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Avant Homes Ltd (05208, 05209 and 05210) From: Spawforths on behalf of Avant Homes Sent: 30 September 2019 16:29 To: Local Plan Subject: Doncaster Local Plan - representations Importance: High Please find attached representations to the Doncaster Local Plan on behalf of Avant Homes, in respect of their interests in Doncaster. The representation covers the following matters: General Comments Policy 2 – Spatial strategy and settlement hierarchy Policy 3 – Level and distribution of growth Policy 6 – Housing Allocations o Rejected and New Sites: o Site 494: Green Lane, Scawthorpe o Site 1036: Melton Road, Newton o HELAA Site (871): Wadworth Hill, Wadworth Policy 8 – Delivering the necessary range of housing Policy 19 – Development affecting public rights of way Policy 20 – Access, design and layout of public rights of way Policy 29 – Open space provision in new developments Policy 39 – Historic Parks and Gardens Policy 46 – Housing design standards Policy 66 – Developer contributions Policy 67 – Development viability We trust that you will confirm that these representations are duly made. We welcome the opportunity for further engagement and to continue the dialogue with the Council in respect of these issues as the Local Plan progresses. Please do not hesitate to contact us to discuss any issues raised in this representation further. HANNAH LANGLER Principal: Chartered Town Planner BSc (Hons), Dip CRP, MRTPI Junction 41 Business Court, East Ardsley, Leeds, WF3 2AB Development Plan Representation Doncaster Local Plan: 2015- 2035: Publication Version (June 2019) On behalf of Avant Homes Ltd (Various Sites – Land at Scawthorpe, Newton and Wadworth) September 2019 Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019 1. Introduction 1.1. Spawforths have been instructed by Avant Homes to submit representations to the Doncaster Local Plan 2015-2035 Publication Version and for their site at Scawthorpe, Newton and Wadworth. 1.2. Appended to these representations is a report assessing the housing requirement, prepared by Regeneris Consulting. 1.3. Avant Homes welcomes the opportunity to contribute to the emerging Local Plan for Doncaster and is keen to further the role of Doncaster within the Sheffield City Region, South Yorkshire and the Yorkshire and Humber Region as a whole. 1.4. Avant Homes has significant and deliverable land interests in the area, which can positively contribute towards the economic and housing growth agenda. 1.5. Avant Homes would like to make comments on the following policies in the Doncaster Local Plan 2015-2035 Publication Version: • General Comments • Policy 2 – Spatial strategy and settlement hierarchy • Policy 3 – Level and distribution of growth • Policy 6 – Housing Allocations o Rejected and New Sites: o Site 494: Green Lane, Scawthorpe o Site 1036: Melton Road, Newton o HELAA Site (871): Wadworth Hill, Wadworth • Policy 8 – Delivering the necessary range of housing • Policy 19 – Development affecting public rights of way • Policy 20 – Access, design and layout of public rights of way • Policy 29 – Open space provision in new developments • Policy 39 – Historic Parks and Gardens • Policy 46 – Housing design standards • Policy 66 – Developer contributions • Policy 67 – Development viability 2 Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019 1.6. In each case, observations are set out with reference to the provisions of the Framework and where necessary, amendments are suggested to ensure that the Local Plan is found sound. 1.7. Avant Homes welcomes the opportunity for further engagement and the opportunity to appear at the Examination in Public. 1.8. We trust that you will confirm that these representations are duly made and will give due consideration to these comments. 1.9. Please do not hesitate to contact us to discuss any issues raised in this Representation further. 3 Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019 2. National Planning Policy Context and Tests of Soundness 2.1. The Government's core objectives as established through the 2018 National Planning Policy Framework (the 2019 Framework) are sustainable development and growth. Paragraph 11 of the Framework stresses the need for Local Plans to meet the objectively assessed needs of an area. The 2019 Framework sets out to boost significantly the supply of homes and that a sufficient amount and variety of land can come forward where it is needed. In terms of building a strong and competitive economy the 2019 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2019 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes. 2.2. In relation to Local Plan formulation, paragraphs 15 to 37 of the Framework states that Local Plans are the key to delivering sustainable development which reflects the vision and aspirations of the local community. The Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where. 2.3. In relation to the examination of Local Plans, paragraph 35 of the Framework sets out the tests of soundness and establishes that: 2.4. The Local Plan and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sounds. Plans are ‘sound’ if they are: Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; 4 Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019 Effective – deliverable over the plan period, and based on effective joint working on cross- boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework. 2.5. This document therefore considers the content of the Doncaster Local Plan – Publication Version (2015-2035) on behalf of Avant Homes in light of this planning policy context. 5 Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019 3. General Comments 3.1. Avant Homes is concerned that the Doncaster Local Plan – Publication Plan is deficient in its content and the evidence base does not reflect national guidance. Test of Soundness 3.2. Avant Homes considers that the Doncaster Local Plan – Publication Version 2015-2035 is unsound. Which test of soundness are comments about? X Positively Prepared X Effective X Justified X Consistency with National Policy Justification 3.3. Avant Homes is concerned that the draft Local Plan does not reflect the Framework (2019). Avant Homes is concerned that the housing requirement does not reflect economic growth ambitions, the level of employment allocations, nor is it sufficient to meet the identified needs for affordable housing. Further Avant Homes are concerned that there are insufficient housing allocations to meet the housing requirement. 3.4. Avant Homes is concerned that there is a lack of up to date, available, and robust evidence base to accompany the Plan, particularly in respect of an up to date Housing Needs Assessment, whilst a 2019 update is referred to in the Plan, it is not yet publically available, the Viability Evidence (May 2019), which requires further testing to support its conclusion, and specific evidence to justify key policies. 3.5. Avant Homes consider that the Policies in the Local Plan are not justified and does not provide an appropriate strategy. The Plan in its present form could fail to deliver sustainable development in accordance with the policies in the Framework and is not consistent with national policy. 6 Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019 3.6. In these circumstances, Avant Homes do not consider the Doncaster Local Plan, in its current form, to be sound. 3.7. However, Avant Homes consider that the plan can be made sound subject to proposed changes as set out within the following sections of these representations. Avant Homes will continue to work with the Council to develop appropriate modifications to the Local Plan. Proposed Change 3.8. To overcome the objection and address soundness matters, the Council should: • Identify a higher housing requirement to meet economic and affordable housing ambitions and needs. • Identify sufficient supply of housing to meet the identified housing requirement. • Review and make available supporting evidence for the Plan as indicated in these representations. • Review and provide additional testing in the Whole Plan Viability Report; and • Respond to the evidence and provide increased flexibility in the Plan, refer to specific proposed changes under each policy. 7 Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019 4. Policy 2: Spatial
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