Ref: Doncaster

Local Plan

Publication Draft 2019 (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

Please respond by 6pm Monday 30 September 2019.

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

Please email your completed form to us at

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

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

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

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

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

First Name Clare

Last Name Plant Organisation Bellway Homes Ltd (Yorkshire) DLP Planning Ltd (where relevant) Address – line 1 C/O Agent Ground Floor, V1 – Velocity

Address – line 2 2 Tenter Street

Address – line 3 Sheffield

Postcode S1 4BY

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on?

You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ).

Do I have to use the response form?

Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form.

You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination.

For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan

Can I submit representations on behalf of a group or neighbourhood?

Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached.

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

Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan

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

Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.

• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.

• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.

• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).

Question 8 (below) – Do I need to attend the Public Examination?

You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.

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

Part B

Please complete this Part to make your comments. After this Publication stage, further submissions will only be at the request of the Inspector, based on the matters and issues she/he identifies for examination.

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

Name / Organisation Name:

DLP Planning Ltd

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

Doncaster Local Plan Publication Draft ☒ Policies Map ☒ Sustainability Appraisal ☐ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☐

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

Page No.: Paragraph: Policy Ref.: 3, 6, 7, 8, 27, 29, 30, 66 and Site Ref.: Site 189: Higgins Site, Old Bawtry Road Appendix 2 Finningley, Auckley-Hayfield Policies Map: Green and Blaxton

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☐ Yes ☒

4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6)

5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☒ Justified ☒

Effective ☒ Consistent with National Policy ☒

6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.

Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.

You can attach additional information but please make sure it is securely attached and clearly referenced.

Please see Local Plan Representations Report.

7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.

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

Please see Local Plan Representations Report.

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

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

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

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

To support the Representations and the Inspector’s understanding of the site.

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

Your Date Signature 30/09/2019

Please send your completed form, by no later than 6pm on 30th September 2019, to: • Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU • or email:

Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan

Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:

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

For and on behalf of

Bellway Homes (Yorkshire) & Mr D Higgins

REPRESENTATION TO THE PUBLICATION VERSION OF THE DRAFT DONCASTER LOCAL PLAN CONSULTATION (REGULATION 19)

Higgin’s Site, Old Bawtry Road, Finningley

Prepared by DLP Planning Ltd Sheffield

September 2019

Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

Stuart Howden Prepared by: BA (Hons) MA MRTPI Senior Planner Clare Plant Approved by: MRTPI AssocRICS Director

Date: September 2019

DLP Planning Ltd Ground Floor V1-Velocity Tenter Street Sheffield S1 4BY

Tel:

DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is confidential to the client and DLP Planning Ltd accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk.

2 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

CONTENTS PAGE

1.0 INTRODUCTION ...... 4 2.0 OBJECTIONS TO DRAFT POLICIES ...... 6 Policy 3: Level and Distribution of Growth ...... 6 Policy 6: Housing Allocations ...... 10 Policy 7: Doncaster Sheffield Airport and Business Park ...... 13 Policy 8: Delivering the Necessary Range of Housing ...... 18 Policy 29: Open Space Provision in New Developments ...... 21 Policy 30: Ecological Networks (Strategic Policy) ...... 23 Policy 66: Developer Contributions (Strategic Policy) ...... 23 Appendix 2: Development Requirements ...... 25 3.0 ASSESSMENT OF THE SITE ...... 26 Site Location ...... 26 Proximity to Local Facilities ...... 27 Landscape/Visual Impact ...... 29 Heritage Impact ...... 29 Flood Risk/Drainage ...... 29 Ecology/Trees ...... 29 Highways Safety ...... 30 HELAA Representations ...... 31 Availability ...... 31 Suitability ...... 31 Achievability ...... 32 Capacity ...... 32 Conclusions ...... 32 4.0 CONCLUSIONS ...... 33

Appendix 1 Representation by SPRU Appendix 2 Preliminary Bat Survey Report by Wardall Armstrong Appendix 3 Highways Scoping Report by Andrew Mosely Associates

3 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

1.0 INTRODUCTION

1.1 This representation is made on behalf of Bellway Homes (Yorkshire) and Mr D Higgins (as landowner) in response to the Doncaster Local Plan Publication Consultation in relation to the Higgin’s Site, Old Bawtry Road, Finningley (Figure 1). The site is identified under draft Local Plan site reference ‘189 - Higgins Agriculture Ltd, Old Bawtry Road, Finningley’.

Figure 1. Location Plan

1.2 The site has previously been promoted for residential development by DLP Planning at the following stages:

• Sites and Policies Development Plan Document – September 2013

• Call for Sites – October 2014

• Issues and Options – Summer 2015

4 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

• Vision, aims and objectives – Summer 2015

• Homes and Settlements – April 2016

1.3 The site is a partial brownfield parcel of land, sustainably located adjacent to the Finningley settlement boundary. The site is also immediately adjacent to Doncaster Sheffield Airport, which is specifically identified as a key driver of economic growth during the proposed local plan period.

1.4 Despite this, the site is indicated to be retained within a Countryside Policy Area in the draft Local Plan. DLP strongly objects to the omission of the site from the proposed Housing and/or potentially Employment allocations.

1.5 To this end, Section 2 of this representation considers the strategic approach to housing and employment delivery within the Publication Local Plan, objecting to the policies as drafted and providing recommendations regarding the level of housing as set out in the draft Local Plan, in order to ensure the soundness of the plan. A number of objections are also raised and recommendations provided on other relevant draft policies.

1.6 Section 3 goes on to provide a detailed site-specific assessment of the Higgin’s Site (Site 189) in order to demonstrate the capacity, suitability and deliverability of the site for development in order to support the Local Plan objectives.

1.7 Section 4 confirms the primary objections raised in the representation and recommends that the land at the Higgin’s Site, Finningley should be identified as a Housing allocation, in order to meet the housing need in the Borough. This approach will ensure the plan I positively prepared and sound in accordance with the National Planning Policy Framework (2019).

5 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

2.0 OBJECTIONS TO DRAFT POLICIES

Policy 3: Level and Distribution of Growth 2.1 The Doncaster “Inclusive Growth Plan” is supported.

2.2 The level of housing development to be delivered is set out in Policy 3, which states that the Council will seek to facilitate the delivery of at least 920 (net) new homes each year over the plan period 2015-2032 (15,640 homes in total) with sufficient land allocated to deliver at least 15 years’ supply (13,800).

2.3 Paragraph 59 of the National Planning Policy Framework (the ‘Framework) sets out the Government’s objective of significantly boosting the supply of homes, through the identification of a sufficient amount and variety of land where it is needed and to meet the needs of groups with specific housing requirements [authors own emphasis].

2.4 The SPRU report provided at Appendix 1 assesses the soundness of the proposed jobs-led housing requirement and the implications for the proposed spatial strategy.

2.5 For the reasons outlined within the SPRU report, DLP objects to Policy 3 of the draft Local Plan as there are found to be substantial soundness failings with the draft Local Plan resulting from a failure to test an appropriate reasonable alternative based on meeting the strategic priorities for economic development over a full 15-year plan period. These issues are compounded based on treating the housing requirement from 2018-2033 as a ‘residual total’ to account for perceived oversupply in the period 2015-2018, which has not been adequately justified.

2.6 The Council’s approach fails to accurately reflect the strategic priorities and future economic potential of the Sheffield City Region and further assessment of the proposed requirement is recommended to reflect the requirements of the revised Strategic Economic Plan (once published) and to consider recent trends in jobs growth and housing delivery across the sub-region. This is anticipated to lead to a reassessment of current and future demographic trends in relation to future labour supply.

2.7 The SPRU report also concludes that arbitrary constraints to the requirement for additional development are applied, which will lead to an overreliance on extant planning commitments and historic allocations in previous iterations of the development plan. The implications of this in terms of prospects for maintaining a five year supply of deliverable sites and meeting the housing needs of different groups have not been fully assessed,

6 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

however it is anticipated that there could be a failure to meet housing need, particularly in respect of affordable housing in the short to medium term, as the physical and viability related constraints that have prevented these sites being delivered to date may persist.

3.1 The SPRU report concludes that these issues are capable of remedy within the Council’s broad emerging approach to managing the distribution of growth across the spatial strategy. This acknowledges that significantly greater levels of potentially suitable growth could be provided at different tiers of the settlement hierarchy, in-particular Main Towns at Tier 2. We endorse the Council’s position that Main Towns are appropriate locations to accommodate up to 10% of the economic-led component of the housing requirement. However, we also recommend the consideration of Tier 3 – Service Towns and Larger Villages as potential locations for additional growth, where sustainable growth opportunities are identified.

Recommendation 2.8 The Local Plan should be updated to reflect the housing requirement of 1,073 dwellings per annum for the plan period to 2035.

Justification 2.9 For the reasons set out above and within the appended SPRU report, it is correct to accommodate growth based on meeting requirements under the full assessment of jobs-led growth (1,073 dpa) for the full plan period to 2035.

Distribution of Growth

2.10 The proposed housing distribution within the draft plan has a strong focus on the Main Urban Area with 50% of development proposed in the Doncaster Main Urban Area, followed by 40% in second tier (Main Towns) locations, 10% in Services Towns and Larger Villages and limited development in Defined Villages. The proposed distribution is based on the Settlement Background Paper which forms a settlement hierarchy and informs the location of housing and employment sites.

2.11 The Publication Doncaster Local Plan identifies Finningley as one of 10 Service Towns/Villages which will provide about 10% of the Borough’s total housing requirement during the plan period. Specifically, Finningley is identified to deliver 55 dwellings in the plan period (50 of which are based on existing permissions)

7 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

2.12 The Sustainability Appraisal for the Publication Local Plan discounts Site 189 and all other alternatives within Finningley from allocation based on the proposed housing distribution and the level of housing already committed within the settlement. We object to this approach and consider it to be unsound.

2.13 It is not considered appropriate that such limited levels of allocations have been identified in reasonably sized settlements such as Finningley. The only justification put forward for failing to allocate new sites for development is based on existing permissions within these settlements. However, these sites have yet to be delivered and may suffer from issues including viability that could impact future delivery.

2.14 Settlements including Finningley have been identified as ‘Larger Villages’ within the settlement hierarchy. There is a population of over 6,800 people in the immediate area surrounding the airport (Auckley, Blaxton and Hayfield Green) and as such it is larger than settlements such as Tickhill (over 5,200 people) and Askern (over 5,500 people) and is of a similar size to Edlington (7,500). However the draft Plan proposes to retain existing settlement boundaries in Auckley and Finningley, allowing only infill small scale affordable housing.

2.15 The proposed approach to the delivery of housing, as drafted, fundamentally fails to recognise the emphasis within the Framework on the deliverability of housing and the need to support the prosperity of settlements outside of the main urban area.

2.16 The draft Local Plan proposes a housing target based on economic growth objectives, a substantial element of which will be linked to the growth of the airport. The approach to limiting the expansion of those settlements surrounding the airport, together with the objectives of draft Policy 7, which seeks to support ‘windfall’ housing development linked to employment growth within the airport sites, risks creating an isolated community and fails to take the opportunity to ensure the future sustainability of existing communities located in close proximity to the airport.

2.17 While settlements such as Finningley may rely on towns to provide essential services, the need to sustain the existing services will require additional employment and housing. The continuing trend for a reduction in household size means downsizing will undercut the customer / user thresholds to which current amenities and facilities have become accustomed. This poses a significant threat to the current level of sustainability enjoyed by 8 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

the settlement.

2.18 The housing allocations requirements should not be based purely on the hierarchy of a settlement as there are a number of considerations namely urban capacity, need and demand for housing, regeneration, environmental and social considerations which need to be taken into account to ensure the growth of settlements in a sustainable manner. In the case of Finningley, the proximity to the DSA Masterplan area is a particularly relevant consideration in order to ensure support for the proposed economic strategy.

Recommendation 2.19 The distribution of housing provision within Policy 3 – Service Towns and Larger Villages should be increased to meet the updated housing requirement, and reapportioned (or alternatively flexibility introduced) to support the delivery of a higher proportion of the housing within sustainable and desirable locations close to economic growth.

Justification 2.20 The Local Plan as drafted is overly reliant on a significant quantum of sites within the Main Urban Area. This approach relies on the delivery of a notable number of large sites, which will require substantial enabling infrastructure in order to deal with constrains that may include contamination and highways infrastructure upgrades as well as drainage and other matters.

2.21 The growth potential of a number of Service Towns and Larger Villages has been underplayed and that Finningley, together with neighbouring Auckley/Hayfield Green should have an increased allocation of housing land within these settlements, in order to capture the regeneration opportunities provided by the proximity to the airport and to deliver housing in sustainable locations where there is a recognised demand.

2.22 Given the size of the committed level of airport related employment on the airport itself it is also considered that the current approach fails to consider the obvious beneficial impact of concentrating further employment and residential development in close proximity to the airport, especially as there are large areas of despoiled land that are well related to public transport infrastructure and can be developed for mixed use schemes.

2.23 The limited housing target apportioned to Finningley, as well as neighbouring

9 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

Auckley/Hayfield Green does not appear to be appropriate and there seems to be no justification of not meeting some level of demand and need in these locations. This approach is likely to result in not only a missed opportunity to support the projected economic growth but also lead to the decline of those settlements.

2.24 The potential for redevelopment of sustainable sites such as the Higgin’s site in these areas should be realised, where deliverable, in order to support the long term viability of these areas. By reviewing existing Countryside designations around these settlements, boundaries can be rationalised to allocate land for development to serve the purposes of these policy areas.

2.25 New housing allocations are considered to be an appropriate response to accommodating further development in these locations.

Policy 6: Housing Allocations 2.26 The Housing Allocations required to deliver the proposed housing requirement and distribution as set out in Policy 3, are identified by Policy 6.

2.27 Site 189, the Higgin’s Site is not currently proposed for allocation, and is designated within the Countryside Policy Area (figure 2).

2.28 We strongly object to the current designation of the site within the Countryside Policy Area and the omission of the site from allocation within Policy 6.

10 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

Figure 2: Extract of the site from the draft Doncaster Local Plan Proposals Map (2015-2035)

Recommendation 2.29 Site 189 should be removed from the Countryside Policy Area and added to the list of housing allocations and the Proposals Map should be updated to reflect this.

Justification 2.30 The site should be allocated for housing development in order to meet the future short- medium term housing requirement, as discussed with reference to Policy 3 above. The allocation would also take the opportunity to deliver new sustainable development on land (part of which is brownfield) adjacent to an existing settlement in order to meet the needs of the local population.

2.31 Full justification for this recommendation is set out within Section 3 of this representation, which confirms that the site is suitable, deliverable and developable for housing, and capable of being brought forward and allocated for housing within the Local Plan.

2.32 The site adjoins the Finningley development boundary and contains existing built form associated with the commercial use of the site. The site is not protected for employment use, as more suitable sites are identified elsewhere within the Borough.

2.33 Furthermore, substantial growth is anticipated in association with the neighbouring airport site, resulting in job creation and a need for housing within the locality. It is considered to be both logical and sustainable to therefore focus housing growth within the area surrounding the airport, in order to support Policy 7 of the draft plan and to support the future sustainability of services within Finningley.

2.34 It is acknowledged that land has been identified for housing under Policy 7 in the draft Local Plan to facilitate the growth of the airport. The Airport Masterplan includes an initial allocation of 280 dwellings to help it realise its economic aspirations under site ref: 223 ‘Land at Hayfield lane, Auckley’, as well as an additional 920 units, only to be released when jobs are evidenced to support the requirement for additional dwellings under site ref: 940 ‘Land East of Poplars Farm, Hurst Lane, Auckley.

2.35 Site ref 940 is isolated from the existing settlements surrounding the airport and would

11 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

result in a residential scheme that in our view would not sympathetically integrate with the existing area. In addition, it is a significant distance from the centre of Auckley-Hayfield Green or Finningley and the services within it, therefore occupiers would be likely to be reliant on the use of private car.

2.36 The Higgin’s site is more sustainably located when compared to those sites within the DSA Masterplan, but not withstanding this, for the reasons set out within this representation, additional housing land should be allocated in any case to support the additional requirement that we have identified. In order to support the economic growth strategy set out within the Local Plan and the sustainability of existing settlements, it is recommended that site 189 is allocated for housing.

2.37 A number of the Housing allocations put forward within the draft Local Plan are currently within the Green Belt and/or within flood zone 3.

2.38 Allocated sites within the green belt include:

• Site Ref: 33 ‘Land adjacent 163 Sheffield Road, Warmsworth (112 units).

• Site Ref: 40 ‘Land at Sheffield Road/Old Road, Hilltop, Conisbrough’ (200 units).

• Site Ref: 115 ‘Alverley Lane’ (150 units).

• Site Ref: 141 ‘Westwood Road, Bawtry’ (20 units).

• Site Ref: 165 ‘Land North of the A1, Skellow’ and Site Ref: 186 ‘Land off Crabgate Lane, Skellow’ (300 units).

• Site Ref: 777 ‘Plot 3, Harlintgon’ (66 units).

• Site Ref: 929 ‘Land North of Cadey Road, Sprotbrough’ (80 units).

• Site Ref 1028 ‘Sunderland Street, Tickhill’ (74 units).

Allocated sites within Flood Zone 3 include:

• Site Ref: 81 ‘Alexander Street. Thorne’ (113 units).

• Site Ref: 343 ‘Alexander Street, Thorne’ (74 units). 12 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

• Site Ref: 396 ‘North Eastern Road, Thorne’ (53 units).

• Site Ref: 147 ‘Land to the North of Hatfield Lane, Barnby Dun’ (175 units).

2.39 These sites are considered to be less sequentially preferable in policy terms for development when compared to the Higgin’s Site. As outlined in the National Planning Policy Framework (the ‘Framework’), exceptional circumstances are required to justify changes to Green Belt boundaries. The Framework also sets out that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk.

2.40 The Higgin’s Site is not situated within the Green Belt and is located within Flood Zone 1. Given that the site is suitable, available and achievable for housing development (as outlined in Section 3), and that housing on the site would support the economic growth of the Airport, the distribution of housing within the Local Plan should be reviewed as suggested to ensure accordance with the National Planning Policy Framework.

Policy 7: Doncaster Sheffield Airport and Business Park 2.41 Policy 7 of the Publication Local Plan supports the growth of and investment in Doncaster Sheffield Airport, which will be supported by its future expansion. These representations endorse the support for Doncaster Sheffield Airport (DSA). This strategically important location is central to the strategic priorities of the plan area and delivery of the Local Plan’s objectives. However, it is necessary to highlight a number of issues of soundness regarding the relationship between DSA and the Council’s approach to the wider spatial strategy. These concerns should be read in the context of the SPRU commentary regarding the appropriateness of the housing requirement identified in the Pre-Submission Local Plan and the resulting outcomes for scale and distribution of development (see Appendix 1).

2.42 This Appendix highlights the need to ensure that the number of new homes proposed in Policy 3 adequately reflects the requirement to support economic growth and availability of labour to meet the future potential for growth in the number of jobs in the Borough. The draft Local Plan should therefore support the delivery of 1,073 dwellings per annum for the full plan period 2015-2035, ensuring provision for a full 15 years following adoption.

2.43 The Council must consider a more flexible approach to the scale and distribution of growth to recognise the range of potentially suitable locations to meet development need identified

13 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

under the government’s standard method plus the component of the requirement necessary to support economic growth (and ensure the delivery of affordable housing).

2.44 Policy 7 is therefore supported in principle but requires modifications to other policies as proposed herein, to ensure that it is effective.

Higgin’s Site and Relationship to the Spatial Strategy

2.45 Specifically, these representations demonstrate that the Local Plan should support housing development at the Higgin’s Site and that the site should be reassessed in the context of Finningley’s ability to support the spatial strategy in the Local Plan.

2.46 This site represents a suitable and sustainable location to meet the growth needs of existing settlements (Section 3 provides more detail regarding the suitability of the site). The site is also assessed in the Council’s HELAA (Ref: 189) and found to be suitable for development, subject to local policy constraints.

2.47 The HELAA identifies the site as ‘Isolated Greenfield’, which is not justified given the Council’s assessment of capacity of up to 827 homes. This location should instead be regarded as a site that will provide sustainable links to Finningley and represent an appropriate contribution to the scale and distribution of growth as part of the spatial strategy. This would ensure a positive prepared response to local demand for growth. This strategy seeks to avoid an ad-hoc approach to development in nearby settlements that has occurred over recent years without an up-to-date plan in place.

2.48 It is therefore requested that Site 189 by identified as an allocation in the draft Local Plan contributing towards housing requirements during the plan period. This approach would overcome soundness concerns regarding the Council’s proposed approach to restrict housing growth directly related to an increase in jobs at DSA.

Delivery of this site will contribute towards the Local Plan housing requirement and will support achieving the economic growth-led component of the housing requirement given the proximity to DSA, thus complement the potential for economic development at this location.

Objection to Policy 7 – Relationship with the Spatial Strategy

14 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

2.49 In relation the potential for job growth at DSA, the draft Local Plan looks to divorce DSA from its role in the wider spatial strategy. This is significant because it overlooks the existing demand for jobs (and by association the requirement for homes and labour supply) associated with role of DSA as a growth driver. This also raises issues of consistency with national policy, given the ability of DSA to support a prosperous rural economy. Specifically, the spatial strategy fails to recognise that a number of settlements in close proximity to DSA, including Finningley and Auckley-Hayfield, have significant potential to support sustainable patterns of development associated with the delivery of housing and economic growth consistent with paragraphs 78 and 83 of the National Planning Policy Framework 2019 and achievement of the airport’s objectives.

2.50 It is therefore not justified that the proposed spatial strategy, and the approach to the scale and distribution of housing outlined in proposed Policy 3, does not support any contribution to the economic-led component of housing growth at Service Towns and Larger Villages in close proximity to DSA. This only applies to ‘Main Towns’ identified as potentially suitable to deliver up to 10% of the economic-led growth requirement. We advocate that suitable sites, sustainably located in relation to settlements at Finningley and Auckley-Hayfield, and which complement the strategy for DSA, should be identified to meet the need for jobs-led growth in the overall housing requirement. It is appropriate that such sites contribute towards the Borough’s identified housing needs without delivery being directly linked to jobs growth at DSA.

2.51 It should also be noted that the DSA Masterplan 2018-2037 ‘Interim Consultation Summary Report’ (August 2018) (p.41) identifies that, in terms of demand for residential development to support the airport’s objectives, surrounding settlements already demonstrate high volumes of property transactions. This is a strong indicator of local demand and reflects that pressure for housing in the local area already reflects the area’s significant contribution to the wider sub-region. This is best addressed through the plan-led approach.

Objection to Policy 7 – Jobs-Growth Related Housing Provision

2.52 The overall vision for DSA demonstrates the importance of the airport in boosting productivity, job creation and as a catalyst for the sub-region. The Draft Doncaster Sheffield Airport Masterplan (2018-2037) is underpinned by the potential for the creation of up to 73,000 jobs, which reflects aspirations beyond the plan period. It is broadly appropriate that

15 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

proposed Policy 7 is not underpinned by these requirements, but they form an important context for DSA’s relationship to strategic priorities in the sub-region and the overall justification for the employment-led component of the Local Plan’s requirement for housing growth to support labour supply. This is in-turn important evidence to inform the distribution of growth to this part of the plan area. The significant ‘gap’ between the assumptions for job growth in the DSA Masterplan and the potential for development identified in Policy 7 indicate that this element of the spatial strategy is not positively prepared.

2.53 Our soundness concerns with the proposed approach to Policy 7 are that the relationship to potential jobs growth (and existing levels of employment at DSA) is based on an extremely narrow interpretation of the Draft Masterplan’s explanation of the airport’s contribution towards economic development. Page 6 of the Draft Masterplan states that DSA currently supports around 1,000 jobs, which is the figure relied upon in Policy 7 as the baseline above which future housing growth in association with delivery of the Masterplan will be supported.

2.54 The approach to identifying the ‘baseline’ in Policy 7 also wholly fails to acknowledge significant existing planning commitments that complement opportunities for jobs growth outside of the DSA Masterplan (and Local Plan allocation) boundary. The Council’s Housing and Employment Land Availability Assessment confirms 3.6ha of deliverable supply on the site of the Former Blaxton Quarry (see Policy 4). Planning permission for the site (under 09/01292/OUTM) provides indicative totals for floorspace of 215,003 sqft (19,975sqm) B2/B8/Sui Generis and 7459sqft (693sqm) B1 Offices. This would provide for an estimate of at least 375 jobs in accordance with jobs-to-floorspace densities used in the Council’s HELAA.

2.55 This interpretation of the baseline in terms of its relationship with future potential and the economic-led component of housing growth to support necessary growth in the labour force is not justified. Draft Policy 7 relies on reference to the 1,000 existing jobs figure, plus the Council’s pro-rata assumption for provision of 2,545 jobs over the whole plan period to 2035, in order to account for initial support for up to 280 homes within the DSA Masterplan (at Hurst Lane – Site E2).

2.56 This is divorced from the ‘Core growth scenario economic benefit summary’ outlined in the Draft Masterplan, which anticipates growth to 4,495 Full-Time Equivalent jobs by 2026

16 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

(DSA Draft Masterplan, 2018, p.90).

2.57 The Council provides no clear justification for how it interprets the role of the airport in the local and sub-regional economy and as a result Policy 7 does not provide a basis to assess the overall contribution to economic development. The core scenario of the DSA Masterplan provides a wider view, and recognises that a substantial proportion of this activity will be generated locally and induced by increased passenger numbers and associated visitor spending associated with use of the airport. The Draft Masterplan notes:

“Based on average inbound visitor spending and assumptions regarding the proportion of spending that could be retained within Sheffield City Region, it is estimated that the spending of inbound visitors could support a further 638 gross FTE jobs annually by 2037” (DSA Draft Masterplan 2018, p.89).

2.58 This is in addition to the substantial potential for growth in permanent, FTE, jobs associated with the construction phase. While this calculation is based on development of DSA airport itself this sector of the economy will support delivery of the Local Plan’s overall requirement for growth; equally some growth in the construction workforce may take place before aspects of the DSA Masterplan are implemented. Neither of these components of economic development appear to be recognised in the Council’s Appendix 3 which is associated with monitoring jobs growth at DSA.

2.59 National planning policy requires that Local Plans are reviewed at least every five years. The objective for a substantial opportunity for residential growth south of the Airport Approach Road should, as outlined in the Council’s Pre-Submission Local Plan (paragraph 5.30), form part of measures to ensure comprehensive delivery and masterplanning. The measures to control any potential additional growth in the plan period through Policy 7 and the accompanying Appendix 3 are not justified and would not be effective. This would generate significant uncertainty surrounding future monitoring requirements (in terms of measuring job growth) and barriers to implementing the policy as intended.

2.60 It is notable that the Council’s own 2018 Housing and Economic Land Availability Assessment (HELAA) indicates that for Site Ref 940 (‘Poplars Farm, Hurst Lane’) only 140 should be regarded as deliverable in years 0-5 of the plan period. This is significantly less than the 280 units indicated as a first phase of growth (Site E1) nearest the approach road and indicative location for the Commercial Plaza. This strongly indicates that the future 17 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

requirements for comprehensive development can most effectively be addressed as part of Local Plan review, whereas both Site E2 (as identified in the Local Plan) and the proposed additional capacity at the Higgin’s Site provide essential opportunities to address the housing requirement upon adoption.

Recommendation

2.61 Policy 7 should be revised to focus supporting development associated with the airport growth within the surrounding settlements to meet the objectives of Policies 3 and 6 (based on recommended amendments as made herein).

Justification 2.62 The Higgin’s Site is located directly adjacent to the airport site boundary and the provision of housing in this location would support the regeneration of a previously developed site and the vitality and sustainability of the existing settlement. The site is therefore a highly sustainable location for which to accommodate new housing development to support growth in the area. The allocation of the site for housing will also support the regeneration of the site and the sustainable future of the village of Finningley.

2.63 As outlined above when discussing Policy 6, the Higgin’s Site is a more sustainable and desirable option than site ref: 940 for the housing required to support the substantial growth of Doncaster Sheffield Robin Hood Airport.

2.64 The additional housing will support the uplifted housing figure proposed within this representation in relation to Policy 3. If the Council is not minded to accept this figure, the inclusion of the site for development under Policy 7 (i.e. in addition to the standard Local Plan figures) is also considered to be justified on the basis of supporting sustainable economic growth associated with the Draft DSA Masterplan.

Policy 8: Delivering the Necessary Range of Housing 2.65 Policy 8 sets out that the delivery of a wider range and mix of housing types, sizes and tenures will be supported through the following measures:

a) “New housing developments will be required to deliver a mix of house size, type, price and tenure to address as appropriate the needs and market demand

18 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

identified in the latest Housing Need Assessment / Study (or other robust evidence). b) There is a clear requirement for the provision of affordable housing to meet local needs in each individual community. Housing sites of 15 or more homes (or 0.5Ha or above) will normally be expected to include 23% affordable homes in the Borough’s high value housing market areas (as defined in explanatory text below), or a lower requirement of 15% elsewhere in the Borough (including starter homes / discounted market sales housing which meet the definition in the NPPF) on-site. Proposals for affordable housing on developments of less than 15 units will be supported where these meet other development plan policies. c) Commuted sums in lieu of on-site affordable housing provision and of broadly equivalent value will only be accepted where this is robustly justified. These commuted sums will be used to target areas of need in the Borough in order to assist with rebalancing the housing market. They may also be combined with council house building programmes that would take place on land that the council owns or subsequently needs to acquire. d) In order to provide the necessary housing supply required for the changing needs of residents and to support independent living, new developments should include the provision of homes which are adaptable, accessible, and suitable for people with a wide range of needs in line with Policy 46. It must also be demonstrated how the provision of housing types suitable for older people can be increased, especially bungalows, extra care facilities and supported living accommodation. These will be supported on sites suitable for housing and which have good access to local services and facilities by means other than private car. e) Specialist student accommodation will be supported on sites with walk/cycle and/or public transport access to Doncaster College or other training facilities. Wherever possible, commuted sums relating to such accommodation will be used to target areas of need in the Borough.

19 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

f) The provision of opportunities to accommodate custom build and self-build homes will be encouraged on housing allocations and elsewhere.”

2.66 The supporting text for Policy 8 sets out that the required affordable housing percentages have been determined from the Doncaster Local Plan Viability Testing (2016) evidence base.

2.67 It is of note that there is no specific mention within the policy itself of the affordable housing requirement being subject to viability testing. However, Policy 67 (Development Viability (Strategic Policy)) states the following with regard to such testing:

“Where the applicant can demonstrate that particular circumstances justify the need for a Viability Appraisal, the Council will take a pragmatic and flexible approach to planning obligations and consider their genuine impact on viability of development proposals on an independent and case by case basis, at the applicant’s expense, and in line with the following principles:

a) Development which is unable to make the full contribution at the point at which the application is submitted may be supported where:

1. a robust and fit for purpose viability assessment shows that the full contribution would make the development unviable;

2. the possibilities for reduced, deferred or phased contributions have been fully explored; and,

3. it can be demonstrated that the wider benefits of the scheme outweigh its lower level of contribution.

b) Where a lower level of contribution is agreed, this may be subject to reassessment once the development commences and / or any other suitable trigger point(s) as appropriate and agreed between the Council and the applicant.”

2.68 In principle, the setting out of an affordable housing requirement as in Policy 8 is supported, subject to the inclusion of a direct reference to Policy 67. 20 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

Recommendation 2.69 Policy 8 to include direct reference to the need to consider viability, in accordance with Policy 67.

Justification 2.70 The Council should include a reference to Policy 67 to ensure clarity in the application of this policy and to ensure that the plan remains viable and deliverable, as therefore sound, within the plan period.

Policy 29: Open Space Provision in New Developments 2.71 Policy 29 states the following with regard to open space provision:

“To address local green (open) space needs and deficiencies, development proposals:

a) of 20 family dwellings or more will be supported which contribute 10% or 15% of the site as on-site open space to benefit the development itself – the nature and type of which will be determined by having regard to the Council’s Green Space Audit and Playing Pitch Strategy.

b) of 20 family dwellings or more, adjacent or close to a large open space (such as a public park or recreation area) alternatively may be asked to provide a commuted sum of 10% or 15% of the residential land value of the development site.

c) of between 10 and 20 family dwellings will be supported which provide for a commuted sum of 10% or 15% of the residential land value of the development site to improve existing open spaces within the vicinity of the development.

d) for retirement living schemes and / or aftercare facilities will be required to provide good quality on-site amenity spaces equating to 16sqm of open space per person.

e) providing on-site open space will be required to provide for sustainable open space management and maintenance to be determined in

21 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

discussion with the planning authority.”

2.72 Policy 29 reiterates extant UDP Policy RL4, which requires 10 – 15% on-site provision or a commuted sum in lieu of provision on-site dependent on-site specific circumstances (the number of dwellings proposed for example). The draft Policy does not appear to be based on, or justified by, an up to date evidence base.

2.73 The Council’s Green Space Audit, which is referenced in Policy 29 and comprises part of the evidence base for the publication version of the Plan, is dated July 2013. This evidence is considered to be out of date.

2.74 It is also of note that the word “close” [to a large open space …] in part 29(b) of the policy is not defined within the policy, to enable those reading the policy to understand when the clause might be triggered.

2.75 The policy proposes the calculation of a commuted sum, in lieu if on-site POS provision, based on residential land value. This figure would not ordinarily be agreed or disclosed at the planning stage and will create an unacceptable circularity issue to the policy. In light of these points, we object to the current wording of Policy 29.

2.76 The general objective of Policy 29 is understood. However, the policy should be clear so that future developers understand what the open space requirements are.

Recommendations 2.77 The Council’s Green Space Audit should be updated and then periodically reviewed so that the information being relied upon is kept up to date. The threshold requirements should be set with reference to this evidence.

2.78 The word “close” [to a large open space …] should be specifically defined within the policy itself or within a glossary to provide clarity for future applications.

2.79 All reference to calculating off-site contributions based on “residential land value” should be deleted from Policy 29.

2.80 The Council should base their commuted sum value for off-site open space provision on a justified calculation, which is secured through a CIL and / or S106 agreement (as appropriate) so that future developers understand what the costs will

22 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

be.

Justification 2.81 Policy 29 is inadequately clear, with references to an evidence base document that is out of date. It also seeks to calculate a commuted sum based on information that will not be agreed / disclosed at the planning application stage.

Policy 30: Ecological Networks (Strategic Policy) 2.82 Policy 30 states that:

“Proposals will only be supported which deliver a net gain for biodiversity and protect, create, maintain and enhance the Borough’s ecological networks by:

a) being of an appropriate size, scale and type in relation to their location within and impact on the ecological network; b) maintaining, strengthening and bridging gaps in existing habitats networks; c) planting native species and creating new, or restoring existing, national and local priority habitats and / or species; and d) working with strategic partnerships to deliver conservation projects at a landscape scale where appropriate.”

2.83 It is of note that there is no reference within the policy or the supporting text to possible mitigation measures or biodiversity offsetting calculations, should a development proposal creates a biodiversity loss. In light of this, we object to the current wording of Policy 30.

Recommendations 2.84 Policy 30 should refer to supplementary guidance (to be prepared) regarding possible mitigation measures and biodiversity offsetting calculations, so that the policy requirement is fully understood with reference to guidance in the Framework.

Justification 2.85 Policy 30 is inadequately clear or effective as currently drafted and should be amended as suggested to ensure it does not undermine the delivery of the Local Plan.

Policy 66: Developer Contributions (Strategic Policy)

23 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

2.86 Policy 66 states the following regarding developer contributions:

“It is important that new proposals are planned in step with the necessary supporting infrastructure, and can make appropriate contributions towards new infrastructure as required, in order to deliver sustainable development. However, developments should not be subject to such a scale of developer contributions or policy requirements that development viability is put at risk. To help ensure this balance is achieved, proposals will be expected to accord with the following:

a) Where necessary, directly related to the development, and fair and reasonable in scale and kind, developer contributions will be sought to mitigate the impacts of development through:

1. direct provision on site (e.g. for on-site affordable housing, education facilities, biodiversity net gain, open space, or sustainable drainage schemes);

2. provision off site, to ensure the development can be delivered in line with other policy objectives, and to a safe and satisfactory standard (such as off-site affordable housing, education facilities, biodiversity net gain, flood mitigation, or highways improvements); and

3. contributions towards softer interventions to ensure the benefits of the development are maximised by local communities (such as skills and training programmes including local labour agreements).

b) Where infrastructure is to be provided either on or off site, provision for its long-term maintenance will be required (which may include its adoption either by the Council or a third party, subject to the provision of appropriate maintenance funding from the developer).

c) To address developer requirements as a whole, where development proposals on a large composite or naturally defined area are sub divided into multiple applications (or phases) over time, planning applications which form

24 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

part of a more substantial proposed development, on the same or adjoining land will be treated as one application for the whole development.”

2.87 We object to the current wording of Policy 66.

Recommendation 2.88 The specific developer contribution requirements need to be defined either in policy, a supplementary planning document or a CIL document for clarity and to ensure deliverability and soundness of the plan.

Justification 2.89 Policy 66 is inadequately clear and ineffective, and therefore unsound.

Appendix 2: Development Requirements 2.90 The development requirements for new development sites are set out in Appendix 2 of the draft plan. However, there is no reference within the plan as to how the required education contribution will be calculated or what the precise green infrastructure and public open space requirements will be for the site. We object to this approach.

Recommendations 2.91 Details of how the required education contribution will be calculated should be included within the requirements information, or, if our recommendation is implemented, a reference to Policy 66 / the relevant supplementary planning or CIL document should be included.

2.92 Details of what the green infrastructure and public open space requirements will be for the site should be included within the requirements information, or, if our recommendation is implemented, a reference to Policies 27, 29 and 30 should be included.

Justification 2.93 The development requirements set out in Appendix 2 are likely to be ineffective and have a directly detrimental impact on viability if clarity of contributions expected is not set out within the Local Plan or supplementary planning documents. This undermines the soundness of the Local Plan.

25 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

3.0 ASSESSMENT OF THE SITE

3.2 The site, known as Higgin’s Potato Stores, Old Bawtry Road, Finningley (LPA ref: 189) is assessed within the Council’s HELAA document (2017), however, the emerging Local Plan discounts this site, along with other promoted land surrounding Finningley, on the basis that sufficient land is already committed within Finningley to meet the housing need.

3.3 The following section provides a detailed assessment of the Higgin’s Site and confirms why it is available, suitable and deliverable for development and should therefore be allocated for Housing to meet future need.

Site Location 3.4 Site 189 comprises land east of Old Bawtry Road, a significant part of which is currently

26 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

occupied by the built form as shown in Fig. 3.

3.5 The site is located approximately 12.8km east of Doncaster and immediately to the east of Doncaster Sheffield Airport.

Figure 3: Aerial View of the Site and Surrounding Area

3.6 The site comprises of 36 hectares of part-brownfield, part greenfield-land (with a capacity of up to 221 dwellings, but with an additional capacity of up to 827 dwellings if required).

3.7 Directly to the north of the site is Finningley village. To the east of the site is the A614 Bawtry Road and aggregate works access via Croft Lane. To the south of the site is dense woodland, beyond which is the Doncaster Moto Cross Centre.

3.8 Access to the site is currently taken from Old Bawtry Road on the western boundary of the site. This access point is well-established and has clear visibility. The principle of residential development would not create a demonstrably adverse impact on highway safety or volumes of traffic.

Proximity to Local Facilities 3.9 There are a number of local services and facilities within Finningley and the surrounding area, which are easily accessible from the site using alternative means of transport to the

27 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

private car and include:

• Post Office/Convenience Store

• Village Hall

• Public Houses

. The Harvey Arms

. Station Hotel

• Primary Schools

. St Oswald’s C of E Academy

. Finningley C of E Primary School

• Hayfield School (secondary school) – In neighbouring Auckley

• New College (sixth form) – in neighbouring Auckley

• Mayflower Medical Practice (open every weekday)

• Finningley Park

• Golden Sun Takeaway

3.10 The centre of Finningley is accessible from the site by public footpath along Old Bawtry Road. In addition, Public Rights of Way dissect the site and provide a direct link to the village centre.

3.11 The site is accessible by public transport with the nearest bus stop being located approximately 400 metres away at The Green in the centre of the village. This bus stop is served by routes 57f/58f, which provides access up to twice an hour to Doncaster town centre.

3.12 The DSA Masterplan confirms that funding is currently being sought for a new airport railway station, which would be located on the part of the existing railway line adjacent to the Hurst Lane. This would be within close proximity to Finningley village and would provide frequent public transport connections towards Sheffield and Lincoln.

28 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

Landscape/Visual Impact 3.13 The development of this site for housing would significantly improve the landscape character of the area given the large scale dominant buildings and vast areas of hardstanding and untidy storage areas within the site. The visual amenity of the surrounding area would be improved through the development of the site.

3.14 With the demolition of the large factory buildings on the site and the delivery of a sensitive residential development, it can be considered development would make a positive contribution to the local landscape and visual amenity.

3.15 The site topography is relatively flat with a significant block of woodland to the south west of the site. The existing settlement edge of Finningley is to the immediate north of the site and the site could form a natural extension to the village.

3.16 It is considered that residential development on the site could enhance the local landscape and make a positive contribution to visual amenity.

Heritage Impact 3.17 The site is not within a Conservation Area. There are no listed buildings or other defined heritage assets within the boundary of the site or within close proximity to the site.

Flood Risk/Drainage 3.18 The site is located in Flood Zone 1 as illustrated in the Environment Agency’s online flood map records. The site is considered to be at low risk of flooding. There are no known drainage constraints which would form insurmountable barriers to the delivery of this site subject to detailed design and consideration of infrastructure capacity.

Ecology/Trees 3.19 The brownfield parcel of the site is expected to have limited ecological value. The larger greenfield parcel of the site is currently in active agricultural use. There are very few trees onsite and the wider site is again expected to have little ecological value.

3.20 The site does benefit from established hedgerow boundaries which are expected to be of some ecological importance. By retaining the existing boundary treatment and enhancing where necessary alongside other opportunities for further planting within landscaped and garden areas, development of the site will enhance the ecological value of the site overall

29 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

and offer an improved habitat network to the local green infrastructure network.

3.21 A Preliminary Bat Survey (PBS) has been undertaken by Wardell Armstrong (Appendix 2). The PBS consists of a desktop study and an inspection of the site. This confirms that there are several mature trees and four buildings which are suitable for roosting bats, and that it will be therefore necessary to undertake emergence surveys and/or climbed inspections in the event that development proposals are likely to adversely affect any roosts which may be present.

3.22 The PBS states that the vegetated parts of the site are suitable for foraging bats. The PBS goes on to note that it may be necessary to undertake activity surveys to establish levels and distribution of site usage by foraging bats such that appropriate mitigation can be designed.

3.23 A botanical survey has been undertaken and recorded habitats to the south of the main access road (by the ponds), which are notable and ideally should be retained if at all possible. Elsewhere, the habitats identified should not constrain the proposal.

3.24 In relation to newts, ponds have been subject full EDNA surveys at the correct time this summer and no evidence of newts was found.

3.25 It is considered that the residential development of the site could be undertaken without adverse harm to biodiversity.

Highways Safety 3.26 A Highways Scoping Note (HSN) has been prepared to inform the initial consideration of the brownfield element of the site (Appendix 3). The HSN outlines that based on the anticipated number of trips generated by such residential development and the distribution of the local highway network, a number of nearby junctions are calculated to have an increase of 30 or more two-way movements during the network peak hours, and will have capacity assessments undertaken upon them.

3.27 However, it is considered at this stage that the residential development would not create a demonstrably adverse impact on highway safety or volumes of traffic.

3.28 The HSN notes that site access will be controlled by a single priority controlled T-junction, and that no right turn ghost island is considered to be required given that the south, Old

30 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

Bawtry Road turns into a dead end.

HELAA Representations 3.29 The most recently available Housing and Economic Land Availability Assessment (HELAA) published July 2019, but with an April 2018 base data, identified the site under reference: 189 – Higgins Agriculture Ltd, Old Bawtry Road, Finningley.

3.30 The HELAA assessment identified that the site:

• Is not on land that is contaminated.

• Benefits from all essential utility services.

• Could be appropriately mitigated from noise from the airport.

• Is suitable, but with local policy constraints.

• Is developable in a timeframe of 0-5 years for 827 units.

Availability 3.31 The site is under single ownership and there is a strong interest in developing the site from Bellway Homes. The submission of the pre-application enquiry for the residential development of the site confirms interest in developing the site (Appendix 1 contains the reports and plans supporting this pre-application submission). The site is no longer required for commercial use by the landowner.

3.32 There are no physical constraints to suggest that a carefully designed residential development could not be brought during the plan period. There is a significant opportunity to provide much needed housing for the settlement of Finningley.

Suitability 3.33 The site is within a suitable location for residential development and this would contribute to the creation of sustainable, mixed communities.

3.34 The site is currently located within Countryside Policy Area, however it is partly brownfield land, is adjacent to the existing settlement boundary and is considered to be in a sustainable location, supported by village services and public transport links.

3.35 The village of Finningley has a number of local services. There are also convenient public

31 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

transport links via bus into Doncaster and throughout the surrounding area.

3.36 The site itself, which is partly brownfield, has strong natural boundaries and is adjacent to existing residential development to the north, meaning the site could provide a natural extension to the village. Suitable access to the site is already established from Old Bawtry Road, where there is clear visibility in both directions.

3.37 Residential development on the site has been assessed as viable, and would be attractive to the market. There is more than a reasonable prospect that housing on the site will be deliverable within 5 years.

Achievability 3.38 The site is available for residential development now, suitable in a sustainable location for growth with development readily achievable to commence within the next five years of the plan period. The allocation of this site for housing would help achieve the Government’s aims and objectives regarding the delivery of additional residential stock throughout the Country and serve to meet the specific objectively assessed housing need. There are no insurmountable physical constraints which would prevent the efficient use of this site for residential development.

3.39 The site is within a sustainable location in terms of access to essential shops, services and infrastructure. The site is adjacent to the settlement boundary and would support the growth aspirations of the emerging Local Plan.

Capacity 3.40 The site area is approximately 36 hectares and we would suggest that new residential development could initially be focused within the brownfield element of the site, providing capacity for up to 221 dwellings, with additional capacity for further dwellings in the longer term.

Conclusions 3.41 Site 189 provides the opportunity to deliver additional, sustainably located housing adjacent to the existing settlement of Finningley. The site, which is partly brownfield land, is adjacent residential development and the allocation of this site for housing would provide a logical extension to the village of Finningley. The site has no overriding environmental constraints. The site is available and deliverable in the short term and represents the most sustainably

32 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

located site for housing within the Finningley area. There is a strong interest in developing the site from Bellway Homes as confirmed by the submission of a pre-application enquiry for residential development at the site.

3.42 Based on the above information, the site is considered to be suitable, deliverable and developable and subject to policy designation is capable of being brought forward and allocated for housing within the emerging Local Plan.

4.0 CONCLUSIONS

4.1 This representation is submitted on behalf of Bellway Homes (Yorkshire) and Mr D Higgins in response to consultation on Doncaster Council’s Draft Policies & Proposed Sites (2018). This representation relates specifically to the promotion of Site 189 Higgins Agriculture Ltd, Old Bawtry Road, Finningley’ for Housing allocation.

4.2 This representation follows on from previous representations made to Local Plan consultation between 2012 and 2018.

4.3 Section 2 of this representation considers the strategic approach to housing and

33 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

employment delivery within the Publication Local Plan. Our representations demonstrate that the overall housing requirement is above that currently planned for and should be distributed in a more flexible manner, in order to ensure that the economic growth objectives of the plan are fully supported, as well as meeting local housing need.

4.4 Within this context, the representation objects to the current wording of Policies 3, 6, 7, 27, 29, 30 and 66, and of Appendix 2, and makes a number of recommendations for amendments to ensure the soundness of the Plan.

4.5 Section 3 provides a detailed individual site-specific assessment of the Higgin’s Site in order to demonstrate the suitability and deliverability of the site for housing development. Such development will complement the growth of the Airport and its hinterland.

4.6 The site has previously been considered for housing within the Council’s HELAA document and assessed as being a suitable, achievable and deliverable in order to accommodate further housing growth.

4.7 Therefore, it is recommended that the site should be allocated for housing in order to provide housing including affordable housing, within a sustainable location, which can make a viable contribution to the vitality and sustainability of the village, in accordance with the aspirations of the Framework.

34 Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

Appendix 1

Representation by SPRU

35

For and on behalf of Various Clients

Soundness Assessment of the Proposed Jobs-Led Housing Requirement and Implications for the Proposed Spatial Strategy

Objection to Policy 3 and the Sustainability Appraisal

Doncaster Local Plan 2015-2035 Publication Version

Prepared by Strategic Planning Research Unit DLP Planning Ltd Sheffield

September 2019

Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

Jon Goodall (Associate Director, SPRU) and Roland G Bolton Prepared by: (Senior Director)

Roland G Bolton (Senior Director) Approved by:

Date: September 2019

Strategic Planning Research Unit

V1 Velocity Building Broad Quay House (6th Floor) 4 Abbey Court Ground Floor Prince Street Fraser Road Tenter Street Bristol Priory Business Park Sheffield BS1 4DJ Bedford S1 4BY MK44 3WH

Tel: Tel: Tel:

DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is confidential to the client and DLP Planning Ltd accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk.

2 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

CONTENTS PAGE

0.0 Executive Summary ...... 4 a) Objection to Policy 3 ...... 4 b) Objection to the Sustainability Appraisal...... 5 1.0 Objection to Policy 3: The appropriate Employment-Led Housing Requirement .... 6 2.0 Objection to Policy 3: The consideration of Past Rates of Delivery, the Residual method of calculating the Plan Requirement, and the failure to make allocations for the last 2 years of the plan period...... 11 a) The background to past rates of delivery – the extant Core Strategy ...... 11 b) The residual calculation of the future plan requirement ...... 12 c) Failure to make allocations for the past two years of the plan ...... 13 3.0 Reasonable Alternatives and the Sustainability Appraisal ...... 15 4.0 Implications for The Spatial Strategy and Housing Distribution ...... 16 5.0 Conclusions ...... 19

3 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

0.0 EXECUTIVE SUMMARY 0.1 This report sets out in detail our client’s objection to Policy, 3 and the Sustainability Appraisal for failure to consider reasonable alternatives. 0.2 The basis of these objections are as follows: a) Objection to Policy 3 0.3 This objection relates to the time period of the plan provided for upon adoption. While the plan states that it is to cover the period 2015 to 2035 it fails to make adequate provision for the post adoption period 2020 to 2035 because: a. Table 5 illustrates that allocations are only to be made for the period 2018 to 2033. This means the proposed allocations cover just 13 years from the adoption of the plan expected in December 2020. This is contrary to paragraph 22 of the Framework that states strategic policies should look ahead over a minimum 15 year period from adoption. Paragraph 20 of the framework states that strategic policies include making sufficient provision for housing. b. The approach adopted reduces the overall level of housing requirement to be provided for following adoption by using a “residual” calculation to reduce the future planned requirement on the basis of higher rates of completions prior to the adoption of the plan. There is no support in either the Framework or the PPG to “discount” future levels of requirement based on past levels of “over provision”. Such overprovision may only be used to offset any shortfalls against requirements from previous years (PPG Paragraph: 032 Reference ID: 68-032-20190722) c. The employment led housing requirement of 912 dpa is based upon a projection for the period 2016 to 2016 i.e. just the first 6 years after the adoption of the plan rather than the requirement for the plan period as a whole. This is contrary to the Framework paragraph 20 which requires provision be made for 15 years from the adoption of the plan. 0.4 It is correct that the plan should provide for a figure above the minimum required by the application of the standard method. There is a growth strategy in place for the area which is already being delivered and as such a higher level of growth than the standard method is justified (PPG Paragraph: 010 Reference ID: 2a-010-20190220). 0.5 From the date of adoption, the plan will make provision for 882 dpa but this is not considered to be an appropriate level of housing requirement for the following reasons: a. The justification for the 882 dpa as a response to the planned levels of economic growth is flawed as it: i. Discounts previous high levels of completions prior to adoption from the future annual requirement which is contrary to the PPG (see above) ii. Fails to respond to the evidence of employment growth for the whole plan period: The employment led housing requirement of 882 dpa is based upon a requirement figure of 912 dpa for the period 2016 to 2026 as such it covers just the first 6 years of the plan period after adoption. The requirement for the plan period (2015 to 2032) and the correct interpretation of the council’s evidence base is that there is a requirement for 1,073 dpa . iii. Fails to provide for specific allocations in accordance with the spatial strategy and distribution of development to support economic growth for the final years of the plan period.

4 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

b. Past Completion Rates: Recent rates suggest a much higher demand for housing. recent levels of completions are over 1,000 dpa and reflect the growing market demand and local economy. These rates of completions are significantly above (almost double) the outcome of the standard method which suggests 550 dpa (2019 – 2029 using the 2014 DCLG projections and the most uptodate evidence on affordability). The PPG requires Authorities to take such evidence into account when considering whether it is appropriate to plan for a higher level of need than the standard model suggests (Paragraph: 010 Reference ID: 2a-010-20190220). b) Objection to the Sustainability Appraisal 0.6 The Sustainability Appraisal fails to consider reasonable alternatives. The SA considers the impact of the following: a. The planned housing allocations to meet the need to 2033 not 2035, b. The planned provision of 889 dpa for the period 2018 to 2033 and not the higher requirement based on meeting future economic growth which would be 1,073 dpa for the period 2015-2032. 0.7 The reasonable alternatives that the SA has failed to consider are as follows: a. The impact of making housing allocations to meet the need to 2035, b. The impact of making housing allocations to accommodate 1,073 dpa for the period 2015-2032 (or any higher alternative figure to support the demand for job-led growth to 2035).

5 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

1.0 OBJECTION TO POLICY 3: THE APPROPRIATE EMPLOYMENT-LED HOUSING REQUIREMENT 1.1 We consider that there is strong evidence to support the approach for this plan to make provision for more housing above that required to meet the Government’s minimum requirement as defined by the Government’s Standard Method. However, the Council’s own evidence base does not support the housing requirement proposed in Policy 3 (Level and Distribution of Growth), which applies arbitrary constraints to seeking to support the full demand for economic growth over the full plan period to 2035. 1.2 The Council’s Economic Forecasts and Housing Needs Assessment Update (EFHNA) (June 2018) accepts that the existing Strategic Economic Plan for the Sheffield City Region is out of date, with evidence dating back to 2013 (see paragraph 2.20). Paragraph 2.22 acknowledges a range of emerging targets and indicators to support growth in the Sheffield City Region as part of a review of the Strategy. These provide a longer-term vision for growth in the city-region as a whole to 2040. This represents an appropriate basis to consider the needs for economic development as part of a positively prepared Plan. 1.3 It should be noted that a number of individual projects and initiatives across the Sheffield City Region also reflect an appropriately long-term vision for the area, including those affecting Doncaster directly. For example, the Doncaster Sheffield Airport Masterplan indicates goals for growth in passenger and job numbers over a 2018-2037 period, with longer-term objectives to 2050. It is expected that the Masterplan for the Airport will generate 73,000 net additional jobs. 1.4 It is within this context that Paragraphs 4.29 and 4.30 of the EFHNA update must be assessed in terms of the recommendations on an employment-led component of the housing requirement. Paragraph 4.29 states: “In relation to the job-led scenario driven by SCR targets, we have already calculated the additional population needed to meet demand (para 2.40). To convert that population into housing, we have used the assumptions of SNHP 2014 regarding household formation rates and the size of the institutional (non-household) population. The resulting housing numbers are:  For the plan period 2015-32, 1,073 dpa  For 2016-26, the assessment period used in the new standard method, 912 dpa.” 1.5 Paragraph 4.30 indicates that the difference between the two figures is as much as 114dpa. The basis for that calculation is unclear, as this difference between the two bullets is in-fact 161 dwellings per annum. The decision to recommend a reduced requirement for jobs-led component based on an artificially constrained period for the assessment (2016-2026) that conflates the approach to the standard method to assess housing need is not justified and not consistent with national policy. This is likely to significantly restrict the ability to meet the forecast demand for employment growth over the plan period. 1.6 Paragraph 22 of the NPPF2019 clearly states that strategic policies should look ahead over a minimum 15 year period. Chapter 6 of the NPPF seeks to ensure that policies and decisions support a strong, competitive economy and support the conditions in which businesses can thrive. This is particularly important to drive innovation and to support areas to capitalize on their performance and potential including improving productivity. 1.7 The Council’s approach, including the evidence on the EFHNA, is, in principle, consistent with paragraph 60 of the NPPF2019. Circumstances in Doncaster justify taking account of market signals and current and future demographic trends to indicate future levels of housing need that exceed the results of the government’s standard method. These circumstances apply given the economic potential of the area and by extension ensuring a sufficient supply 6 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

of labour to sustainably support demand for economic growth and job creation. These factors exist alongside the Council considering uplifts to ensure that future needs for affordable housing are met (NPPG ID: 2a-024-20190220). 1.8 Given the date of publication, the EFHNA (June 2018) at paragraph 4.46 refers to draft practice guidance available at the time and states that the higher number in the range of requirements proposed (i.e. 912dpa) will be considered sound unless there are compelling reasons to indicate otherwise. Paragraph ID: 2a-010-20190220 in the published Planning Practice Guidance states: “The government is committed to ensuring that more homes are built and supports ambitious authorities who want to plan for growth. The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.

This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:

growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);

strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or

an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground;

There may, occasionally, also be situations where previous levels of housing delivery in an area, or previous assessments of need (such as a recently-produced Strategic Housing Market Assessment) are significantly greater than the outcome from the standard method. Authorities will need to take this into account when considering whether it is appropriate to plan for a higher level of need than the standard model suggests.”

1.9 The relevant guidance therefore clearly indicates that higher levels of housing requirement based upon the above evidence are an important consideration for the Local Planning Authority and Inspector appointed to examine the Local Plan. The Planning Practice Guidance provides a clear indication of the importance of assessing market signals in the context of ensuring that strategic policies meet the future business needs of an area. This involves taking account of alternative economic scenarios and considering longer-term economic cycles. An adequate assessment should reflect a range on inputs and consultation with relevant organisations, particularly in terms of understanding current and future assessments of labour supply. The objectives for job growth in the Sheffield City Region are clearly set out over a longer-term horizon than the 2016-2026 period relied upon in the EFHNA recommendations to justify the reduced housing requirement of 912 dpa. The more

7 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

appropriate projection is the one for the majority of the plan period 2015 to 2032 of 1,073 dpa. 1.10 Paragraph 4.30 of the EFHNA explains the difference between the need for an increased housing requirement to provide the population to support forecast labour demand over the different 2016-2026 or 2015-2032 assessment periods as follows: “The main reason for the difference is that, as we also mentioned earlier, in the job-led scenario job numbers grow faster every year than the baseline – in which population grows in line with the official projections. Consequently, the longer the forecast period the greater is the difference between the scenario and the baseline, whether in terms of jobs, population or household numbers.” 1.11 It is therefore clear that if the dwelling requirement for the 2015-2032 period of 1,073 dpa is not supported via strategic policies and allocations then there will be a growing disparity between the resident population and the ability to provide a local labour force to support the long-term growth objectives of the Sheffield City Region. This issue is compounded by the fact that the Pre-Submission Local Plan actually only makes provision for the residual requirement (i.e. 882dpa) from 2018/19 to 2032/33 not even for the shorter term forecast requirement of 912 dpa. 1.12 It is also necessary to highlight that pursuing a requirement based on the shortened assessment period (2016 to 2026) fails to take account of how recent levels of housing delivery and job creation relate to the wider evidence base for economic development. National Planning Practice Guidance states that this will require an assessment of trends across the sub-region, particularly where assessments of need cross local authority boundaries. This is clearly relevant to the Sheffield City Region. 1.13 One particular weakness of the EFHNA 2018 is that it does not consider these factors in relation to existing trends. The EFHNA does in several places acknowledge the relationship with net commuting across the sub-region, and that Doncaster is a net exporter of commuters. Paragraph 2.8(vii) sets out the results of the Experian model to indicate a net outflow of -7,300 commuters at the 2015 base-date. The EFHNA does not acknowledge that this level of commuting represents a significant uplift in out-commuting of some 1,000 persons since the the 2011 Census, as indicated in Figure 1 below:

8 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

Figure 1. Travel to Work Flows to/from Doncaster (Census 2011)

Source: Office for National Statistics

1.14 The EFHNA (2018) indicates that the Experian forecast expects net out-commuting to fall as a result of increased job creation and a tightening labour market. However, at Paragraph 2.28 also notes that for the purpose of preparing a jobs-led forecast of future housing needs in Doncaster: “The job-led scenario assumes that the rest of Sheffield City Region, like Doncaster, receives additional migration to meet policy-led job demand. This assumption impacts on the results for Doncaster, because if other places in the city region did not have enough population to meet demand they would attract more net commuting from Doncaster.” 1.15 The Council’s evidence base does not outline any effect of the existing impact of any such trends across the sub-region, despite the clear evidence of increased out-commuting since 2011. The precise implications for labour supply and economic development in Doncaster will be a result of various other factors including the impact of an ageing population and performance in different sectors. Pursuing a lower residual target (below the 912 dpa) beyond 2018 will not provide the necessary growth in labour supply to meet demand and support 9 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

local job creation. It is considered that in order to meet the economic strategy for the area that the plan should make provision for at least 1,073 dpa for the 15 years from the date of adoption (i.e. the period 2020 to 2035).

10 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

2.0 OBJECTION TO POLICY 3: THE CONSIDERATION OF PAST RATES OF DELIVERY, THE RESIDUAL METHOD OF CALCULATING THE PLAN REQUIREMENT, AND THE FAILURE TO MAKE ALLOCATIONS FOR THE LAST 2 YEARS OF THE PLAN PERIOD. a) The background to past rates of delivery – the extant Core Strategy 2.1 Policy CS10 of the adopted Doncaster Core Strategy sets what is described as an ‘ambitious’ housing target of 1230 net additional homes per year. Acknowledging the different characteristics of sites identified and deferral of additional allocations to subsequent development plan documents (that have not been prepared) the Core Strategy relies on an ‘interim requirement’. This effectively means that the deliverable housing requirement was applied based on average annual completions rates for the first part of the plan period and disregard any shortfall against the Core Strategy requirement arising prior to 2011. The Core Strategy therefore states that supply from existing commitments and UDP allocations without planning permission are regarded as sufficient to deliver the interim requirement (which is effectively a figure constrained by industry capacity and macroeconomic circumstances). 2.2 The background to housing delivery is important for the context of preparing the new Local Plan and particularly assessing the soundness of the proposed housing requirement. Table 5 of the Regulation 19 Plan indicates that supply in the first three years of the plan period (2015/16 to 2017/18) has substantially exceeded the proposed housing requirement. The Council proposes to treat the requirement for the remaining years of the plan period as a ‘residual’ total whereby the outstanding total is based on the total 20 year requirement (i.e. 920 x 20 = 18,400) less total completions recorded 2015-2018. This effectively seeks to take account of ‘oversupply’ against the Council’s proposed requirement in the early part of the plan period. 2.3 There are a number of issues with this in terms of national policy and guidance for the calculation of housing land supply, but in this context, we seek to emphasise that this approach to managing needs over the plan period demonstrates that the housing requirement is not justified and therefore unsound. 2.4 The recent performance of housing delivery contrasts starkly with the longer-term record of housing completions, as confirmed by the Council’s 2017/18 Authority Monitoring Report. This is summarised in Table 1 below: Table 1. 10 Year Housing Completions in Doncaster Housing Housing Target Supply vs. Target Completions 2008/09 598 1230 -632 2009/10 309 1230 -921 2010/11 529 1230 -701 2011/12 457 1230 -773 2012/13 316 1230 -914 2013/14 654 1230 -576 2014/15 933 1230 -297 2015/16 1089 920 169 2016/17 1067 920 147 2017/18 1208 920 288 2018/19 Tbc 920 Source: Doncaster Borough Council Authority Monitoring Reports

2.5 It can be demonstrated that until 2014/15 completions lagged substantially below the Core Strategy housing target, as broadly anticipated under Policy CS10. Housing delivery has 11 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

improved since 2015/16, albeit the Core Strategy target has not yet been achieved in any monitoring year. However, the uplift in completions is consistent with the aspirations for regeneration and economic development contained in the longer-term phasing of the Core Strategy. As part of preparing the new Local Plan this level of aspiration has been abandoned in place of the lower figure for housing need of 920 dwellings per annum, which the Council seeks to emphasise has been exceeded in the early part of the plan period. This is illustrated in Table 2 below. Table 2. Calculation of the Council’s Suggested Performance versus Proposed Local Plan 2015-2035 Housing Target Cumulative Cumulative Target Cumulative Completions (920 * 3) Completions vs. Target 2015/16 to 2017/18 3,364 2,760 +604 Source: Doncaster Borough Council Authority Monitoring Reports b) The residual calculation of the future plan requirement 2.6 This approach to calculating provision required over the plan period means that the Pre- Submission Local Plan seeks to provide only around 96% of the annualised assessment of need over the period 2018/19 to 2034/35. The ‘residual’ calculation adopted in Policy 3 is replicated in Table 3 below: Table 3. Calculation of the ‘Residual’ Requirement 2018-2035 Component of Calculation Calculation of Residual Requirement A Requirement 2015/16 to 2034/35 18,400 B Annualised Requirement 920 (A / 20) C Completions 2015/16 to 2017/18 34001 D Residual Requirement 2018-2035 15,000 (A – C) E Residual Annualised Requirement 882 (D / 17)

2.7 The resulting provision for future needs is therefore considered unsound. It cannot be regarded as positively prepared, and is not justified by the evidence base for the Plan; nor can it be treated as consistent with national policy and support for the plan-led approach. Although performance in terms of housing delivery has improved since 2015/16 this is largely in the context of an out-of-date Core Strategy and the absence of site allocations that it was expected would be provided for in subsequent development plan documents. The result is a high level of delivery provided from speculative applications and housing completions on ‘windfall sites’. Table 6.1g of the Council’s most recent Authority Monitoring Report confirms that between 2014/15 and 2017/18 over 73% of completions have occurred on windfall sites. 2.8 As a result of this approach to addressing the residual requirement for the plan period the Council’s approach generates a significantly reduced requirement for further site allocations. This leads to an over-reliance on existing components of supply, including extant planning permissions with significant barriers to development or previous allocations from the Unitary Development Plan rolled-forward into new allocations policies. Given the ‘residual’ approach to calculating the 2018-2035 requirement these sites are able to meet a greater proportion of the Council’s assessed need but will not necessarily contribute to a significant boost in housing supply.

1 Figure provided by Doncaster Local Plan Pre-Submission Version Table 5 12 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

2.9 The Council’s own evidence base demonstrates how future potential supply is considered against the reduced residual requirement. The Council’s ‘Five Year Statement 2017’ (August 2017) (paragraph 5.7) provides the same basis for calculating the five-year requirement for housing, taking account of past ‘oversupply’ since 2015. It should be noted that the inclusion of oversupply to reduce the annualised five year requirement is contrary to current national policy and guidance. The Council’s last published evidence of supply against the proposed Local Plan requirement substantially pre-dates revisions to the NPPF and NPPG. We reserve the right to present further analysis of the Council’s assessment of deliverable supply against the annualised five year housing requirement during the course of the Local Plan Examination. 2.10 The 2017 Statement is useful in explaining how the residual requirement compares with identified sources of supply in the Council’s Housing and Economic Land Availability Assessment. Paragraph 6.4 (ii) explains that this: “Identifies the deliverable supply from sites classified as “suitable but with no constraints” (labelled “suitable non-permissions” in Table A above) or only “suitable with local policy constraints” as 5,613. This includes sites designated in the UDP as Housing Allocations or as Countryside Policy Area, community facilities, open space or employment land that is now being pursued for housing development.” 2.11 The Council’s evidence suggests that such sites may be developed in years 0-5 of the assessment period, albeit this source of capacity fails to satisfy the definition of ‘deliverable’ in the revised NPPF without further clear evidence of housing completions beginning on site within five years. More importantly, this means supply against requirements is over reliant on long-standing sites with a reduced requirement for new allocations. The Council has since issued a HELAA 2018 Update (July 2019) this does not provide any substantive revision of the criteria for concluding that sites are deliverable/developable or the proportion that have long-standing barriers to development (including as part of being previously identified in the UDP). The Council’s Five Year Deliverable Housing Land Supply Statement 2018-2023 only addresses supply against the government’s standard method and does not assist in understanding how supply against the proposed Local Plan requirement has been assessed. 2.12 The approach adopted reduces the overall level of housing requirement by using a “residual” calculation to reduce the future planned requirement on the basis of higher rates of completions prior to the adoption of the plan. There is no support in either the Framework or the PPG to “discount” future levels of planned requirement based on past levels of “over provision”. Such overprovision may only be used to offset any shortfalls against requirements from previous years (PPG Paragraph: 032 Reference ID: 68-032-20190722) c) Failure to make allocations for the final two years of the plan 2.13 Another issue with the Council’s approach, which compounds the use of a ‘residual’ approach to calculating future requirement, is the fact that the proposed spatial strategy to determine the scale and distribution of housing is only based on seeking to ensure sufficient allocations to achieve this for a period 2018-2033. Paragraph 1.4.7 of the Council’s Housing Background and Strategy Paper states: “For the years 2033 – 35, there will be no settlement specific requirement, but enough land to meet the two year requirement of 1,764 will be shown. This will be formed oversupply from permissions and allocations (when an area will deliver more units than specified in the above table). This includes oversupply in Dunscroft, Dunsville, Hatfield and Stainforth; Armthorpe; Rossington; Carcroft – Skellow; Edlington; Askern; Auckley – Hayfield Green; and Finningley.”

13 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

2.14 Although this assessment of total provision may mean that housing needs can be met beyond 2033 this approach is potentially ‘blind’ to any barriers to delivery and the requirements of individual settlements. This component of the strategy is not positively prepared and lacks the key elements of flexibility and contingency required by national policy. These issues will be compounded in any individual settlement where there is a failure to bring forward completions on any of the sites identified to provide needs up to 2033 only. 2.15 Table 5 in the draft plan illustrates that allocations are only to be made for the period 2018 to 2033. This means the proposed allocations cover just 13 years from the adoption of the plan expected in December 2020. This is contrary to paragraph 22 of the Framework that states strategic policies should look ahead over a minimum 15 year period from adoption. Paragraph 20 of the Framework states that strategic policies include making sufficient provision for housing. This approach is therefore contrary to the Framework.

14 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

3.0 REASONABLE ALTERNATIVES AND THE SUSTAINABILITY APPRAISAL 3.1 These soundness concerns with the approach to identifying the housing requirement have clear implications for the Council’s chosen spatial strategy and the scale and extent of housing allocations identified. 3.2 Paragraph 5.3.1 of the Council’s August 2019 Sustainability Appraisal lists the range of growth options tested and confirms that 920 dwellings per annum is the highest number tested. Paragraph 5.3.3 goes on to explained: “All options would meet local needs, but Option 1 goes further by contributing to the Sheffield City Region Strategic Economic Plan and the broader aspirations of the northern powerhouse area, through employment-led housing growth and a higher target for employment land that provides for flexibility over the plan period;” 3.3 It is nonetheless the case that 920dpa does not in-fact reflect a figure to support the forecast demand for labour supply over the full plan period to 2035. The Council’s EFHNA 2018 provides a clear basis to test a further reasonable alternative of 1,073dpa. This would represent a more ambitious level of growth associated with planning positively for a full 15 year plan period from adoption. The associated requirement can be calculated as follows:  Jobs-led scenario 2015 – 2035 = 1,073 * 20 = 21,460 dwellings 3.4 This would represent an increase of +3,060 dwellings (21,460 vs 18,400) compared to the requirement indicated in Policy 3 of the Pre-Submission Local Plan. The Sustainability Appraisal also seeks to provide justification for the selected option with reference to the Council’s previous Housing Need Assessment (2015) indicating a requirement of 920 dwellings per annum. However, there is no clear relationship between these sources. In- particular the 2015 Assessment was prepared substantially before the introduction of the government’s standard method to assess housing need so does not follow the same approach as the EFHNA 2018 in calculating local housing need plus an economic-led component. The 920dpa figure in the 2015 Assessment has not itself been subject to independent examination, albeit it was successfully challenged in earlier planning appeals determined under the NPPF20122. 3.5 Secondly, the 2015 Housing Needs Assessment is based on a different set of official subnational population and household projections. Finally, section 2.4 of the 2015 Housing Needs Assessment appears to indicate that 920dpa was identified as a requirement for the full 2015-2032 period. The more appropriate comparison in terms of the relevant timeframes is the 1,073dpa identified in the EFHNA to meet requirements in the Sheffield City Region for a minimum period of 15 years. This is the approach necessary to ensure that the Local Plan is consistent with national policy.

2 See Land off Westminster Drive, Dunsville - APP/F4410/W/16/3158500 15 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

4.0 IMPLICATIONS FOR THE SPATIAL STRATEGY AND HOUSING DISTRIBUTION 4.1 We consider that the resulting implications in terms of the ability of the Pre-Submission Local Plan to make sufficient provision for future housing requirements can be addressed within the Council’s current approach to managing housing distribution and site selection. 4.2 There are a number of gaps and omissions in the Council’s evidence base at the point of publishing the Pre-Submission Local Plan for consultation. This includes Topic Papers to address the distribution of growth to individual settlements (see Paragraph 4.42) and illustrate how land supply will be managed in future (see Paragraph 16.21). This illustrates a number of outstanding issues in terms of soundness, particularly regarding the reasons for selecting and rejecting different options for levels of growth and individual potential site allocations. The Pre-Submission Local Plan also lacks detail on how the Local Plan will maintain a sufficient supply of deliverable sites to meet the annualised five year requirement plus whether identified sites will ensure the Plan meets the housing needs of different groups (including affordable housing). The latter point is particularly relevant to any proposed allocations or existing commitments with barriers to delivery or viability. 4.3 The Council’s Housing Background and Strategy Paper provides the starting point to illustrate that the Council acknowledges a greater capacity for potentially suitable growth at individual settlements, particularly those Main Towns at tier 2 of the hierarchy. We do not in principle object to a pro-rata apportionment of the ‘baseline’ requirement indicated by the government’s standard method. The Council’s strategy seeks to apportion the additional economic-led component of the requirement based on a split between the Main Urban Area and Main Towns. There is a clear acknowledgement that each Main Town may be appropriate to accommodate up to 10% of the economic component (see page 16 of the Strategy Paper). This provides a range of potentially appropriate levels of growth, albeit for each Main Town the level of proposed allocations is typically significantly below the upper end of the range that has been indicated. 4.4 We therefore recommend that that calculation for these components of the Council’s proposed spatial strategy are re-run based on assessment of the appropriate jobs-led requirement for the full plan period. This would be a relatively simple calculation, outlined as follows (assuming the calculation of Local Housing Need outlined in the Council’s own evidence base). We have based the comparison on the period 2015-2032 covered by the Council’s evidence, but in practice requirements should be calculated for 2015 to 2035 to ensure the plan makes provision in accordance with the proposed spatial strategy for a full 15 year plan period upon adoption. This is replicated in the Table 4 below (separate page):

16 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

Table 4. Proposed Spatial Distribution Based on Full Employment-Led Housing Needs (1,073dpa) (2015/16-2031/32) Standard Method + Calculation and Distribution of ‘Standard Method’ Calculation and Distribution of Economic Component Economic Component Baseline LHN (Annual) Economic Component (Standard Method) 585 (Annual) (1073 - 585) 488 Full OAN 1073 2015-2032 Total 9945 2015-2032 Total (i.e. 488 * 17) 8296 2015-2032 18241 plus Defined Villages 'standard method' Baseline (716 units 2015-2032) 9012

% of Total Apportionment Distribution of Economic-Led Lower Upper Distribution of LHN Population of Baseline Element Range 60% 70% Range Range Main Urban Area (Tier 1) 42.71 4248 Main Urban Area (Tier 1) 60-70 5407 6308 9655 10556 Lower Upper Main Towns (Tier 2) Main Towns (Tier 2) Range 0% 10% Range Range Dunscroft, Dunsville, Dunscroft, Dunsville, Hatfield Hatfield and Stainforth 6.52 648 and Stainforth 0-10 0 901 648 1550 Thorne and Moorends 5.77 574 Thorne and Moorends 0-10 0 901 574 1475 Mexborough 5.41 538 Mexborough 0-10 0 901 538 1439 Conisbrough and Denaby 5.25 522 Conisbrough and Denaby 0-10 0 901 522 1423 Artmthorpe 4.74 471 Artmthorpe 0-10 0 901 471 1373 Rossington 4.34 432 Rossington 0-10 0 901 432 1333 Adwick and Woodlands 2.86 284 Adwick and Woodlands 0-10 0 901 284 1186 Total Tier 3 Service Towns and Villages 15.2 1512 Total Tier 3 0 N/A N/A 1512 1512 Defined Villages 716 Defined Villages 0 N/A N/A 0 0 Total 2015-2032 9945

17 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

4.5 The recalculated distribution identified in Table 4, seeking to meet the full assessment of economic-led needs to 2031/32 in accordance with the Council’s own EFHNA evidence, indicates a potential scale and distribution of growth that compares closely to the Council’s existing proposals. The absolute uplift to the proposed distribution at each Main Town (Tier 2) is modest. In-fact, we emphasise that sound solutions to the spatial strategy exist even when seeking to address the specific requirement for allocations for a full 20 year plan period (and 15 year period from adoption) that are excluded from the Council’s approach. This would provide greater certainty as well as flexibility and contingency for individual settlements in the borough. 4.6 It is not necessarily the case that allocations would need to be provided for the top end of the range in any individual settlement, and therefore there is a substantial overlap with potential levels of development that the Council has already accepted as suitable. 4.7 We would emphasise that in absolute terms the difference in the potential levels of growth distributed to the Main Urban Area under the scenario to meet the full assessment of employment-led needs is more significant. This gives a range of 9655 to 10556, compared to 7145-7710 in the Council’s Background Paper. This may indicate a requirement for a closer assessment of the deliverability and developability of potential sites over the plan period and, if necessary, making provision for allocations at the lower end of the range. 4.8 This could be compensated by growth elsewhere in the settlement hierarchy. 4.9 A key implication of the revised calculation in Table 4 above is that it highlights that Tier 3 Settlements (Service Towns and Villages) make no additional contribution to the proposed distribution of economic growth. This is not justified and as a result the proposed spatial strategy is not effective and not positively prepared. As demonstrated by relevant representations outlining our various clients’ interests a number of suitable and sustainable opportunities for growth in Service Towns and Villages exist that would support delivery of the economic-led component of growth. 4.10 As identified in Paragraph 2.12 of this Annex, the Council claims an ‘oversupply’ of allocations in some Tier 3 and Tier 4 settlements. However, this is based only on the distribution of the baseline component provided by the outputs of the government’s standard method. This conclusion is therefore clearly unjustified, as it takes no account of the potential for the sustainable distribution of growth in this location associated with the economic component of housing needs. This may include factors such as strong provision for employment in the local area or the benefits of additional residential development to support local regeneration. This would further reduce delivery pressures in the Main Urban Area associated with meeting housing needs in full for the period to 2035. In association with seeking to meet the requirement for job-led growth over the full plan period it is therefore considered necessary that the spatial strategy is modified to acknowledge scope for further distribution to Tier 3 or Tier 4 settlements where this would complement the requirement to support economic development. Proposed Modification to the Spatial Strategy –  Increase the potential level of allocations at Main Towns in accordance with Table 4 above and providing for the proposed distribution of the economic-led component of growth based on meeting full housing needs; and  Amend the proposed distribution of the economic-led component of housing need to indicate a potentially suitable range of 0-10% of the total requirement based on full needs in Tier 3 or Tier 4 settlements in accordance with suitable opportunities for development.

18 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

5.0 CONCLUSIONS 5.1 For the reasons outlined there are substantial soundness failings with the Pre-Submission Doncaster Local Plan resulting from a failure to test an appropriate reasonable alternative based on meeting the strategic priorities for economic development over a full 15-year plan period. These issues are compounded based on treating the housing requirement from 2018- 2033 as a ‘residual total’ to account for perceived oversupply in the period 2015-2018, which has not been adequately justified. 5.2 The Council’s approach fails to accurately reflect the strategic priorities and future economic potential of the Sheffield City Region. Further assessment of the proposed requirement should also be undertaken to reflect the requirements of the revised Strategic Economic Plan (once published) and to consider recent trends in jobs growth and housing delivery across the sub-region. This may lead to a reassessment of current and future demographic trends in relation to future labour supply. 5.3 It furthermore applies arbitrary constraints to the requirement for additional development, which will lead to an overreliance on extant planning commitments and historic allocations in previous iterations of the development plan. The implications of this in terms of prospects for maintaining a five year supply of deliverable sites and meeting the housing needs of different groups have not been fully assessed. 5.4 These issues are capable of remedy within the Council’s broad emerging approach to manage the distribution of growth across the spatial strategy. This acknowledges that significantly greater levels of potentially suitable growth could be provided at different tiers of the settlement hierarchy. 5.5 This acknowledges that significantly greater levels of potentially suitable growth could be provided at different tiers of the settlement hierarchy. This includes the Main Towns at Tier 2. We endorse the Council’s position that such locations are appropriate to accommodate up to 10% of the economic-led component of the housing requirement. However, we further endorse that this broad approach to distribution should be treated flexibly. It is appropriate to fully assess the ability of sustainable locations to accommodate growth based on meeting requirements under the full assessment of jobs-led growth (1,073dpa) for the full plan period to 2035. The approach to scale and distribution should therefore not restrict the ability to support additional suitable and sustainable opportunities at Tier 3 and Tier 4 settlements where this would assist in meeting needs in full.

19 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Doncaster Local Plan 2015-2035 Submission Version On behalf of Various Clients

20 09.30.JG.YK5788-3P SPRU Various Clients Jobs-Led Requirement Soundness Assessment Final FINAL Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

Appendix 2

Preliminary Bat Survey Report by Wardall Armstrong

36

BELLWAY HOMES LTD

OLD BAWTRY LANE, FINNINGLEY

PRELIMINARY BAT SURVEY REPORT

JULY 2019 Wardell Armstrong 36 Park Row, Leeds, LS1 5JL Telephone: www.wardell-armstrong.com

DATE ISSUED: July 2019 JOB NUMBER: LD10010 REPORT NUMBER: 001

BELLWAY HOMES LTD

OLD BAWTRY LANE, FINNINGLEY

PRELIMINIARY BAT SURVEY REPORT

July 2019

PREPARED BY:

Alex Bingle Ecologist

CHECKED AND APPROVED BY:

Tim Palmer Technical Director (Ecology)

This report has been prepared by Wardell Armstrong LLP with all reasonable skill, care and diligence, within the terms of the Contract with the Client. The report is confidential to the Client and Wardell Armstrong LLP accepts no responsibility of whatever nature to third parties to whom this report may be made known.

No part of this document may be reproduced without the prior written approval of Wardell Armstrong LLP.

ENERGY AND CLIMATE CHANGE ENVIRONMENT AND SUSTAINABILITY INFRASTRUCTURE AND UTILITIES Wardell Armstrong is the trading name of Wardell Armstrong LLP, Registered in England No. OC307138. LAND AND PROPERTY

Registered office: Sir Henry Doulton House, Forge Lane, Etruria, Stoke-on-Trent, ST1 5BD, United Kingdom MINING AND MINERAL PROCESSING MINERAL ESTATES AND QUARRYING UK Offices: Stoke-on-Trent, Birmingham, Cardiff, Carlisle, Edinburgh, Greater Manchester, London, Newcastle upon Tyne, Shaftesbury, Sheffield, WASTE RESOURCE MANAGEMENT Taunton, Truro, West Bromwich. International Offices: Almaty, Moscow

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

CONTENTS 1 INTRODUCTION ...... 1 1.1 Terms of Reference ...... 1 1.2 Site Context ...... 1 2 METHODOLOGY ...... 2 2.1 Desk Study ...... 2 2.2 Preliminary Building/Tree Survey ...... 2 2.3 Nomenclature...... 3 2.4 Assessment Limitations ...... 3 2.5 Quality Assurance & Environmental Management ...... 3 3 RESULTS AND EVALUATION ...... 4 3.1 Desk Study ...... 4 3.2 Preliminary Building Survey ...... 4 3.3 Preliminary Tree Surveys ...... 4 4 Evaluation and discussion...... 5 4.1 Development Proposals and Potential Effects ...... 5 4.2 Further Survey ...... 5 4.3 Mitigation and Licensing ...... 6 5 CONCLUSIONS...... 8 6 REFERENCES ...... 9

APPENDICES APPENDIX 1 – LEGISLATION AND POLICY SUMMARY ...... APPENDIX 2 – BUILDING DESCRIPTIONS ......

DRAWING SCALE LD10010/001 BUILDING LOCATION PLAN 1:2500

LD10010/001 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

1 INTRODUCTION

1.1 Terms of Reference

1.1.1 Wardell Armstrong LLP (WA) was commissioned by Bellway Homes Limited to undertake a Preliminary Bat Survey of a proposed residential development scheme at Old Bawtry Lane, Finningley (Ordnance Survey central grid reference SK66905 98421).

1.1.2 The aim of the survey is to i) determine the likely presence/absence of bats and their roosts, ii) assess whether additional surveys are required, iii) assess the conservation value of the site for bats, iv) to determine likely impacts of the proposed development, v) to inform whether a European Protected Species Licence is required and inform appropriate mitigation measures.

1.2 Site Context

1.2.1 The site lies to the south of the village of Finningley, near Doncaster and borders Robin Hood airport to the west. The site is occupied by a potato storage/processing plant and as such is dominated by large warehouses with surrounding aprons of hard standing. There are also extensive areas of neutral grassland, scattered trees, scrub, hedgerows and treelines. The wider site also supports a large undisturbed woodland to the south, with adjacent ponds and arable/grazing land beyond. The location of the buildings and the current site layout is shown in Drawing LD10010/001 Building Location Plan.

LD10010/001 Page 1 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

2 METHODOLOGY

2.1 Desktop Study

2.1.1 The desktop study was informed by review of existing available information provided by South Yorkshire Bat Group (SYBG) and Notts Biological and Geological Records Centre (NBGRC) for a 2km search radius from the sites central grid reference, for all bat records. Ordnance Survey (OS) and satellite mapping was also used to gain contextual habitat information.

2.2 Preliminary Building/Tree Survey

2.2.1 External buildings and trees inspections were undertaken on 26 July 2019 by a Natural England Bat Licensed (Natural England Class Licence CL18 (Bat Survey Level 2): CLS00883 Technical Director, from Wardell Armstrong LLP.

2.2.2 The external examination of the buildings and trees was undertaken using binoculars and high-powered torches to check for entry points such as cracks or holes, evidence of bat activity such as staining, droppings and feeding remains.

2.2.3 Based on the location, age and type of the building or tree, the potential features present and the indicating signs recorded, each building was placed into one of the following categories (Collins, 2016):

• Confirmed roost – Bat or signs of bats discovered during the survey; • High – Buildings located within or connected to suitable habitat (foraging and/or commuting) with a large number of suitable features for supporting a bat roost. No supporting evidence found. • Moderate- Buildings located within or connected to suitable habitat (foraging and/or commuting) with a number of suitable features for supporting a bat roost. No supporting evidence found. • Low - Buildings located within or connected to suitable habitat (foraging and/or commuting); however largely unsuitable for supporting a bat roost with a few suitable features for supporting a bat roost. No supporting evidence found. • Negligible – no or very few suitable features. Often well-sealed buildings, with high levels of disturbance and high internal light levels.

LD10010/001 Page 2 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

2.3 Nomenclature

2.3.1 All flora and fauna names follow the National Biodiversity Network (NBN) Gateway (NBN, 2013). The common and scientific name of species/taxa is provided (if available) when first mentioned in the text, with only the vernacular name referred to thereafter.

2.4 Assessment Limitations

2.4.1 The absence of desk study records has not been relied upon to infer absence of a species/habitat. Often, the absence of records is a result of under-recording within the given search area.

2.4.2 The interior of buildings was not always accessible and thus could not be assessed.

2.5 Quality Assurance and Environmental Management

2.5.1 All Ecologists employed by WA are members of CIEEM and are bound by its code of professional conduct. All surveys and assessments have been undertaken with reference to the recommendations given in BS 42020.

LD10010/001 Page 3 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

3 RESULTS AND EVALUATION

3.1 Desk Study

3.1.1 There are no sites designated for bats within 5km. There is one Local Nature Reserve and three Sites of Special Scientific Interest; none of which are designated specifically for bats.

3.1.2 Records of six bat species have been supplied within 2km of the site in the last five years; namely Brown Long-eared Bat Plecotus auratus, Common Pipistrelle Pipistrellus pipistrellus, Daubenton’s bat Myotis daubentonii, Myotis sp., Noctule Nyctalus noctula, and Soprano Pipistrelle Pipistrellus pygmaeus.

3.1.3 The supplied data set includes roosts of Brown long-eared bat, Common Pipistrelle and Noctule species located approximately 600m from the site.

3.2 Preliminary Building Survey

3.2.1 Appendix 2 provides full descriptions and photographs of the buildings surveyed and an assessment of their suitability for roosting bats.

3.2.2 In summary, of the five buildings within the site, one is assessed as being of ‘Negligible’ suitability (Building B4) and the remaining four are of ‘Low’ suitability.

3.2.3 Buildings 1, 2, 3 and 5 (B1, B2, B3 and B5) have some limited suitability for roosting bats, with gaps behind overlapping (cement asbestos) barge boards/fascias, as well as gaps in air vents, gaps in the corrugated metal cladding, and gaps where the steel sheet cladding covers the brickwork. These features are likely to support small groups/individuals of crevice dwelling species such as Pippistrellus sp. rather than maternity colonies

3.3 Preliminary Tree Surveys 3.3.1 There are several mature trees on site supporting bat roosting features (cracks and splits in main trunks and branches). These trees were located adjacent to the main access road into the site.

LD10010/001 Page 4 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

4 EVALUATION AND DISCUSSION

4.1 Development Proposals and Potential Effects

4.1.1 The development would involve clearance of parts of the site to create a development platform for the construction of a number of residential dwellings; although it is currently unknown where the building will take place and whether this will require the demolition of the current buildings. Consequently, the impacts to bats are currently unknown at this stage.

4.2 Further Survey

Buildings

4.2.1 Further surveys are required in compliance with standard guidelines (Collins, 2016) summarised in Table 1, below. The surveys should be undertaken during the period May – August (inclusive) by suitably qualified ecologists, in possession of a Natural England Bat Licence or working under the direction of a Natural England licenced bat surveyor. An appropriate number of surveyors should be utilised to ensure that all potential roost access features are visible to the surveyors.

4.2.2 Surveys should commence c.15 minutes prior to local sunset and continue for at least 1.5 hours after sunset. It may be necessary to undertake additional surveys in the event that insufficient data is accrued by the surveys to enable the design of appropriate mitigation/compensation. The survey requirements provided below should therefore be considered to be an acceptable minimum.

Table 1. Further Survey Requirements (Buildings)

Building Reference Bat Roost Potential Further Survey 1 Low One dusk/dawn survey 2 Low One dusk/dawn survey 3 Low One dusk/dawn survey 4 Negligible None 5 Low One dusk/dawn survey

4.2.3 If the works do not commence within 12 months of the date of these surveys, update surveys may be required. The surveys will have elapsed in June 2020.

Trees LD10010/001 Page 5 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

4.2.3 A climbed tree inspection would need to be undertaken by a surveyor holding aerial ascent and rescue tree certification (either holding a Natural England Bat Licence or under the direct supervision of a Natural England Bat Licensed Ecologist). This would involve undertaking a detailed inspection of the suitable bat roosting features recorded during the preliminary survey and searching for any additional suitable features which cannot be identified from the ground. The features would be searched using a high-powered torch and/or an endoscope inspection camera. Evidence of roosting bats would be sought in the form or droppings, fur staining and/or the bats themselves.

4.2.4 All Category 1 trees could be surveyed using a climb and inspect survey method. If no bats or signs of bats are recorded, it may then be possible to downgrade the tree(s) to category 2.

4.2.5 In the event that arboricultural work or felling of trees is required to facilitate the development, further surveys are recommended in accordance with national standard guidelines (Collins 2016).

Foraging/Commuting Habitats

4.2.6 In the event that the development proposals involve the loss of neutral grassland, scrub and/or woodland habitats which are of high value to roosting bats, it would be necessary to undertake bat activity surveys. This would involve deploying automated detectors to record levels of bat activity within the development area as well as other retained habitats in order that levels of usage and species composition can be compared. A walked transect should also be undertaken by a suitably qualified bat ecologist to quantify levels of site usage in general terms. Survey methods should follow Collins 2016; however, the nature and location of the scheme and consequent habitat losses should be considered when developing the scope of the survey.

4.3 Mitigation and Licensing

4.3.1 The requirement of a European Protected Species Licence (EPSL) will depend on the outcome of the further surveys recommended and the exact location and nature of the development proposals. Wherever possible, retention of roosts in-situ should be encouraged, in which case licensing may not be required.

LD10010/001 Page 6 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

4.3.2 In the event that further surveys identify the presence of a roost, the compensatory measures required would be designed in relation to the species present, the status of the roost recorded and the number of bats utilising the roost. Compensatory measures would be required to maintain the favourable conservation status of the species concerned.

LD10010/001 Page 7 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

5 CONCLUSIONS

5.1.1 The Preliminary Bat Survey confirms that there a number of mature trees as well as four buildings (B1, B2, B3 and B5) which are suitable for roosting bats. Consequently, it will be necessary to undertake emergence surveys and/or climbed inspections (trees) in the event that the development proposals are likely to adversely affect any roosts which may be present.

5.1.2 In the event that a bat roost is identified by the additional surveys, it would be necessary to submit a mitigation statement alongside the planning application, such that the Local Authority can discharge their obligations under the Conservation of Habitats and Species Regulations (2017) i.e. to ensure that all necessary information to inform necessary mitigation and compensatory measures is in place. In this circumstance, it would be necessary to acquire a European Protected Species Licence prior to the onset of works. Natural England are the licensing authority and would issue the licence once all the necessary planning consents are approved, assuming that adverse effects can be adequately mitigated/compensated.

5.1.3 The vegetated parts of the site are also suitable for foraging/commuting bats. Consequently, it may be necessary to undertake activity surveys to establish the levels and distribution of site usage by foraging bats such that appropriate mitigation can be designed. Surveys may be required during spring, summer and autumn depending on predicted development impacts. The results of the surveys would inform mitigation requirements and hence are required in advance of planning determination.

LD10010/001 Page 8 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

6 REFERENCES

Chartered Institute of Ecological and Environmental Management. (2012). Guidelines for Preliminary Ecological Appraisal.

Collins (2016). Bat Surveys – Good Practice Guidelines (3rd Edition). Bat Conservation Trust: London.

Joint Nature Conservation Committee, Handbook for Phase 1 habitat survey: A technique for environmental audit (2007), English Field Unit, Nature Conservancy Council.

Mitchell-Jones, A.J, & McLeish, A.P. Ed., (2004), 3rd Edition Bat Workers' Manual, JNCC.

National Biodiversity Network (2013) NBN Gateway

http://data.nbn.org.uk/

West Yorkshire Ecology Advisory Group (2008). Minimum standards for Bat survey in west Yorkshire (Version 3). Available at: www.ecology.wyjs.org.uk/documents/ecology/Bat-Surveys-Approved.pdf/

LD10010/001 Page 9 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

APPENDIX 1 – LEGISLATION AND POLICY SUMMARY

LD10010/001 Page 10 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

Appendix 1 – Legislation and Policy Summary

6.1.1 All bat species are listed within Schedule 5 of the Wildlife and Countryside Act 1981 as amended) and receive protection under section 9 of this act. They are also protected under section 39 of the Conservation (Natural Habitats, &c.) Regulations 1997 (and amendments) (known as the Habitats Regulations). Taken together the following offences apply under the combined acts:

6.1.2 Regulation 41 of the Habitats Regulations 2012, states that a person commits an offence if they: • Deliberately or intentionally capture, injure or kill a bat; • Intentionally or recklessly damage, destroy or obstruct access to; any structure or place used for shelter or protection by a bat; • deliberately, intentionally or recklessly disturb a bat; • damage or destroy a breeding site or resting place of a bat; or • keep, transport, sell, exchange or offer for sale any bat(s) or anything derived from this species.

6.1.3 Disturbance of animals includes in particular any disturbance which is likely to impair their ability to survive, to breed or reproduce, or to rear or nurture their young, or in the case of animals of a hibernating or migratory species, to hibernate or migrate; or to affect significantly the local distribution or abundance of the species to which they belong.

6.1.4 The Natural Environment and Rural Communities (NERC) Act 2006 places a duty on public bodies to have regard for the conservation of biodiversity and maintains lists of species and habitats which are of principal importance for the purposes of conserving biodiversity in England and Wales. These lists supersede Section 74 of the CRoW Act 2000.

6.1.5 The United Kingdom Biodiversity Action Plan (UK BAP) first published in 1994 and updated in 2007, is a Government initiative designed to implement the requirements of the Convention of Biological Diversity to conserve and enhance species and habitats. The UK BAP contains a list of priority habitats and species of conservation concern in the UK, and outlines biodiversity initiatives designed to enhance their conservation status. The priority habitats and species in England accord with those listed on Section 41 of the NERC Act.

LD10010/001 Page 11 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

6.1.6 The ‘UK Post-2010 Biodiversity Framework’ (Revised July 2012) succeeds the UK BAP and ‘Conserving Biodiversity – the UK Approach’, and is the result of a change in strategic Thinking following the publication of the CBD’s ‘Strategic Plan for Biodiversity 2011–2020’ and its 20 ‘Aichi targets’, at Nagoya, Japan in October 2010, and the launch of the new EU Biodiversity Strategy (EUBS) in May 2011. The framework demonstrates how the work of the four countries and the UK contributes to achieving the ‘Aichi targets’, and identifies the activities required to complement the country biodiversity strategies in achieving the targets.

6.1.7 The NPPF underpins the Government’s planning policies for England and how these are to be applied. The central theme of the NPPF is a presumption in favour of sustainable development. This presumption does not apply where development requiring Appropriate Assessment under the Birds or Habitats Directives is being considered, planned or determined.

6.1.8 The NPPF states: ‘When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: • if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; • proposed development on land within or outside a Site of Special Scientific Interest (SSSI) likely to have an adverse effect on a SSSI (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site’s notified special interest features is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of SSSIs; • development proposals where the primary objective is to conserve or enhance biodiversity should be permitted; • opportunities to incorporate biodiversity in and around developments should be encouraged; • planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss

LD10010/001 Page 12 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss; and • the following wildlife sites should be given the same protection as European sites: • potential Special Protection Areas (SPA) and possible Special Areas of Conservation (SAC); • listed or proposed Ramsar sites; and • sites identified, or required, as compensatory measures for adverse effects on European sites, potential SPAs, possible SACs, and listed or proposed Ramsar sites.’

6.1.9 The NPPF requires the Planning Authority to have a responsibility to promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan. In addition, the planning system should contribute to and enhance the natural and local environment by minimising impacts on biodiversity and providing net gains in biodiversity where possible, con tributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.

LD10010/001 Page 13 JULY 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

APPENDIX 2 – BUILDING DESCRIPTIONS

LD10010/001 Page 14 JULY 2019

BELLWAY HOMES LTD LD10010 Old Bawtry Road Bat Preliminary Survey Report

APPENDIX 2: BUILDING DESCRIPTIONS

Building Description and Photograph Bat Features Present Bat Signs Bat Roost Number Potential Access points in to void via No bats or signs Low roost spaces in corrugated metal of bats recorded potential and warped roof covering. during the Gaps between metal and inspection brickwork. Located with proximity to suitable commuting corridors and foraging areas

1

Two storey corrugated metal warehouse, with a brick first floor used for intake from HGV with simple pitched corrugated metal roof.

Brick work and mortar in good state of repair. Metal and Perspex windows and door frames are in good state of repair.

LD10010/Appendix 2 Page 1 July 2019

BELLWAY HOMES LTD LD10010 Old Bawtry Road Bat Preliminary Survey Report

Gap between doorway and No bats or signs Low roost walls, gaps in air vents, gaps of bats recorded potential in corrugated metal Located with close proximity to suitable commuting corridors and foraging areas Located with proximity to suitable commuting corridors and foraging areas

2

Two storey corrugated metal warehouse used as for storage with simple pitched corrugated metal roof. The interior is open with no barriers between the roof and main building. The void is large but simple with metal rafters supporting and is easily accessed. The void was mainly uncluttered, with an open airspace. The void is dark and warm.

LD10010/Appendix 2 Page 2 July 2019

BELLWAY HOMES LTD LD10010 Old Bawtry Road Bat Preliminary Survey Report

Gaps in corrugation allowing No bats or signs Low roost access to void of bats recorded potential Located with proximity to suitable commuting corridors and foraging areas

3

Asbestos cladded sheet warehouse with corrugated, overlapping roofing. The interior is open with no barriers between the roof and main building. The void is large but simple with metal rafters supporting. There is easy access to the void. The void was mainly uncluttered, with an open airspace. The void is dark and warm.

LD10010/Appendix 2 Page 3 July 2019

BELLWAY HOMES LTD LD10010 Old Bawtry Road Bat Preliminary Survey Report

No suitable feature No bats or signs Negative of bats recorded bat roost potential

4

Sheet steel cladded warehouse

LD10010/Appendix 2 Page 4 July 2019

BELLWAY HOMES LTD LD10010 Old Bawtry Road Bat Preliminary Survey Report

Gaps between gable ends No bats or signs Low roost and corrugated walls of bats recorded potential Located with proximity to suitable commuting corridors and foraging areas

5

Single story metal garage corrugated metal garage with gable ends

LD10010/Appendix 2 Page 5 July 2019

BELLWAY HOMES LTD OLD BAWTRY ROAD PRELIMINARY BAT SURVEY REPORT

DRAWINGS

LD10010/001 Page 15 JULY 2019

KEY

Site Boundary Buildings

Notes:

Boundaries are indicative.

Aerial imagery shown for context purposes only.

Contains Ordnance Survey data. © Crown Copyright and database right 2019.

REVISION DETAILS DATE DRAWN CHK'D APP'D 1 CLIENT

BELLWAY HOMES LIMITED 5 2

PROJECT

OLD BAWTRY LANE 3

DRAWING TITLE

BUILDING LOCATION PLAN 4

DRG No. REV LD10010/001 A

DRG SIZE SCALE DATE A3 1:2,500 17/07/2019

DRAWN BY CHECKED BY APPROVED BY SW AB TP

0 100

Metres © 2019 Microsoft Corporation © 2019 DigitalGlobe ©CNES (2019) Distribution Airbus DS © 2019 HERE © Copyright Reserved

Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

APPENDIX 3

Highways Scoping Report by Andrew Mosely Associates

37 ■ SCOPING STUDY FOR: Proposed 221 Residential Dwellings, Finningley ■ LOCAL AUTHORITY: Doncaster Metropolitan Borough Council (DMBC)

■ SUPPORTED BY: Figure 1 – Site Location, Appendix A – Indicative Site Layout, Appendix B ‐ Development Traffic Distribution, Appendix C – Development Traffic Assignment, Appendix D – TRICS Output.

Ref Item Parameters Comments from DMBC 1 Level of planning approval sought? Full planning permission. e.g. outline, full. 2 Size and description of development The planning application is for a development of 221 residential dwellings on existing B2 use light industrial proposals sheds to the east of Old Bawtry Road, Finningley. Details of the indicative site layout are provided at Appendix A.

3 Description of existing land uses. The site is located on land to the south of the residential settlement of Finningley, South Yorkshire and is bound to the north‐west by residential dwellings and associated gardens; to the north‐east by grazing land and a Public Right of Way (PRoW); to the east by grazing land and a PRoW; to the south by a woodland; and to the west by Old Bawtry Road.

The location of the site is shown on the plan at Figure 1.

4 Does the development involve the No. relocation of an existing use? 5 How are existing land use flows going The existing flows associated with the current land use will discounted from the proposed residential use. to be dealt with? 6 Are traffic surveys of the existing Based on the anticipated number of trips generated by the proposed development (Section 13) and the conditions available or required? distribution to the local highway network (Section 14), the following junctions are calculated to experience an increase of 30 or more two‐way movements during the network peak hours, and as are proposed to have capacity assessments undertaken upon them;

 Site Access / Old Bawtry Road (Priority Junction);  Old Bawtry Road / Doncaster Road / The Green (Priority Junctions);  High Common Lane / A614 / Cross Lane (Roundabout);  A614 Station Road / Throne Road / B1396 Bank End Road / B1396 Mosham Road (Roundabout);  B1396 Mosham Road / Gate House Lane (Signals);  B1396 Doncaster Road / B1396 Cantley Lane / School Lane / Warning Tongue Lane (Roundabout);  B1396 Cantley Lane / Goodison Boulevard / Green Boulevard (Roundabout);  B1396 Cantley Lane / A638 Bawtry Road (Signals);  A638 Bawtry Road / Gilwice Way and Gilwice Way / Booth Avenue (Combined Double Signals); and  A638 Carr House Road / A18 Leger Way / A638 Bennetthorpe / A18 Carr House Road (Roundabout).

If recent data is not available from DMBC or previous planning applications in the public domain on the planning portal, traffic surveys will be undertaken at these junctions.

Surveys if required, will be undertaken on a neutral weekday (Tues – Thurs) between the AM and PM periods of 07:00 to 10:00 and 16:00 to 19:00 to determine suitable network peak hours.

7 Are further traffic surveys required? No.

8 Details of any other developments to We are currently unaware of any committed developments locally in the area, therefore please can you be taken into account. advise of any committed developments which are required to be included within the assessment?

9 Details of any adjacent highway Please advise of any adjacent highway improvements planned in the vicinity of the site. improvement proposals by others

1 of 6 Ref Item Parameters Comments from DMBC 10 When are the critical periods for Critical periods for assessment will be based on the identified network AM and PM peak hours and the assessments? proposed residential development peak trip generation for these peaks.

11 What are the assessment years? The assessment years are as follows; Base 2019 and Future Year 2024. The 2024 future year scenario has been chosen to provide a five year horizon period. 12 Traffic growth factors? Weekday AM and PM growth factors have been derived using TEMPRO 7.2 for the Doncaster 033 MSOA, for which the site is situated, for the 2024 Future Year Scenario.

Table 1. TEMPRO Traffic Growth Factors – 2019 to 2024 AM PM

Doncaster 026 1.87 1.085

13 What will be the trip generation for the The trip rates set out below in Table 2, are based on trip rates for a residential development as detailed in proposals? the appended TRICS output and is considered to provide a good comparison to the proposed site, these trip rates have been previously accepted on numerous other residential sites. The TRICS output is provided in Appendix C.

The vehicular trip rates are applied to the 221 dwelling residential development in Table 2.

Table 2. New Trips AM PM Arrivals Departures Arrivals Departures

Trip Rates 0.138 0.386 0.334 0.170 Trip Generation 30 85 74 38

Based on the above analysis the two‐way flows for the proposed development are; 115 vehicles in the AM peak and 111 vehicles in the PM peak.

2 of 6 14 What is the assumed trip distribution? The anticipated traffic distribution of the residential trips is based on 2011 Census data using a gravity model technique.

Based on the strategic site layout it is assumed that all of vehicles will access the development to the north. At the Old Bawtry Road / Doncaster Road / The Green three arm‐priority junction it is assumed that 71% of vehicles will travel north‐west onto Doncaster Road, whilst 29% of vehicles will travel north‐east onto Wroot Road. Details of the distribution from the proposed site are set out below:

Table 3. Site Access / Old Bawtry Road (Priority Junction) Destination % Split Old Bawtry Road (N) 100% Old Bawtry Road (S) 0% TOTAL 100%

Table 4. Old Bawtry Road / Doncaster Road / The Green (Priority Junctions) Destination % Split Doncaster Road (NW) 71% Wroot Road (NE) 29% TOTAL 100%

Of the 29% which turn right onto Wroot Road, it is anticipated that 19% of vehicles will take a right onto High Common Lane at the A614 (N) / Cross Lane / A614 (S) / High Common Lane four‐arm priority controlled roundabout whilst 10% travel south onto the A614 (S). Details of the calculated distribution are set out in Table 5.

Table 5. High Common Lane / A614 / Cross Lane (Roundabout) Destination % Split Cross Lane 0% A614 (S) 10% High Common Lane 19% TOTAL 29%

Of the 71% which turn left onto Doncaster Road, 57% of vehicles take a left onto B1396 Mosham Road at the Station Road / B1396 Mosham Road / Thorne Road / B1396 Bank End Road four‐arm priority‐ controlled roundabout, whilst 14% continue north onto Throne Road. Details of the calculated distribution are set out in Table 6.

Table 6. A614 Station Road / Throne Road / B1396 Bank End Road / B1396 Mosham Road (Roundabout) Destination % Split B1396 Mosham Road (W) 57% Thorne Road (N) 14% B1396 Blank End Road 0% TOTAL 71%

Of the 57% of vehicles that travel west down B1396 Mosham Road it is anticipated that 57% will continue straight through the B1396 Mosham Road / Gate House Lane traffic signal‐controlled T‐junction. 7% of these vehicles will then turn right onto Whiphill Top Lane whilst 50% continue along B1396. Details of the calculated distribution are set out in Tables 7 and 8 respectively.

3 of 6 Table 7. B1396 Mosham Road / Gate House Lane (Signals) Destination % Split B1396 Mosham Road 57% Gate House Lane 0% TOTAL 57%

Table 8. B1396 Mosham Road / Gate House Lane (Signals) Destination % Split B1396 50% Whiphill Top Lane 7% TOTAL 57%

It is anticipated that all of the vehicles that continue along B1396 will continue straight on the B1396 Doncaster Road / B1396 Cantley Lane / School Lane / Warning Tongue Lane roundabout. Of the 50% of vehicles that continue straight. 49% will continue straight along Cantley Lane whilst 1% turn onto Goodison Boulevard at the B1396 Cantley Lane / Goodison Boulevard / Green Boulevard roundabout. Details of the calculated distribution are set out in Tables 9 and 10 respectively.

Table 9. B1396 Doncaster Road / B1396 Cantley Lane / School Lane / Warning Tongue Lane (Roundabout) Destination % Split B1396 Cantley Lane 50% School Lane 0% Warning Tongue Lane 0% TOTAL 50%

Table 10. B1396 Cantley Lane / Goodison Boulevard / Green Boulevard (Roundabout) Destination % Split B1396 Cantley Lane 49% Goodison Boulevard 1% Green Boulevard 0% TOTAL 50%

Of the 49% of vehicles, 49% are expected to turn right at the B1396 Cantley Lane / A638 Bawtry Road traffic signal‐controlled junction. 40% of vehicles are expected to continue on A638 Bawtry Road, whilst 7% take a left onto Gliwice Way. Prior to this junction 2% of generated traffic is expected to disperse from the network. Details of the calculated distribution are set out in Tables 11 and 12 respectively.

Table 11. B1396 Cantley Lane / A638 Bawtry Road (Signals) Destination % Split A638 Bawtry Road (NW) 49% A638 Bawtry Road (SE) 0% TOTAL 49%

4 of 6 Table 12. A638 Bawtry Road / Gliwice Way and Gliwice Way / Booth Avenue (Combined Double Signals) Destination % Split A638 Bawtry Road 40% Gliwice Way 7% TOTAL 47%

Of the 47% of generated traffic, it is expected that 16% will turn left onto A18 Carr House Road at the A638 Carr House Road / A18 Leger Way / A638 Bennetthorpe / A18 Carr House Road (Roundabout) whilst 17% travel ahead onto Benetthorpe and the remaining 7% turn right onto A18 Leger Way. Details of the calculated distribution are set out in Table 13 respectively.

Table 13. A638 Bawtry Road / A18 Leger Way / A638 Bennetthorpe / A18 Carr House Road (Roundabout) Destination % Split A638 Carr House Road 16% A18 Leger Way 7% A638 Bennetthorpe 17% TOTAL 49%

The AM and PM peak traffic distributions and are shown on the network diagram attached at Appendix A.

15 Would traffic from adjacent sites be No. attracted to the site? 16 Capacity tests required? Due to the anticipated level of traffic departing / arriving in the AM and PM peak, junction capacity analysis of the site access junction will be undertaken on the key junctions identified in Section 6 and as below.

 Site Access / Old Bawtry Road (Priority Junction);  Old Bawtry Road / Doncaster Road / The Green (Priority Junctions);  High Common Lane / A614 / Cross Lane (Roundabout);  A614 Station Road / Throne Road / B1396 Bank End Road / B1396 Mosham Road (Roundabout);  B1396 Mosham Road / Gate House Lane (Signals);  B1396 Doncaster Road / B1396 Cantley Lane / School Lane / Warning Tongue Lane (Roundabout);  B1396 Cantley Lane / Goodison Boulevard / Green Boulevard (Roundabout);  B1396 Cantley Lane / A638 Bawtry Road (Signals);  A638 Bawtry Road / Gilwice Way and Gilwice Way / Booth Avenue (Combined Double Signals); and  A638 Carr House Road / A18 Leger Way / A638 Bennetthorpe / A18 Carr House Road (Roundabout).

Should DMBC Officers require any further / additional junctions to have capacity assessments undertaken please could you identify these in the comments box to the right.

The AM and PM peak development assignment is shown on the network diagram attached at Appendix B.

It is proposed that junction capacity assessments for the priority junctions will be undertaken using the Junctions 9 software package and capacity assessments for the signalised junctions will be undertaken using the LinSig software package.

17 Are adjacent junctions or links likely to Appropriate assessments will be undertaken at the junctions identified above for the future year scenarios become overloaded? to determine the impact of the proposals.

5 of 6 18 Is a new or modified highway access Access to the site will be gained from a single access point in the form of a single simple priority‐controlled likely? T‐junction, no right turn ghost island is considered to be required given that to the south, Old Bawtry Road tuns into a dead end.

The access junction and internal road will be designed to DMBCs adoption standards with consideration of the relevant residential design guide.

The internal road network will be designed in accordance with Manual for Streets (MfS) to encourage vehicles to travel at an appropriate speed throughout the development.

19 What are the visibility requirements? Visibility requirements will be met and the access points designed to adoptable standards. Are those requirements met? 20 Do the proposals comply with The proposals will be considered in‐line with National and Local policy. Transport Policy? 21 Are there any further transport related An Interim Travel Plan (ITP) for the 221 dwelling residential development will be submitted in support of the reports required? e.g. Travel Plans, Car planning application. This would be ‘updated’ to a Full Travel Plan post occupancy once resident surveys can Park Management Plans. be undertaken. 22 Will a review of Road Traffic Accidents A review of accidents within the vicinity of the development, for the latest 5 year period will be reviewed. (RTA’s) be undertaken?

6 of 6 Title: Indicative Site Location Plan Proposed Residential Development Finningley

Figure No: Figure 1

Green Boulevard School Lane

PM AM PM PM AM PM AM AM 49% 49% 50% 50%

Cantley Lane Cantley Lane B1396 Doncaster Road

AM PM AM PM

AM 1% 49% 49% AM 50% 50% PM 1% 1% 1% PM

Goodison Boulevard

Warning Tongue Lane

B1396

PM 50% AM 50%

Whiphill Top Lane

AM PM AM 50% 7% PM 50% 7% 7% 7%

Cantley Lane

B1396

A18 Leger Way Thorne Road

PM AM PM 7% PM AM PM 14% AM 7% PM AM PM 49% 0% PM AM AM 14% 17% 17% 40% 40% PM AM AM 49% 0% 57% 57% 49% 49% 57% 57%

Bennetthorpe A638 Bawtry Road A638 Bawtry Road A638 Bawtry Road Mosham Road B1396 Mosham Road Bank End Road

AM PM AM PM AM PM AM PM AM PM 7% 7% 40% 40% 0% 0% 57% 57% AM 16% 17% 17% AM 7% 7% 7% AM AM 57% 14% 0% PM 16% 16% 16% PM 7% PM PM 57% 14% 0% 0% 0%

A18 Carr House Road Gliwice Way Gate House Lane Station Road

PM AM

71% 71%

Doncaster Road The Green Wroot Road

AM PM

AM 71% 29% 29% 29% PM 71% 29% A614 (N)

Old Bawtry Road

PM AM PM 19% 10% 0% PM 100% 19% 19% AM 19% 10% 0% AM 100%

Site Access High Common Lane Cross Lane

AM PM AM PM AM 0% 100% 100% 0% 0% PM 0% 0% 0% AM 10% PM 10%

A614 (S)

06/09/2019 Old Bawtry Road, Finningley

Job Number - AMA/20538

Traffic Distribution - Gravity Modelling Appendix B Green Boulevard School Lane

PM AM PM PM AM PM AM AM 36 15 37 15

Cantley Lane Cantley Lane B1396 Doncaster Road

AM PM AM PM

AM 0 42 18 AM 43 19 PM 1 1 1 PM

Goodison Boulevard

Warning Tongue Lane

B1396

PM 37 AM 15

Whiphill Top Lane

AM PM AM 43 6 PM 19 3 2 5

Cantley Lane

B1396

A18 Leger Way Thorne Road

PM AM PM 5 PM AM PM 10 AM 2 PM AM PM 18 0 PM AM AM 4 12 5 29 12 PM AM AM 42 0 42 17 36 15 42 17

Benetthorpe A638 Bawtry Road A638 Bawtry Road A638 Bawtry Road Mosham Road B1396 Mosham Road Bank End Road

AM PM AM PM AM PM AM PM AM PM 6 3 34 15 49 22 AM 5 14 6 AM 2 6 2 AM 0 0 0 AM 49 12 0 PM 12 14 6 PM 5 PM 0 PM 22 5 0 0 0

A18 Carr House Road Gliwice Way Gate House Lane Station Road

PM AM

52 22

Doncaster Road The Green Wroot Road

AM PM

AM 61 25 9 21 PM 27 11 A614 (N)

Old Bawtry Road

PM AM PM 7 4 0 PM 74 14 6 AM 16 9 0 AM 30

Site Access High Common Lane Cross Lane

AM PM AM PM AM 85 38 00 PM 0 0 AM 3 PM 8

A614 (S)

06/09/2019 Old Bawtry Road, Finningley

Job Number - AMA/20538

Trip Assignment Appendix C TRICS 7.4.2 290817 B17.57 (C) 2017 TRICS Consortium Ltd Tuesday 19/09/17 Page 1 WYG Transport Planning Arndale Court LEEDS Licence No: 705101

Calculation Reference: AUDIT-705101-170919-0913 TRIP RATE CALCULATION SELECTION PARAMETERS:

Land Use : 03 - RESIDENTIAL Category : A - HOUSES PRIVATELY OWNED MULTI-MODAL VEHICLES

Selected regions and areas: 02 SOUTH EAST ES EAST SUSSEX 1 days HC HAMPSHIRE 1 days SC SURREY 1 days WS WEST SUSSEX 3 days 03 SOUTH WEST DV DEVON 3 days SM SOMERSET 1 days 04 EAST ANGLIA NF NORFOLK 1 days 06 WEST MIDLANDS SH SHROPSHIRE 2 days 07 YORKSHIRE & NORTH LINCOLNSHIRE NE NORTH EAST LINCOLNSHIRE 1 days NY NORTH YORKSHIRE 3 days SY SOUTH YORKSHIRE 1 days 09 NORTH CB CUMBRIA 1 days DH DURHAM 1 days 11 SCOTLAND FA FALKIRK 2 days HI HIGHLAND 1 days PK PERTH & KINROSS 1 days

This section displays the number of survey days per TRICS® sub-region in the selected set TRICS 7.4.2 290817 B17.57 (C) 2017 TRICS Consortium Ltd Tuesday 19/09/17 Page 2 WYG Transport Planning Arndale Court LEEDS Licence No: 705101

Secondary Filtering selection:

This data displays the chosen trip rate parameter and its selected range. Only sites that fall within the parameter range are included in the trip rate calculation.

Parameter: Number of dwellings Actual Range: 33 to 805 (units: ) Range Selected by User: 30 to 805 (units: )

Public Transport Provision: Selection by: Include all surveys

Date Range: 01/01/09 to 28/03/17

This data displays the range of survey dates selected. Only surveys that were conducted within this date range are included in the trip rate calculation.

Selected survey days: Monday 4 days Tuesday 3 days Wednesday 6 days Thursday 7 days Friday 4 days

This data displays the number of selected surveys by day of the week.

Selected survey types: Manual count 24 days Directional ATC Count 0 days

This data displays the number of manual classified surveys and the number of unclassified ATC surveys, the total adding up to the overall number of surveys in the selected set. Manual surveys are undertaken using staff, whilst ATC surveys are undertaking using machines.

Selected Locations: Suburban Area (PPS6 Out of Centre) 15 Edge of Town 9

This data displays the number of surveys per main location category within the selected set. The main location categories consist of Free Standing, Edge of Town, Suburban Area, Neighbourhood Centre, Edge of Town Centre, Town Centre and Not Known.

Selected Location Sub Categories: Residential Zone 20 No Sub Category 4

This data displays the number of surveys per location sub-category within the selected set. The location sub-categories consist of Commercial Zone, Industrial Zone, Development Zone, Residential Zone, Retail Zone, Built-Up Zone, Village, Out of Town, High Street and No Sub Category.

Secondary Filtering selection:

Use Class: C 3 24 days

This data displays the number of surveys per Use Class classification within the selected set. The Use Classes Order 2005 has been used for this purpose, which can be found within the Library module of TRICS®. TRICS 7.4.2 290817 B17.57 (C) 2017 TRICS Consortium Ltd Tuesday 19/09/17 Page 3 WYG Transport Planning Arndale Court LEEDS Licence No: 705101

Secondary Filtering selection (Cont.):

Population within 1 mile: 1,001 to 5,000 3 days 5,001 to 10,000 7 days 10,001 to 15,000 5 days 15,001 to 20,000 4 days 20,001 to 25,000 4 days 25,001 to 50,000 1 days

This data displays the number of selected surveys within stated 1-mile radii of population.

Population within 5 miles: 5,001 to 25,000 3 days 25,001 to 50,000 4 days 50,001 to 75,000 3 days 75,001 to 100,000 8 days 100,001 to 125,000 2 days 125,001 to 250,000 3 days 250,001 to 500,000 1 days

This data displays the number of selected surveys within stated 5-mile radii of population.

Car ownership within 5 miles: 0.6 to 1.0 5 days 1.1 to 1.5 19 days

This data displays the number of selected surveys within stated ranges of average cars owned per residential dwelling, within a radius of 5-miles of selected survey sites.

Travel Plan: Yes 5 days No 19 days

This data displays the number of surveys within the selected set that were undertaken at sites with Travel Plans in place, and the number of surveys that were undertaken at sites without Travel Plans.

PTAL Rating: No PTAL Present 24 days

This data displays the number of selected surveys with PTAL Ratings. TRICS 7.4.2 290817 B17.57 (C) 2017 TRICS Consortium Ltd Tuesday 19/09/17 Page 4 WYG Transport Planning Arndale Court LEEDS Licence No: 705101

LIST OF SITES relevant to selection parameters

1 CB-03-A-04 SEMI DETACHED CUMBRIA MOORCLOSE ROAD SALTERBACK WORKINGTON Edge of Town No Sub Category Total Number of dwellings: 8 2 Survey date: FRIDAY 24/04/09 Survey Type: MANUAL 2 DH-03-A-01 SEMI DETACHED DURHAM GREENFIELDS ROAD

BISHOP AUCKLAND Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 5 0 Survey date: TUESDAY 28/03/17 Survey Type: MANUAL 3 DV-03-A-01 TERRACED HOUSES DEVON BRONSHILL ROAD

TORQUAY Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 3 7 Survey date: WEDNESDAY 30/09/15 Survey Type: MANUAL 4 DV-03-A-02 HOUSES & BUNGALOWS DEVON MILLHEAD ROAD

HONITON Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 1 1 6 Survey date: FRIDAY 25/09/15 Survey Type: MANUAL 5 DV-03-A-03 TERRACED & SEMI DETACHED DEVON LOWER BRAND LANE

HONITON Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 7 0 Survey date: MONDAY 28/09/15 Survey Type: MANUAL 6 ES-03-A-02 PRIVATE HOUSING EAST SUSSEX SOUTH COAST ROAD

PEACEHAVEN Edge of Town Residential Zone Total Number of dwellings: 3 7 Survey date: FRIDAY 18/11/11 Survey Type: MANUAL 7 FA-03-A-01 SEMI-DETACHED/TERRACED FALKIRK MANDELA AVENUE

FALKIRK Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 3 7 Survey date: THURSDAY 30/05/13 Survey Type: MANUAL TRICS 7.4.2 290817 B17.57 (C) 2017 TRICS Consortium Ltd Tuesday 19/09/17 Page 5 WYG Transport Planning Arndale Court LEEDS Licence No: 705101

LIST OF SITES relevant to selection parameters (Cont.)

8 FA-03-A-02 MIXED HOUSES FALKIRK ROSEBANK AVENUE & SPRINGFIELD DRIVE

FALKIRK Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 1 6 1 Survey date: WEDNESDAY 29/05/13 Survey Type: MANUAL 9 HC-03-A-18 HOUSES & FLATS HAMPSHIRE CANADA WAY

LIPHOOK Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 6 2 Survey date: TUESDAY 29/11/16 Survey Type: MANUAL 10 HI-03-A-14 SEMI-DETACHED & TERRACED HIGHLAND KING BRUDE ROAD SCORGUIE INVERNESS Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 4 0 Survey date: WEDNESDAY 23/03/16 Survey Type: MANUAL 11 NE-03-A-02 SEMI DETACHED & DETACHED NORTH EAST LINCOLNSHIRE HANOVER WALK

SCUNTHORPE Edge of Town No Sub Category Total Number of dwellings: 4 3 2 Survey date: MONDAY 12/05/14 Survey Type: MANUAL 12 NF-03-A-02 HOUSES & FLATS NORFOLK DEREHAM ROAD

NORWICH Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 9 8 Survey date: MONDAY 22/10/12 Survey Type: MANUAL 13 NY-03-A-06 BUNGALOWS & SEMI DET. NORTH YORKSHIRE HORSEFAIR

BOROUGHBRIDGE Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 1 1 5 Survey date: FRIDAY 14/10/11 Survey Type: MANUAL 14 NY-03-A-09 MIXED HOUSING NORTH YORKSHIRE GRAMMAR SCHOOL LANE

NORTHALLERTON Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 5 2 Survey date: MONDAY 16/09/13 Survey Type: MANUAL TRICS 7.4.2 290817 B17.57 (C) 2017 TRICS Consortium Ltd Tuesday 19/09/17 Page 6 WYG Transport Planning Arndale Court LEEDS Licence No: 705101

LIST OF SITES relevant to selection parameters (Cont.)

15 NY-03-A-10 HOUSES AND FLATS NORTH YORKSHIRE BOROUGHBRIDGE ROAD

RIPON Edge of Town No Sub Category Total Number of dwellings: 7 1 Survey date: TUESDAY 17/09/13 Survey Type: MANUAL 16 PK-03-A-01 DETAC. & BUNGALOWS PERTH & KINROSS TULLYLUMB TERRACE GORNHILL PERTH Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 3 6 Survey date: WEDNESDAY 11/05/11 Survey Type: MANUAL 17 SC-03-A-04 DETACHED & TERRACED SURREY HIGH ROAD

BYFLEET Edge of Town Residential Zone Total Number of dwellings: 7 1 Survey date: THURSDAY 23/01/14 Survey Type: MANUAL 18 SH-03-A-04 TERRACED SHROPSHIRE ST MICHAEL'S STREET

SHREWSBURY Suburban Area (PPS6 Out of Centre) No Sub Category Total Number of dwellings: 1 0 8 Survey date: THURSDAY 11/06/09 Survey Type: MANUAL 19 SH-03-A-05 SEMI-DETACHED/TERRACED SHROPSHIRE SANDCROFT SUTTON HILL TELFORD Edge of Town Residential Zone Total Number of dwellings: 5 4 Survey date: THURSDAY 24/10/13 Survey Type: MANUAL 20 SM-03-A-01 DETACHED & SEMI SOMERSET WEMBDON ROAD NORTHFIELD BRIDGWATER Edge of Town Residential Zone Total Number of dwellings: 3 3 Survey date: THURSDAY 24/09/15 Survey Type: MANUAL 21 SY-03-A-01 SEMI DETACHED HOUSES SOUTH YORKSHIRE A19 BENTLEY ROAD BENTLEY RISE DONCASTER Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 5 4 Survey date: WEDNESDAY 18/09/13 Survey Type: MANUAL TRICS 7.4.2 290817 B17.57 (C) 2017 TRICS Consortium Ltd Tuesday 19/09/17 Page 7 WYG Transport Planning Arndale Court LEEDS Licence No: 705101

LIST OF SITES relevant to selection parameters (Cont.)

22 WS-03-A-04 MIXED HOUSES WEST SUSSEX HILLS FARM LANE BROADBRIDGE HEATH HORSHAM Edge of Town Residential Zone Total Number of dwellings: 1 5 1 Survey date: THURSDAY 11/12/14 Survey Type: MANUAL 23 WS-03-A-05 TERRACED & FLATS WEST SUSSEX UPPER SHOREHAM ROAD

SHOREHAM BY SEA Suburban Area (PPS6 Out of Centre) Residential Zone Total Number of dwellings: 4 8 Survey date: WEDNESDAY 18/04/12 Survey Type: MANUAL 24 WS-03-A-06 MIXED HOUSES WEST SUSSEX ELLIS ROAD S BROADBRIDGE HEATH WEST HORSHAM Edge of Town Residential Zone Total Number of dwellings: 8 0 5 Survey date: THURSDAY 02/03/17 Survey Type: MANUAL

This section provides a list of all survey sites and days in the selected set. For each individual survey site, it displays a unique site reference code and site address, the selected trip rate calculation parameter and its value, the day of the week and date of each survey, and whether the survey was a manual classified count or an ATC count. TRICS 7.4.2 290817 B17.57 (C) 2017 TRICS Consortium Ltd Tuesday 19/09/17 Page 8 WYG Transport Planning Arndale Court LEEDS Licence No: 705101

TRIP RATE for Land Use 03 - RESIDENTIAL/A - HOUSES PRIVATELY OWNED MULTI-MODAL VEHICLES Calculation factor: 1 DWELLS BOLD print indicates peak (busiest) period

ARRIVALS DEPARTURES TOTALS No. Ave. Trip No. Ave. Trip No. Ave. Trip Time Range Days DWELLS Rate Days DWELLS Rate Days DWELLS Rate 00:00 - 01:00 01:00 - 02:00 02:00 - 03:00 03:00 - 04:00 04:00 - 05:00 05:00 - 06:00 06:00 - 07:00 07:00 - 08:00 24 118 0.072 24 118 0.295 24 118 0.367 08:00 - 09:00 24 118 0.138 24 118 0.386 24 118 0.524 09:00 - 10:00 24 118 0.151 24 118 0.167 24 118 0.318 10:00 - 11:00 24 118 0.126 24 118 0.156 24 118 0.282 11:00 - 12:00 24 118 0.137 24 118 0.149 24 118 0.286 12:00 - 13:00 24 118 0.154 24 118 0.152 24 118 0.306 13:00 - 14:00 24 118 0.156 24 118 0.162 24 118 0.318 14:00 - 15:00 24 118 0.147 24 118 0.181 24 118 0.328 15:00 - 16:00 24 118 0.243 24 118 0.163 24 118 0.406 16:00 - 17:00 24 118 0.273 24 118 0.165 24 118 0.438 17:00 - 18:00 24 118 0.334 24 118 0.170 24 118 0.504 18:00 - 19:00 24 118 0.274 24 118 0.167 24 118 0.441 19:00 - 20:00 20:00 - 21:00 21:00 - 22:00 22:00 - 23:00 23:00 - 24:00 Total Rates: 2.205 2.313 4.518

This section displays the trip rate results based on the selected set of surveys and the selected count type (shown just above the table). It is split by three main columns, representing arrivals trips, departures trips, and total trips (arrivals plus departures). Within each of these main columns are three sub-columns. These display the number of survey days where count data is included (per time period), the average value of the selected trip rate calculation parameter (per time period), and the trip rate result (per time period). Total trip rates (the sum of the column) are also displayed at the foot of the table.

To obtain a trip rate, the average (mean) trip rate parameter value (TRP) is first calculated for all selected survey days that have count data available for the stated time period. The average (mean) number of arrivals, departures or totals (whichever applies) is also calculated (COUNT) for all selected survey days that have count data available for the stated time period. Then, the average count is divided by the average trip rate parameter value, and multiplied by the stated calculation factor (shown just above the table and abbreviated here as FACT). So, the method is: COUNT/TRP*FACT. Trip rates are then rounded to 3 decimal places.

Parameter summary

Trip rate parameter range selected: 33 - 805 (units: ) Survey date date range: 01/01/09 - 28/03/17 Number of weekdays (Monday-Friday): 24 Number of Saturdays: 0 Number of Sundays: 0 Surveys automatically removed from selection: 1 Surveys manually removed from selection: 0

This section displays a quick summary of some of the data filtering selections made by the TRICS® user. The trip rate calculation parameter range of all selected surveys is displayed first, followed by the range of minimum and maximum survey dates selected by the user. Then, the total number of selected weekdays and weekend days in the selected set of surveys are show. Finally, the number of survey days that have been manually removed from the selected set outside of the standard filtering procedure are displayed. Local Plan Representation – Bellway Homes (Yorkshire) & Mr D Higgins YK6323-1P – Higgin’s Site, Finningley September 2019

38