue threshold (m) Percentiles delay capacity Threshold threshold (s) (PCU) 5.75 0.85 36.00 20.00

1 Generated on 24/09/2019 13:43:02 using Junctions 9 (9.5.0.6896)

Demand Set Summary ID Scenario name Time Period name Traffic profile type Start time (HH:mm) Finish time (HH:mm) Time segment length (min) Run automatically D8 2035 Do Min AM ONE HOUR 08:00 09:30 15 ü D9 2035 Do Min PM ONE HOUR 16:00 17:30 15 ü

Analysis Set Details ID Name Include in report Network flow scaling factor (%) Network capacity scaling factor (%) A2 Existing Layout & West Moor Link ü 100.000 100.000

2 Generated on 24/09/2019 13:43:02 using Junctions 9 (9.5.0.6896)

Existing Layout & West Moor Link - 2035 Do Min, AM

Data Errors and Warnings Severity Area Item Description Arm 1 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 2 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 3 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 4 - Roundabout Warning Geometry Effective flare length is over 30m, which is outside the normal range. Treat capacities with increasing caution. Geometry Arm 4 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout HV% is zero for all movements / time segments. Vehicle Mix matrix should be completed whether working in Warning Vehicle Mix PCUs or Vehs. If HV% at the junction is genuinely zero, please ignore this warning.

Junction Network

Junctions Junction Name Junction type Use circulating lanes Arm order Junction Delay (s) Junction LOS 1 untitled Standard Roundabout 1, 2, 3, 4 5.62 A

Junction Network Options Driving side Lighting Left Normal/unknown

Arms

Arms Arm Name Description 1 M18 Northbound 2 Holme Wood Lane 3 M18 Southbound 4 A630

Roundabout Geometry V - Approach road half- E - Entry width l' - Effective flare R - Entry radius D - Inscribed circle PHI - Conflict (entry) Exit Arm width (m) (m) length (m) (m) diameter (m) angle (deg) only 1 6.50 6.50 0.0 126.8 160.0 15.0 2 2.85 5.50 20.0 57.5 160.0 17.1 3 6.40 6.40 0.0 57.3 160.0 23.4 4 7.30 11.50 39.0 27.6 160.0 62.2

Slope / Intercept / Capacity

Roundabout Slope and Intercept used in model Arm Final slope Final intercept (PCU/hr) 1 0.528 2153 2 0.439 1537 3 0.505 2046 4 0.584 2848

3 Generated on 24/09/2019 13:43:02 using Junctions 9 (9.5.0.6896)

The slope and intercept shown above include any corrections and adjustments.

Traffic Demand

Demand Set Details ID Scenario name Time Period name Traffic profile type Start time (HH:mm) Finish time (HH:mm) Time segment length (min) Run automatically D8 2035 Do Min AM ONE HOUR 08:00 09:30 15 ü

Vehicle mix varies over turn Vehicle mix varies over entry Vehicle mix source PCU Factor for a HV (PCU) ü ü HV Percentages 2.00

Demand overview (Traffic) Arm Linked arm Profile type Use O-D data Average Demand (PCU/hr) Scaling Factor (%) 1 ONE HOUR ü 1093 100.000 2 ONE HOUR ü 39 100.000 3 ONE HOUR ü 695 100.000 4 ONE HOUR ü 1798 100.000

Origin-Destination Data Demand (PCU/hr) To 1 2 3 4 1 0 5 0 1088 From 2 6 1 10 22 3 2 22 0 671 4 975 31 752 40

Vehicle Mix Heavy Vehicle Percentages To 1 2 3 4 1 0 0 0 0 From 2 0 0 0 0 3 0 0 0 0 4 0 0 0 0

Results

Results Summary for whole modelled period Average Demand Total Junction Arm Max RFC Max Delay (s) Max Queue (PCU) Max LOS (PCU/hr) Arrivals (PCU) 1 0.72 7.85 2.6 A 1003 1504 2 0.07 6.15 0.1 A 36 54 3 0.55 5.65 1.2 A 638 957 4 0.70 4.24 2.3 A 1650 2475

4 Generated on 24/09/2019 13:43:02 using Junctions 9 (9.5.0.6896)

Main Results for each time segment

08:00 - 08:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 823 206 635 1818 0.453 820 738 0.0 0.8 3.595 A 2 29 7 1410 917 0.032 29 44 0.0 0.0 4.053 A 3 523 131 868 1607 0.326 521 572 0.0 0.5 3.309 A 4 1354 338 23 2834 0.478 1350 1366 0.0 0.9 2.419 A

08:15 - 08:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 983 246 760 1752 0.561 981 883 0.8 1.3 4.659 A 2 35 9 1688 796 0.044 35 53 0.0 0.0 4.732 A 3 625 156 1038 1521 0.411 624 684 0.5 0.7 4.009 A 4 1616 404 28 2832 0.571 1615 1634 0.9 1.3 2.954 A

08:30 - 08:45 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1203 301 930 1662 0.724 1198 1080 1.3 2.5 7.676 A 2 43 11 2063 631 0.068 43 65 0.0 0.1 6.123 A 3 765 191 1269 1405 0.545 763 837 0.7 1.2 5.594 A 4 1980 495 34 2828 0.700 1976 1998 1.3 2.3 4.204 A

08:45 - 09:00 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1203 301 931 1661 0.724 1203 1082 2.5 2.6 7.853 A 2 43 11 2070 628 0.068 43 65 0.1 0.1 6.153 A 3 765 191 1274 1402 0.546 765 839 1.2 1.2 5.650 A 4 1980 495 34 2828 0.700 1980 2005 2.3 2.3 4.242 A

09:00 - 09:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 983 246 762 1750 0.561 988 886 2.6 1.3 4.752 A 2 35 9 1697 792 0.044 35 53 0.1 0.0 4.759 A 3 625 156 1045 1518 0.412 627 687 1.2 0.7 4.049 A 4 1616 404 28 2832 0.571 1620 1644 2.3 1.3 2.982 A

09:15 - 09:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 823 206 638 1816 0.453 825 741 1.3 0.8 3.639 A 2 29 7 1418 914 0.032 29 44 0.0 0.0 4.069 A 3 523 131 873 1605 0.326 524 574 0.7 0.5 3.336 A 4 1354 338 23 2834 0.478 1355 1374 1.3 0.9 2.438 A

5 Generated on 24/09/2019 13:43:02 using Junctions 9 (9.5.0.6896)

Existing Layout & West Moor Link - 2035 Do Min, PM

Data Errors and Warnings Severity Area Item Description Arm 1 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 2 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 3 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 4 - Roundabout Warning Geometry Effective flare length is over 30m, which is outside the normal range. Treat capacities with increasing caution. Geometry Arm 4 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout HV% is zero for all movements / time segments. Vehicle Mix matrix should be completed whether working in Warning Vehicle Mix PCUs or Vehs. If HV% at the junction is genuinely zero, please ignore this warning.

Junction Network

Junctions Junction Name Junction type Use circulating lanes Arm order Junction Delay (s) Junction LOS 1 untitled Standard Roundabout 1, 2, 3, 4 4.89 A

Junction Network Options Driving side Lighting Left Normal/unknown

Traffic Demand

Demand Set Details ID Scenario name Time Period name Traffic profile type Start time (HH:mm) Finish time (HH:mm) Time segment length (min) Run automatically D9 2035 Do Min PM ONE HOUR 16:00 17:30 15 ü

Vehicle mix varies over turn Vehicle mix varies over entry Vehicle mix source PCU Factor for a HV (PCU) ü ü HV Percentages 2.00

Demand overview (Traffic) Arm Linked arm Profile type Use O-D data Average Demand (PCU/hr) Scaling Factor (%) 1 ONE HOUR ü 1092 100.000 2 ONE HOUR ü 50 100.000 3 ONE HOUR ü 782 100.000 4 ONE HOUR ü 1562 100.000

Origin-Destination Data

6 Generated on 24/09/2019 13:43:02 using Junctions 9 (9.5.0.6896)

Demand (PCU/hr) To 1 2 3 4 1 0 4 0 1088 From 2 15 2 17 16 3 2 14 0 766 4 974 12 552 24

Vehicle Mix Heavy Vehicle Percentages To 1 2 3 4 1 0 0 0 0 From 2 0 0 0 0 3 0 0 0 0 4 0 0 0 0

Results

Results Summary for whole modelled period Average Demand Total Junction Arm Max RFC Max Delay (s) Max Queue (PCU) Max LOS (PCU/hr) Arrivals (PCU) 1 0.67 6.00 2.0 A 1002 1503 2 0.08 5.31 0.1 A 46 69 3 0.61 6.57 1.6 A 718 1076 4 0.61 3.25 1.5 A 1433 2150

Main Results for each time segment

16:00 - 16:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 822 206 454 1914 0.430 819 744 0.0 0.7 3.282 A 2 38 9 1249 988 0.038 37 24 0.0 0.0 3.785 A 3 589 147 859 1612 0.365 586 427 0.0 0.6 3.504 A 4 1176 294 25 2834 0.415 1173 1421 0.0 0.7 2.164 A

16:15 - 16:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 982 245 543 1867 0.526 980 890 0.7 1.1 4.055 A 2 45 11 1494 881 0.051 45 29 0.0 0.1 4.307 A 3 703 176 1028 1526 0.461 702 511 0.6 0.8 4.361 A 4 1404 351 30 2831 0.496 1403 1700 0.7 1.0 2.521 A

7 Generated on 24/09/2019 13:43:02 using Junctions 9 (9.5.0.6896)

16:30 - 16:45 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1202 301 664 1802 0.667 1199 1090 1.1 2.0 5.930 A 2 55 14 1828 734 0.075 55 35 0.1 0.1 5.300 A 3 861 215 1257 1411 0.610 858 626 0.8 1.5 6.485 A 4 1720 430 36 2827 0.608 1718 2079 1.0 1.5 3.238 A

16:45 - 17:00 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1202 301 665 1802 0.667 1202 1091 2.0 2.0 6.000 A 2 55 14 1832 732 0.075 55 35 0.1 0.1 5.315 A 3 861 215 1261 1409 0.611 861 626 1.5 1.6 6.567 A 4 1720 430 36 2827 0.608 1720 2085 1.5 1.5 3.251 A

17:00 - 17:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 982 245 544 1866 0.526 985 892 2.0 1.1 4.104 A 2 45 11 1500 878 0.051 45 29 0.1 0.1 4.322 A 3 703 176 1033 1524 0.461 706 512 1.6 0.9 4.416 A 4 1404 351 30 2831 0.496 1406 1709 1.5 1.0 2.531 A

17:15 - 17:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 822 206 455 1913 0.430 824 747 1.1 0.8 3.311 A 2 38 9 1255 986 0.038 38 24 0.1 0.0 3.796 A 3 589 147 864 1609 0.366 590 429 0.9 0.6 3.533 A 4 1176 294 25 2833 0.415 1177 1428 1.0 0.7 2.176 A

8 Generated on 24/09/2019 13:49:39 using Junctions 9 (9.5.0.6896)

Junctions 9 ARCADY 9 - Roundabout Module Version: 9.5.0.6896 © Copyright TRL Limited, 2018 For sales and distribution information, program advice and maintenance, contact TRL: www.trlsoftware.co.uk The users of this computer program for the solution of an engineering problem are in no way relieved of their responsibility for the correctness of the solution

Filename: 03 J4 M18 With West Moor Link (no increase flare required).j9 Path: X:\Jobs\3132 Blue Anchor Leisure\Junctions 9\2019-09-19 Updated 2019 Models Report generation date: 24/09/2019 13:34:33

»With WML & Flare - 2028 With Dev, AM »With WML & Flare - 2028 With Dev, PM

Summary of junction performance

AM PM Queue (PCU) Delay (s) RFC LOS Queue (PCU) Delay (s) RFC LOS With WML & Flare - 2028 With Dev

Arm 1 7.8 22.78 0.90 C 2.6 7.67 0.73 A Arm 2 0.5 5.70 0.33 A 0.9 6.59 0.48 A Arm 3 2.8 10.54 0.74 B 2.9 10.97 0.75 B Arm 4 4.2 7.10 0.81 A 1.9 3.90 0.66 A

There are warnings associated with one or more model runs - see the 'Data Errors and Warnings' tables for each Analysis or Demand Set.

Values shown are the highest values encountered over all time segments. Delay is the maximum value of average delay per arriving vehicle.

File summary

File Description

Title Location Site number Date 24/09/2018 Version Status (new file) Identifier Client Jobnumber Enumerator WEEZY\Modelling Description

Units Distance units Speed units Traffic units input Traffic units results Flow units Average delay units Total delay units Rate of delay units m kph PCU PCU perHour s -Min perMin

Analysis Options Vehicle length Calculate Queue Calculate detailed queueing Calculate residual RFC Average Delay Queue threshold (m) Percentiles delay capacity Threshold threshold (s) (PCU) 5.75 0.85 36.00 20.00

1 Generated on 24/09/2019 13:49:39 using Junctions 9 (9.5.0.6896)

Demand Set Summary ID Scenario name Time Period name Traffic profile type Start time (HH:mm) Finish time (HH:mm) Time segment length (min) Run automatically D10 2028 With Dev AM ONE HOUR 08:00 09:30 15 ü D11 2028 With Dev PM ONE HOUR 16:00 17:30 15 ü

Analysis Set Details ID Name Include in report Network flow scaling factor (%) Network capacity scaling factor (%) A3 With WML & Flare ü 100.000 100.000

2 Generated on 24/09/2019 13:49:39 using Junctions 9 (9.5.0.6896)

With WML & Flare - 2028 With Dev, AM

Data Errors and Warnings Severity Area Item Description Arm 1 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 2 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 3 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 4 - Roundabout Warning Geometry Effective flare length is over 30m, which is outside the normal range. Treat capacities with increasing caution. Geometry Arm 4 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout HV% is zero for all movements / time segments. Vehicle Mix matrix should be completed whether working in Warning Vehicle Mix PCUs or Vehs. If HV% at the junction is genuinely zero, please ignore this warning.

Junction Network

Junctions Junction Name Junction type Use circulating lanes Arm order Junction Delay (s) Junction LOS 1 untitled Standard Roundabout 1, 2, 3, 4 12.01 B

Junction Network Options Driving side Lighting Left Normal/unknown

Arms

Arms Arm Name Description 1 M18 Northbound 2 Holme Wood Lane 3 M18 Southbound 4 A630

Roundabout Geometry V - Approach road half- E - Entry width l' - Effective flare R - Entry radius D - Inscribed circle PHI - Conflict (entry) Exit Arm width (m) (m) length (m) (m) diameter (m) angle (deg) only 1 6.50 6.50 0.0 126.8 160.0 15.0 2 3.65 7.50 20.0 57.5 160.0 17.1 3 6.40 6.40 0.0 57.3 160.0 23.4 4 7.30 11.50 39.0 27.6 160.0 62.2

Slope / Intercept / Capacity

Roundabout Slope and Intercept used in model Arm Final slope Final intercept (PCU/hr) 1 0.528 2153 2 0.499 1968 3 0.505 2046 4 0.584 2848

The slope and intercept shown above include any corrections and adjustments.

3 Generated on 24/09/2019 13:49:39 using Junctions 9 (9.5.0.6896)

Traffic Demand

Demand Set Details ID Scenario name Time Period name Traffic profile type Start time (HH:mm) Finish time (HH:mm) Time segment length (min) Run automatically D10 2028 With Dev AM ONE HOUR 08:00 09:30 15 ü

Vehicle mix varies over turn Vehicle mix varies over entry Vehicle mix source PCU Factor for a HV (PCU) ü ü HV Percentages 2.00

Demand overview (Traffic) Arm Linked arm Profile type Use O-D data Average Demand (PCU/hr) Scaling Factor (%) 1 ONE HOUR ü 1178 100.000 2 ONE HOUR ü 277 100.000 3 ONE HOUR ü 899 100.000 4 ONE HOUR ü 1964 100.000

Origin-Destination Data Demand (PCU/hr) To 1 2 3 4 1 0 90 0 1088 From 2 51 1 116 109 3 2 226 0 671 4 975 197 752 40

Vehicle Mix Heavy Vehicle Percentages To 1 2 3 4 1 0 0 0 0 From 2 0 0 0 0 3 0 0 0 0 4 0 0 0 0

Results

Results Summary for whole modelled period Average Demand Total Junction Arm Max RFC Max Delay (s) Max Queue (PCU) Max LOS (PCU/hr) Arrivals (PCU) 1 0.90 22.78 7.8 C 1081 1621 2 0.33 5.70 0.5 A 254 381 3 0.74 10.54 2.8 B 825 1237 4 0.81 7.10 4.2 A 1802 2703

4 Generated on 24/09/2019 13:49:39 using Junctions 9 (9.5.0.6896)

Main Results for each time segment

08:00 - 08:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 887 222 912 1671 0.531 882 771 0.0 1.1 4.538 A 2 209 52 1409 1265 0.165 208 385 0.0 0.2 3.404 A 3 677 169 966 1558 0.434 674 651 0.0 0.8 4.058 A 4 1479 370 210 2725 0.543 1474 1430 0.0 1.2 2.866 A

08:15 - 08:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1059 265 1091 1577 0.672 1055 923 1.1 2.0 6.859 A 2 249 62 1686 1127 0.221 249 461 0.2 0.3 4.096 A 3 808 202 1155 1462 0.553 806 779 0.8 1.2 5.474 A 4 1766 441 251 2701 0.654 1763 1710 1.2 1.9 3.824 A

08:30 - 08:45 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1297 324 1333 1449 0.895 1277 1127 2.0 7.1 19.000 C 2 305 76 2048 946 0.322 304 562 0.3 0.5 5.599 A 3 990 247 1400 1339 0.739 984 952 1.2 2.7 9.983 A 4 2162 541 307 2669 0.810 2153 2077 1.9 4.1 6.867 A

08:45 - 09:00 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1297 324 1339 1446 0.897 1294 1132 7.1 7.8 22.783 C 2 305 76 2067 937 0.326 305 566 0.5 0.5 5.699 A 3 990 247 1417 1330 0.744 989 956 2.7 2.8 10.538 B 4 2162 541 308 2668 0.810 2162 2098 4.1 4.2 7.102 A

09:00 - 09:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1059 265 1099 1573 0.673 1082 929 7.8 2.1 7.653 A 2 249 62 1715 1112 0.224 250 466 0.5 0.3 4.176 A 3 808 202 1180 1449 0.558 814 784 2.8 1.3 5.722 A 4 1766 441 253 2700 0.654 1775 1741 4.2 1.9 3.927 A

09:15 - 09:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 887 222 917 1669 0.531 891 775 2.1 1.1 4.649 A 2 209 52 1420 1259 0.166 209 388 0.3 0.2 3.430 A 3 677 169 974 1553 0.436 679 655 1.3 0.8 4.126 A 4 1479 370 211 2725 0.543 1481 1442 1.9 1.2 2.904 A

5 Generated on 24/09/2019 13:49:39 using Junctions 9 (9.5.0.6896)

With WML & Flare - 2028 With Dev, PM

Data Errors and Warnings Severity Area Item Description Arm 1 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 2 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 3 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout Arm 4 - Roundabout Warning Geometry Effective flare length is over 30m, which is outside the normal range. Treat capacities with increasing caution. Geometry Arm 4 - Roundabout Roundabout diameter is over 130m; roundabout should be treated as a Grade Separated and/or Large Warning Geometry Geometry Roundabout HV% is zero for all movements / time segments. Vehicle Mix matrix should be completed whether working in Warning Vehicle Mix PCUs or Vehs. If HV% at the junction is genuinely zero, please ignore this warning.

Junction Network

Junctions Junction Name Junction type Use circulating lanes Arm order Junction Delay (s) Junction LOS 1 untitled Standard Roundabout 1, 2, 3, 4 6.74 A

Junction Network Options Driving side Lighting Left Normal/unknown

Traffic Demand

Demand Set Details ID Scenario name Time Period name Traffic profile type Start time (HH:mm) Finish time (HH:mm) Time segment length (min) Run automatically D11 2028 With Dev PM ONE HOUR 16:00 17:30 15 ü

Vehicle mix varies over turn Vehicle mix varies over entry Vehicle mix source PCU Factor for a HV (PCU) ü ü HV Percentages 2.00

Demand overview (Traffic) Arm Linked arm Profile type Use O-D data Average Demand (PCU/hr) Scaling Factor (%) 1 ONE HOUR ü 1128 100.000 2 ONE HOUR ü 461 100.000 3 ONE HOUR ü 868 100.000 4 ONE HOUR ü 1633 100.000

Origin-Destination Data Demand (PCU/hr) To 1 2 3 4 1 0 40 0 1088 From 2 92 2 201 166 3 2 100 0 766 4 974 83 552 24

6 Generated on 24/09/2019 13:49:39 using Junctions 9 (9.5.0.6896)

Vehicle Mix Heavy Vehicle Percentages To 1 2 3 4 1 0 0 0 0 From 2 0 0 0 0 3 0 0 0 0 4 0 0 0 0

Results

Results Summary for whole modelled period Average Demand Total Junction Arm Max RFC Max Delay (s) Max Queue (PCU) Max LOS (PCU/hr) Arrivals (PCU) 1 0.73 7.67 2.6 A 1035 1553 2 0.48 6.59 0.9 A 423 635 3 0.75 10.97 2.9 B 796 1195 4 0.66 3.90 1.9 A 1498 2248

Main Results for each time segment

16:00 - 16:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 849 212 571 1851 0.459 846 802 0.0 0.8 3.568 A 2 347 87 1248 1345 0.258 346 169 0.0 0.3 3.598 A 3 653 163 1029 1526 0.428 651 565 0.0 0.7 4.098 A 4 1229 307 147 2762 0.445 1226 1532 0.0 0.8 2.339 A

16:15 - 16:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1014 254 683 1792 0.566 1012 959 0.8 1.3 4.605 A 2 414 104 1494 1223 0.339 414 202 0.3 0.5 4.446 A 3 780 195 1231 1424 0.548 778 676 0.7 1.2 5.564 A 4 1468 367 176 2745 0.535 1467 1834 0.8 1.1 2.813 A

16:30 - 16:45 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1242 310 836 1712 0.726 1237 1174 1.3 2.6 7.501 A 2 508 127 1826 1057 0.480 506 247 0.5 0.9 6.517 A 3 956 239 1505 1286 0.743 949 827 1.2 2.8 10.515 B 4 1798 449 215 2723 0.660 1795 2239 1.1 1.9 3.867 A

7 Generated on 24/09/2019 13:49:39 using Junctions 9 (9.5.0.6896)

16:45 - 17:00 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1242 310 838 1711 0.726 1242 1176 2.6 2.6 7.671 A 2 508 127 1832 1054 0.482 508 248 0.9 0.9 6.588 A 3 956 239 1510 1283 0.745 955 829 2.8 2.9 10.971 B 4 1798 449 216 2722 0.661 1798 2250 1.9 1.9 3.895 A

17:00 - 17:15 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 1014 254 686 1791 0.566 1019 962 2.6 1.3 4.696 A 2 414 104 1502 1219 0.340 416 203 0.9 0.5 4.494 A 3 780 195 1239 1420 0.550 787 679 2.9 1.2 5.744 A 4 1468 367 177 2744 0.535 1471 1849 1.9 1.2 2.835 A

17:15 - 17:30 Total Junction Throughput Start End Unsignalised Circulating Capacity Throughput Arm Demand Arrivals RFC (exit side) queue queue Delay (s) level of flow (PCU/hr) (PCU/hr) (PCU/hr) (PCU/hr) (PCU) (PCU/hr) (PCU) (PCU) service 1 849 212 574 1850 0.459 851 805 1.3 0.9 3.609 A 2 347 87 1255 1342 0.259 348 170 0.5 0.4 3.623 A 3 653 163 1035 1523 0.429 655 568 1.2 0.8 4.159 A 4 1229 307 148 2762 0.445 1231 1543 1.2 0.8 2.355 A

8

Appendix D

Colour-coding by SEVERITY Total Accidents (67) Fatal (1)  Serious (8) Slight (58)

Total Casualties (100) Fatal (1) Serious (10) Slight (89)

A-00897-15 1673111 Reproduced from the Ordnance Survey mapping with the permission of the Controller of Her Majesty's A-01442-14 A-01293-13 Stationery Office © Crown copyright. Unauthorised 1637560 A-01168-15 reproduction infringes Crown copyright and may lead to 18289330 133667 prosecution or civil proceedings. Rotherham MBC Licence A-00717-14 16110163 No. 100019587. 18291135 South Yorkshire LTP Partnership 18286288 A-01440-14 1662562 Licence No: 100019587 2018 A-01230-13 A-01661-15 A-00142-15 A-01627-14 A-00157-15 A-01975-15 17240445 A-01713-15 16128872 A-00180-13 A-01732-15 A-00115-13 A-01620-14 A-00534-14 17218239 17163058 18311724 A-01605-14 17253630 16112586 A-01272-15 A-00929-15 A-00692-13 A-01298-15 1687314 A-00033-15 1660236 A-00996-14 A-01008-14 A-01139-13 A-00115-14 17241804 17254385 16143393 17254817 A-00570-14 A-00175-14 A-00347-15 A-01757-15 A-00172-13 A-00239-14 A-01052-15 17227517 Her Majesty's Office (c) Crown Copyright. 17246954 Unauthorised reproduction infringes Crown 16138927 Copyright and may lead to prosecution or civil proceedings. 1699599 A-01459-13

17227785 A-00032-15 A-01193-13

A-01072-14

18275617

17216220

DRAWING TITLE 5 Year Collision Search Armthorpe, Doncaster

SCALE NTS

DATE 03/10/2018

DWG No. 46002/296/NJA

DRAWN BY

Fore Consulting Limited 2nd Floor, Queens House Wellington Street Leeds LS1 2DE

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Review of the Doncaster Publication Draft Local Plan 2015- 2035

In respect of

Site Reference 937/1031 West Moor Park East Holme Wood Lane Armthorpe Doncaster

By

Dove Haigh Phillips LLP 11 Park Square East Leeds LS1 2NG

On behalf of

Blue Anchor Leisure Ltd

30 September 2019

Contents

Report

1.0 Qualifications and Experience 3 2.0 Instructions 4 3.0 Background 5 4.0 Site Characteristics 6 5.0 Publication Draft Local Plan Employment Aspirations 8 6.0 Market Conditions 9 7.0 Analysis of Available Sites 14 8.0 Assessment of the Site 20 9.0 Summary and Conclusions 23

Appendices

Appendix 1 Location Plan - Subject Site Appendix 2 Market Assessments of Sites with Draft Allocations

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 2 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

1.0 Qualifications and Experience

1.1 Dove Haigh Phillips LLP are a firm of Chartered Surveyors and Property Consultants which were formed in 2006. The founding Members were all previously Partners at Knight Frank, operating out of the Leeds office.

1.2 The firm advises owner managed businesses, publicly quoted companies, public bodies, property companies, banks and other financial institutions on the viability, procurement and appraisal of commercial development land and property in the Yorkshire region.

1.3 In particular, the firm advises on the development, letting, sale and acquisition of a wide number of industrial and distribution buildings and industrial development land of varying size and purpose throughout the motorway corridors of the Yorkshire region including Doncaster over the past 13 years. This is particularly relevant due to the change in market conditions and dynamics which have influenced this sector of the property market which is specifically relevant to the subject site.

1.4 Dove Haigh Phillips therefore have the appropriate experience and qualifications to provide an objective review of the allocation of employment sites for this purpose in respect of the Publication Draft Local Plan Site Assessments Doncaster Local Plan in the context of the subject site and its current status as a non allocated site.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 3 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

2.0 Instructions

2.1 We have been instructed by Blue Anchor Leisure to undertake an objective review of sites which have been allocated for employment purposes in the Draft Local Plan, including sites with draft allocations and sites with planning permission already granted, together with a review of the evidence base and other accompanying plans and documents.

2.2 These instructions have been provided against the background of a non-allocated status for the subject site by Doncaster Metropolitan Borough Council (DMBC). This report provides an assessment of the subject site, together with a market overview for employment land and considers the suitability of the site against those which have either been granted planning permission or been provided with a draft allocation.

2.3 The summary assessment by DMBC why the site has not been allocated are as follows;

 The site fails flood risk sequential test as it is within flood Zone 3;  The site scores similarly to other sites within the Council’s Sustainability Appraisal process;  The site is currently within a defined Countryside Policy Area;  There is already a substantial amount of employment land within the Armthorpe Parish;  The site is to the east of the M18 and more isolated than other options available;  Other options are directly adjacent to the Main Urban Area and main towns that offer better opportunities for sustainable development such as long term public transport access;  There are concerns over vehicular access from Junction 4; and  Sites other than this one have been chosen for allocation in order to provide a balanced distribution of employment land across the Borough.

2.4 Blue Anchor Leisure do not agree with the rejection of their site for non-allocated status and therefore this report considers the suitability of the site against the Councils ambition for a sustainable and deliverable supply of employment land over the plan period, market conditions and forces which are relevant to the suitability of the site, and analysis of other potential employment sites (relevant to the draft allocations and permissions granted). This allows a suitable assessment of the site with an appropriate summary and conclusions.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 4 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

3.0 Background

3.1 The site is located adjacent to Junction 4 of the M18 motorway, approximately 6 miles north east of Doncaster town centre.

3.2 The site is located within the UDP Countryside Policy Area, along with all other land outside the built up areas that is not Green Belt. In fact it is not truly countryside from a practical point of view however, as it has existing planning history for motorsport and leisure uses and consent for these uses have been part implemented.

3.3 West Moor Park East has been promoted for employment uses and has received expressions of interest from the market for this use.

3.4 It comprises a significant area of land which can provide comprehensive and cohesive development which is in the control of two landowners who are working together to promote the combined areas of land as a comprehensive development opportunity.

3.5 The site has been submitted for an allocation for employment use, although this has been rejected for a number of reasons set out in 2.3.

3.6 This report demonstrates that the subject site should be included as an allocated site as it is in fact one of the most suitable sites for future employment use over the plan period.

3.7 This is following our assessment of the sites which have been given an allocation in the Publication Draft Local Plan. We identify that there is doubt over the suitability and deliverability of these sites from a market perspective and that there is likely to be a shortfall in meeting the Plan's requirement.

3.8 The analysis therefore has regard to the site characteristics, relevant planning policy, competing sites, existing and draft allocations, together with current property market conditions; the latter of which is particularly important in terms of the ultimate delivery of employment land.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 5 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

4.0 Site Characteristics

4.1 The site is located adjacent to the M18 motorway, with access less than ¼ mile from Junction 4. This is an excellent strategic location for the national motorway network and for an occupier seeking representation in this location, the site would be regarded as a prime location benefitting from access to major communication links.

4.2 The site is approximately 6 miles to the north east of Doncaster Town centre and lies approximately 1 ½ miles to the north east of Armthorpe town centre.

4.3 For a variety of reasons, and not only cost, proximity to motorway networks is of paramount importance to major employment occupiers in the current market.

4.4 In addition to transport network communications, occupiers are also concerned with the availability of a suitable labour pool and thus proximity to the local population/workforce is an important factor and there is an important desire to satisfy both these criteria. Sanderson Associates (appointed to undertake transportation and highways advice on behalf of Blue Anchor Leisure) consider that the Councils Sustainability Appraisal is incorrect both in respect of the sites which have been granted an allocation and also in respect of the subject site.

4.5 Their findings confirm inter-alia that there is a large residential population within the vicinity of the subject site which will help to minimise travel to work distances, and that the Council reasons not to allocate the site on accessibility grounds are incorrect as the site compares favourably with all of the Councils preferred employment site allocations.

4.6 The adjacent West Moor Park to the west of Junction 4 is already an established distribution location. It is without doubt one of the two most successful employment locations on the M18 with significant occupiers including Ikea, Next, ABP Foods and Fellowes Distribution. West Moor Park has built development extending in excess of 232,255 sq m (2,500,000 sq ft) and according to HGV isoschrone statistics, 33.8 million population of working age can be reached within a 4.5 hour drive. This is particularly relevant because it confirms the suitability of the this location for development . It is a ‘tried and tested’ location which is important to secure confidence from the market to deliver further investment in the Doncaster region. The site has direct access to a motorway junction and access to an available labour pool. It is our opinion that a number of the Councils preferred sites do not satisfy this criteria.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 6 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

4.7 The site is also well located for access to the east coast ports including Goole, Immingham, Hull and Grimsby. The three regional international airports of Doncaster/Sheffield, Humberside and Leeds/Bradford are also within range of this location.

4.8 Since the October 2018 Local Plan, Blue Anchor Leisure have taken the opportunity to engage with the adjacent landowner of sites 938/1014; Vigo Group. Vigo Group have also confirmed willingness to promote their land together with the subject site in order to present a proposal for comprehensive development. As such, the potential development area of West Moor Park East now extends to 88.54 hectares.

4.9 With the benefit of the existing infrastructure network, proximity to Junction 4 of the M18 Motorway the existing developed area of West Moor Park on the opposite site of the Junction 4 and accessibility to an existing labour pool this is a very sustainable location for employment use.

4.10 A location plan of the site is set out within Appendix 1.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 7 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

5.0 Publication Draft Local Plan Employment Aspirations

5.1 Policy 3 of the Publication Draft Local Plan identifies the need for at least 481 hectares of employment land over the plan period – 2015-2035.

5.2 The land requirement identified is based on the Economic Forecasts and Housing Needs Assessment (Peter Brett Associates, May 2018) and an Employment Land Need Assessment (ELNA 2019). We have also considered the Doncaster Employment Land Review prepared by Colliers International in February 2018 which has formed part of the evidence base for the Local Plan.

5.3 We have considered a report prepared by Hatch Regeneris to review the Doncaster Employment Land Evidence and reference to the documents which form the basis of this review. Within these documents, the ELNA Update 2019 updated the land need from 2015 on a pro-rata basis and adjusting figures by use class, the implied requirements are as follows;

 Offices (B1) – 14ha  Industrial (B2) – 125ha  Non-strategic warehousing (B8) – 73ha  Strategic warehousing – (B8) 271ha

5.4 It is therefore very evident that by far the overwhelming land requirement is for B8 with a combined total between of non-strategic and strategic warehousing of 344ha, reflecting 71.5% of the total employment land need in the plan period. Hatch Regeneris undertook further analysis on the Councils approach and their findings demonstrated a slightly higher need for warehousing as follows; 75ha for non-strategic warehousing and 278ha for strategic warehousing. They therefore concluded that the Councils estimates by Use Class represent a sound basis for planning purposes. In our opinion, this confirms the need for prime, well located employment land.

5.5 This is therefore a very relevant factor in the selection of sites from a market perspective in respect of the land need for warehousing. Due to the costs of construction for buildings, ground works, on site and off site infrastructure works, sites which are suitable for development (in particular strategic warehousing) need a certain scale in order to sustain economic development. Therefore, sites which are identified for employment also have to be capable of delivering development, which not only meets a need ‘throughout the Borough’ but must be economically viable. This is in addition to proximity to high profile locations which are readily accessible from the major transport networks and to a labour pool.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 8 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019 Mark6.0 Market Conditions

6.0 Market Conditions

Economic and Financial Overview

6.1 A snapshot overview of the UK Economic is set out below

Bank Base Rate 0.75%

UK LIBOR (12 months) 1.17%

CPI (Inflation) August 2019 1.70%

GDP to Q2 2019 - 0.20%

6.2 The UK is set to leave the European Union at some point in the future. At present, there is political uncertainty surrounding how the exit will proceed. To date, we have not noted any significant impact on the residential or commercial property markets in the region specifically due to this factor.

6.3 However, if the proposed exit and / or method of exit leads to an economic downturn or has a direct influence on any other factors which may cause market instability, this could have an impact on commercial and residential property markets. This confirms our view that prime sites must be considered as primary choices for land allocations. In the event of any future changes to market conditions, only prime sites will be those which will be capable of being developed and this is a fundamental feature of the subject site.

6.4 This is particularly relevant for Doncaster as it competes on a sub / regional market basis, not only within the confines of the Borough but including neighbouring markets in West and South Yorkshire, for example the M62 and M1 motorway corridors between Leeds, Sheffield, Wakefield and Doncaster. If Doncaster cannot offer a suitable choice of prime sites to occupiers, investors/developers, then it will not be able to compete on a regional basis, especially when prime sites are those which will only be considered by the market.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 9 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

National Market Overview

6.5 The market for industrial buildings has evolved significantly since the late 1990s. Many occupiers traditionally associated with distribution units of 100,000 sq ft+, (including manufacturers, retailers and specialist 3rd party distribution companies) have restructured their strategy for warehouse occupation. A significant number of corporate occupiers have commenced programmes to consolidate their property distribution locations throughout the UK.

6.6 The factors associated with consolidation, such as improved fluidity of logistics, savings of labour costs and general economies of scale have becoming increasingly important in a competitive market seeking to maximise efficiency of all resources. In addition, the advent of e-tailing in the retail markets over the past 10 years have had and will continue to have a significant impact on occupiers requirements in large scale buildings.

6.7 These factors have led to an emergence of well located, motorway orientated single distribution units of 100,000+ sq ft which have become increasingly popular over the past 20 years. Locations traditionally favourable for large scale distribution centres have included the prime sites around London (M25) and the area of the East Midlands known as the Golden Triangle.

6.8 However, elsewhere throughout the UK, other regional motorway corridor locations have also been able to attract occupiers, albeit at more conservative levels of rent and cost. Therefore, the majority of occupiers have sought to achieve a balance between distribution logistics and costs of occupation and operation. This has included areas such as Doncaster which is now regarded as a major location for distribution occupiers.

6.9 As a result of the increase in demand from the early part of the millennium, developers have responded to market demand by a combination of build to suit and speculative development in order to capitalise on the opportunities of the market. The market continues to be buoyed by a variety of participants including traditional logistics developers, institutions/funds speculative funding schemes and an emergence of new property company entrants into the market.

6.10 With healthy levels of demand and sector-wide confidence, one of the significant restrictions on delivery is the availability of deliverable sites in the right location.

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Doncaster Market Overview

6.11 Doncaster has emerged to compete with the more historic established distribution locations due to its excellent transport links, proximity to airports and the east coast ports.

6.12 In addition, occupiers are attracted to Doncaster due to the availability of an economic labour pool and competitive value for leasehold and freehold property terms. Doncaster is strategically located at the intersection of the A1(M) and the M18. It straddles the East Coast Mainline and boasts its own international airport. Doncaster has established three major employment and logistics hubs along its motorway corridor. These are as follows;

 West Moor Park J4 M18,  iPort J3 M18 and;  Redhouse Interchange J38 A1M.

6.13 Demand for Doncaster as employment location and in particular for B8 use has been demonstrated by the calibre of occupiers which have committed to the location over the past 10 years.

Occupier Requirements

6.14 Occupiers will seek to achieve market terms which reflect the size and specification of accommodation required with these six key criteria:-

i) Proximity to affordable labour pool and markets. ii) Strong communication links for goods/HGVs and workforce, and access to motorway networks. iii) A high profile environment including proximity to similar quality property and efficient infrastructure and naturally advantageous topography and security. iv) An efficiency of design to embrace new technologies with full consideration given to the cost of operation for more factors influencing occupation and function of the property. v) The initial cost of the development and/or ongoing operational costs. vi) Certainty of delivery and timing

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 11 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

6.15 The specification of property suitable for distribution has also evolved in order to achieve maximum efficiency on any particular site and a minimum standard specification in the current market would be regarded as follows:-

i) Minimum eaves height of 10 metres. ii) Dock loading doors commensurate with size of unit. iii) A number of level access doors in addition to the above. iv) 50 Kn per sq m floor loading. v) High bay lighting, heating and sprinkler systems. vi) Yard depth of 40 metres/50 metres. vii) Site density layout of 40% footprint cover.

6.16 Sites must therefore have the ability to be developed to accommodate this type of specification and of critical importance is the ability to accommodate a critical mass in a particular location which will justify the cost of initial infrastructure (which can be considerable) in order to open up land to facilitate sustainable and economically viable development.

Summary

6.17 Since the start of the millennium there has been a changed pattern in distribution requirements with occupiers consolidating their operations into buildings of 100,000+ sq ft, the majority of which being located in prime locations adjacent to motorway networks. Building design has evolved to create efficient costs of occupation although other factors including proximity to labour are a key consideration for distribution occupier requirements.

6.18 It is our considered view that the subject site would be regarded as a prime site for employment use due to its proximity to Junction 4 of the M18 and ability to deliver suitable accommodation for current occupiers requirements.

6.19 West Moor Park East can readily satisfy each of the six points identified above;

i) it is within close proximity of readily available labour pool at Armthorpe with adequate transport connectivity. It is also directly adjacent to West Moor park which is a proven employment location; ii) It is directly adjacent to Junction 4 of the M18 including frontage to the slip road exit; iii) The scale of the site will allow for economic development to provide a high quality environment without any prohibitive site constraints;

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iv) Any development on site will be capable of embracing efficiencies of design and technology; v) The initial cost of development can be absorbed due to the ability of the site to accommodate a large format building and; vi) There is a collaborative approach between just two landowners across a site of 88.54 hectares

6.20 The Doncaster Employment Land Review prepared by Colliers International for the Council states that investors will look to satisfy both macro and micro level factors in relation to sites. Any site identified for employment use needs a large workforce in reasonable proximity and for many occupier customers, an available, skilled and mobile workforce is a pre-requisite. Therefore, close proximity to existing investment and operations is a key factor when successful companies are considering expansion and relocation. This is because the retention of existing workforce is a primary consideration. Existing industrial and distribution hubs have a natural advantage over emerging locations. This is particularly important when those hubs can demonstrate three of the fundamental characteristics set out as above;

i) Proximity to affordable labour pool and markets. ii) Strong communication links for goods/HGVs and workforce, and access to motorway networks. iii) A high profile environment including proximity to similar quality property and efficient infrastructure and naturally advantageous topography and security.

The statements set out in i), ii) and iii) in paragraph 6.19 above demonstrate that West Moor Park East can readily satisfy the 3 key criteria.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 13 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

7.0 Analysis of Allocated Sites

7.1 The Employment Land Need Assessment (2019) identifies that there is a requirement of 481 hectares of Employment Land over the plan period 2015 – 2035 for Use Classes B1, B2 and B8.

7.2 From the total requirement of 481 hectares, sites with planning permission total 318 hectares (23 sites) and the balance has been identified from proposed sites with draft allocations; 164 acres (6 sites). This would provide a total of 482 hectares.

7.3 Of the consented sites, it is stated that 118 hectares have been developed out whilst those with planning permission and are undeveloped total 201 hectares. It is acknowledged that these sites are suitable to come forward for development, although we do raise the question whether these sites will deliver what the Council aspires to deliver and we make further comments on this aspect at the end of this section.

7.4 The focus of the analysis of our review is therefore on the sites which have been given a draft allocation. These are as follows;

Land Available Contribution Site Gross Site Site Name Employment towards Local Ref Area (ha) Use (ha) Plan (ha)

001 Jnc 6 M18 North- Thorne 73.63 73.63 51.54

092 Balby Carr Bank, Balby 11.25 11.25 8.60

Plot 1 Lakeside, Potteric 258 8.48 5.00 5.00 Carr Road

441 Land at Carcroft Common 49.28 24.64 12.32

878 / Site A, East of Bankwood 17.68 17.68 17.68 1032 Lane, Rossington Site 2, Land East of 941 68.54 68.54 68.54 Poplars Farm, Auckley

Total 164

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 14 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

7.5 The Council state that there is a requirement of at least 481 ha within the plan period. Therefore, looking at the total of the consented sites (318 ha) and the those with a draft allocation (164 ha as above), this provides the total of 482 ha. Our immediate reaction is that (with the exception of 1 ha), this does not provide for any contingency in an allocation of sites throughout the plan period; i.e. there is no buffer or reserve capacity to meet the at least land requirement. Sites that are not allocated in the plan will not flexibly be able to provide a reserve for unforeseen events due to policy constraints.

7.6 Therefore we have undertaken a detailed review of the Employment Site Conclusions (in particular Table 9.27), The Colliers ‘Doncaster Employment Land Review’ prepared in February 2018, and we have also undertaken physical inspections of the sites with the draft allocations as identified in the table above. We have considered the salient characteristics of the sites under a number of criteria and also adopted our own assessment of the realistic market approach to the sites; i.e. how would the market, both in terms of occupiers and developers / investors perceive these sites as realistic opportunities.

7.7 In Appendix 3 we set out detailed site proformas with our considered opinion on each of the sites from a market perspective. This approach focusses on how we consider the ‘market’ would view the sites, i.e. are they realistically suitable, available and achievable in order to deliver buildings suitable for employment over the Local Plan period. Our summary conclusions for each of the sites are as follows;

Local Plan Ref 001 – Junction 6, M18 Thorne North 7.8 This site is situated adjacent to Junction 6 of the M18, approximately 5 miles north of the subject site. Current occupiers in this location include BMW, and The Range. There are also a number of smaller units which have been developed at Capitol Park. These buildings have been developed over a 20 year period and in this regard, Thorne cannot be considered as an established distribution hub; the pace of delivery in this location has been more piecemeal than other locations and buildings have taken longer to come forward and secure occupiers..

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 15 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

7.9 The Colliers Employment Land Report also confirms (Page 22, Section 4.1 – para 5) that the site is ‘ more remote’ location from the main urban area of Doncaster than some of the other LP review sites. This is one of the key considerations we consider vital to the sustainability of sustainable development, i.e. proximity to an available labour pool. Colliers also state that they would anticipate only 50% of the entire site (which equates to 73.63ha) could be developed out within the plan period, thus equating to a net contribution of 36.8ha . This is at odds with the stated contribution towards the Local Plan Requirement of 51.54 hectares. In particular, we note that in the ‘Doncaster Employment Land Review – amendments to be made in light of the Local Plan Informal Consultation Stage undertaken in September-October 2018’, Colliers state again that they only anticipate 36.8ha is likely to be developed out in the plan period (this is despite some negative commentary being deleted from the site description).

7.10 From a market perspective, we therefore have to question the reality of the amount of land which could be developed within the plan period, and if adopting Colliers estimate, this could leave a shortfall of 14.74 hectares attributable to this site (51.54 as per LP contribution – 36.8ha as per Colliers estimate = 14.74 hectares).

Local Plan Ref 092 – Balby Carr Bank 7.11 This site has a more modest LP contribution of 8.6 ha. It is located in an established industrial location, approximately 1 mile south of Doncaster town centre, however, access is poor.

7.12 From a market perspective, the site is likely to provide land suitable for small format buildings with improvements required to achieving better access to Balby Carr Road, and from surrounding residential areas.

Local Plan Ref 441 – Carcroft Common, Carcroft 7.13 This site is located immediately adjacent to the east of Bentley Moor Industrial Estate area. The proposed allocation is 12.32ha and the site could be capable of supporting smaller format buildings. We do not consider that this is a strategic warehouse location as it is too remote from major transport infrastructure.

7.14 However, it is clearly stated in the Doncaster Employment Land Review that the site requires major road infrastructure investment to open it up for development. Sanderson Associates conclude that the delivery of the A1-A19 link road cannot be relied on and there are significant barriers to the delivery of the scheme during the Local Plan Period. In summary, they state that “Delivery of these draft transport interventions should not be relied upon for planning and development purposes’.

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7.15 Therefore in light of the conclusion above and from a market perspective, we consider that this land is particularly vulnerable and the inclusion of it for the Local Plan is incorrect. Therefore, the 12.32ha should not be included in the LP requirement.

Local Plan Ref 258 – Plot 1, Lakeside, Potteric Carr Road 7.16 This is also a modest site, with an allocation of 5ha towards the LP contribution. It is set in the Lakeside employment area with occupiers nearby including Tesco, Royal Mail and a number of trade counter type occupiers.

7.17 This site is actually located at the junction of Middle Bank and Stadium Way, not Potteric Carr Road. ‘XP’ occupy two buildings on the site, the remainder of which is linear in nature and would potentially be suitable for small scale development B1 / B2 use.

Local Plan Ref 878 / 1032 – Site A, East of Bankwood Lane, Rossington 7.18 This site is located around 4 ½ miles south west of Doncaster town centre, with a fairly circuitous route off the Great Yorkshire Way. It is adjacent to mixed industrial / commercial accommodation and also residential.

7.19 This site is occupied by Tanks and Vessels industries. It is a developed area and even if there is an intention for this occupier to relocate, which we are not aware of, it does not provide any net gain as the relocation site will come out of supply somehow. The proposed contribution to the LP requirement is 17.68 hectares, but it is our view this must be discounted because it is already in heavy industry use.

Local Plan Ref 941 - Site 2, Land East of Poplars Farm, Hurst Lane, Auckley 7.20 This is an extensive site, with a significant proposed allocation of 68.54ha towards the LP requirement. It is located in close proximity to Doncaster-Sheffield Airport which is served by Great Yorkshire Way. However the site is situated in the south west quadrant of the airport area and is only proximate to a single carriageway road and is remote from a motorway junction.

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7.21 It is our opinion from a market perspective that development of this site will be contingent on the growth of the airport and airport related businesses. It is also adjacent to site LP Ref 517 (Safeguarded Cargo Area) which extends to 44.05 hectares. That adjacent site does not count to the LP requirement as it is for air related needs. Nevertheless, the aggregate of these sites is a combined area of 112.59 ha, which is large area of land available in this location. Looking solely at the LP Ref Site 941, we consider that this has similar characteristics to site LP Ref 001 insofar as it is remote from the urban area (and in particular remote from direct proximity to a motorway junction). We are therefore surprised that the Employment Land Review does not make similar comments in respect of the realistic amount of land which would come forward in the plan period (i.e. a realistic amount being 50%). We consider that this factor has been overlooked in respect of this site due to its characteristics (it does not readily or easily satisfy the 6 criteria we have identified) and therefore the reality of this land being available or capable of satisfying the land requirement in the plan period has to be questioned. With a more realistic approach view that 50% of this site is appropriate, then this would leave a shortfall of 34.27 hectares attributable to this site.

Sites with Employment Planning Permissions 7.22 There are 23 sites identified which have an existing employment permission (as at 31/03/2018). These range from sites which are anticipated to provide a Local Plan contribution of 0.74ha to 158.00ha. Within this range, there are only 3 sites in excess of 30.00ha, and these are the sites which we consider would be most suitable for B8 development. These are as follows;

 Site Ref 418 – Unity (DN7); 33.60ha  Site Ref 747 – iPort, Rossington; 158.00ha  Site Ref 1099 – West Moor Park Extension; 30.42ha

7.23 The aggregate land within these sites is therefore 222.02 hectares and below the total required for strategic warehousing alone (273ha) and well below the total required for non-strategic and strategic warehousing combined (344 ha), based on the evidence base that underpins the Councils case for 481 ha overall.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 18 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

7.24 It is acknowledged that the balance of supply for the B8 need should be met partly from other sites with existing permissions which can accommodation non-strategic warehousing and also from the sites which have been granted the draft allocation. However, if any of supply of the land which has been granted permission is at risk of being restricted, constrained, or for any other reason, unable or incapable of being developed, this could also prevent an adequate supply of land being met. For example a modest reduction of 10% of the land with permission would result in a reduction of supply of an additional 20.95ha, and we consider that the lack of any contingency supply must be considered as a real possibility, in addition to our conclusions from the sites which have been provided with a draft allocation.

Summary

7.25 Following our review of the sites identified, it is clear that there is a shortfall of the target of at least 481ha of employment land identified by the Council required to satisfy the land need over the plan period.

7.26 This is evidenced by the fact that Site Ref 878 / 1032 – Site A, East of Bankwood Lane, Rossington is already in use and does therefore not provide any further net contribution. We conclude that this is a reduction of 17.68 hectares from the plan total.

7.27 We also cast doubt on the ability of Sites Ref 001 (Junction 6 M18 Thorne) and 941 (Site 2 Lane East of Poplars Farm, Hurst Lane Auckley) to deliver the amounts of land identified for the reasons set out above. This would leave a further shortfall of 14.74ha and 34.27ha respectively (combined 49.01ha)

7.28 The land identified from Site Ref 441 (Carcroft Common) extending to 12.32 ha should be removed because of the uncertainty of the delivery of new infrastructure upon which it is reliant.

7.29 In addition, even a nominal non delivery reduction on the supply of land with planning permission could also reduce supply by 20.95ha. The aggregate shortfall would therefore be a combined total of 99.96ha from the identified need of employment land.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 19 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

8.0 Assessment of the Site

8.1 The suitability of the site is now assessed in terms of its market appeal having regard to its suitability for employment use which is driven by the demand of current occupier requirements and its key criteria.

8.2 Section 6.14 of this report, set outs the key criteria necessary for occupiers to make strategic decisions for their distribution requirements. I now address these directly in relation to the subject site.

8.3 We assess the site in detail following the same criteria we have adopted for the sites with the draft allocations which are set out in Appendix 3;

 Gross Site Area / Potential Local Plan Contribution.

The site has the potential to contribute a gross area of a gross area of 88.54ha This is therefore a significant amount of land which can make a valuable contribution to the supply of employment land to the Local Plan contribution.

 Suitability.

Macro Location The site has unrivalled access to the motorway network being adjacent to Junction 4 of the M18, approximately 5 miles north east of Doncaster town centre, but more importantly on the opposite side of the motorway from West Moor Park which is a proven and established employment location. None of the other sites with a draft allocation can demonstrate all of these fundamental characteristics.

Micro Location The site has direct frontage to the M18 including the south bound exit slip road and frontage from the Junction 4 roundabout into the site.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 20 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

Proximity to Markets and Labour The site is located close to existing built development extending to in excess of 2,500,000 sq ft of large format buildings and several other smaller units. Occupiers, developers and investors are attracted to sites and locations which have a proven track record of delivering sustainable development over may economic cycles. The site has close proximity to the labour pool of Armthorpe and whilst on the opposite side of the roundabout from West Moor Park, it is ranked second out of 5 sites within an assessment of the residential population within an 8km travel distance as assessed by Sanderson Consulting Engineers. Therefore this will allow development at the site to contribute to minimising travel to work distances (irrespective of any bus improvements which would also provide access to a significant workforce via extension of the No.15 service)

 Availability The entire site is with two ownerships who are collaborating to promote the land for comprehensive development. Vacant Possession can be delivered at short notice. All the land necessary to deliver enhanced local improvement off site to the highway is either within public highway ownership of the existing land owners.

 Achievability Due to a combination of the key characteristics above, high quality development on this site is eminently achievable.

 Concluding Comments We refer to the six key occupier criteria set out Section 6.13 above;

i) Proximity to affordable labour pool and markets. ii) Strong communication links for goods/HGVs and workforce, and access to motorway networks. iii) A high profile environment including proximity to similar quality property and efficient infrastructure and naturally advantageous topography and security. iv) An efficiency of design to embrace new technologies with full consideration given to the cost of operation for more factors influencing occupation and function of the property. v) The initial cost of the development and/or ongoing operational costs. vi) Certainty of delivery and timing

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 21 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

8.4 The site clearly satisfies the first two criteria due to its macro and micro location. It occupies a prime location within close proximity of an available workforce (and none of the other sites with allocations can satisfy these two most important criteria). There are no reasons why development on site would not satisfy criteria iii) and iv) and criteria v) can be satisfied due to the scale of the site and vii) due to the ownership of the land.

8.5 In view of the above assessment, we conclude that the site is a prime opportunity for an employment land allocation. In its own right it fundamentally satisfies the key criteria we have identified which are essential for prospective occupiers. However, it is our considered opinion that the West Moor Park East site has significantly more appeal to the market than the other sites which have been provided draft allocations, and is therefore far more likely to be able to respond to occupier and developer requirements seeking a presence in the Doncaster Market.

8.6 Therefore, and having regard to a consistent form of assessment, the site occupies an excellent strategic location both from occupiers and workforce perspective, it is capable of providing a high quality design which would be in keeping with the adjacent environment on the opposite side of the Junction 4 roundabout, this is a very sustainable location for development, and this site is capable of delivery in the short term.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 22 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

9.0 Summary and Conclusions

9.1 West Moor Park East occupies a prime strategic location adjacent to Junction 4 of the M18 and on the opposite side of the roundabout junction to West Moor Park. Major occupiers have proven confidence in this location, with representation from Next, Ikea, Fellowes and a number of other well-known companies.

9.2 The site has not been allocated in the Publication Draft Local Plan, with a number of reasons cited, although including statements that the “…site is more isolated than other options… better options for sustainable development….concerns over access from Junction 4..” and “other sites chosen to provide a balanced distribution of employment land across the borough..”

9.3 We do not consider that there has been adequate testing and assessment of the subject site and the other sites which have been given draft allocations from a market perspective; i.e. where will occupiers and investors / developers commit in order to achieve the anticipated outputs required.

9.4 In order to deliver future sustainable growth and “property” development, only prime sites will be capable of attracting occupiers and funding in order to react to any market requirements in the region.

9.5 Our analysis of sites which have been provided draft allocations demonstrates that there is likely to be a shortfall in the Councils ambition to provide at least 481ha of employment land throughout the plan period. This is due to a net shortfall of at least 17.68 hectares due to land identified at Rossington already in industrial use, and an additionalup to 61.33 hectares, as our analysis casts significant doubt on the reality of three other sites to deliver the amount of land stated towards the Local Plan Contribution.

9.6 In addition to the assessment of the sites which have been provided draft allocations, if there is any shortfall in the sites which have been granted permission, this will further exacerbate the position. For example, even a nominal reduction of 10% of the land which has been granted permission would be another loss of 20.95ha. The total combined shortfall could therefore be 99.96ha reflecting circa 21% of the identified need. There is no contingency for any reserve sites and therefore we conclude that there is a real risk of the sites with permission and those identified so far failing to meet to the required need.

9.7 Based on the analysis of the subject site in alongside those which have been allocated, we consider that from a market perspective, West Moor Park East would be a clear preferred option from occupiers and developers / investors and should therefore be reconsidered for allocation.

West Moor Park East, Holme Wood Lane, Armthorpe, Doncaster – Site Reference 937 / 1031 23 Review of the Doncaster Publication Draft Local Plan 2015-2035 ∙ September 2019

Appendix 1. Location Plan

Appendix 2. Assessments of Sites with Draft Allocations

Local Plan Ref 001

Site Name Junction 6 M18 Thorne North

Gross Area 73.63 acres

Local Plan Contribution (DMBC) 51.54 acres

Planning Status A planning application has been submitted.

Suitability Macro Location The town of Thorne is situated 9 miles north east of Doncaster town centre. It is served by Junction 6 of the M18 and Junction1 of the M180.

Micro Location The site is located approximately ½ mile north of Junction 6 M18. Surrounding sites are primarily undeveloped. The Doncaster Employment Land Review states that the site is slightly more remote from the main urban area of Doncaster than some of the other LP review sites.

Proximity to Markets and Labour Thorne’s existing population of large industrial and distribution buildings consists of one large format warehouse of 69,675 sq m let to The Range at Nimbus Park. Two smaller speculative warehouse buildings at Nimbus Park and Omega Kitchen Manufacturing Plant at Capitol Park. BMW have built a large new vehicle delivery park and a number of smaller business units have been developed at Capitol Park.

These facilities have been developed over a 20 year period and reflect a more modest pace of investment and occupier commitment than the pace of development recently achieved at West Moor Park and iPort. In this regard, Thorne cannot be considered as an established distribution hub.

Because the site is not well located to the main urban area of Doncaster, there is a limited catchment population to provide a local labour force to support such a large scale location. This is confirmed by Sanderson Associates; their report concludes that ‘in accessibility terms, the Thorne North Site does not offer better opportunities for securing sustainable development than the West Moor Park East site; and in fact is likely to be inferior due to the limited residential population in the local area’ Availability The site is within a single ownership and a planning application has been submitted. The entire site is located within flood zone 3A. Although the site benefits from some flood defences, the council’s site selection methodology recognises the possibility that these may fail.

Achievability The delivery of this site will be contingent upon: 1. Attracting a large scale commitment from an investor and/or occupier to fund significant enabling infrastructure in a location which is more remote from Doncaster urban area with weaker labour supply than competing sites. 2. Providing a viable solution to the inherent problems with the site’s exposure to flooding Concluding Comments  Remote from main urban area of Doncaster  A weaker labour supply than competing sites  Doubt whether the area identified is realistically capable of being delivered in the plan period. The area identified for allocation is larger than that stated by Colliers in the Employment Land Review 2018  Viable solution to flooding problem required

Local Plan Ref 092

Site Name Balby Carr Bank, Balby

Gross Area 11.25 ha

Local Plan Contribution (DMBC) 8.6 ha

Planning Status N/A.

Suitability Macro Location The site is located 1.5 miles south of Doncaster town centre. It is served by Balby Carr Bank and several side roads. This provides direct egress to A630 within 500 m however this is a one way junction. Access to the site from Doncaster town centre therefore involves a 4.8 km circular route. Junction 3 M18 is 3 km distant.

Micro Location The immediate surrounding uses are well established with industrial to the north, east and west. To the south is an operational sewage works. To the west and south west are extensive residential areas which are lacking in direct access to the site.

Proximity to Markets and Labour Balby Carr is a well-established industrial district of Doncaster’s main urban area. Long-established industrial occupiers exist alongside recently developed warehouse facilities. These include Bridon Ropes, MS International and Amazon. However, Sanderson Associates conclude that ‘in accessibility terms, the Balby Carr Bank site does not offer any benefits to the West Moor Park East site; and that road access to the site is inferior to the West Moor Park East site.’ Availability The site is within the ownership and control of a major industrial occupier and experienced developer. The main challenge on delivery is expected to be the poor access to the surrounding residential areas at the Balby Carr Road/Bolton Road junction. Achievability The delivery of this site will be dependent upon: 1. Achieving primary access to Balby Carr Road 2. Enhancing access to the site from surrounding residential areas. Concluding Comments  A modest scale site in an established industrial location  Macro location is good for general/heavy industrial  Micro location requires enhancement in order to connect with surrounding residential and labour supply.

Local Plan Ref 258

Site Name Plot 1, Lakeside, Potteric Carr Road

Gross Area 8.48 ha

Local Plan Contribution (DMBC) 5.00 ha

Planning Status N/A

Suitability Macro Location The site is located 1 mile south-east of Doncaster town centre. It is served by the A6182 and A18. The nearest motorway junction is Junction 3 of the M18, approximately 2 miles to the south. The surrounding area is generally a mixed business environment.

Micro Location The site is situated to the north of the intersection / junction of Stadium Way and Middle Bank (it is not on Potteric Carr Road). Occupiers nearby include XP, Tesco, and a variety of trade counter occupiers. The Keepmoat Stadium is approximately ¼ mile to the south.

Proximity to Markets and Labour Lakeside is a well-established commercial area of Doncaster and a relatively high quality environment. There is adequate proximity to existing markets and labour force. Availability The site appears to be available – it comprises a linear site opposite two buildings occupied by XP Achievability We are not aware of any reasons why this site cannot be achieved. Concluding Comments  Located in an existing and well established commercial area of Doncaster.  Likely to be suitable for B1 use of smaller format buildings.

Local Plan Ref 441

Site Name Carcroft Common, Carcroft

Gross Area 49.28 ha

Local Plan Contribution (DMBC) 12.32 ha

Planning Status N/A

Suitability Macro Location The village of Carcroft is just under 6 miles by road to Doncaster town centre by the A19. Furthermore, access to the A1 from the site involves a 2½ mile journey along the B1220 through a residential area. This gives access to the A1 at a south bound sub-standard and dangerous junction.

Micro location The site is located immediately to the east of the Bentley Moor Industrial Estate area. This is not an established large format logistics location and this is reflected in the existing population of the estate. The estate is dominated by Europe’s largest vehicle dismantler and a number of smaller units.

Proximity to Markets and Local Labour Local labour supply is available by virtue of the nearby village, however the infrastructure necessary to deliver the workforce to support a large format industrial and logistics facility in this location simply does not exist. Nor do viable access routes to Redhouse Interchange, (which is the nearest large format logistics park), exist in this location. Availability The Doncaster Employment Land Review states that ‘the site requires major road infrastructure investment to open it up for development and, in particular, the A1M to A19 link road. Sanderson Associates confirm that this road should not be relied on for planning and development purposes. Achievability The Doncaster Employment Land Review also states that ‘development of the site is likely to require some form of development funding, possibly introducing higher value non- employment uses to be incorporated into any scheme on the site, not least to help with the costs of bringing the land forward including a contribution towards the link road.’ Delivery For the reasons stated under Availability, there is no certainty for the delivery of this site towards LP contribution. Concluding Comments  Proximity to local labour only  Viable access and infrastructure for large format development does not exist  The major road infrastructure required is not funded or programmed  The site cannot be considered suitable towards the LP contribution

Local Plan Ref 878/1032

Site Name Site A, East of Bankwood Lane, Rossington

Gross Area 17.68 ha

Local Plan Contribution (DMBC) 17.68 ha

Planning Status Existing industrial use by Tanks and Vessels.

Suitability Macro Location The property is located around 4 miles south west of Doncaster town centre. It is accessed via Junction 3 of the M18, the Great Yorkshire Way and West End Lane, which in turn, passes through a mixed residential and commercial area.

Micro Location Whilst the site has profile from the Great Yorkshire Way, its micro location is less obvious. Access to the property for goods and private vehicles involves a circuitous 1.6 km route from the Great Yorkshire Way via mixed residential and commercial areas.

Proximity to Markets and Labour The general locality is a proven location for large format distribution at iPort, serviced by major new infrastructure. The subject property is, however, in the centre of Bankwood Lane, Rossington, which is a long established mixed residential and employment area. Proximity to labour and markets is good. Availability The property comprises an established industrial building together with storage land which has been occupied by Tanks and Vessels for nearly 40 years.

The property has a rateable value of £221,000 and is a substantial existing industrial facility.

The vast majority of the site was identified in the adopted 1998 UDP and has not been developed further for new built development. Achievability Part of the site is located within flood zones 2 and 3 and the north-eastern part is vulnerable to flooding.

Development of the site will necessitate the relocation of the existing owner occupiers at significant cost and business disruption. Deliverability This site does not represent a new employment site. It is a significant existing built facility on an existing employment site. There would be no net gain if it were to be allocated for employment purposes. Concluding Comments  A substantial industrial built facility  Good macro, weak micro location  Allocation of this property delivers no net gain

Local Plan Ref 941

Site Name Site 2, Land East of Poplars Farm, Hurst Lane, Auckley

Gross Area 68.54 ha

Local Plan Contribution (DMBC) 68.54 ha

Planning Status N/A

Suitability Macro Location The property is located just under 8 miles by primary road links from Doncaster town centre and is adjacent to Doncaster Airport. However, the subject site is currently bound by Great North Road (A638) and High Common Lane.

Micro Location The site forms part of the masterplan for Doncaster Sheffield Airport and will be reliant on the growth of airport related business.

Proximity to Markets and Labour The site is in close proximity to the Airport but currently comprises open countryside. It is also adjacent to another site which has been reserved for airport related business (which is not identified for a contribution to the Local Plan requirement). Whilst the site is proximate to the airport, it is remote from labour.

Sanderson Associates conclude that ‘in accessibility terms, the Poplars Farm site does not offer better opportunities for securing sustainable development that the West Moor Park East site; and in fact is likely to be inferior due to the smaller residential population in the local area. Furthermore, high quality access to the site has currently not been demonstrated and may not be achievable. Availability Current agricultural land and no obvious infrastructure underway at present.

Achievability Reliant upon longer term success of the airport. Doubts over high quality access to the site. Concluding Comments  An extensive area of land which is currently open countryside extending to 68.54ha. No obvious infrastructure at present. Adjacent to another site extending to 44.05 hectares reserved for airport related activities. In total therefore 112.59ha of land in this location.  Remote from the motorway and labour pool.  In a similar way to Site Ref 001, we question the realistic amount of supply that this site can deliver in the Local Plan period and consider that a more realistic amount is 50% of the total which has been identified.

West Moor Park East Vision Document

Proposed M18 Employment Opportunity (Site Ref: 937) Response to Doncaster Informal Local Plan Consultation: Draft Policies and Proposed Sites October 2018 Site Location

This Vision document concerns 195 acres (79ha) of land to the east of Junction 4 of the M18 motorway at Armthorpe (West Moor Park East) in the sole ownership of Blue Anchor Leisure Ltd.

2 . Summary

West Moor Park East is a 195 acre (79ha) Class B2/B8 development opportunity located off Junction 4 of the M18 near Armthorpe, Doncaster. It is one of the UK’s largest, best located, most accessible and most deliverable employment development sites in single ownership.

The site is solely owned by Blue Anchor Leisure, a Company • Two of the Council’s proposed employment allocations with a long established track record in bringing land to the are also in Countryside Policy Areas. West Moor Park East market place in Doncaster for development. West Moor Park would be located in an area of low quality countryside East has been promoted for employment early in the Local that is already influenced in landscape terms by large Plan process and it is anticipated that following consultation warehouse buildings at West Moor Park. with key stakeholders this vision document will evolve to support further submissions to the Plan. • Deliverability of West Moor Park East is evident given the significant interest in it by a number well known The site has a significant recent planning history for commercial developers with a track record in delivering major motorsport and leisure uses and a consent for this major employment developments. development has already been part implemented. The land comprises a large number of buildings, roads, hard • Blue Anchor Leisure has obtained confirmation from surfaces and substantial earth features. To that extent the First Bus that 15 minute frequency bus services can be character and appearance of the site contrasts with the wider extended into the proposed development, thus providing surrounding countryside. high quality public transport access. This service would be self funding after 5 years. There is considerable developer interest in the site from a number of well-known commercial developers with the • West Moor Park East is conveniently located for the experience and funding to successfully implement a major housing areas of Armthorpe, and it is also well located employment scheme. Heads of Terms from one developer in relation to the Main Urban Area of Doncaster. The have already been provided, the only outstanding matter being potential workforce accessible by public transport far confirmation of support from the Local Planning Authority. exceeds that available at proposed allocations at sites 160 and 441. This vision document demonstrates that access/transport, landscape, ecology and flood risk/drainage matters have • The emerging Local Plan confirms that West Moor Park been considered and initial technical work demonstrates East would not be located in an area that is considered that there are no showstoppers that would prevent a prompt as a minerals opportunity. delivery of the site for employment, subject to mitigation measures. It is therefore considered that the stated reasons for rejection of West Moor Park East as an allocation at this stage are In the current Local Plan consultation West Moor Park East not sound. It is also considered that this Vision Statement is identified as a ‘option’ (site ref: 937) but it is not proposed identifies a shortage of large, deliverable employment sites as an allocation. The Council’s Site Selection Methodology with good access to the motorway network. indicates that main reasons for this relate to flood risk, countryside policy, deliverability, accessibility and minerals value. However this Vision document demonstrates that: This proposal would deliver significant employment and economic benefits to the people of Doncaster (approximately • A significant part of the site is in Flood Zone 1,and 3,500 jobs). It is expected that development of the scheme therefore it is sequentially preferable to a number of the could commence within 12 months of an adopted Local Plan Council proposed employment allocations. confirming allocation of the site for employment. The site would be completed within a period of approximately 5 years.

West Moor Park East . 3 Contents

1.0 Introduction and Vision for the Site 06

2.0 The Consultant Team 08

3.0 Planning History 09

4.0 Planning Policy Analysis 10

5.0 Comments on Employment Sites with Planning Permission 12

6.0 Comments on Sites Proposed as Employment Allocations 15

7.0 Response to Councils Comments on Proposed Employment Land Allocation 18

8.0 Site Analysis 21 8.1 Site and Surrounding Areas 22 8.2 Site Photographs 24 8.3 Aerial Views 26 8.4 Flood Risk Analysis 28 8.5 Access Transport and Highways 31 8.6 Landscape and Ecological Analysis 35

9.0 Indicative Masterplan 38

10.0 Landscaping and Ecology Vision 40

11.0 Benefits and Opportunities 42

12.0 Conclusion and Next Steps 43

Appendix 1: Access Appraisal

Appendix 2: Accessibility Comparison

Appendix 3: Employment Developments East of M18 Motorway

Appendix 4: Email from DMBC regarding minerals potential

4 . One of the UK’s largest, best located, most accessible and most deliverable, employment development sites in single ownership.

West Moor Park East . 5 1.0 Introduction and Vision for the Site

The purpose of this document is to set out in outline form Subject to satisfactory support from the Local Planning the vision and planning policy justification to develop land Authority, the site is considered to be free from any significant at West Moor Park East for major employment uses (Class constraint and it is eminently deliverable for employment B2 and B8), capitalising on its strategic location adjacent development to help meet Doncaster’s needs over the new to the motorway network and complementing the Class B8 Local Plan period. development that has already taken place on the western side of Junction 4 at West Moor Park. Significant commercial developer interest has been expressed in the site to date - thus providing strong evidence The land has already been promoted for employment at that this is a location that the market wishes to bring forward earlier stages of the Local Plan process and it is anticipated for employment. that following the current informal consultation the Vision document will evolve to support further submissions to the Plan as it progresses.

Route of West Moor

Park (A630)

Existing West Moor Park Junction 4 of Employment Site M18 Motorway

Development site

Other land owned by Blue Anchor Leisure

Site Location Plan

The Strategic Advantages of the Site Location the Doncaster urban area through the proposed upgrades to The site is a rare commodity in that it has considerable the A630 (Westmoor Link). This will enhance accessibility to frontage (and therefore commercial presence) to the M18 the local workforce and assist supply and distribution for local and easy access from Junction 4 of the motorway via a short businesses located in premises at West Moor Park East. length of Holme Wood Lane. Site Ownership and Deliverability It is strategically important in accessibility terms with seamless A further unique advantage of the site in terms of commercial access to the M18, A1, M1, M180 and M62 motorways. It also deliverability is in respect of land ownership. Whilst a number lies in close proximity to major transport infrastructure at Robin of other potential employment opportunities along the M18 Hood Airport, Doncaster IPort and the Humberside Ports. corridor are in multiple ownership, West Moor Park East is owned solely by Blue Anchor Leisure. This provides certainty At the local level the site is close proximity to the built up area to the development industry that all of the land is available of Armthorpe, one of 7 defined main towns in the Local Plan. and its delivery will not be hindered or delayed by protracted It is also a short distance to the defined main Urban Area of land assembly negotiations. Doncaster and the local bus operator, First Bus, has confirmed that it is feasible to extend existing bus services to access the This document also demonstrates that there are no proposed development (on a 15 minute frequency). ‘showstoppers’ from an environmental or technical point of view that would constrain development of West Moor Park Furthermore, the site will soon benefit from improved links to East for employment.

6 . Allocated, Permitted and Pending Major Housing and Employment Sites in Armthorpe and surrounding areas

1. 16/02060/OUTM - 800 homes, retail, employment. Approved 6. Allocated in Neighbourhood Plan (185 homes) 2. 18/01417/SCRE - 700 homes. Screening Opinion 7. 17/01528/REMM: Approved: B8 floorspace - 22,300m2. 3. 14/00297 - 65 homes. Approved 8. 14/02125/FULM: Approved: B1(a) floorspace -6390m2, B8 2 4. 16/02224/OUTM. 400 homes. Application pending. Allocated in floorspace - 75,642m Neighbourhood Plan. 9. 18/00688/REMM: Approved: B1(c) floorspace – 3531m2, B8 2 5. 12/00188/OUTM. 500 homes. Allocated in Neighbourhood Plan. floorspace 80,634m

Doncaster Main Urban Area Allocated Sites/Sites with Planning Permission/ Pending Consideration (Residential) Allocated Sites/Sites with Planning Permission/ Pending Consideration (Employment)

West Moor Park East

Proposed Improvements to A630 (West Moor Link)

Armthorpe Built-up Area (Current and Proposed)

West Moor Park East - Relationship to Doncaster Main Urban Area and Major Development Schemes

Blue Anchor Track Record of Delivering Development • Another large ex quarry workings which the company has Blue Anchor Leisure Limited has significant experience of developed and brought forward is the hugely successful bringing forward attractive development land to the market. and very picturesque Woodward Lakes and Lodges, Some examples are as follows: which sits alongside the reach of land promoted in this document. • 400 Acres of land adjoining Doncaster Airport, which was successfully sold to Peel. (Which is earmarked for • Blue Anchor Leisure continues to purchase and develop major development to run alongside Doncaster Airports land around the Lincolnshire, Yorkshire and Humberside operations). areas under the guidance of the company founders, the Woodward family. • 200 Acres of land surrounding West Moor Park which was bought by Gazely, (which has already seen major Developer Interest development works on site including the Next retail Doncaster Council can be assured that West Moor Park East distribution centre). is an opportunity that will happen-providing support from the Authority is forthcoming through the Local Plan process. • Several patches of land along the FARRS development.

• Blue Anchor Leisure is currently working alongside another Initial marketing of the site reveals significant interest from a developer and High Peaks Council at Buxton to develop number of well-established commercial developers with the another area of the company’s land into a major roundabout experience and funding sources to successfully implement and spine road which will lead to the development of 330 a major employment scheme. These developers include houses and a large industrial estate which 280 houses sit Buccleugh/Litton Properties, Carta RE/Oxenwood, Wykeland on one of Blue Anchor Leisure’s properties. Group and CWC Group.

• Also in Buxton Blue Anchor Leisure sold an area of land In the case of Buccleugh/Litton Properties, Heads of Terms for development of a crematorium. have been provided to purchase the land, with the only outstanding matter being confirmation of support from the • In addition the company have been involved with defunct Local Planning Authority. quarries in the Buxton area. In an effort to rejuvenate them for alternative uses.

West Moor Park East . 7 2.0 The Consultant Team

Blue Anchor has appointed a team of experienced Yorkshire- Should the Local Plan process highlight a need for based consultants with the knowledge and track record to additional expertise, then Blue Anchor has the resources to effectively promote the site through the Local Plan process expand the consultant team as required. and to progress an outline planning application at the appropriate point in time. The consultant team comprises:

Masterplanning Planning Bowman Riley Peacock and Smith

Commercial Property Advice Transport and Accessibility Barnsdales Fore Consulting

Landscape and Ecology Flood Risk and Drainage Smeeden Foreman Fairhursts

Planning Solicitors Walker Morris

8 . 3.0 Planning History

The Subject Site The description of development of the outline permission is Parts of the site historically formed part of Holme House Farm, as follows: remnants of which can be seen in a group of large portal framed storage buildings on the north eastern side of the site. “Application for water based holiday lodge complex comprising More recently the main body of the site has a history of use for up to 150 lodges, up to 24 touring caravan pitches, an aqua motocross-related motorsport uses. centre amenity building, lake activities and 9 hole golf course, together with expansion of the existing motorpark comprising a In this context an outline application for a major motocross central bub building and additional tracks, parking, servicing, and leisure facility at the site was approved in March 2009 landscaping and ancillary paintballing.” (ref: 09/00728/OUTA) served by a widened (5.5m) section of Holme Wood Lane and this was followed by the approval of a detailed scheme in January 2011 (ref: 10/01593/REMM).

Previously Approved - Planning Approval Ref: 09/00728/OUTA

Significant aspects of the above application (as amended by To that extent the character and appearance of the site contrasts a subsequent 2015 S73 application) have been implemented with the wider surrounding countryside. Furthermore, as the in the form of the ongoing development of the holiday motocross and leisure consent is extant there is a significant lodge complex (more than 40 no. lodges to date) with golf fallback position should it be fully developed out. course and tennis court facilities; and extensive parts of the motorpark, including support facilities and a shop. The Adjacent Quarry land now comprises a large number of buildings, roads, Land to the south of Holme Wood Lane has a long history hardsurfaces and substantial earth features created as part associated with sand and minerals extraction, and these of the motorsport element of the approved scheme. activities are ongoing. The Council has recently granted a consent to the minerals operator to extend extraction activities up to 2025 (ref: 15/03012/MINA).

West Moor Park East . 9 4.0 Planning Policy Analysis

Existing Development Plan “Employment allocations will support the settlement In the Doncaster Unitary Development Plan (UDP) (1998) hierarchy but must also take account of deliverability issues West Moor Park East is not allocated for a particular purpose. (i.e. the needs of business) and Doncaster’s Economic It is designated as part of a Countryside Policy Area and it Strategy; employment sites cannot always be located next to is also safeguarded for minerals extraction. However, the the communities they serve. The Local Economic Assessment UDP only seeks to meet development needs in the Borough stresses the need for Doncaster to concentrate on using up to 2001, and the designations pre-date the subsequent its assets that give it comparative advantage to enable the approval of planning applications for major motorsport and economy to catch up with regional averages. This means leisure development on the site. exploiting the transport connectivity in Doncaster and its developable land alongside. However, priority will be given to sites within or adjacent to the Main Urban Area, Principal Towns and Potential Growth Towns where infrastructure can be brought forward; transport connectivity will be a priority to ensure there is access to jobs for all communities (see Policy CS5: Employment Strategy)….”

Para 3.24 comments on the employment opportunities at Armthorpe in particular:

“.…Within the M18/M180 corridor a number of opportunities exist associated with the strategic transport network at the junctions near to Armthorpe and Thorne. Improvements to public transport connectivity to the Main Urban Area and wider opportunities will be supported, as will improvements to access for pedestrians and cyclists. In addition, the transport policies will support improving accessibility to employment Doncaster UDP Proposals Map Extract sites from across the borough.”

Current Informal Local Plan Consultation (September to The Doncaster Core Strategy (2012) also forms part of the October 2018) current development plan, although it is not a site-specific The Council is preparing a comprehensive Local Plan to replace allocations document. Armthorpe is a Principal Town in the the UDP and Core Strategy. This will provide for development settlement hierarchy and therefore a focus for growth and needs between 2015 and 2032. The settlement hierarchy of regeneration. Table 2 of Policy CS2 confirms that distribution the Local Plan defines Armthorpe as a Main Town, which is warehousing will be located in the M18/M180 corridor the second tier below the Doncaster Main Urban Area (MUA). at junctions close to (inter-alia) Armthorpe. Light industry and manufacturing is to be located in accordance with the Policy 3 of the plan states that ‘at least’ 407 hectares of settlement hierarchy. employment land will be provided to meet employment needs. At least 50% of new housing development will be provided in Blue Anchor Leisure considers that it is pertinent that the Core the MUA and 40% will be provided in the 7 Main Towns. The Strategy key diagram identifies broad areas with potential for policy indicates that in terms of logistics development, this major employment sites at Junction 4 of the M18 (in land will be distributed as follows: shown as countryside on the UDP Map). Whilst the southern broad area now has planning permission, the remaining broad “Locations that can accommodate large buildings with good area north of the A630 is wholly in Flood Zone 3. Given that access to the M18/M180 motorways. Sites within the multi- a large part of West Moor Park East is in Zone 1 the broad modal transport corridor around the Great Yorkshire Way/ location is less sequentially preferable than the Blue Anchor White Rose Way lining the urban centre to the Doncaster Leisure land and therefore in effect undeliverable. Sheffield Airport, including the urban centre, Lakeside, Rossington iPort, Bankwood Lane and the Airport.” Paragraph 3.14 of the Core Strategy refers to the importance of deliverability and transport connectivity in the employment Regarding light industry and manufacturing, Policy 3 indicates land strategy: that these uses will be located as follows:

10 . “Locations with good access to the M18/M180 motorways Employment Land Availability Assessment (HELAA), but it is and strategic road network. Unity (Hatfield Power Park and not allocated at this stage. The stated reasons why the site associated business parks).” has not been proposed for allocation are as follows: Policy 13 sets out a number of strategic transport proposals, “Site not proposed for allocation. May be an option after including the West Moor Link (A630), which connects with other sites are developed. To East of M18. More deliverable Junction 4 of the M18. The table associated with Policy 13 states: sites adjacent to urban area. See Site Selection Methodology document for further detail.” “The scheme involves improvements to the A630 between junction 4 of the M18 motorway to the A18 (Thorne Road) and In relation to the proposed allocation at Site 441 we consider between the A18 and A630 Wheatley Hall Road. The scheme that there are significant doubts about its deliverability, as may involve the widening of a rail bridge thereby removing explained at Section 6 of this Vision Document. In respect a pinch point. Once complete, the scheme will increase the of the proposed allocation at Site 160, this is considerably capacity of the network, facilitate the unlocking of housing further from the Main Urban Area than West Moor Park East, development and employment land along the route, and as we also explain in Section 6. It is our view that the stated support sustainable modes such as cycling.” reasons for rejection of West Moor Park East as an allocation are therefore unsound. The Local Plan Site Selection Methodology document states that approximately 298 hectares of employment land already The Site Selection Methodology states that West Moor Park has planning permission. As a result just 3 sites are proposed has been rejected as an allocation for the following reasons: for allocation. These are as follows: As with all the potential sites, this site fails the flood risk • Ref: 160 Thorne South Urban Extension (40 ha) sequential test as it is within Flood Zone 3. It scores similar • Ref: 441 Bentley Moor Lane (12 ha) to the other sites through the Sustainability Process. It is currently within Countryside Policy Area as designated in • Ref: 941 RHADS Site 1, Phase 4 Business Park (68 ha) the UDP. It is to the east on the M18 and there are more The Employment Proposals Map for Armthorpe confirms that deliverable sites which are adjacent to the main urban area there are no sites proposed for employment in the settlement. and main towns which offer better opportunities for securing sustainable development particularly in securing public West Moor Park East is identified as a potential site option transport access. Land to the east of the M18 is also a that has been considered by the Council’s Housing and potential Minerals Area of Search.

We address each of the above reasons in section 7 of this Vision document. We also make comments on sites with planning permission for employment referred to in the local plan consultation and sites proposed for employment allocations at Sections 5 and 6 respectively.

Armthorpe Local Plan Map Extract

West Moor Park East . 11 5.0 Comments on Employment Sites with Planning Permission

Section 9.4 of the Local Plan Site Assessment Methodology Comments on Employment Sites with Planning Permission - sets out details of 20 sites that already have planning Conclusion permission for employment, and which are considered by the Taken at face value there is a significant amount of land that Council to contribute towards the 407 hectares of employment already benefits from planning permission for employment. land required over the plan period of 2015 to 2032. In total However, our assessment demonstrates that a significant these sites are considered by the Council to contribute 298 element is not available, as at least a quarter of the sites hectares (73%) towards the requirement. relate to completed sites that are let/partially let.

We have assessed the availability and achievability of Furthermore our assessment shows that of completed sites these sites with the assistance of local commercial agents, that are available/undeveloped sites, there are only 6 that Barnsdales. We have also checked the planning history of are suitable for largescale employment and close to the each site and the proximity to the motorway network. The motorway network. Availability and deliverability constraints resulting information is set out in tabular format overleaf. Our are likely to impact on the timing at which developments in summary findings are as follows: these locations could contribute to employment supply.

• The outline planning permission for Site 183 (2.54 In short, we consider that notwithstanding the quantitative hectares) has now expired. Given that planning contribution of the sites with planning permission towards permission is a valuable commodity this indicates that the Local Plan employment land requirement it is also the viability of the site for employment may be in doubt. essential that qualitative factors and choice are considered. In our view there is a paucity of deliverable opportunities for • Of the 20 sites listed by the Council 12 (60%) are already footloose occupiers seeking large sites with easy access to complete/under construction. A further five sites of the motorway network at the beginning of the plan period. these sites are either fully let or partially let. The only There is therefore a risk that as currently drafted the Local opportunities available for largescale employment Plan places Doncaster in a position where it may miss out on close to the motorway network that are complete/under inward investment and job creation. construction are at Iport, Rossington (Site 747) and at Nimbus Park, Thorne (Site 735). This is an important issue that goes to the heart of the soundness of the Local Plan, since the employment land • There are only 6 sites with planning permission where strategy is predicated on meeting the Sheffield City Region there are opportunities for an occupier to design and (SCR) job growth target for Doncaster, which represents a layout a scheme to suit their needs. However, only faster growth rate than the rest of the UK. Sites 227, 418, 818 and 984 are located close to the motorway network. Of these sites, Site 227 (West Allocation of West Moor Park East would help alleviate the Moor Extension) is for Class B8 use only and therefore risk we identify above, as it is a large, deliverable site in single unsuitable for Class B2 uses. Site 418 (Unity) is reliant ownership that benefits from direct access to the motorway on the completion of the Hatfield link road (which is not network via Junction 4 of the M18. Development of the site programmed for completion until the end of 2020) and would not be contingent on public subsidy. The strong level there will be a significant amount of land remediation of interest in the site from a number of well-known developers required given the previous use of the land as a mine/ demonstrates that it is a site that the market wishes to see former landfill site. come forward in the short term.

12 . Review of Employment Sites with Planning Permission

RED: Application expired, not implemented AMBER: Outline permission granted, but development not started GREEN: Development complete

Site Gross site Site name Permission type and status Permitted use class Comments ref. area (ha)

183 Waste Treatment 2.54 Outline Planning Permission B1(c), B2, B8 • Flood Zone 3 Works, Kirk Sandall Application ref: 14/02815/OUTM • Contaminated site EXPIRED • Good location for smaller units • Distance to M18 junction: J4, 3.3 miles (7 minutes) 227 West Moor 33.45 Outline Planning Permission B1, B8 • Multiple ownerships (8) Extension Application ref: 15/03013/OUTM • Attractive location (Approved 7th July 2017) 18/00688/ • Distance to M18 junction: J4, 1.7 REMM (Approved 12TH October 2018) miles (6 minutes) CURRENTLY DISCHARGING CONDITIONS 418 Unity (DN7) 428.37 Outline Planning Permission Residential development • Likely contamination issues Application ref: 15/01300/OUTA (3100 units), community • Attractive location with close (Approved 21st April 2017) facilities, industrial and connectivity to M180 and M62 NO RESERVED MATTERS YET logistical development, • Distance to M18 junction: J5, 4.3 commercial development miles (8 minutes) and a local centre 522 Tornado, Redhouse 6.91 Development Complete B8 • Complete Interchange • Situated north of Doncaster – less attractive location • Fully let 528 Brooklands Road, 0.76 Development Complete B8 • Complete Carcroft Common • Situated north of Doncaster – less attractive location 569 Askern Saw Mills 15.14 Outline Planning Permission 220 dwellings, up to • Owned by two parties who have Application ref: 08/01077/OUTA 310m2 of A1, up to been unable to agree value (Approved 11th July 2013) 310m2 of A3, up to • North of Doncaster RESERVED MATTERS PENDING 560m2 of Class A4, up to • Lesser location 16/01651/REMM 1400m2 of Class B1(c), • Distance to M18 junction: J5, 12 up to 8550m2 of Class B2 miles (25 minutes) 730 Bullrush Grove, 2.04 Development Complete B8 • Fully developed Balby • Smaller units than WMPE • Fully let • Distance to M18 junction: J4, 1.4 miles (4 minutes) 733 Capitol Park, Omega 8.94 Development Complete B1, B2, B8 • Fully developed Boulevard, Thorne Application refs: 10/03149/OUTM and • Almost fully let 14/02310/REMM (Approved: 17th Dec • Same side of motorway as WPME 2014) • Distance to M18 junction: J6, 0.2 miles (1 minute) 735 Quest Park, Silk 1.41 Development Complete B1, B2, B8 • Completed Road, Wheatley Application ref: 15/01977/FULM • Prominent location for smaller (Approved: 10th Dec 2015) developed units • Distance to M18 junction: J6, 4.5 miles (9 minutes) 736 Nimbus Park Phase 6.55 Full Planning Permission B8 • On site 2, Land Ends Road, Application ref: 16/00126/FULM • Adjacent to The Range Thorne (Approved: 3rd January 2017) Distribution Centre • Same side as WMPE • Spec built • Distance to M18 junction: J6, 0.2 miles (1 minute)

Continued overleaf

West Moor Park East . 13 Continued...

RED: Application expired, not implemented AMBER: Outline permission granted, but development not started GREEN: Development complete

Site Gross site Site name Permission type and status Permitted use class Comments ref. area (ha)

740 Former Doncaster 0.20 Full Planning Permission B1, B2 • Partially complete College Application ref: 10/00723/FUL • Council Offices completed (Approved: 20 Jul 2010) • Car parking may cause limitations with office lettings • Distance to M18 junction: J3, 4.8 miles (17 minutes) 743 Broomhouse 0.74 Full planning permission B1, B2, B8 • Under construction phased Lane Industrial 17/00014/FULM (Approved: 3rd April completion with phase 1 due Estate, Wood View, 2017) imminently Edlington • Lesser location • Distance to A1(M): 1.6 miles (5 minutes) 745 West Moor Park 16.35 Development Complete B8 • Completed Extension Unit C Application ref: 14/02125/FULM • Unit let • Distance to M18 junction: J4, 1.2 miles (4 minutes) 746 Former Tyco Factory, 0.71 Development Complete B2 • Site under construction by St Wheatley Hall Road Application ref: 13/00308/REM Modwen (Approved: 9th Apr 2013) • Occupied by two car dealerships • Attractive location for trade counters • Distance to M18 junction: J4, 4.9 miles (11 minutes) 747 iPort Rossington 403.89 Strategic inter-model logistics park B1, B8 • Large Distribution Units incorporating rail freight terminal. • Same side of motorway as WMPE Approx. 50% complete • Three units currently available • Distance to M18 junction: J3, 0.2 miles (2 minutes) 748 Doncaster Sheffield 14.25 Outline Planning Permission B1, B2, B8 • Attractive location close to airport Airport, First Application ref: 16/01019/OUTM • Under one ownership Avenue, Auckley (Approved: 30 September 2016) • Distance to M18 junction: J3, 5 NO RESERVED MATTERS YET miles (12 minutes) 770 Zone 3, Carr Hill, 4.69 Development Complete B2 • Site has been delivered Balby Carr • Attractive location for smaller units/trade counter • Distance to M18 junction: J3, 5 miles (12 minutes) • Fully let 818 Land at Hatfield 12.74 Reserved Matters Approved B2 • Short distance from WMPE Lane, Armthorpe Application ref: 18/00688/REMM (12 • Deliverable Oct 2018) • Attractive location • Distance to M18 junction: J4, 1.8 miles (2 minutes) 984 McCormick, 40.93 Outline Permission B1, B2, B8 • Situated in Flood Zone 3 Wheatley Hall Road Application ref: 10/02600/OUTA • Ideal location for small units/ (Approved: 07 Nov 2011) trade counters RESERVED MATTERS PENDING • Distance to M18 junction: J4, 1.8 Application ref: 18/00774/MAT (22 miles (2 minutes) June 2018)

14 . 6.0 Comments on Sites Proposed as Employment Allocation

Once sites with planning permission are taken into account, In our view development of Site 160 for major employment the Draft Local Plan proposes to allocate 4 sites as allocations use would therefore give rise to a significant change to the to meet the employment need set in the Local Plan. However, character of the land and the southern approaches to Thorne one of these sites, Site ref: 517 (Safeguarded Cargo Area, generally. Whilst a development of West Moor Park East for Doncaster Sheffield Airport) does not contribute to the employment would also lead to a change to the appearance requirement, as it is an air-related proposal. of that site, we consider that it is a location with a greater environmental capacity to accommodate change, for the This leaves the following 3 sites that the Council presently following reasons: proposes to allocate for employment: West Moor Park East is part previously-developed. It • Site ref: 160 Thorne South Urban Extension, Bradholme • (40 ha); already accommodates a variety of roads, structures and buildings (please refer to Section 8.0 of this Statement) • Site ref: 441 Bentley Moor Lane (12 ha); and and also is frequently used for motorcross purposes, • Site ref: RHADS Site 1, Phase 4 Business Park (68 ha). which is an activity characterised by high levels of dust, noise and vehicle movements. These features and uses Blue Anchor Leisure wishes to make comments on the first are readily visible from the M18 corridor. two of these sites, Sites 160 and 441, as follows. • West Moor Park East is located opposite an established Site ref: 160 Thorne South Urban Extension, Bradholme (40 ha) distribution park, West Moor Park, that already accommodates very large warehouse type buildings Flood Risk occupied by national companies such as Ikea and Next. Site 160 is almost entirely in Flood Zone 3 and it is not These buildings are prominent features in the local protected by flood defences. In contrast a substantial landscape, and thus there is a precedent for that type of proportion of West Moor Park East (approximately 65%) is in building in the locality. Flood Zone 1, as explained at Section 8.4 of this Statement. Planning Practice Guidance requires that where suitable sites • West Moor Park East comprises low quality countryside in Zones 1 and 2 are not available, development is allocated that abuts the motorway corridor and is dominated by in land with the lowest risk of flooding. West Moor Park East noise and traffic moving along it. It does not have the is clearly sequentially preferable to Site 160 in that regard. same character of tranquillity as Site 160.

We note that the Local Plan Sustainability Appraisal awards In short, we consider that these site characteristics Site 160 and West Moor Park the same negative (pink) demonstrate that West Moor Park East is a site that is more score in relation to main river flooding. We understand that suited to the accommodation of a large scale employment the approach of the Council’s assessment is to treat all development than Site 160. In particular, given the close opportunities with more than 20% of site area in Zone 3 in proximity of the site to the established employment destination this way. However, this approach is a flawed policy tool to at West Moor Park large scale employment buildings would compare sites. It is not consistent with the sequential test, as read as ‘more of the same’ in a landscape and visual context. it fails to differentiate between sites that may be substantially Furthermore, Blue Anchor Leisure proposes to provide or wholly in Zone 3 (such as Site 160) and sites that comprise significant landscape mitigation to filter and soften views of significant areas of land with a lower risk of flooding (as in the new buildings. case of West Moor Park East). This demonstrates that the sustainability appraisal is unsound in respect of flood risk. Accessibility We note that the Council’s Sustainability Appraisal awards Character of Site and Area Site 160 a positive (green score), as it states that the site Site 160 is a wholly greenfield site located beyond the canal lies within 800m of a train station. However, the Accessibility and railway line in Thorne, which are significant physical Comparison (AC) document prepared by Fore Consulting features that demark the current built edge of the settlement. that we attach at Appendix 2 explains that pedestrian links The site does not adjoin the motorway network and therefore between Site 160 and the train station are poor. The AC it benefits from an element of tranquillity as a wide expanse of states that: agricultural land located to the south of Thorne. Furthermore, we note that there is no precedent for large warehouse “Although the station is located 400m north of the site, given type buildings on the southern side of Thorne – all existing the alignment of the Stainforth and Keadby Canal (which runs properties are domestic in scale. between the station and the site), there is no direct pedestrian route to the station to the south. Without a direct pedestrian

West Moor Park East . 15 connection over the canal, staff and visitors arriving via the Site ref: 441 Bentley Moor Lane (12 ha) station would be required to walk via South End, crossing the existing bridge on South End; this would require a diversion Flood Risk of approximately 1.5km to the allocation site, assuming a Site 441 is entirely in Flood Zone 3. Whilst it is protected by pedestrian access could feasibly be provided from the public flood defences, the Council’s Stage 1 Flood Risk Assessment footpath which runs along the southern edge of the canal.” notes at Section 3.3.2 that these can be overtopped in an extreme event or that they could fail or breach. Fore Consulting therefore conclude that rail travel to/from Site 160 is unlikely to be attractive to staff/visitors without Around 65% of West Moor Park East is located in Flood Zone significant improvements. 1. This area is greater in quantum than all of the 12 ha of land proposed for employment at Site 441. In flood risk We also consider that Site 160 is inferior to West Moor terms there is therefore no need to release Site 441, since Park East in respect of accessibility to the Main Urban Area the equivalent area of employment land can be provided in of Doncaster (MUA), which is where most existing housing Zone 1 at West Moor Park East. The proposed allocation of in the Borough is located, and where most new homes will Site 441 fails the sequential test. be accommodated over the plan period. In our view this is a key issue to consider when assessing the relationship Reserve Employment Site Designation between a major employment development and the local Whilst Site 441 might be designated as a reserve employment workforce. In this context whereas Thorne is a modest-sized site in the UDP, it is inappropriate that it is simply rolled forward settlement that is somewhat detached from the MUA (some into the new plan. Para 120 of the NPPF requires allocations 7km away), Armthorpe effectively adjoins the MUA, and will to be reviewed. The site has not been taken up and is clearly shortly benefit from improved connections with it via the unattractive to the market. There are more accessible, more proposed improvements to the A630 (West Moor Link). This deliverable opportunities such as West Moor Park East that is demonstrated by the plan we provide at Page 7 of this are available to meet employment needs. In our new Site 441 Vision Statement. should be re-designated in countryside. This would safeguard the countryside between Toll Bar and Carcroft and maintain The AC goes on to show that whereas some 9,194 people the distinctive identity of these settlements. (4,018 households) would be within walking distance of a direct bus service to Site 160, a significant proportion of Character of Site and Area Doncaster Borough would be able to access West Moor Park Site 441 is a greenfield parcel used for agriculture. It does East by public transport – some 20,860 persons (9,258 not adjoin the motorway network and so it has a relatively households). This demonstrates the superior accessibility of tranquil character. Furthermore, the countryside in this part West Moor Park East to Site 160. of Doncaster plays a function in separating the built up areas of Carcroft and Toll Bar, which are presently two separate Access to the Motorway Network settlements. Unlike West Moor Park East Site 160 does not benefit from direct access to the motorway network. Access would be via In our view these characteristics indicate that Site 441 is less the A614 roundabout, which can be accessed directly from suitable for a major employment proposal than West Moor Junction 1 of the M180 by eastbound motorway traffic, but Park East. A development of Site 441 for employment would not by westbound traffic. Similarly traffic leaving Site 160 can result in the amalgamation of Toll Bar and Carcroft and the exit the A614 roundabout onto the motorway at Junction 1 in loss of the distinctive identity of these 2 communities. a westbound direction only. As explained in relation to our assessment of Site 160, West In order to address these shortcomings it would be Moor Park East is more suited to a major employment scheme necessary for arrivals from the east and departures to the because it comprises low quality countryside that already east to undertake double movements using the M18/M180 accommodates buildings and intensive motorsport uses, and roundabout junction 1 mile away to the west. This is clearly it is located opposite an established distribution park, West not as commercially attractive to occupiers as a site that has Moor Park. Furthermore development of West Moor Park direct access to an all movements motorway junction such East would not give rise to any settlement coalescence. as West Moor Park East. The Local Plan strategy requires logistics and industrial sites to have good access to the motorways and the absence of such access at Site 160 casts doubt on its delivery for employment.

16 . Accessibility The Accessibility Comparison (AC) document prepared by Fore The suggestion by Colliers that high value non-employment Consulting that we attach at Appendix 2 indicates that Adwick uses might be required to make a development of Site 441 train station would be a 20 to 25 minute walk from Site 441 viable also indicates that such uses may be inappropriate and the route would unattractive. It is therefore considered in planning terms. There is no consideration of this in the that rail travel to/from Site 441 is unlikely to be attractive to Council’s support for Site 441. staff/visitors. Having regard to the above, West Moor Park East has direct The AC goes on to show that whereas some 5,563 people access to Junction 4 of the M18 and so it does not have any of (2,572 households) would be within walking distance of the access difficulties faced by Site 441. It is therefore a site a direct bus service to Site 441, a significant proportion of that can be brought forward early on in the plan period and Doncaster Borough would be able to access West Moor Park it is not reliant on any public funding to deliver a satisfactory East by public transport – some 20,860 persons (9,258 access solution. households). This demonstrates the superior accessibility of West Moor Park East to Site 441. Comments on Sites Proposed as Employment Allocations – Conclusion Access to the Motorway Network In our view the planning case for the proposed allocations at Site 441 is located a considerable distance from the Sites 160 and 441 has not been adequately demonstrated motorway network (4 miles from the A1/A638 junction) and in the context of the Council’s current rejection of West Moor so it is unlikely to be as commercially attractive to occupiers. Park East as an allocation. As explained in relation to Site 160, the Local Plan strategy requires logistics and industrial sites to have good access In particular we have significant concerns regarding the to the motorway network. Site 441 has poor access to the soundness of Sites 160 and 441 in respect of the flood risk motorway network and in our view this casts significant doubt sequential test, accessibility and access to the motorway on its deliverability for major employment sites. Furthermore, network. in the event that the existing road network were to be used to achieve access to Site 441 this would result in significant HGV Notwithstanding these concerns (and without prejudice) traffic being directed through the residential communities of we consider that there is a compelling case for allocation Skellow, Carcroft, Adwick le Street and Woodlands. of West Moor Park East as an allocation in addition to Sites 160 and 441. Our assessment of sites with planning We note that access to the motorway network is also a permission demonstrates that there is a paucity of deliverable disadvantage of Site 441 that is highlighted in the Colliers opportunities for footloose occupiers seeking large sites Employment Land Review (February 2018), which forms part with easy access to the motorway network at the beginning of the evidence base to the Local Plan: of the plan period. This situation will not be assisted by the allocation of Site 441. Whilst Site 160 would represent an “The site is currently too remote from the motorway network opportunity close to the motorway network, it has constrained compared with other available/pipeline sites. It is farmed access, as explained above. Allocation of West Moor Park and crossed by drainage ditches. East would substantially increase the choice and availability of unconstrained land with direct access to the motorway Whilst potentially suited for employment use, the site network in that regard. requires major road infrastructure investment to open it up for development, and in particular, the A1M to A19 Link Road. However, as this link-road scheme isn’t funded or programmed currently, we believe the site represents a medium to long term opportunity at best.

Assuming the proposed link-road is delivered and the site allocated, we assess that 25% (12.2 ha) of the land may come forward for development in the LP period, but not until 2023-32 at the earliest. Development of the site is likely to require some form of development funding, possibly including higher value non-employment uses to be incorporated into any scheme on the site, not least to help with the costs of bringing the land forward (including a contribution towards the link-road). “

West Moor Park East . 17 7.0 Response to Council’s Comments on Proposed Allocation at West Moor Park East

In this section we provide a response to the stated reason It scores similar to the other sites through the Sustainability with the Local Plan consultation why West Moor Park East is Process not proposed as an allocation. The reason is set out below: Blue Anchor Leisure is concerned that there are some aspects “As with all the potential sites, this site fails the flood risk of the Sustainability Appraisal of West Moor Park East that sequential test as it is within Flood Zone 3. It scores similar to have not been scored correctly. Our client’s concerns are as the other sites through the Sustainability Process. It is currently follows: within Countryside Policy Area as designated in the UDP. It is to the east on the M18 and there more deliverable sites • In respect of promotion of public transport, we have which are adjacent to the main urban area and main towns received confirmation from First Bus that West Moor Park which offer better opportunities for securing sustainable East can be served by a 15 minute frequency bus service development particularly in securing public transport access. and this would become self funding after 5 years. In our Land to the east of the M18 is also a potential Minerals Area view this warrants a positive score. of Search.” • Regarding re-use of previously-developed land, West We consider each discrete element of the reason as follows: Moor Park East would involve the development of land that currently accommodates numerous buildings, Site fails the flood risk sequential test as it is within Flood roads and motorsport tracks. At it is a part-previously Zone 3 developed site this warrants a positive score.

As explained at Section 8.4 of this Vision Statement, a • In relation to biodiversity impacts, the Sustainability substantial proportion (approximately 65%) of West Moor Appraisal awards West Moor Park East a significant Park East is located Flood Zone 1. It is therefore sequentially negative score given that the site overlaps a designated preferable to sites which are predominantly in Flood Zone 2 or local wildlife site – Holme Wood. However, the indicative 3. We note that the approach in the Council’s Sustainability proposals for the site within this Statement show that Appraisal is to treat all opportunities with more than 20% of Holme Wood would be retained and enhanced within site area in Zone 3 in this way. However, this approach is not a new landscaped setting. In our view this warrants a consistent with the sequential test, as it fails to differentiate neutral score in relation to biodiversity impacts at worst, between sites that may be substantially or wholly in Zone 3 and arguably a green positive score given the scope for and sites that comprise significant areas of land with a lower a well planned development to respond to Holme Wood risk of flooding (as in the case of West Moor Park). As stated in a more sensitive manner than the current motorsport in Section 6, we consider that this is a flawed and blunt policy uses at West Moor Park East. tool to compare sites. • In respect of landscape impact, the Sustainability We have assessed the proposed employment allocations Appraisal states that West Moor Park East has low to no at Site 160 and Site 441 in the context of the sequential landscape capacity. However the origin of this comment test. Site 160 is almost entirely in Flood Zone 3 and it is not appears to be from the Council’s 2006/7 Landscape protected by flood defences. West Moor Park East is clearly Character Assessment and Capacity Study, which is out sequentially preferable to Site 160 in that regard. of date. The latter study pre-dates the development of West Moor Park East for motorsport uses and the Site 441 is entirely in Flood Zone 3. Whilst it is protected by development of a number of the large warehouses at flood defences, the Council’s Stage 1 Flood Risk Assessment the adjacent West Moor Park employment site. In the notes at Section 3.3.2 that these can be overtopped in an absence of up to date landscape evidence, it is our view extreme event or that they could fail or breach. Furthermore, that the Sustainability Appraisal landscape score is not the part of West Moor Park East in Zone 1 is substantially sound. greater in quantum than all of the 12 hectares of land proposed for employment at Site 441. In flood risk terms there is therefore no need to release Site 441, since the equivalent area of employment land can be provided in Zone 1 at West Moor Park East. The proposed allocation of Site 441 fails the sequential test.

18 . It is currently within Countryside Policy Area as designated These more deliverable sites which are adjacent to the main in the UDP urban area and main towns offer better opportunities for securing sustainable development particularly in securing West Moor Park East is located within a Countryside Policy public transport access. Area as defined in the UDP, but the UDP was prepared to meet development needs up to 2001 and it is therefore Deliverability out of time. Consistency with the Core Strategy overrides The deliverability of West Moor Park East is considered to the UDP-defined Countryside Policy Area as confirmed by be one of its strong points. The site is in single ownership the appeal decision at Westminster Drive, Dunsville (APP/ and direct access to Junction 4 of the M18 can be achieved F4410/W/16/3158500). Policy CS2 of the Core Strategy without the need to acquire third party land. directs new distribution warehousing to M18/M180 junctions at (inter-alia) Armthorpe. At Armthorpe this has resulted in Blue Anchor Leisure has a strong track record in delivering the identification of Broad Locations for major employment attractive unconstrained sites to the market as explained at Junction 4 of the M18 on the Core Strategy diagram in at Section 1 of this Vision Statement. The marketing of UDP-defined Countryside Policy Areas. Whilst we consider West Moor Park East that has been undertaken to date has that the Broad Location north of the A630 at Armthorpe is identified a number of well known commercial developers that undeliverable, as it fails the sequential test for flooding, these are interested in progressing an employment development designations show that the Council has previously been willing on the site. Furthermore, one of these developers has signed to release Countryside to meet Doncaster’s development Heads of Terms to acquire the land. This is a strong indication needs. Allocation of West Moor Park East for employment of the viability of West Moor Park East for employment and its would not create an unusual precedent in that regard. deliverability.

The UDP also pre-dates the Council’s approval of major Other Sites Adjacent to the Main Urban Area and Main Towns motorsport uses on the site, and the growth of the adjacent West Moor Park East is not located adjacent to the MUA, but West Moor Park, which has significantly changed the character it is a short distance from it, as confirmed by the plan we of the landscape in this part of Doncaster. In our view West provide at Section 1 of this Statement. Furthermore, the links Moor Park East comprises poor quality countryside. with the MUA will be improved by the proposed improvements to the A630 (West Moor link) - which are intended to unlock The Local Plan is the appropriate point to review UDP new housing and employment developments. The site has far designations in the context of development needs over superior links to the MUA than the proposed allocation at Site the plan period. In this context we note that the proposed 160 in that regard. employment allocations at Site 160 and 941 also comprise defined UDP Countryside Policy Areas. West Moor Park East is located in Armthorpe, a defined Main Town. Section 8.5 of this Vision Statement shows It is to the east on the M18 that a significant proportion of Doncaster Borough would be able to access West Moor Park East by public transport The Council’s comment in relation to this issue has not been – some 20,860 persons (9,258 households). This potential fully explained. There are numerous other major developments catchment workforce is more than double than the equivalent in Doncaster located on the eastern side of the M18, as we figure for the proposed employment allocations at Site demonstrate in the photographs we provide at Appendix 3. 160 and 441. West Moor Park East therefore compares These include schemes at Iport and Thorne. favourably with the alternatives that are presently supported by the Council. West Moor Park East is a part previously developed site that comprises poor quality countryside adjacent to the M18. It is Better opportunities for securing sustainable development also in the lee of the major warehouse buildings established particularly in securing public transport access at West Moor Park. It is our view that these characteristics, together with the high level of accessibility of the site, are The Council’s site assessment states that West Moor Park more important factors than the location of the site to the East scores similar to the other sites through the Sustainability east of the M18. The support in the Local Plan for employment Appraisal process. This does not indicate that there are other development along the M18 corridor is not conditional upon it alternatives that perform significantly better in respect of being to the West of the motorway. sustainability. In any event we have identified aspects of the Sustainability Appraisal of West Moor Park East that require revision.

Regarding public transport, Blue Anchor Leisure has secured in principle agreement with First Bus that existing bus services West Moor Park East . 19 can be extended into West Moor Park East to achieve a 15 minute frequency service at peak times. First Bus state in their 15 October 2018 letter of confirmation that “We feel the proposal ensures that the site is well served by public transport…”

Land to the east of the M18 is also a potential Minerals Area of Search

West Moor Park East is a mineral safeguarded area in the UDP, but the latter plan is out of time and it pre-dates the approval of major motorsport uses on the land. We have also confirmed with the Council’s Planning Policy Team that West Moor Park is not designated a Minerals Area of Search in the new Local Plan.(email attached at Appendix 4)

Response to Council’s Comments on Proposed Allocation at West Moor Park East - Conclusion Whilst we appreciate that the Council has to assess many sites as part of the Local Plan process, we consider that the stated reasons for rejection of the site as an employment allocation are not justified when broken down into their constituent parts. We assume that the new information provided within this Vision Statement will allow the Council to review its position on these issues.

Blue Anchor’s position is that West Moor Park East is a more sound allocation for employment than Sites 160 and 441, particularly when factors in relation to flood risk, accessibility and access to the motorway network are considered. However (and without prejudice) our client considers that there is a compelling case for allocation of West Moor Park East as an allocation in addition to Sites 160 and 441. Our assessment of sites with planning permission demonstrates that there is a paucity of deliverable opportunities for footloose occupiers seeking large sites with easy access to the motorway network at the beginning of the plan period.

20 . 8.0 Site Analysis

This section of the report sets out to summarise the existing with the additional small ponds added by 2018 with site information delivered through investigation and analysis current land use as a mobile home park. under the following headings; • A motorbike dirt track is shown in the north west of the 8.1 Site and Surrounding Areas site between 2006 and 2018. An additional motorbike 8.2 Site Photographs dirt track is located in the centre of the site however this 8.3 Aerial Views is not displayed on any of the historical maps. 8.4 Flood Risk Analysis The following ground profile has been identified on geological 8.5 Access Transport and Highways maps: 8.6 Landscape and Ecological Analysis • Superficial deposits - River Terrace Deposits present as Site Setting sands and gravels, Breighton Sand Formation as sands The site is centred at National Grid Reference: 466175 and the Hemingbrough Glaciolacustrine Formation as 405649 on land directly east of Junction 4 of the M18, clays and silts. Doncaster. • Nottingham Castle Formation Bedrock as Sandstone. The site is bound by the following: Borehole records from the historical site investigation (Ref.1 • North: Agricultural land and Appendix B) identified the following ground conditions;

• East: Agricultural land • Topsoil to 0.1m bgl.

• South: Yorkshire Aggregates, dog kennels, lakes and • Made Ground to 0 - 3.2m bgl – clays, silts, sands and lodges and scrub vegetation gravels.

• West: M18 road with agricultural land beyond • Natural Deposits to 3.5 – 9m bgl – clays, sands and gravels. The site covers an area of approximately 195 acres (79ha) and is currently used as arable land with former farm related • Bedrock was inferred at a depth of around 8.2m based properties, a motorbike park in the north and a mobile home on borehole refusal. park adjacent to Huggin Lake in the east. The site contains a gently climbing mound towards the south west. The site’s The EnviroCheck Report indicates the following: general topography is as follows: • A landfill site is located directly adjacent to the south of • North: 6m AOD the site.

• East: 2m AOD • BGS recorded mineral sites sit to the south and east of the site. • South: 9m AOD • Potentially infilled land sits to the west of the site. • West: 4m AOD • Discharge consents are associated with ditch drains Site Conditions within the centre and the eastern boundary of the site. A review of historical site plans from 1854 to 2018 has been undertaken. These indicate the site has predominantly The following groundwater conditions have been identified for remained undeveloped in agricultural land use associated the site: with Holme Wood farm and Holme Wood grange. The following • Groundwater was encountered during historical site historical development has been identified; investigation (Ref.1) at 0.9 – 6.78m depth.

• A sand and gravel pit is shown in the south east of the site • The site is located in an area of known ponds and ditch between 1930 to 1961. drains, indicating the presence of shallow groundwater • Holme Wood farm was constructed to the centre of the and poor surface water drainage. site in 1980. • The site is within a Zone 3 Total Catchment Source • A sand and gravel pit is shown in the east of the site in Protection Zone. 2000. This is shown as the current Huggin Lake in 2006

West Moor Park East . 21 8.1 Site and Surrounding Areas

Opportunities

Major transport corridor

Local arterial corridor

A630 to be upgraded to dual carriageway

Existing distribution units

Potential site access

Strategic transport nodes

Existing quarry

Off site woodland (screening)

Constraints

On site existing woodland (to be preserved and enhanced with scheme)

Site and the Surrounding Areas

22 . Site and the Surrounding Areas

West Moor Park East . 23 8.2 Site Photographs

15 In order to develop a sustainable and deliverable masterplan, the key link points and contours of the site have 14 been visually analysed to show key views and potential link 5 6 points. This has enabled us to sensibly develop a realistic 1 concept, diagrams and access points to the site 11 7 13 8 9 1 View West of Holme Wood Grange towards M18, with distribution centres in the background 12 10

2 View East showing boarding kennels and land for new access road into site 4 2 3

3 View North West towards M18

4 View West towards M18 with distribution Centres in the background

5 View South East to old motocross site

1 6 View West towards motocross

7 View South towards motocross

8 Derelict building on site

9 View East of Holme Wood Lane

2 10 View North across the site

11 View South across the site

12 View South across the site

3 4 13 View West across the site

14 View South across the site

15 View South across the site

5

24 . 6 7

8 9

10 11

12 13

14 15

West Moor Park East . 25 8.3 Aerial Views 4

1

2 This series of aerial views show the 3 topography, existing grass land and the built environment in and around the site.

E D A

B C

F

1

G

2

26 . B D C E

3

E I H D

A F

B

4

A Redundant buildings F M18

B Current Motocross/Go Kart track G Adjoining leisure site with holiday lodges

C Rough ground H Junction 4

D Proposed container storage I West Moor Park

E Quarry (Yorkshire Aggregates)

West Moor Park East . 27 8.4 Flood Risk Analysis

Flood Zone 2 Flood Zone 3 Main River Call for sites

Flood Risk Map Extract

The site is partly categorised within Flood Zone 3, that element In terms of the proposed development flood impact will be has a medium risk of flooding from the surrounding Rivers mitigated by; and watercourses, between 1 and 3.3% every year, however, significant areas are located in Flood Zone 1. • Adopting site levels/FFL’s above a design flood level • The design flood level is usually set at the 1:100 +Climate The vast majority of the site has a very low risk of flooding change flood level plus a 300mm freeboard from surface water around 0.1% every year. There are small pockets adjacent to the M18 which have a low to medium risk • Adopting flood resilient design measures in areas which between 0.1 and 3.3%. are below this level

These small areas could see levels below 300mm and up to • Adopting a Flood Action Plan which ensures the 900mm of surface water. development is safe for end users by detailing safe access/egress routes and management procedures The development type is classified as “less vulnerable” by during flood events the NPPF guidance. This development type is permissible in Flood Zone 3 subject to completion of an FRA and sequential In terms of the wider area flood impact will be mitigated by; test. An exception test is not required. • Modelling to demonstrate there is no loss of flood capacity – such that some areas of the site may require lowering The FRA will need to demonstrate there is no impact from of ground levels flooding to both the proposed development and the wider area.

28 . In terms of the layout, the following measures would make for • Provision of onsite treatment an easier argument to satisfy any flood risk concerns; Maintenance of the existing ponds and creation of • The denser built development should be focused towards new attenuation ponds draining to the ditch network is the centre of the site which sits within Flood Zone 1 recommended. • Areas of landscaping, hardstanding and new ponds Extension of the ditch drainage system is recommended as it should be focused to Flood Zone 3 areas will allow the development to maintain shallow gradients and • The above comments should not be taken to preclude will provide more efficient drainage of the site. this development in other Flood Zones (it is permissible subject to the details above) Areas of external hardcover should where feasible utilise porous paving and infiltration storage where possible. The site is anticipated to be underlain by granular material over clay. As such, groundwater levels are shallow during The site will need to be raised to the 1 in 100 year event flood winter periods and infiltration within the site will be poor. The level +300mm. anticipated drainage solution is; Flooding Sequential Test • Adoption of localised porous paving/Soakaways where Approximately 65% of West Moor Park East lies within Flood feasible Zone 1. The vast majority of the remainder of the site is Zone 3, with a small area within Zone 2. It is expected that of the • Surface water transit by open ditch network rather than developable area of the site, approximately 50% would take main drainage sewer- this will also help with the SUD’s place in Zone 1 and 50% would be provided in Zone 3. credentials for the site

• Attenuation by new/existing pond features The Local Plan must satisfy the sequential test when allocating sites for employment and other uses. As shown • Final discharge to the land drainage network in the Planning Practice Guidance table below, this requires land uses to be directed to the lowest risk sites first where At this stage comments have not been received from Yorkshire development needs cannot be allocated in Zone 1. Water regarding foul water drainage- though we would anticipate there to be limited foul water drainage/or capacity The Local Plan consultation confirms that it is not possible in the area. As such, at this stage we would expect to need to meet employment needs within Flood Zone 1. We have to include for; therefore compared West Moor Park East to the Council’s proposed employment allocations in order to establish • Upgraded YW foul water infrastructure whether development is being directed to the lowest risk land • Foul water pump station - consistent with the requirements of the sequential test.

Diagram Showing Sequential Test for Local Plans (source: Planning Practice Guidance)

West Moor Park East . 29 Proposed Sites for Employment Allocation Approximately 95% of Site 160 is located within Flood Zone 3, with a small residual area being located in Zone 2. The site does not benefit from flood defences.

The area of West Moor Park East in Zone 1 is sequentially preferable to Site 160. Given that no part of Site 160 is in Zone 1, and a significantly greater proportion of the site is in Zone 3, we conclude that it is not sequentially preferable to West Moor Park East.

Site 441 falls wholly within Flood Zone 3 albeit in an area benefitting from flood defences. However, we note that Para 7.1.3 of the Site Selection Methodology states that there is a risk that defences could fail. The Council’s Stage 1 Strategic Flood Risk Assessment states at Section 3.3.2:

“Even when flood defences are in place, there is always a likelihood that Site 160: Thorne South Urban these could be overtopped in an extreme event or that they could fail or Extension (40ha) breach. Where there is a consequence to that occurrence, this risk is known as residual risk. Defence failure can lead to rapid inundation of fast flowing and deep floodwaters, with significant consequences to people, property and the local environment behind the defence. Whilst the actual risk of flooding to a settlement that lies behind a fluvial flood defence that provides a 1 in 100- year SoP may be low, there will always be a residual risk from flooding if these defences overtopped or failed that must be taken into account. Because of this, it is never appropriate to use the term “flood free”.”

The part of West Moor Park East within Zone 1 is sequentially preferable to Site 441. Excluding flood defences there is no sequential preference between the part of West Moor Park East in Zone 3 and Site 441. As a whole West Moor Park East is considered sequentially preferable to Site 441 given the significant area in Zone 1. Site 441: Land at Carcroft Common, Site 941 lies wholly within Flood Zone 1. It is therefore sequentially preferable Carcroft (12ha) to that part of West Moor Park East that lies in Zone 2 and 3.

Rejected Sites for Employment Allocation We have additionally considered the rejected sites for employment allocation to further demonstrate that the low risk associated the subject site makes it sequentially preferable to many of the sites considered. Some sites are wholly covered by Flood Zone 3 (site refs: 001, 013, 091, 101, 461, 462, 932, 933, 934); some sites are no longer considered available/suitable for employment use by the Council (site refs: 041, 254, 265, 432, 771, 942); some sites are located in the Green Belt and therefore very special circumstances would need to be demonstrated for their release for employment (site refs: 159, 251, 461, 462).

Accordingly, none of the rejected sites are considered sequentially preferable to West Moor Park East.

Conclusion Site 941: Site 2, Land East of Poplars West Moor Park East is sequentially preferable to Site 160 given that almost Farm, Hurst Lane, Auckley (68ha) all of the latter site is in Flood Zone 3.

As a whole West Moor Park East is also sequentially preferable to Site 441. The Local Plan Allocation of Site 441 could be fully met within the Zone 1 area of West Moor Park East.

West Moor Park East is not sequentially preferable to Site 941. However, it is sequentially preferable to the other rejected employment allocations.

30 . 8.5 Access, Transport and Highways

Fore Consulting Ltd has been commissioned to provide a Sustainable Access Transport and Access Appraisal of the proposed development at West Moor Park East. This is provided in full at Appendix Pedestrian Accessibility 1 of the Vision document, and key extracts are also set out in Pedestrian infrastructure in the immediate vicinity of the site this section. is limited to a footway adjacent the southern edge of Holme Wood Lane, linking to uncontrolled crossings on the slip Existing Situation roads on the southern side of Junction 4 and along the A630 The proposed allocation site comprises around 195 acres towards Armthorpe. In addition, a Public Right of Way runs (79ha), and is located on the western edge of Armthorpe, along the eastern boundary of the site from Boston Park Farm approximately 15km from Doncaster town centre. The site is to Mosscroft Lane. bound by the M18 to the west, Holme Wood Lane to the south and east and agricultural land to the north. Although acceptable walking distances will vary between individuals and circumstances, standard distances that are Highway Network often used to describe short, medium, and long walks are The highway network in the vicinity of the site comprises the 0.5km, 1.0km, and 2.0km respectively. Figure 2 of the following: Access Appraisal presents the isochrones for these walking distance thresholds from the site, assuming only designated • The site is close to Junction 4 of the M18 motorway footways/footpaths are used. which provides strategic access to Doncaster, and in turn provides links to the wider motorway network from The existing footway along Holme Wood Lane will be improved its connections to the M1 at Rotherham and to the M62 to provide a width of 2.0m along the frontage of the allocation at Goole. The junction is a grade-separated roundabout, site. This would connect to the network of external pedestrian with slip roads connecting the roundabout to the mainline infrastructure. carriageways. Two circulating lanes are provided, with two lanes on each of the slip roads. Cycle Accessibility There is no existing cycle infrastructure in the immediate vicinity • From Junction 4, the A630 provides a strategic highway of the site. The Doncaster Cycle Map identifies a number of link to the Doncaster district. Immediately west of bridleways and advisory routes that provide links to Armthorpe, Junction 4, the A630 is a single carriageway road Cantley (and on to the town centre) to the south west, as well as subject to the national speed limit, with a carriageway Dunscroft and Stainforth, avoiding Junction 4 of the M18 and width of approximately 9m. A series of roundabout the A630. It is generally accepted that for commuting journeys, junctions provide access from the A630 to residential a distance of 5 miles [8 km] should be assumed; based on and commercial areas at Armthorpe, Edenthorpe, Long these distances, a large proportion of the Doncaster district is Sandall and Wheatley. It is understood that in partnership potentially within cycling distance of the site. with the Sheffield City Region, Doncaster Council have aspirations to upgrade the A630 to dual carriageway Cycle parking provision will be determined at the planning standard between Edenthorpe and Junction 4. application stage to confirm that an appropriate level of bicycle parking is provided for the development. The eventual • The site is accessed from Holme Wood Lane, which level of parking to be provided will accord with DMBC’s policy in turn is accessed from the east of M18 Junction 4. requirements. Holme Wood Lane is subject to the national speed limit. Immediately east of Junction 4 the carriageway is around 6m wide, reducing to generally narrower than 6m in the immediate vicinity of the site.

West Moor Park East . 31 Public Transport At present, bus service 15 serves Doncaster town centre along with residential suburbs across the borough, such as Wheatley to the north and also Balby (south west of the town centre); terminating at its northern extent at Clay Lane approximately 3 miles from the proposed allocation. In discussions, First South Yorkshire Ltd have confirmed that this service can feasibly be extended to the proposed allocation site to provide a public transport service and this could potentially operate at a frequency of up to 20 minutes. A letter confirming this is provided on the right and in Appendix 1.

The proposed extension to the 15 service route is demonstrated below and in Appendix 1 . By extending the 15 service to the allocation site, a substantial population catchment within the Doncaster district (including areas south west of the town centre) will be within a convenient walking distance of a bus stop that will provide direct bus services to West Moor Park East.

It is estimated that a population of approximately 20,860 people and 9,258 households across the borough would then be served by a direct public transport service to the allocation site.

Site boundary

Bus stop catchment

Bus stops 15-15A

Proposed bus stop extension

Proposed Bus Stop Extension

32 . Vehicular Access the changes are likely to involve widening of the carriageway Based on the quantum of development envisaged, it is to 7.3m (plus further widening around the bend towards anticipated that Holme Wood Lane will need to be upgraded. Junction 4) plus provision of a footway of 2.0m width. An The precise changes will be confirmed in detail at the indicative arrangement is demonstrated on Fore Consulting appropriate stage; however, following an initial assessment, drawing 3132/SK001/001.

Possible Vehicle Access Arrangements

Based on adopted highway information obtained from Internal Layout and Car Parking Doncaster Council, it is evident that the embankments and The internal layout of a future development on the allocation verge on the north side of Holme Wood Lane form part of the site and car parking requirements will be considered and adopted highway. The necessary widening of Holme Wood Lane determined at the appropriate stage of the planning process. can therefore feasibly be achieved within the extent of land controlled by the promoter and the adopted highway, without However, car parking will be identified in accordance with land controlled by third parties. On this basis, the necessary DMBC’s prevailing technical guidance. At the time of writing highway works are deliverable by the scheme promoters. this is set out in the DMBC document “Development Guidance and Requirements Supplementary Planning Document”. For ‘General Industrial’ developments above 2,500m2, 1 space per 30-50m2 would be expected.

West Moor Park East . 33 Similarly, the requirement for electric vehicle charging points Based on the assessments undertaken, it is considered will be determined at the appropriate stage of the planning that the proposed development is capable of being safely process in discussion and agreement with DMBC. accessed, and that there are no transport or highway reasons to prevent allocation of the site for development. In particular: Traffic Impact Given that vehicular access will be taken from Holme Wood • Based on an initial assessment of feasibility, satisfactory Lane directly off Junction 4 of the M18, an initial capacity vehicular access can be provided on land under the assessment of the junction has been undertaken at this early control of the promoted or adopted highway via Holme stage given its importance to the operation of the strategic Wood Lane. road network. • Technical dialogue has commenced with Highways The assessments undertaken demonstrate that the Junction England regarding the impact of the proposals on the 4 layout would satisfactorily accommodate the proposed Strategic Road Network. Based on the initial assessments, development traffic associated with West Moor Park East. traffic associated with the allocation proposals is capable of being safely and efficiently accommodated at Junction It is considered that traffic associated with the West Moor 4 of the M18. Park East development as proposed, plus planned and committed development can be satisfactorily accommodated • Satisfactory mitigation in respect of sustainable access at Junction 4 of the M18. The promoters have commenced can be delivered. Specifically, in discussion with First technical dialogue on the impact of the proposals Highways South Yorkshire it will be feasible to extend the 15 England and the relevant assessments have been submitted service to directly serve the development site. This for review. would provide a direct, sustainable connection to a significant residential catchment within Doncaster, Summary and Conclusions including residential areas at Wheatley, around the town This Transport Appraisal has been prepared to support the centre (including interchange possibilities at Frenchgate promotion of land adjacent Holme Wood Lane, known as Interchange) and Balby, south west of the town centre. West Moor Park East. At this stage the proposal comprises up to 2,301,000ft2 of floorspace of employment uses. Overall, the proposals are deliverable in highways terms and can be satisfactorily accommodated on the local transport This report has examined the existing transport network in the network. On this basis there are no barriers to the site being vicinity of the site, outlined the current allocation proposals allocated for employment use. and considered the resulting impact on the transport network.

34 . 8.6 Landscape and Ecological Analysis

Existing Landscape Character The wider landscape is generally flat, however, the centre of The site comprises a significant area of previously disturbed the site is lower than the surrounding access road, motorway ground, partly restored following sand and gravel extraction, and boundaries following previous gravel workings. Generally, and now covered by low quality grassland and the more recent from the centre the ground rises towards the boundaries. significant disturbance of the motorcross park. Whilst some areas of the site have an open character, some The site is partially enclosed by mature trees and hedgerow sense of enclosure is provided locally to the north-east and to the south west and bounded by the M18 motorway to the south and south-west by mature trees and hedegrows. north and west.

Existing Leisure Site Land

Vigo Owned Land

Potential Residential/ Dominant Site Future Existing commercial Water body Woodland/ Managed Disturbed landscape boundary Development building land use mature landscape landscape feature Landscape Analysis

Vegetation screening the M18 is patchy and the motorway is There is a lack of tranquillity on the site primarily due to evident throughout the site, interrupting views to the north movement and noise from the M18 motorway and also the and west. motorcross activities within the site.

Views to the west and south are characterised by the skyline The movement and noise disturbance, and evidence of dominance of industrial/commercial activities in the form of industrial and commercial activities are in contrast to the large commercial units and existing gravel workings. perceptual and aesthetic qualities that would be expected from open countryside. To the north east and east, views are local, curtailed by the rising ground of the site boundary.

West Moor Park East . 35 Landscape Opportunities shelter and screening, in particular from the M18 motorway There is an opportunity on the site to enhance the boundaries and also from existing and future site activities. of the site with new woodland planting. In addition to the ecological benefits described in the following section, a There is an opportunity within the site to provide sustainable new peripheral woodland would reflect and strengthen the urban drainage (SUDs) features with associated internal site general landscape pattern of woodland cover found in the landscaping. This would improve the aesthetic qualities of the wider landscape. site resulting in an attractive place to work.

Enhancement of the boundaries would also provide a new Furthermore, larger SUDs features and associated naturalistic woodland setting to existing residential and recreational land landscaping will not only provide habitat improvements but use bordering the site. New woodland planting would provide also provide informal recreation opportunity and improve site wide amenity value.

1 M18 MOTORWA

COMMERCIAL / IDUSTRIAL LAD USE

AGRICULTURAL LAD LAD RISIG

2 COMMERCIAL / IDUSTRIAL LAD USE

LAD RISIG

3 M18 MOTORWA

4 COMMERCIAL / IDUSTRIAL LAD USE

36 . Existing Ecology Holme Wood along with sections of hedgerows and trees to Broad habitat types on site include improved and species the north and south west boundaries provide more mature, poor semi-improved grassland (acidic), ruderal vegetation, established habitats of value due to age, structure and individual trees and tree belts, woodland, hedgerows and species composition. The habitats of value are limited in water bodies (lakes and drains). extent and isolated both within site and the wider landscape.

The locally designated woodland, Holme Wood LWS, lies Water bodies include drainage ditches associated with the along the northern boundary of the site. It includes mature surrounding agricultural land provide potential habitat for oak and sycamore and sweet chestnut in the canopy, a variety water vole, grass snake and wildfowl species. of native shrubs in the understory and bluebell throughout the ground flora. The species present and evidence of past Ecological Opportunities coppice management indicate that the woodland has a long Mitigation and enhancements opportunities with the history, potentially ancient in origin. development of this site include:

Generally, across the rest of the site the habitats are young • Protect existing features of ecological importance. and of low ecological value, originating from restoration • Create, extend and diversify semi- natural habitats. works following sand and gravel extraction, predominantly consisting of improved grassland. • Enhance connectivity within the site and wider landscape by providing stepping stones of semi natural habitat within an intensive agricultural area.

Site boundary Existing building

Existing leisure site Water body

Hedgerow with mature trees

Ecological Analysis

West Moor Park East . 37 9.0 Indicative Masterplan

38 . Class Unit Sq.m Sq.ft B2 Unit 1 4,047 43,000 B2 Unit 2 4,047 43,000 B2 Unit 3 3,420 36,000 B2 Unit 4 3,420 36,000 B2 Unit 5 2,905 31,000 B2 Unit 6 3,900 42,000 B2 Unit 7 8,225 88,000 B2 Unit 8 17,716 190,000 B2 Unit 9 32,640 350,000 B2 Unit 10 27,136 292,000 B8 Unit 11 46,788 500,000 B8 Unit 12 60,500 650,000 2,301,000 *Indicative only

Phase 1 Phase 2

Potential extension to allocation on parcel of land owned by Vigo Group.

West Moor Park East . 39 10.0 Landscape and Ecology Vision

The site offers an opportunity for the sustainable development of a high quality work environment which integrates landscape The elements of the new landscape include: and ecological features that are sympathetic to the wider • new woodlands and habitat connection to existing landscape. woodlands; and new ponds and swales connecting to existing watercourses. The development of a multifunctional landscape will bring about important ecological and aesthetic qualities alongside an improvement in amenity value and informal recreational opportunities.

Extend diversify semi-natiral habitats

Preserve enhance existing features of ecolgical importance SUDs habitat creation - - Holme Wood with landscape scrub and grassland buffer

Strengthened peripheral Enhanced habitat connectivity - vegetation new woodland and scrub

Peripheral screening

SUDs with landscaping associated with internal roads - improved aestheic qualities of SUDs habitat creation - developemnt scrub and grassland with stands of trees to boundary

Informal recreation increased amenity value

Boundary enhancement - new woodland setting providing New boundary hedge shelter screening reflecting existing along Holme Wood Lane

Site entrance

Site Primary Secondary boundary estate road estate roads

Landscape and Ecological Vision

Primary Estate Road - D

40 . Habitat Creation and SUDS - C

A Main Entrance

Existing Proposed Proposed entrance Proposed screen vegetation Existing arable Track scrub road with scrub edge Kennels

Low mounding to maximum of 1.5m with species to Species to include broom, gorse, scrub, include oak, birch, hazel, sycamore, hawthorne. occasional birch, rowan and oak.

B Peripheral Vegetation

Enhanced screening Proposed

M18 Existing ditch vegetation development area B D

C

Approximately 20m wide A woodland belt set on low mounding

C Amenity Value, Habitat Creation & SUDs

Woodland screening to the Open grassland with Scrub planting south east of proposed units occasional scrub SuDs (varying depth) with trees

D Primary Estate Road, Landscape & SUDs

Boundary Footpath landscape buffer Proposed units SuDs Primary estate road

West Moor Park East . 41 11.0 Benefits and Opportunities

The development will be accessible by Existing planning permission on the site for frequent bus services. major motorsport and leisure uses. The development will be accessible by a large potential workforce, including significant parts of the main urban area of Doncaster.

Part previously-developed site. Not Green Belt or subject to any other landscape or ecological designation. Single land ownership, with Blue Anchor Significant proportion of site within Flood having an impressive track-record of Zone 1. delivering similar schemes and bringing land to the market. Significant habitat creation and new tree/ shrub planting. Strong interest from a number of commercial developers with the experience and financial resources needed to bring forward industrial sites of this scale.

An employment offer orientated towards Class B2 uses in the first phase, responding to current market needs and providing something different to the Class B8 focused schemes developed in the area to date. A unique, strategically important location, Delivering a range of employment uses to close to Junction 4 of the M18, meaning meet Doncaster’s economic needs. The easy access to the national highway network. estimated job creation of the proposed development is approximately 3,500 jobs. Significant additional employment would be created during the construction phase.

Creating jobs for local people, close to areas of proposed major housing development. Increasing demand for local suppliers and services, thus supporting existing businesses.

42 . 12.0 Conclusion and Next Steps

This Vision Statement presents the evidence necessary to justify the allocation of West Moor Park East for employment in the Local Plan. It has been shown that:

• There is a shortage of deliverable opportunities for major employment with good access to the motorway network. Failure to provide sufficient deliverable sites attractive to the market will prevent Doncaster from achieving the SCR growth target, which is set at a higher level than the rest of the UK.

• The planning case for the proposed allocation of Sites 160 and 441 has not been adequately demonstrated in the current draft Local Plan or the evidence base. We have particular concerns about these sites in respect of the flood risk sequential test, accessibility and access to the motorway network.

• Notwithstanding these concerns (and without prejudice) there is a compelling case for allocation of West Moor Park East in addition to Sites 160 and 441 to help remedy the deliverable opportunity shortage we identify above.

• The stated reasons within the Local Plan Site Methodology for rejection of West Moor Park East are not justified when broken down into their constituent parts.

• Key strengths of West Moor Park East are the ability to achieve direct access onto the M18 at Junction 4; the single ownership of the site; the accessibility to the MUA; and the significant proportion of the site within flood Zone 1.

• There is very significant interest in the development of West Moor Park East by the commercial development sector. It is a site that the market wishes to see come forward.

Blue Anchor Leisure wishes to work collaboratively with the Local Planning Authority with a view to ultimately achieving an employment allocation in the new Local Plan. It is anticipated that this vision document will evolve and accompany representations at subsequent stages of the Local Plan process.

An employment allocation in the new Local Plan will give rise to a formal contract between Blue Anchor and a commercial developer to develop the land for employment. Initially an outline planning application would be submitted to secure a broad planning framework for the entire site with the means of access. Reserved matters applications would then follow according to operator demand or whether the developer wished to deliver some speculative floorspace.

It is expected that the site would be developed in three phases, with the first phase being started within 12 months of adoption of the Local Plan. The entire development would take approximately 5 years to complete.

West Moor Park East . 43

EXISTING SUSTAINABILITY APPRAISAL

3A(ii)Distance to StopBus (SYPTE 8A(i) Encourage 8A(i) rethe 9A(i) Access 9A(i) toPublic Space Open 11A(iv)EAFlood Warning or Alert 7B(i)Minimise RiskHealth to and 8B(ii) 8B(ii) FibreBroadband Coverage 14(ii) PollutionSurface to Water 3A(iii)Access Cycleto Network 11A(ii)Surface Water Flooding 14A(ii) BestandMost Versatile 3B(i)Access Existingto Centre 11A(iii)Areas Benefitting fr 3A(i) Distance 3A(i) Trainto Station

14A(i) Minerals 14A(i) Sterilisation 14B(i)Groundwater Source 14b Agricultural14b Land 12B(i)Landscape Capacity 11A(i) Main 11A(i) RiverFlooding 8A(ii)Contaminated Land 8B(i)Highways Capacity 13A(i) Heritage 13A(i) Impacts 8A(iv)Unstable Land 8A(iii)Landfill Sites 13B(i)Archaeology Agricultural Land Air14C(i) Quality 12(i) 12(i) Biodiversity additionalwork) FloodDefences CoreNetwork and Protection Bodies Safety buildings Area Site Ref. Site Name

-

useof land

(with

om

937/1031 West

Moor Park - - 0 - + 0 0 0 0 + + 0 - + - - -- - 0 -- ? ? 0 0 -- 0 East 001 Thorne 0 - + - + 0 0 0 0 0 0 0 - + + + - - 0 0 0 ? ? 0 -- 0 North 092 Balby Carr - + 0 0 - 0 0 0 0 + + + + - + + - + 0 0 + + + 0 -- 0 Bank 441 Carcroft 0 + + - + 0 0 0 0 - + 0 - 0 + + - - 0 0 0 ? ? 0 -- 0 Common 878/1032 Rossington - + 0 + + ++ + - 0 0 + + + + + + -- ? 0 0 + ? ? 0 -- 0 941 Poplars - + 0 - + 0 0 0 0 - + 0 + + + + ------? ? 0 0 -- 0 Farm

AMENDED SUSTAINABILITY APPRAISAL

8B(ii) 8B(ii) FibreBroadband Cove 14(ii) PollutionSurface to Wate 3A(iii)Access Cycleto Network 11A(ii)Surface Water Flooding 14A(ii) BestandMost Versatile 3B(i) 11A(iii)Areas Benefitting from 3A(i) Distance 3A(i) Trainto Station 8A(i) Encourage 8A(i) rethe REPLACEMENTCRITERION: 7B(i)Minimise RiskHealth to 11A(iv)EAFlood Warning or NEWCRITERION: Ability to 14A(i) Minerals 14A(i) Sterilisation 9A(i) Access 9A(i) toPublic Open 14B(i)Groundwater Source 14b Agricultural14b Land (with 12B(i) 3A(ii)Distance to StopBus Main 11A(i) RiverFlooding 8A(ii)Contaminated Land (CRITERIONREMOVED) 12(i) 12(i) Biodiversity Impact 8B(i)Highways Capacity 13A(i) Heritage 13A(i) Impacts minimise travel workto

(SYPTECore Network 8A(iv)Unstable Land Access Existingto Centre 8A(iii)Landfill Sites 13B(i)Archaeology landandbuildings Agricultural Land Air14C(i) Quality additionalwork) FloodDefences LandscapeCapacity andSafety Protection AlertArea distances Bodies Space Site Ref. Site Name

-

useof

rage

r

937/1031 West Moor Park n/a + 0 + + 0 0 0 + + 0 0 + - - 0 - 0 0 ? ? 0 0 -- 0 + East 001 Thorne - - 0 + 0 0 0 0 0 0 0 - + + + - - 0 0 0 ? ? 0 -- 0 - North 092 Balby Carr - 0 0 - 0 0 0 0 + + + + - + + - + 0 0 + + + 0 -- 0 + Bank 441 Carcroft 0 0 0 + 0 0 0 0 - + 0 - 0 + + - - 0 0 0 ? ? 0 -- 0 + Common 878/1032 Rossington n/a + 0 + ++ + - 0 0 + + + + + + -- ? 0 0 + ? ? 0 -- 0 + 941 Poplars - 0 0 + 0 0 0 0 - + 0 + + + + ------? ? 0 0 -- 0 0 Farm

Plans and LDF Room 3/12 Direct Line: Temple Quay House Customer Services: 2 The Square e-mail: Bristol, BS1 6PN

Mr Jeremy Johnson, Regeneration and Environment, Your Ref: S&PDPD Sub Doncaster Metropolitan Borough Council, Our Ref: Civic Office, Doncaster, Date: 03 June 2014 DN1 3BU

Dear Mr Johnson,

Doncaster LDF Sites and Policies Development Plan Document

Introduction

1. I have been appointed by the Secretary of State under Section 20 of the Planning & Compulsory Purchase Act 2004 to undertake the independent Examination of the Doncaster Metropolitan Borough Sites and Policies Development Plan Document (the DPD). The preparation of the DPD follows the adoption of the Council’s Core Strategy in May 2012. It is the Council’s intention that, together, these documents will form the Local Plan for the Borough.

Format of Examination

2. The purpose of the Examination is to enable me to assess the DPD against the statutory requirements to ensure that it is legally compliant, justified, effective, positively planned and consistent with national guidance and that any requirements in terms of the duty to co-operate have been satisfied.

3. Having read all of the Representations made to the DPD and the other documents which have been provided to me I have decided to hold the Hearing sessions of the DPD Examination in 2 parts. I will first examine the methodologies, processes and contextual background provided by the adopted Core Strategy and national guidance which the Council employed to arrive at its choice of allocated sites and policy directions. These sessions I refer to as the Stage 1 Hearings. These will be followed by the Stage 2 Hearings which will examine individual sites. Should the methodologies, processes and contextual background examined in the Stage 1 Hearings be found to be unsound and/or not legally compliant, the resources required to undertake the further examination of individual sites could be wasted.

4. In these circumstances I have agreed to provide the Council with a letter

www.planningportal.gov.uk/planninginspectorate

setting out my conclusions on the matters examined at the Stage 1 Hearings. After considering this the Council would then be in a position to decide the way in which the Examination should proceed. The Stage 1 Hearings were held between 29 April and 2 May 2014 and this letter sets out my conclusions on the matters examined. As I made clear at the beginning of the Stage 1 Hearing sessions, I do not intend that the matters which have been explored through the Hearing sessions which have already taken place will be subject of further debate. My further consideration of the matters raised by Representors will be strictly limited to consideration of any Main Modifications upon which the Council has re-consulted, the merits of individual sites and whether the Council’s methodologies, processes and contextual background have been applied to individual sites and policies in a consistent manner.

Main Modifications

5. The legislation contains a clear dispensation that a DPD can be changed after Submission. Where these changes are significant and have a bearing on the soundness or legal compliance of the DPD they are referred to as Main Modifications. The Council is required to formally request me to make Main Modifications before I can recommend such changes. However, on my advice, the Council has not yet made such a request. Where proposed Main Modifications are very extensive they can amount to what is fundamentally a new plan. It would not be appropriate to make Main Modifications which have this effect at this late stage in the process. Until I have heard the evidence and I know the extent of any proposed Main Modifications, I am not in a position to know whether they would amount to a new plan. Some potential Main Modifications were discussed during the Hearing sessions. However, any Main Modifications which the Council proposes will need to be the subject of re- consultation and Sustainability Appraisal (SA). I will take into account any duly- made Representations which are submitted in regard of the proposed changes in a later stage of the Examination.

The adopted Core Strategy and the DPD

6. The Core Strategy Objectives seek, amongst other things, the regeneration of Doncaster and the surrounding former mining settlements. To achieve this, Core Strategy Policy CS2 closely specifies the quanta of housing development which would be directed to each group of settlements – the Sub-Regional Centre (Doncaster), the Principal Towns, the Potential Growth Towns, etc. A similar – albeit less closely confined - approach is adopted in respect of employment development. The overall effect is that the Core Strategy is a complex document which seeks, in a settlement-selective framework, to deliver the sustainable regeneration of Doncaster and surrounding settlements. However, this detailed approach significantly constrains the freedom of choice available in any subsequent Site Allocations DPD.

7. Given that it is designed to take forward what is already a complex Core Strategy, it is almost inevitable that the DPD will itself be complex. At the Hearings a number of representors expressed the view that the DPD was difficult to use. I have to agree. I found that the DPD was extremely difficult to understand and, in my view, dealt with issues in a overly-complicated way.

8. Partly in an effort to resolve its own difficulties in producing the DPD, the Council has adopted an ‘interactive map’ approach. This electronic document gives ready access to relevant policies from a series of map-based documents. By identifying the site in question, the tool allows access to the relevant policies. For those who are familiar with this tool, it appears to work very well. However, not all users will employ the DPD in this way. When produced as a ‘paper’ document, the DPD appears somewhat muddled and difficult to follow with matters relevant to individual sites being scattered in policies throughout the document. In my view the ‘interactive map’ approach deserves praise. It is clearly an innovative approach to a difficult problem. It presents a wide range of information in an accessible form – but only provided that the user is aware of which site he or she is concerned with. In my view the Council needs to assess the way in which the DPD is perceived as a ‘paper’ document and should seek to rationalise and simplify the structure of the ‘paper’ document to make it more ‘accessible’ to users. I also consider that the Council should reappraise the way in which it organises the subject matter of the DPD to exclude unnecessary complexities and to bring related matters into one place.

Duty to co-operate

9. Section 110 of the Localism Act 2011 amends section 33 of the Planning and Compulsory Purchase Act 2004 and imposes a ‘duty to co-operate’ on Councils who submit plans for Examination after 15 November 2011. The National Planning Policy Framework (NPPF) was published in March 2012. Paragraph 178 states that public bodies have a ‘duty to co-operate’ on planning issues that involve strategic priorities which cross administrative boundaries.

10. In circumstances where a Local Plan is coming forward as a Core Strategy with subsidiary DPDs (as is the case here), one would expect that the bulk of the strategic issues would have been resolved at the Core Strategy stage. However, this need not always be the case. The Council’s Core Strategy was submitted before 15 November 2011 and the Inspector’s Report was provided to the Council before the former Regional Strategy (RS) was revoked and before the NPPF was formally published. The Core Strategy was not therefore required to satisfy the ‘duty to co-operate’. However, that is not to say it was prepared outside of any strategic context. The Core Strategy was found sound and therefore was in general compliance with the, at that time extant, RS. The RS was prepared on a collaborative basis which itself demonstrates a foundation of co-operative working.

11. Since the revocation of the RS, co-operative working has moved forward. The creation of the Sheffield City Region (SCR) Combined Authority is clearly a significant step. Its shared decision making powers are currently limited to economic development, regeneration and transport issues. An Economic Growth Plan has been produced which aims to structurally transform the City Region’s economy and, through officer working groups, a variety of joint studies and reports have been produced. Work is proceeding on developing consistent databases. Co-operative working with neighbouring authorities who are not part of the SCR is less formalised. Nonetheless, there has been regular contact through the plan preparation processes. The private sector and other bodies have been included in the Council’s processes as appropriate.

12. I note concerns raised by some Representors that the new decision making processes at strategic level are sometimes less than transparent. The Council may wish to address these concerns. Nonetheless, I am satisfied that the Core Strategy was produced on the basis of the clear strategic context provided by the RS and that collaborative working has progressed since the time that the RS was revoked. No adjacent local authority raises any concerns that the ‘duty to co-operate’ has not been satisfied. Whilst the ‘duty to co-operate’ goes beyond simply consulting neighbouring authorities and other bodies on proposals, I note that a number of adjacent authorities refer to on-going liaison with the Council or state that there are no strategic issues which need to be addressed at this stage. The Council argues that the consultation responses represent only the ‘tip of an iceberg’ in respect of the amount of background liaison which has taken place.

13. I can understand that some Representors foresee that a number of strategic issues are likely to be identified in the future which could only be resolved between local authorities working at a strategic level. For instance, the Forecasts of Population and Households for the Sheffield City Region - Final Report March 2013 document raises significant issues around the balance of jobs and houses which will need careful consideration. Where these are issues which have a bearing on this DPD, I deal with them below. However, co- operation is an on-going process which needs constant re-appraisal. It cannot be expected that the Council will, at every stage, have achieved a co-operative solution to every matter as it arises. I am satisfied that, up to this point, this DPD has been prepared within a context of proportionate ongoing engagement with the relevant bodies, that the engagement has been constructive and that the ‘duty to co-operate’ has been satisfied. However, co-operation clearly needs to continue and an early review of the DPD may be necessitated if this work demonstrates that the assumptions on which the DPD is based have changed.

Objectively assessed need for housing

14. Paragraph 47 of the NPPF states that Councils should ensure that their local Plan meets the full, objectively assessed needs for market and affordable housing in the Housing Market Area (HMA) so far as is consistent with the policies set out elsewhere in the NPPF. Paragraph 159 indicates that Councils should prepare a Strategic Housing Market Assessment (SHMA) to assess their full housing needs working with neighbouring authorities where HMAs cross administrative boundaries. Paragraph 218 of the NPPF makes clear that, in appropriate circumstances, RS policies can be reflected in emerging Local Plans by undertaking a partial review which focuses on the specific issues involved and that, in drawing up DPDs, authorities may draw on the evidence which supported RSs supplemented as necessary by up-to-date, robust local evidence.

15. As I have noted above, preparation and Examination of the Council’s adopted Core Strategy pre-dates the publication of the NPPF. The housing requirement set out in Core Strategy Policy CS10 drew on the evidence base used to prepare the RS and the requirement is the same as that which was specified by the RS. The Council claims that it did not simply adopt the RS target and argues that the housing requirement of the Core Strategy was independently arrived at. However, no reassessment exercise took place. Rather, the process appears to have amounted to consulting interested parties on the appropriateness of the RS requirement after RS revocation was announced. No major objections to the employment of the RS requirement were received. The RS requirement was not simply an assessment of housing need. It was based on an apportionment of housing which reflected constraints on provision in other local authority areas.

16. Neither the Core Strategy nor this DPD is supported by an up-to-date SHMA which independently assesses the whole housing need. Although the Core Strategy was adopted only 2 years ago, the evidence which informed the RS housing requirement was collected in 2004 and the national housing market has changed significantly during this period of recession. The Council is currently working on a new SHMA but I was informed that this was primarily aimed at assessing the need for affordable housing and was not intended to provide a full picture of objectively assessed housing need in the Borough. It is the Council’s intention that, at some point in the future, a fully comprehensive SHMA would be produced covering the whole of the SCR which would inform the next round of plan-making.

17. I accept that there is some evidence to suggest that Doncaster operates as a single HMA. There is also evidence to the contrary, including evidence of in-and out-commuting. HMAs can change over time. A SCR-wide SHMA may involve a re-assessment of the Council’s current position. However, in the light of available evidence, I am not persuaded that the Council is necessarily wrong in its conclusions on this point.

18. I heard evidence that recent proposals for significant growth in jobs as set out in the SCR Growth Plan could not be accommodated by the housing requirements used in the DPD. There are clear indications from the Forecasts of Population and Households for the Sheffield City Region - Final Report March 2013 document that the balance of jobs and housing relied on by the Council may be unreliable. The evidence tends to suggest that the Council’s housing requirement would support only a fraction of the jobs sought by the Council’s regeneration strategy. I note the Council’s view that changes in economic activity and commuting rates may deliver the necessary uplift in jobs provision. However, I have seen no evidence to show that these assessments are accurate or that the changes in economic activity and commuting are capable of being achieved. In these circumstances I am not satisfied that reliance on the RS/Core Strategy housing requirements in the preparation of this DPD is a sound approach.

19. In my view neither the adopted Core Strategy nor this DPD is NPPF-compliant. Contrary to paragraph 159 of the NPPF, neither document is supported by an objective assessment of the need for housing. The evidence base which supports the Council’s housing requirement is out-dated and has not been systematically re-appraised. No review focusing on the specific issues involved has taken place nor has the evidence been supplemented by up-to-date, robust local evidence as is required by NPPF paragraph 218. No review is imminent to address these deficiencies. Whilst a SCR-wide SHMA would produce definitive answers to the housing market area/housing needs issues, no such assessment is in prospect in the near future.

20. The Council considers that the DPD should be prepared in-line with the adopted Core Strategy requirements, the 2 documents together forming the Local Plan for the borough. However, in 2 recent similar cases - Gladman Homes v Wokingham Borough Council and Gallagher Homes Ltd and Lioncourt Homes Ltd v Solihull Metropolitan Borough Council - a Council’s decision to adopt a Local Plan has been challenged in the Courts partly on the basis that the documents failed to comply with the NPPF in that they were not based on an up-to-date objective assessment of housing need. The former case is yet to be heard and I understand that the Council in the latter case is submitting an application to appeal to the Court of Appeal following a refusal of permission to appeal in the High Court. Nonetheless, in these circumstances it may be that, even if I considered that the Council’s approach was sound, this may not be accepted by the Courts.

Site assessment and Sustainability Appraisal (SA).

Commitment sites

21. Policy SP16 of the DPD sets out the proposed housing allocations. A large proportion of these are sites which already have planning permission – they are effectively ‘commitments’. The Council has automatically included them as allocations in order to provide a comprehensive picture of its strategy and to provide a solid basis for taking the sites forward should the existing planning permissions expire. These ‘commitment’ sites have not been subject to the same comparative assessment as other allocated sites. However, by including these sites in the list of allocations there is an inference that they are more sustainable than those sites which have not been allocated. That may not the case as the sites have not been compared alongside those other sites. Should the planning permissions on these sites expire without development coming forward, their inclusion as allocations would enable a further planning application to come forward without there being the need to question whether the sites are the most sustainable option when compared to other potential sites.

22. I accept that these commitment sites have been through the planning application process and have been found to be acceptable. However, this is a different process to the comparative process which should inform site selection in a Local Plan. As was pointed out at the Hearings, there are many reasons why the owner of a site may seek planning permission. It does not guarantee that development will come forward. In my view there should be the ability to review the sustainability credentials of these sites against other sites if development has not come forward during the lifetime of the planning permission. While I can understand the Council’s reasons for including the sites as allocations, I do not consider that these ‘committed’ sites should be included in the policy as such.

Phasing of development

23. The council’s overall strategy is directed at the regeneration of settlements and this involves the development of a number of key brownfield sites. In these circumstances I consider that, in principle, a policy which encourages the early delivery of these sites in acceptable and would accord with the thrust of NPPF advice. However, this is provided that there is a reasonable prospect that the brownfield sites will come forward. A strategy which held back all development in the hope that sites which were unattractive to the market would be forced to come forward for development could ultimately be sufficient to inhibit development to the extent that the strategy would be derailed.

24. I have been informed that 61% of the Council’s housing allocations (12,994 dwellings) are phased in a way which would allow them to come forward in the first 5 years of the plan period. Of these, 34% would be on greenfield sites. On the face of it, this pattern of phasing appears essentially sound. However, examination of the housing allocation sites in Table H1 of Policy SP16 indicates that a large proportion of the sites in this early phase of development are sites which already have planning permission – the ‘commitment’ sites referred to above. I accept that development of some of these sites is underway but I have no clear overall understanding of how many of the remainder are realistic contributors to the housing requirement.

25. In these circumstances, I do not consider that, at this stage, I am in a position to decide whether the phasing of the sites is pragmatic. I would need to examine the matter further through examination of individual sites.

Sustainability appraisal and assessment of individual sites

26. A Council’s site-selection processes and methodologies are at the heart of any site allocations plan. If a sound site selection process is applied consistently then it follows that the sites which are selected for allocation will be sound. A recent Court decision - Save Historic Newmarket Ltd v Forest Heath DC - made clear that the background information supporting a Council’s plan needed to be of sufficient quality in terms of information, expertise and perceived effects to ensure that those members of the public affected by the plan were able to understand why the proposals were said to be environmentally sound and why alternatives had been discounted. In the case of a site allocations plan this principle should be applied to individual sites.

27. A key part of the Council’s evidence base is the Sustainability Appraisal (SA). The document should assess the alternatives considered by the Council and, whilst this document does not make the Council’s choices, it should enable users of the document to understand why the Council made its decisions. The Council has prepared a SA to support the DPD. However, whilst it assesses policies of the DPD, it contains no assessment of individual sites. The Council argues that this more detailed assessment information is provided elsewhere in the documentation – notably in the Housing Site Appraisal Summaries. The criteria against which the sites are assessed in these documents are different to those employed in the main SA document. Some apparently important characteristics of sites such as effect on landscape are assessed but evidence which is available in terms of surveys and assessments has not been employed. In the case of flooding, the tests applied to the policies in the SA are different to those which are applied to individual sites.

28. The Council has made some efforts to display the results of its site assessment process in table form to allow the comparison of one site against another. However, it remains unclear to me how individual sites were judged against the criteria applied. In many cases there appears to be no objective test applied which would allow the merits of one site to be weighed against another. When these matters were explored more deeply in the Hearings, it did appear that, at least in some cases, objective tests had been employed but these had not be revealed in the documentation. I appreciate that it will not always be possible to apply objective tests. However, my overall impression of the process of site assessment is that it is muddled, difficult to decipher and may not have been applied in a consistent manner. It may be that the Council has a great deal of the necessary information which would justify its assessment of sites against individual criteria. If this was properly revealed, explained and drawn together, the assessment of individual sites could become more understandable and may provide a SA which would meet the legal requirements. However, on the basis of the evidence before me, I am not persuaded that a proper SA has been carried out.

The process of comparing and selecting sites

29. Having undertaken the assessment of individual sites described above, the Council then adopted a 4 stage process by which the merits of individual sites could be compared. I deal with this process below.

Stage 1

30. Stage 1 involved an initial assessment of the Council’s Strategic Housing Land Availability Assessment (SHLAA) sites. The SHLAA was produced in 2011. It has not been updated but additional sites which were put forward through the DPD consultation process have been assessed using the same process. I am satisfied that the identification of sites has been reasonably comprehensive.

31. At Stage 1 sites which were too small to allocate, which did not comply with the locational requirements of Core Strategy Policy CS2, which were undevelopable for various reasons or which were subject to insurmountable policy restrictions were discounted. The decision-making process included non- Council bodies including the Environment Agency (EA) and the development industry in the form of the Home Builders Federation (HBF). It is not entirely clear how this process worked or what objective tests were applied to ensure that sites were dealt with on a consistent basis. Clearly this is easier in some cases than in others – for instance, sites which were too small or in active flood plains could be discounted on an objective basis. Assessment against the local requirements of Policy CS2 should, on the face of it, be relatively straightforward. However, in other cases the factors on which a decision was made to discount a site are less clear.

32. Deliverability was assessed in Stage 1. Availability, suitability and achievability were appraised. A large number of Representors raised concerns about the deliverability of the sites which the Council had allocated - some of which, it was claimed, had been allocated since 1992. Clearly assessing whether or not a particular site will come forward for development is not an exact science and will involve at least a degree of subjective judgement. The inclusion of the HBF and other parties in the process adds credibility. However, I note that no exercise has been undertaken with landowners to confirm that land which was available in 2011 is still available for development

33. I note that it has been assumed that sites allocated in the Unitary Development Plan dated 1998 and sites with planning permission are generally suitable for allocation – although a small number have been discounted as being undevelopable during the plan period. Within this process I can see no evidence to show that an assessment of sites was made to determine why, if they had been available for development for long periods, they remained undeveloped. Reasons could have been revealed which would exclude these sites from consideration – this is particularly the case where sites have been allocated for development for many years. I have seen no clear evidence to support an assumption that they will come forward.

34. With regard to sites which are subject to a high probability of flooding, I can see no clear evidence to show whether this would affect their deliverability. Difficulties surrounding insurance costs and fear of flooding may be sufficient to hold back development. The Council argued that some sites which are subject to a high probability of flooding are currently being developed and I agree that this may demonstrate that flooding may not be sufficient to hold back development in all cases. However, I have seen no evidence to show that this is generally the case in times when the issue of flooding is becoming of greater public concern.

35. The Council may have the background information which explains the rationale behind its decisions on deliverability. However, on the basis of the evidence before me, the process is unclear. I am not therefore persuaded that the wider issue of deliverability of all sites has been properly assessed.

Stage 2 - general

36. Stage 2 is referred to by the Council as the ‘strategic sieve’. Sites are assessed against Core Strategy Policies CS2, CS3 and CS4 from which are derived 4 strategic principles; prioritising the use of brownfield sites over greenfield sites, minimising development in the countryside, prioritising urban sites before urban extensions and, where possible, directing development to areas at lowest risk of flooding. Each site is ranked in accordance with how it performed collectively against these tests.

Stage 2 – brownfield/greenfield land

37. Given that the NPPF does not require the use of brownfield sites before greenfield sites, some Representors argued that the Council’s approach gave undue emphasis to the brownfield/greenfield qualities of the sites. Paragraph 111 of the NPPF still encourages the effective use of land that has been previously-developed. I am satisfied, therefore, that the Council is justified in seeking to prefer the development of brownfield sites. The way in which the brownfield/greenfield characteristics of a site have been employed in the ‘strategic sieve’ ensures that it only affects the ranking of a site where the other strategic circumstances are equal. I am satisfied that this is a proper approach.

Stage 2 – Green Belt and countryside

38. Within the borough ‘countryside’ falls into 2 parts; Green Belt land to the west of Doncaster and ‘Countryside Policy Protection Area’ to the east of Doncaster. I was informed at the Hearings that there is no other ‘countryside’ which falls outside of these 2 designations. The use of the term ‘Countryside Policy Protection Area’ is misleading. The area so designated has not been assessed for its special qualities and there is no policy either in the Core Strategy or the DPD which gives it any special status. The land is simply countryside. Referring to it as anything else implies a status which it does not possess.

39. The importance of the Green Belt is clearly set out in the NPPF and has been re-affirmed in recent Government statements. The Core Strategy makes clear that no general review of Green Belt boundaries is envisaged as being necessary to meet the housing requirement although some ‘very limited’ changes to the Green Belt may be necessary. However, the Core Strategy Inspector also commented that the Council may wish to consider whether the Green Belt should be comprehensively reviewed as part of a Site Allocations DPD. The Council has chosen not to do this at this stage but will undertake such a review as part of the next plan round.

40. In the Council’s ‘strategic sieve’, countryside does not carry the same weight as Green Belt. This is proper in my view. However, it does carry the same weight as a Flood Zone 2 designation. Green Belt designation carries the same weight as land being Flood Zone 3a. I deal with the treatment of flood risk below.

Stage 2 - Flooding

41. The NPPF needs to be read as a whole. However, it is quite specific in the way in which development of land which is at risk of flooding should be treated. In my view this reflects the importance which the Government attaches to the matter. Paragraphs 99-102 of the NPPF set out the way in which allocations in a Local Plan should be handled. The principle is to seek to avoid ‘where possible’ flood risk to people and property and to manage residual risk. To achieve this Local Plans should adopt a sequential, risk-based approach to the location of development. This would involve applying a Sequential Test designed to steer new development to areas with the lowest probability of flooding. If, following application of the Sequential Test, it is ‘not possible’ consistent with wider sustainability objectives to locate development in zones with a lower probability of flooding, the Exception Test may be applied. To pass the Exception Test it must be demonstrated that there are wider sustainability benefits to the community which outweigh the flood risk and a site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime without increasing flood risk elsewhere.

42. I am not persuaded that the Council has applied these tests as stringently as the NPPF requires. I do not consider that the Council’s starting point has been to seek to steer development away from areas with the highest probability of flood risk. I have seen no evidence that this objective has been properly weighed against wider sustainability objectives or that such an exercise has demonstrated that it is ‘not possible’ to locate development in areas of lower probability of flooding. It is only when these matters have been fully assessed that the Exceptions Test should be applied. As its name suggests the test should involve only exceptional cases. Again I have seen no clear evidence that the Council has weighed the risk from flooding against the wider sustainability benefits to the community which would accrue. Site-specific flood risk assessments have not been carried out in all cases.

43. The Environment Agency (EA) has been consulted on the Council’s approach and appeared at the Hearings. While the EA has expressed itself as being satisfied with the Council’s methodology, it made clear that the weighing of flood risk against wider sustainability objectives and benefits was a matter for the Council. In my view this is a proper position for the EA to take. Perhaps more surprisingly, the EA considered that, in the application of the Exceptions Test, the absence of a site-specific flood risk assessment in each case as is required by the NPPF was acceptable. It foresaw no major issues arising from development of the sites in flood risk zones 3a and 2 and therefore considered that it would be more appropriate to undertake a site specific flood risk assessment at a later stage. This is contrary to the NPPF guidance. The EA confirmed at the Hearings that, even where flood defences were in place, this did not affect whether or not a site fell within an area with a higher probability of flooding.

44. From the evidence before me, it is difficult to avoid the conclusion that the Council has chosen for allocation a number of sites to which it has a long-term commitment for the delivery of its regeneration efforts and has simply decided that these sites are so important to its efforts that this, by itself, is sufficient to provide the wider sustainability objectives and benefits required by the NPPF tests. I do not consider that this can be assumed. The NPPF tests ‘set a high bar’. It is only where it is ‘not possible’ to direct development to areas of lower flood risk that the Council can move on to apply the Exceptions Test. The test is not that it would be preferable to locate development in the areas of highest risk of flooding but that it should be impossible to do otherwise.

45. There may be circumstances where it is genuinely ‘not possible’ to avoid allocating land which is subject to a high probability of flood risk if the settlement-specific strategy of the Core Strategy is to be followed. However, even in the rare instances where this may be the case, I would suggest that this could be an indicator that the strategy could need some re-assessment rather than that sites at risk of flooding should be selected.

46. In my opinion the Council’s approach to the selection of sites in areas of higher probability of flooding has been too inflexible. It has not given due consideration to the alternatives of developing in the countryside or even in the Green Belt in order to avoid making allocations in areas of flood risk. Overall, I do not consider that the Council has made a proper and thorough examination of the issue of flooding before deciding that the risks involved are outweighed. In any event, the Exceptions Test has not been applied in that a site-specific flood risk assessment has not been undertaken as is required by the NPPF.

Stage 2 - Conclusions

47. Stage 2 of the Council’s site selection methodology deals with important matters which should have a clear and substantial bearing on which sites are selected for allocation. However, I find it very confused. Putting to one side the way in which flooding issues have been assessed, the methodology confuses a physical constraint – flooding - with policy matters – Green Belt, countryside and brownfield/greenfield land. The Council could revise its position on the policy matters but the physical constraint cannot be changed and can only be assessed through the NPPF process. The methodology seeks to weigh these matters alongside one another – giving Zone 3a flood risk the same weight as Green Belt land and giving countryside the same weight as Zone 2 flood risk. I do not consider that the matters can be weighed together in this way and I do not consider that this process reflects the importance placed on flood risk by the NPPF or the balancing exercise which it requires.

Stage 3 – Part 1

48. Stage 3 falls into 2 parts. The first part involves a detailed assessment in which sites were assessed against a range of sustainability criteria. However, these are not the same as the criteria employed in the SA – I refer to this in paragraph 27 above. I accept the Council’s argument that some of the SA objectives cannot be usefully employed in a site selection process as matters such as design can only be assessed at a detailed planning stage and that the criteria applied in its Housing Site Appraisal Summaries covers similar issues to those addressed in the SA. However, again it is not clear how sites have been judged against the specified criteria. In the Hearing sessions the Council explained that, in some cases, objective testing had been applied but this was not obvious from the submitted documentation. In some of these cases the objective tests which were applied appeared to be quite crude. For instance, more sophisticated analysis of access to public transport may have revealed different results. In the case of agricultural land quality, the Council ‘erred on the side of caution’ in its analysis which could have over-emphasised a site’s score in this regard. How the Council assessed the relative characteristics of sites and made a distinction between them remains unclear.

49. The way in which the detailed sustainability assessment relates to Stage 2 of the process – the strategic sieve – is confusing. Sites which score quite poorly on the strategic sieve can be allocated for development if they score well on the detailed sustainability assessment. Given the importance of the issues assessed by the strategic sieve this is somewhat surprising and I would suggest that it may be symptomatic of what I consider to be a muddled approach.

50. It is at Stage 3 that flood protection measures appear to have been taken into account. The Council argues that many of the sites which it has allocated for development are, or can be, protected from flooding. However, as the EA made clear at the Hearings, this does not alter the land’s status in terms of the probability of flood risk. The NPPF is clear that Councils applying the NPPF tests should seek to avoid allocations in areas of higher risk. It makes no distinction between that land in zones with a high probability of flooding which are, or can be, protected from flooding and land which is not so protected. I accept that in cases which are balanced, protection from flood risk may be sufficient to determine which site should be chosen. However, in the first instance the Council should have sought to avoid land with a higher flood risk where possible.

Stage 3 – Part 2

51. This involved taking the views of local communities into account. It would appear that it was based on consultation responses made during plan preparation stages. It is not clear how much weight was attributed to these comments and what part they played in the assessment process.

Stage 4

52. Stage 4 involved the weighing of the findings from the 3 earlier stages to reach a final decision on allocation. Again there is no clear explanation of how this process was managed, how determining factors were assessed and weighed or how the decisions were reached.

Conclusions on the site assessment, site selection and Sustainability Appraisal processes.

53. In my opinion the Council’s site assessment, site selection and SA processes and methodologies are unsound and, in some cases, are not legally compliant. The Council may have information available which demonstrates that the characteristics of sites have been objectively assessed in a systematic manner and which allows a clear understanding of why one site was selected for allocation over another. However, this needs to be drawn together and presented in a way which allows those affected by the plan to understand why the proposals are said to be environmentally sound and why alternatives have been discounted. The Council should be able to demonstrate by, where possible, objective testing, that there is a clear, rational basis for the decisions which have been made. At present the evidence base and the SA in particular do not do this.

54. In my view the site selection process needs to be re-evaluated. The tests applied in the Stage 2 ‘strategic sieve’ are clearly very important to any assessment of sites and need to be given proper weight. However at present their influence on the process is entirely unclear. Despite their clear importance – an impression reinforced by the Council’s assessment of them in a separate stage – they can be outweighed by other sustainability criteria. The way in which the ‘strategic sieve’ issues have been weighed alongside one another also needs to be re-assessed. I am not persuaded that, given the guidance in the NPPF, that this weighing together of policy-led matters and physical constraints is a proper approach.

55. The Core Strategy makes clear that the Sequential and Exceptions Tests in respect of flood risk need to be applied and they should be applied as intended by the NPPF. I do not consider that the necessary weighing of the risk of flooding against identified wider sustainability objectives and benefits has been demonstrated and there is no clear case made which shows that the risk of flooding is outweighed by these matters. The lack of a site specific flood risk assessment for all sites being considered under the Exceptions Test is clearly contrary to NPPF guidance.

56. The Core Strategy envisages that, in order to meet the plan objectives, it may be necessary to allocate land in areas subject to flood risk, in parts of the Green Belt and in the countryside. This is made clear in paragraph 4.8 of the Council’s Housing Site Assessment Report (Including Methodology) document. I am not persuaded that the Council has given proper consideration to the alternatives of developing in the countryside and Green Belt before it chose to allocate sites in areas of flood risk. In my opinion the protection of Green Belt and countryside may have been put ahead of flood risk in the weighing process and this does not give the issue of flood risk due weight. The Council’s process demonstrates a lack of flexibility in its decision-making which may have favoured particular sites. The choice of these sites, both in terms of their size and attractiveness to the market, could have a significant impact on the deliverability of development and ultimately on the Council’s overall strategy.

Other policies

General matters

57. During the course of the Stage 1 Hearings a number of other policies were discussed. In many cases the Council proposed Main Modifications to address the various matters raised by Representors. I deal with these policies below. Not all of the changes which were discussed at the Hearings are shown on the Note of working amendments discussed during hearings document and the Proposed Main Modifications document (ref G28) which the Council has supplied to me. The Council will need to re-consult on any proposed Main Modifications and should ensure that its list of proposed Main Modifications is complete before embarking on any such exercise.

Policies SP44 and SP22: Viability

58.There is no clear indication that the viability of sites has been assessed as part of the site selection processes. I have read the Council’s document entitled Viability Testing Report (ref A8.1) but this deals almost exclusively with the Council’s affordable housing aspirations. I have seen no evidence that a wider assessment of viability has informed the site selection process.

59. Policy SP44 deals with developer contributions. In general terms I am satisfied that the policy and its supporting text take a flexible approach to the negotiation of developer contributions which enables viability to be properly addressed. In my view the approach adopted is generally sound. I understand that the Council is proposing Main Modifications to the policy to ensure that it clearly understood alongside Core Strategy Policy CS12.

60. Policy SP22 deals with residential design. I understand that the Council is proposing Main Modifications to make the policy more flexible in order that viability is not compromised by a requirement for over-exacting standards.

Policies SP1 and SP3: Buildings and conversions in rural areas

61. Core Strategy Policy CS3 seeks the protection and enhancement of both Green Belt and countryside. Policies SP1, SP2 and SP3 of the DPD follow this lead and treat both designated areas as having the same protection. The degree of protection provided does not in all cases comply with the NPPF advice. I consider that the approach adopted by the Council does not, therefore, comply with national guidance. The Council is proposing to make Main Modifications which will ensure that Policy SP1 complies with the up-to-date guidance in the NPPF and that a proper distinction is made between the approaches to development in Green Belt and other countryside.

62. The Council is also proposing to make Main Modifications to Policy SP3 to bring its provisions in line with the NPPF guidance.

Policy SP21: Meeting the requirements for gypsies and travellers

63. The provision of sites to accommodate the needs of the gypsy and traveller communities is dealt with by Core Strategy Policy CS13 and Policy SP21 of this DPD. At planning appeals in the past the Council’s Gypsy and Traveller Accommodation Needs Assessment (GTANA) has been criticised. However, the earlier GTANAs which gave rise to this criticism have now been superseded by a 2013 version. This deals with the 2014-2019 period, has been independently reviewed and appears to be more robust. Policy SP21 identifies sites which would, after removing any double-counting, satisfy the identified requirement. The Council claims that it has actively worked with the gypsy and traveller communities to help identify sites and I have seen no evidence to disprove this claim.

64. Both Policies CS13 and SP21 appear to be consistent with the Planning Policy for Traveller Sites guidance. I am satisfied that the policies are sufficient to enable a flexible choice of accommodation to be provided. Where there is a clear, identifiable need the Council has made provision to meet it.

65. The Council proposes Main Modifications to Policy SP21 to clarify the relationship with Policy CS13 and to address issues in criterion H) which deals with enforcement action. It would also appear that the text supporting the policy will need modification to bring the background details up-to-date.

Policies SP9, SP13 and SP14: Retail and town centre issues

66. The Council proposes a range of Main Modifications to address a number of anomalies in the wording of the policies and their supporting text and to bring the DPD up-to-date with planning permissions which have been granted on sites around the town centre. I am satisfied that the proposed changes which were discussed at the Hearings would be sufficient to make the Council’s approach to these matters sound.

Policies SP8, SP15 and SP21: Robin Hood Airport

67. Part A of Policy SP8 supports a range of uses at the business park adjacent to the airport. My reading of the policy is that it supports any uses within Classes B1 b/c, B2 and B8 without restriction but also allows any other use which relates to the airport or which is ancillary to the business park. However, I note that in paragraph 3 (iv) of the Note on Distribution Warehousing Phasing the Council implies that the Class B8 uses at the airport will be ‘related to the operation of the airport’. If my understanding of the meaning of Part A of the policy is wrong then its wording needs to be improved to clarify its meaning. However, given the need to protect town centres and other Council policies, I consider that the range of uses (as I understand it) is sufficiently wide to accommodate most uses which would be likely to wish to locate within the business park and would not unduly hold back investment. In my view the inclusion of the suggested wording from the Growth Plan would allow a potential range of uses which is too wide. Proposed Main Modifications which bring the supporting text up-to-date are acceptable.

68. The Council proposes a number of Main Modifications to address various issues of aircraft safety. The proposed change to Part D of Policy SP8 appears to be generally sound. However, Part C of the policy deals with Public Safety Zones (PSZs). Current traffic levels do not warrant the designation by the Civil Aviation Authority (CAA) of PSZs. However, the Council has employed risk assessments undertaken as part of earlier planning applications to define its own PSZs which it proposes to protect until these are replaced by formal CAA designations. The ‘informal’ nature of the PSZs is referred to in the text supporting the policy. However, I am not persuaded that the Council is justified in applying these restrictions on development when they are not supported by the CAA. The matter should be considered further.

69. I have seen no evidence which supports suggested changes to Part D bullet 3 in respect to windfarm developments.

70. A proposed Main Modification to provide a reference from Policy SP41 to the clause in Policy SP8 regarding birdstrike hazards would be acceptable in order to make the DPD effective.

71. Part C of Policy SP15 which deals with Airport Surface Access Strategy is, in my opinion, incongruously placed and could be easily overlooked by anyone dealing with proposals in and around the airport. I consider that it should be re- positioned. I do not consider that the Council’s choice of words in the last sentence makes the DPD unsound.

72. Some Representors raised concerns that developments at the airport could affect their access to their own site. As I made clear in the Hearings, the fact that a development plan allocation is made or a planning permission is granted does not affect an individual’s property rights. Any effect on rights of access would need to be resolved separately through negotiations between the affected parties.

Policy SP6: Inland Port

73. Core Strategy Policies CS2 and CS5 and the text supporting Policy CS5 set out proposals for the delivery of employment land including distribution warehousing. ‘Distribution warehousing’ is not defined in the Core Strategy. Core Strategy paragraph 4.10 sets out the priority which will be given to the Strategic Rail Freight Interchange at Rossington – now referred to as the Inland Port. It states that a maximum of 62 hectares of the distribution warehousing land (over and above the 166 hectares forming the Inland Port site) will be released in the 5 years from the adoption of the Core Strategy. This text was drawn up by the Core Strategy Inspector and is specific. Whilst ‘broad locations’ in the M18/M180 corridor and at the Inland Port are identified in Table 2 of Core Strategy Policy CS2 I do not consider that the policy or text can be taken as referring exclusively to distribution warehousing allocations in these locations. The text in paragraph 4.10 specifically does not say that the phasing provisions relate only to sites in the ‘broad locations’ specified. Development at the airport is dealt with as a separate entry in the Table. It appears to me, therefore, that, putting the airport aside, the Core Strategy (as written) makes no distinction between distribution warehousing allocations in the broad location of the M18/M180 corridor and sites elsewhere. In my view the 62 hectares mentioned in the text could reasonably be taken to refer to all allocated ‘distribution warehousing’ sites. Representors argued that the Council’s application of this element of the Core Strategy was being blurred by making distinctions between the types of warehouses to which it applies. I do not consider that the approach of the Core Strategy sanctions the making of any such distinction by the Council.

74. The DPD allocates 324 hectares of land which could provide warehouse space. What, on the face of it, appears to be an ‘over-allocation’ has no effect on the commitment made in paragraph 4.10. However much land is allocated, only the Inland Port land and an additional 62 hectares can come forward in the first 5 years of the Core Strategy plan period. The priority given to the Inland Port remains unaltered. Whether the warehouse space is provided for local firms or as part of mixed use sites has no effect on that commitment.

75. I can see little reason for the Council seeking to over-allocate employment land at this stage. The employment land would be developed over the whole of the plan period and over-allocation at this stage to provide flexibility in the event of some sites failing to come forward seems to me to be unnecessary. If proper monitoring showed that employment land was running short at some point in the plan period the Council could review provision. Nonetheless, while I can understand concerns that the Council’s approach may deter investors in the Inland Port, I am not persuaded that the approach is inherently unsound. In these circumstances, I do not consider that any Main Modification is needed to make the DPD sound.

Policy SP39: Minerals

76. The Council is only one of 6 of the 17 Mineral Planning Authorities in the area to have submitted a Local Aggregates Assessment (LAA) to the Aggregates Working Party for consideration. Assessments need to be made on a sub- regional or regional basis and the Council can only do this through the AWP when other authorities produce their own data. The Council argue that the LAA was produced in-line with national guidance – especially that in the first bullet point of paragraph 145 of the NPPF. It also takes into account projections of future building. Areas of search for new deposits have been identified. Working together with adjacent authorities who are outside the AWP area but have traditionally exported materials to Doncaster, the Council has produced a joint position statement and has concluded that it can meet its requirements.

77. From the evidence which I have read and heard at the Hearings I consider that the Council has made considerable efforts to comply with the guidance contained in the NPPF and has done as much as it can to address the question of mineral supply. Assessments are on-going and I am satisfied that the Council is striving to come to an agreed AWP-wide position. In these circumstances I am satisfied that the DPD is sound in this regard.

Summary

78. As I stated at the beginning of this letter, the purpose of the Examination is to ensure that the submitted DPD is legally compliant, justified, effective, positively planned and consistent with national guidance and that any requirements in terms of the duty to co-operate have been satisfied. I have a number of concerns about the DPD which I set out above. However, the most fundamental concerns can be summarised as:

 The DPD is not based on an objective assessment of the need for housing as is required by the NPPF. The adopted Core Strategy is based on RS housing requirements which do not in themselves assess need and, in any event, could not be considered to be up-to-date. The requirement figures have not been reviewed since the Core Strategy was examined in the pre-NPPF era and no review is imminent. Recent evidence tends to suggest that the Core Strategy housing requirement will not support the Council’s objectives in terms of job creation. In these circumstances I consider that the DPD provisions are not justified by the evidence base, would be ineffective in delivering the Core Strategy objectives and would be inconsistent with national guidance. It is also possible that, by basing the housing requirement on the Core Strategy requirement, the DPD could be found to be not lawful.

 The SA and site selection methodologies employed by the Council are flawed. The SA does not, in itself, assess individual sites although I accept that assessments are provided elsewhere in the documentation. However, the information provided does not give any clear picture of why one site was chosen for allocation before another. The DPD is, therefore, based on evidence which is not legally compliant. The selection process itself is muddled. In particular the way in which the NPPF tests for land at risk of flooding have been applied is unacceptable and flood risk should not have been considered collectively with Green Belt, countryside and brownfield/greenfield issues. Throughout the whole of the SA/site selection process there is a lack of clarity about how decisions were reached. In this regard I consider that the DPD is not legally compliant, justified or consistent with national guidance.

 The DPD should be re-drafted to make it simpler. All policies should be re-assessed to bring them in-line with national guidance and misleading designations such as Countryside Policy Protection Area and Public Safety Zones which imply a degree of protection which does not exist should be removed.

Conclusions

79. It is for the Council to decide how to take the DPD forward from this point. However, the issues which I summarise above would, I suggest, make moving forward to the second stage of Hearings abortive. In my opinion it would be a waste of resources to examine the issues surrounding the proposed allocation/non-allocation of individual sites when matters which go to the heart of the plan methodology are in my opinion unsound, not legally compliant or both.

80. Taking matters forward, I could prepare a formal Report on the DPD Examination which has taken place so far although such a Report is likely to say little more than this letter. In the light of the evidence before me my finding is likely to be that the DPD is both unsound and not legally compliant.

81. Alternatively the Council could consider making Main Modifications to the DPD to address the matters I have raised. However, some of my concerns stem from the fact that the Core Strategy housing requirement needs review. There would seem to be little point in seeking to modify the DPD without reviewing this part of the Core Strategy. The Council is currently undertaking a SHMA. Although this is aimed at addressing affordable housing issues it could be extended to provide an overall assessment of housing need and could form the basis for a review of the housing requirement in what the Council considers to be a discrete HMA until such time as a SCR-wide SHMA is produced.

82. However, progressing by way of main Modifications could present difficulties:

 A review of the housing requirement could have significant effects on the content of the DPD. It could affect policies throughout the DPD. There would be little point, in these circumstances, seeking to examine other policies at this stage.

 The Council’s SA/site selection processes need to be reconsidered. While background information may be available to show that objective testing of sites has taken place, this information needs to be brought together in an intelligible form which is capable of being properly assessed. The testing of sites at risk of flooding should be properly built into the process in line with the NPPF guidance. In my view reconsideration of the SA/site selection processes is likely to have a very significant effect on the DPD provisions. Coupled with the changes that could derive from a review of the housing requirement, I consider that it is likely that the DPD which emerges will be very different to that which is currently before me. In these circumstances it may be inappropriate to deal with changes of this magnitude as Main Modifications.

83. I can appreciate that this letter will leave the Council in a difficult position where its options for moving forward are limited. However, all of the work which has led the Council to this point is not necessarily wasted. As I hope I have made clear, much of the evidence background which supports the DPD may be capable of being employed in its current form or could be built upon by additional work and up-dating to provide a more robust evidence base on which to progress a Sites and Policies DPD. I am not suggesting that the Council needs to go back to the beginning of the process. Other alternatives may be available.

84. As I have said it is for the Council to decide how to proceed from this point. However, my own view is that one potential course of action could be for the Council to:

 withdraw this DPD;

 prepare a SHMA which addresses the need for market housing as well as for affordable housing in the HMA;

 bring forward a partial review of the Core Strategy which takes account of any changes in the housing requirement and of up-to-date evidence on the balance of jobs and housing and which brings the Core Strategy policies into line with the NPPF; and,

 bring forward a revised and simplified version of this DPD (either as a separate document or jointly with the reviewed Core Strategy as a Local Plan) based on the reviewed Core Strategy housing requirement, revised SA/site selection processes and NPPF compliant policies.

85. I can understand that the Council will need some time to consider the contents of this letter and how it wishes to proceed. I await the Council’s response.

Yours Sincerely,

R Punshon

INSPECTOR

Review of Doncaster employment land evidence

A Report by Hatch Regeneris 6 September 2019

Blue Anchor Leisure

Review of Doncaster employment land evidence

This report contains the expression of the professional opinion of Hatch Regeneris (the trading name of Hatch Associates UK). It is based upon information available at the time of its preparation. The quality of the information, conclusions and estimates contained in the report is consistent with the intended level of accuracy as set out in this report, as well as the circumstances and constraints under which this report was prepared.

The report was prepared for the sole and exclusive use of Blue Anchor Leisure. Hatch Associates Limited shall only be liable to Blue Anchor Leisure and is not liable to any third party who intends to rely on or has relied or is currently relying upon this report (in whole or part).

6 September 2019 www.hatchregeneris.com

1. Purpose of report

1.1 Doncaster Council is consulting on the Publication Version of its Local Plan which will shape development in the borough between 2015 and 2035. Blue Anchor Leisure is promoting an employment site for allocation in the Plan. To support its case, they have commissioned Hatch Regeneris to review the Council’s employment land policy and underpinning evidence base, and to reach conclusions on whether it is based on sound evidence. 1.2 This report provides the findings from this review. The report is structured as follows: • Section 2 reviews the national and local policy context, and the evidence underpinning the Council’s employment land target. • Section 3 assesses the recent economic performance of Doncaster • Section 4 presents our view of the need for employment land in the borough. • Section 5 summarises our conclusions

1

2. Policy Context

• The revised NPPF continues to attach significant importance to using the planning system to support economic growth. • PPG makes clear that a range of different methods can be used to assess the future employment land needs of local economies. These include approaches based on employment forecasts and those based on past trends. • The Publication Local Plan for Doncaster sets a target of delivering at least 481 Ha of employment land between 2015 and 2035. This has been based on an employment forecast approach applied in the 2019 ELNA. • The 2015 ELNA used a different approach based on past trends in the take-up of employment land. This identified a target of 474 Ha for the period 2015 to 2032. .

National Policy

National Planning Policy Framework

2.1 The revised National Planning Policy Framework (NPPF) was published in February 2019. This retains the three overarching objectives contributing to sustainable development from earlier versions; building a strong, responsive and competitive economy, supporting strong, vibrant and healthy communities and protecting and enhancing the environment. 2.2 The framework continues to highlight the importance that local planning authorities adopt policies which support economic growth in their area, stating “Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development” (para 80). It also states that planning policies should “seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment” (para 81).

National Planning Policy Guidance

2.3 The Planning Practice Guidance was also updated in February 2019. This includes guidance on how the economic needs of functional economic market areas (FEMAs) can be assessed and quantified, although there are no substantive changes from the earlier guidance. The key points are as follows: • Economic needs should be assessed for the best-fit FEMA. • Assessments should involve close liaison with the business community to understand their current future requirements. This should include analysis of recent changes in the demand and supply of commercial property which identifies undersupplies or oversupplies of particular types of space. • A number of different methods can be used to assess future needs including:

◼ sector based employment forecasts (labour demand)

◼ demographically derived assessments of future employment needs (labour supply techniques) and

◼ analysis of past trends in the delivery of employment land or take-up of space.

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Local Policy

Doncaster Local Plan 2015-2035 Publication Version

2.4 The Local Plan sets out “policies and proposals to meet Doncaster’s needs for housing, employment and other development: how much is required, where it should go and when it should happen”. Policy 3 of the Publication Local Plan identifies the need for: 2.5 “at least 481 hectares of employment land over the plan period (2015-2035) to help grow and diversify the Sheffield City Region economy, increase productivity and widen access to learning and training opportunities. The identified land will accommodate business, light industry and manufacturing and distribution and warehouse uses to meet future employment needs on sites that are attractive to market investment and can be accessed via a range of transport modes”. 2.6 The policy does not state how this land will be allocated to different use classes i.e. the split between office and industrial uses, or how the latter should be broken down in to manufacturing/logistics uses. 2.7 The policy also states that 18,400 homes will be delivered in Doncaster over the plan period, equivalent to 920 dwellings per annum.

Supporting evidence base

2.8 The Publication Local Plan notes that the land requirement is based on the Economic Forecasts and Housing Needs Assessment (Peter Brett Associates, May 2018) and the updated Employment Land Need Assessment (ELNA, 2019).

Economic Forecasts and Housing Needs Assessment, 2018

2.9 This report considers needs and targets for employment land and housing for the period 2015-32, under two alternative scenarios: • a business-as-usual scenario based on total jobs growth of 13,800 (0.6% p.a.) • a policy-led scenario in which job growth fulfils the ambitions of Sheffield City Region (SCR). This models jobs growth of 24,200 (1.0% p.a) 2.10 PBA estimate that • growth in the business as usual scenario would require 95,200 sq m of industrial space and 27,648 sq m of offices which together would require an estimated land area of 28 ha. • Growth in in the policy-led scenario would require 751,693 sq m of industrial space and 31,227 sq m of offices which together would require an estimated land area of 193 ha. 2.11 Both of these land estimates are someway below the target in the local plan (481 ha, albeit over a slightly longer time period of 2015-2035). The report did not state which scenario should be used for employment land – describing these scenarios as a “starting point of the employment land requirement… to be included in the next Local Plan”.

ELNA Update, 2019

2.12 This updated the original ELNA published in 2015 and used a different method for calculating employment land need, based on employment forecasts rather than past trends in land take-up. Both methods are consistent with the guidance set out in PPG.

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2.13 The new method takes its jobs growth assumptions from PBA’s policy led scenario (jobs growth of 24,200), but then applies its own assumptions about how jobs growth translates in to employment land. This involves a number of steps and assumptions: 1) The jobs growth forecasts are split in to 38 sectors. The authors make assumptions about the proportion of jobs in each sector that require different land use categories. Eg 100% of jobs in “admin and support service activities” require office space. They estimate that 14,800 of the jobs created between 2015 and 2032 require B class employment space (B1,B2,B8) 2) They then make assumptions about the quantity of floorspace required per worker (the jobs density) which calculates the total amount of employment space required 3) Employment space is then translated in to land by applying assumptions about “plot ratios” (the average net developable area of a site) 4) An additional uplift to allow for “churn” (based on businesses moving within the area from one premise to another) 5) An additional uplift for “other uses” which may be provided on site (eg retail provision on industrial sites) 6) An additional uplift to allow for “choice”. This is to provide “a reasonable level of flexibility allowing for a greater choice of sites”. 2.14 By applying all of these assumptions they arrive at a figure of 409 Ha for the period 2015- 2032). This is made up of the following requirements: • 12 Ha for office development • 106 Ha for light industrial (B1c/B2) • 62 Ha for non strategic warehousing (B8) • 230 Ha for strategic warehousing 2.15 The figure is adjusted to 481 Ha for the period 2015-35 on a pro-rata basis. Adjusting the above figures means the implied requirements by use class are: • 14 Ha for office development • 125 Ha for industrial • 73 Ha for non-strategic warehousing • 271 Ha for strategic warehousing

ELNA 2015

2.16 The 2015 ELNA has not been used to determine the employment land target in the Publication Local Plan, but was used for the earlier version of the plan. It is worth noting here because the 2015 ELNA used a past-trends based approach rather than one based on employment forecasts as used in the 2019 ELNA. 2.17 This set an employment land requirement of 474 hectares over the period 2015-2032 (three years shorter than the current plan period) based on historic employment land take up rates over the previous 15 years (2000 – 2015).

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3. The Economic Performance of Doncaster

• Doncaster has the fastest growing economy in Yorkshire and Humber and one of the fastest growing in the north of England. The district has created around 24,000 jobs between 2000 and 2017, representing a growth rate of 1.1% p.a. • Doncaster’s key asset is its connectivity by road, rail and air which has made it a highly attractive location for inward investment, particularly for industrial and logistics occupiers, with nearly 1.4m sq m of industrial/warehouse space taken up since 2009. • The strong performance is also due to a significant improvement in key economic indicators, including skills and rates of enterprise. The business start-up rate has more than doubled since 2010 and is now in line with the national average. These improvements have removed a key barrier to growth and mean that Doncaster is well placed to continue its high rate of growth. • There are a number of grounds to be optimistic for the future growth of Doncaster. The district’s strong record of jobs growth, significant improvement in key economic indicators and strong track record of attracting inward investment all mean Doncaster is well positioned to achieve high levels of growth over the plan period.

3.1 Doncaster is one of the fastest growing economies in the north of England. Real Gross Value Added (GVA)1 increased at a rate of 2.5% p.a. between 2000 and 2017, which is significantly higher than the national and regional average (1.7% p.a. and 1.4% p.a. respectively) and higher than any other district in Yorkshire and Humber (see Figure 3.1). Figure 3.1 Annual average growth rate in Gross Value Added for local authorities in Yorkshire and Humber (2000 to 2017, 2016 prices)

Source Nominal and real regional gross value added (balanced) by industry, Office for National Statistics

3.2 This growth has driven increased demand for labour in Doncaster, creating around 24,000 new jobs between 2000 and 2017. Figure 3.1 shows that the rate of jobs growth in

1 GVA is the measure of the value of goods and services produced in an area, industry or sector of an economy

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Doncaster has matched the national average and outperformed the average for Y&H. This has been driven by a number of sectors including logistics, retail, professional and business services and the public sector. Figure 3.2 Employment change index, 2000-2017 (2000=100)

Source Jobs density data, Nomis

3.3 Table 3.1 shows how this translates to average annual growth rates over different time periods. Over each time period, Doncaster has achieved a minimum annual growth rate of 0.8% p.a. Average annual growth was lower over the ten-year period because it is skewed by the economic downturn which occurred between 2008 and 2011.

Table 3.1 Jobs growth rates over different time periods Doncaster Y&H GB 5 year (2012-2017) 2.8% 2.1% 2.1% 10 year (2007-2017) 0.8% 0.8% 1.2% 15 year (2007-2017) 1.1% 0.8% 1.1% Source: Jobs density data, Nomis

3.4 Doncaster’s strong performance has been driven by a number of factors. The borough has excellent connectivity across a number of modes of transport, including road, rail and air, which has made it a highly attractive location for inward investment. 3.5 Doncaster has also been extremely successful in addressing some of the challenges which have acted as a constraint on growth in the past. Figure 3.2 shows how the business start- up rate, measuring levels of enterprise in Doncaster, has risen from four new businesses per 1,000 working age people in 2010 to over 10 businesses in 2016. Doncaster’s residents now display levels of enterprise in line with the national average and well above the average for Yorkshire. Doncaster has also seen a significant improvement in the skills of its workforce, particularly among younger residents. The Annual Population Survey shows that the proportion of people with no qualifications (a key barrier to growth) fell from

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over 15% in 2010 to just 9% in 2018, bringing it in line with the average for Yorkshire and much closer to the national average. Figure 3.3 Business start up rate, 2010-2016

Source ONS Business Demography and mid-year population estimates

3.6 The strong performance of Doncaster is due in part to the actions taken as part of the Doncaster Economic Growth Plan. This outlined a number of measures to promote new business and improve skills. Policies to support start-ups included access to start-up advisors and mentors with established local businesses. Skills measures included an apprenticeships programme and improved careers advice and guidance. 3.7 The improvement in its skills and business base led to Doncaster being recognised as one of the fastest improving cities in PWC’s Good Growth for Cities Index. As key drivers of productivity and economic performance these improvements have also addressed barriers to growth and positioned Doncaster to achieve high levels of growth in the future. Commercial Property Market Trends 3.8 One of Doncaster’s key strengths is that it is a highly attractive location for investors, particularly for industrial and distribution occupiers attracted to its excellent connectivity by road, rail and air. 3.9 Figure 3.4 shows that at least 100,000 sq m of industrial space is leased in a typical year in Doncaster. Nearly 1.4m sq m has been leased since 2009, representing 37% of demand in South Yorkshire (despite only accounting for 20% of the population). This is therefore a key source of competitive advantage for Doncaster.

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Figure 3.4 Leased industrial space in Doncaster, 2009-19

Source CoStar

3.10 Figure 3.5 shows that the current vacancy rate for industrial space is 2.1%. This has fallen dramatically since 2009 (17%) and is now close to historically low levels. This is despite the supply of industrial floorspace increasing by nearly 500,000 sq m over the same time period. This shows both the strength of demand for space in Doncaster and that the market is currently undersupplied. Figure 3.5 Vacancy rate for industrial space

Source CoStar

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4. Our View of Need in Doncaster

• PPG encourages plan makers to consider both past-trends and employment forecasts when assessing employment land requirements. • The method used by the Council uses a sound approach. We believe the jobs growth assumptions are justified and consistent with the approach taken to assessing the need for housing. • Nevertheless they are subject to uncertainty and should be cross-referenced with a past trends based approach to give greater confidence in the results. • The Councils analysis of past trends identifies a land requirement broadly compatible with the 481 Ha and we believe it supports the Council’s target. Even our update of this to 428ha is sufficiently close not suggest any issue of soundness • In addition it is good practice to apply an additional safety margin to allow for delays in sites coming forward, leakage to other uses and to provide increased choice as well.

4.1 Section 2 showed that Doncaster Borough Council has used two different approaches to assess the future need for employment land in its recent ELNAs: • A trends based approach, used in the 2015 ELNA • An approach based on employment forecasts, used in the 2019 ELNA Update. 4.2 Both of these approaches are acceptable in the context of PPG which encourages plan makers to consider both methods in their scenario planning. The reason given for the change in approaches is as follows: “The informal Local Plan consultation (2018) asked the question would a land use requirement based on historic trends (as per the ELNA 2015) be preferable to the 1% jobs growth per annum land requirement. Analysis of the consultation responses (which can be found on the Local Plan website) concluded that there was no support for the ‘historic trends’ option. Therefore, the land requirement of 481 ha (based on 1% growth p.a. as per PBA/Experian forecast) remains the option selected in the Local Plan”. 4.3 We do not disagree with forecast-based approaches; these are a commonly used method in employment land reviews (ELRs). We also believe the level of jobs growth used in the scenario is justified; the previous section showed that Doncaster has sustained a similar rate of growth over the last ten and 15 year periods, and a much higher rate of growth in the past five years. We also note that the level of growth is consistent with the assumptions which underpin the Council’s housing target and therefore represents a consistent and joined-up approach to planning. 4.4 Nevertheless, we believe it is prudent to sense-check the employment land targets by comparing these with past trends. This gives greater confidence that the results are robust and represent a sound basis for planning. Employment land completions 4.5 This is effectively a re-run of the approach taken in the 2015 ELNA, using more up to date data. Table 4.1 shows employment land completions between 2000 and 2018 based on data from the previous two ELNAs. It shows approximately 504 Ha of employment land has been delivered over the 19 year period, although this includes non B class uses. If these completions are excluded, the total amount of employment land falls to 407 Ha or 21.4 Ha pa. If these trends were to continue over a 20 year period, it would imply a need

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for 428 Ha of employment land, of which 315 Ha is for warehouses (logistics and distribution). 4.6 Although this is 12% lower than the Council’s target of 481 Ha, we believe it provides evidence that the target is sound. This is for the following reasons: • Both methods are acceptable and there is sufficient proximity of outcome to conclude that the Councils method is sound. • Our property market analysis in the previous chapter showed a vacancy rate of only 2% for industrial space (including B2 and B8). This suggests that, despite a large increase in the supply of sites there is still limited capacity, indicating there is still latent demand for industrial land. 4.7 We would also note that this timeframe includes both periods of expansion and recession (2009 to 2011). It therefore gives us a long enough timeframe to consider the demand for employment land over an economic cycle.

Table 4.1 Employment land completions (Ha), 2000-18 Year Total site All B Class Office Industrial Warehouse Other area 2000 28.4 28.4 0.9 0.5 27.0 0.0 2001 15.2 15.0 1.2 9.1 4.7 0.2 2002 19.8 19.8 8.8 2.4 8.6 0.0 2003 31.6 26.8 1.7 4.0 21.1 4.7 2004 26.7 26.7 0.0 3.0 23.7 0.0 2005 23.7 15.8 0.9 8.0 7.0 7.9 2006 43.1 37.2 3.2 8.9 25.1 5.9 2007 84.1 80.9 3.7 11.6 65.6 3.2 2008 17.9 17.9 1.1 8.3 8.5 0.0 2009 6.4 6.4 0.0 0.8 5.5 0.0 2010 1.0 1.0 0.0 0.7 0.3 0.0 2011 1.3 1.1 0.0 1.1 0.0 0.2 2012/13 21.1 4.1 1.7 2.3 0.2 17.0 2014 12.9 6.6 0.0 6.6 0.0 6.3 2015 15.7 3.2 0.2 2.1 0.8 12.5 2016 36.4 31.5 2.5 5.8 23.3 5.0 2017 78.9 53.0 0.7 3.4 48.9 25.9 2018 40.3 31.4 0.0 2.3 29.1 8.9 Total 504.4 406.7 26.6 80.9 299.3 97.6 Average 26.5 21.4 1.4 4.3 15.8 5.1 20 year 530.9 428.1 28.0 85.1 315.0 102.8 period Source: Doncaster Borough Council Requirements by use class 4.8 Doncaster Borough Council’s policy on employment land does not provide a breakdown for different types of use class (office, industrial etc). PPG does encourage plan-makers to “provide an understanding of the underlying requirements for office, general business and distribution space” . This enables policy makers to “identify whether there is a mismatch

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between quantitative and qualitative supply of and demand for employment sites” (paragraph 2a-029). 4.9 The Council’s forecast based approach yields the following requirements for different use class over the plan period: • 14 Ha for office development • 125 Ha for industrial • 73 Ha for non-strategic warehousing • 271 Ha for strategic warehousing2 4.10 Taking a trends based approach (based on the % split of land in Table 4.1) gives the following requirements: • 31 Ha for office development • 96 Ha for industrial • 353 Ha for warehousing 4.11 The 2019 ELNA does not break down warehousing completions in to strategic and non- strategic uses. If we apply the same split as the forecast based approach (i.e. 79% is strategic warehousing) it gives the following requirements: • 75 Ha for non-strategic warehousing • 278 Ha for strategic warehousing. 4.12 This is a very similar result to the forecast based approach, although there is a much greater difference between the results for office and industrial land. 4.13 Overall, we conclude the Council’s estimates by use class represent a sound basis for planning. While past trends suggest a higher requirement for office space, this is driven by increases in supply that happened in the early and mid 2000s. Recent market conditions have made it much harder to deliver office space due to low rental values, which may take a long time to recover to the point where speculative development is viable. Therefore the trends based approach is likely to overestimate the land required.

2 Neither the 2015 nor the 2019 ELNA provide a definition of strategic and non-strategic warehousing. While it is clear that it is based on the size of warehouses (strategic warehousing is also referred to as ‘sheds’ in the ELNAs), the minimum size is not defined in any of the documents.

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5. Conclusions

5.1 Hatch Regeneris was appointed to review the Doncaster Borough Council’s employment land policy and underpinning evidence base, and to reach conclusions on whether it is based on sound evidence. 5.2 We conclude that the employment target of 481 Ha is justified and based on sound evidence. This is for the following reasons: • The 481 Ha is based on jobs growth of 1% p.a. This is consistent with past trends in Doncaster and the Sheffield City Region’s growth aspirations. • It uses the same jobs growth assumptions as the housing based assessment and therefore represents a joined up approach. 5.3 We also find that the breakdown between different use classes estimated in the ELNA is broadly in line with past trends and therefore found to be sound. This shows that a large share of the requirement for employment land is for strategic warehousing: • 14 Ha for office development • 125 Ha for industrial • 73 Ha for non-strategic warehousing • 271 Ha for strategic warehousing

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