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

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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.

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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;

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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.

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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.

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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.

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4. Policy 2: Spatial Strategy and Settlement Hierarchy (Strategic Policy)

4.1. Avant Homes is concerned that the Doncaster Local Plan 2015-2035 Publication Version is deficient in its content and evidence base and does not reflect national guidance.

Test of Soundness

4.2. Avant Homes considers that the Local Plan is unsound.

Which test of soundness are comments about?

X Positively Prepared X Effective

X Justified X Consistency with National Policy

Justification

4.3. Avant Homes is concerned with the Spatial Strategy and distribution. Avant Homes would expect the spatial strategy and distribution to provide an appropriate development pattern and support economic growth and sustainable development within all market areas.

4.4. The Strategy at present focusses growth towards Doncaster, followed by the Main Towns and then a smaller element in the Service Towns and Larger Villages and then no development in other defined villages. Therefore no new housing is proposed in the rural economy in settlements which are relatively sustainable. This approach is broadly consistent with the strategy set out in the UDP and subsequent Core Strategy. Avant Homes are concerned that this risks focusing development in less viable areas and risks undermining the delivery of the Plan.

4.5. The implementation of the Spatial Strategy will be discussed in response to Policy 6 and the proposed allocations.

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4.6. Doncaster is an integral part of the Sheffield City Region and the ambitious growth aspirations. The Strategic Economic Plan sets out the Sheffield City Region’s plans to transform the local economy over the next decade. At the heart of the plan is the creation of 70,000 new private sector jobs and 6,000 new businesses.

4.7. Therefore, to achieve the aspired growth that the City Region is seeking to achieve and is securing Government funding for the level of new housing needs to reflect the ambitions of the Strategic Economic Plan.

4.8. Furthermore, the Sheffield City Region Integrated Infrastructure Plan states:

A quality housing offer has a crucial role to play in the future economic growth of the City Region. It is essential to attracting and retaining a skills base that supports inward investment as we as meeting existing and future community needs and retention of Sheffield City Region (SCR) talent.

It has been identified that between 70,000 and 100,000 additional homes are needed in SCR to support the proposed economic growth over the next 10 years. These will have the dual benefit of providing accommodation that underpins the proposed increase in employment (70,000 jobs), as well as the wider economic benefits that housing investment brings.

Housing forms a key component of the SCR construction sector. The CBI [CBI (2012) Bridging the Gap – Backing the Construction Sector to Create Jobs] estimates that every £1 spent on construction projects yields a total of £2.84 expenditure in the wider economy. It is estimated that approximately £2,000 per annum per household spending on local convenience goods, and approximately £2,700 per annum per household spending on local comparison goods can be attributed to residents in new housing. (Over the lifetime of the SEP, a similar amount would generate at least £400 million for the SCR economy). The GVA benefits that can be attributable to new housing are as follows:

• Construction: material, labour professional skills and other services for construction, compounded by supply chain benefits

• Household Maintenance Spend: Spend on products and services associated with each new household

• Direct Job Uptake: GVA resulting from new productive workers moving into SCR, compounded by their spend on SCR products and services

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• Indirect (Chain) Benefits): As SCR residents move up the housing chain, this creates new available space in different sub-markets.

• Preventing Displacement: The type and location of construction may be important in mitigating losses of households from the city region that might otherwise occur.

4.9. Within this context it is important that the Council plans for new jobs and associated new homes in accordance with the Strategic Economic Plan growth aspirations.

4.10. To achieve this approach, Avant Homes consider the Local Plan should:

• Focus the majority of development upon Doncaster Main Urban Area but review the likely housing yield from existing sites with planning permission and proposed allocations to ensure that they can all be delivered within the Plan Period. This is explained further in response to Policy 3.

• To focus growth and regeneration on the Main Towns of appropriate scale for their needs and the economic growth aspirations of the Borough. Rossington should be an area of growth given the provision of new infrastructure, its location near to Doncaster Airport, and the scale of economic growth planned at IPort. Thorne and Moorends should grow to reflect its location, regeneration ambitions connected with the logistics and employment parks, and level of facilities available within the designated town and local centres. Within that context Carcroft and Skellow is of similar scale to the Main Towns and should be identified as such, particularly with its provision of employment parks and location on the A1(M) and focus on regeneration and growth.

• Provision should be made in the Service Towns and Larger Villages to reflect their scale and function. These are sustainable towns and villages which serve a hinterland. Wadworth is of a similar scale and function of these settlements and should therefore be defined as such, with appropriate allocations made, recognising its proximity and connectivity to the Main Urban Area.

• Defined Villages are sustainable villages serving a rural economy and should accommodate a level of development appropriate to their scale and function in

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line with the provisions Framework (paragraph 78). Avant note that Barnsley Metropolitan Borough Council sought to take a similar approach and did not identify allocations within the villages. The Inspector considered that the Plan was not positively prepared in relation to the approach to the villages and considered that policy LG2 was unsound. In this case the local authority reviewed the settlements and identified additional sites within the villages to accommodate new development.

4.11. Avant Homes consider that the above approach meets the Local Plan vision and objectives identified within the Local Plan but is also one that is more aligned with the principles of sustainable development.

4.12. Policy 2 establishes the strategic approach to the Green Belt within Doncaster and states that the general extent of the Green Belt will be retained. Avant Homes is concerned that Green Belt boundaries have been drawn tightly around settlements and proposed allocations and as such does not have regard to the intended permanence in the long term so that the boundaries can endure beyond the Plan period. Policy 3 and 6 do not identify any safeguarded land. The Plan does identify reserve sites. However these sites have significant technical constraints. Avant Homes do not consider that they are suitable pool of sites due to the significant constraints and object to their identification in the Plan.

4.13. Whilst there is no definitive guidance indicating the amount of land which should be safeguarded the Framework (2019) is clear that where necessary Local Plans should ‘identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period’, and that local authorities should ‘be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period’. Given that the council considers that the majority of sites will be delivered within the plan period. It is highly likely that further alterations to the green belt will be required at the next review of the Plan. This is not consistent with the provisions of the Framework.

4.14. Avant Homes consider that Policy 2 should establish the approach to Safeguarding land and that safeguarded land should be identified, not only provide a robust long-term Green Belt boundary but will also provide certainty for residents and developers alike in terms of likely growth locations beyond the end of the plan period. Avant Homes therefore suggest that such land be allocated in the Plan across the spatial hierarchy, including smaller settlements per the earlier spatial approach.

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4.15. Avant homes consider that the policy in its current form is not justified and is not consistent with the Framework the Plan in its present form could fail to deliver sustainable development in accordance with policies in the Framework. In these circumstances, we do not consider the Doncaster Local Plan in its current form to be sound.

4.16. However, Avant Homes consider that with the proposed changes to the strategy and establishing the approach to safeguarding land the Local Plan can be found sound. Avant Homes will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

4.17. To overcome the objection and address soundness matters, the Council should:

• Reflect economic and housing growth aspirations

• Amend the Spatial Strategy as indicated

• Identify safeguarded land or suitable Reserve Development Sites across the spatial hierarchy

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5. Policy 3: Level and Distribution of Growth (Strategic Policy)

5.1. Avant Homes is concerned that the Doncaster Local Plan Draft Policies and Proposed Sites is deficient in its content and evidence base and does not reflect national guidance.

Test of Soundness

5.2. Avant Homes considers that the Local Plan is unsound.

Which test of soundness are comments about?

X Positively Prepared X Effective

X Justified X Consistency with National Policy

Justification

5.3. Avant Homes have a number of concerns in relation to the Level and Distribution of Growth. The concerns relate to the following:

• The Local Plan housing requirement is not sufficient and is not fully aligned with forecast economic growth.

• The Local Plan identifies significantly more employment land than the target for provision established in Policy 3.

• There is a significant mismatch between the level of employment land allocated and the level of housing land allocated in the Plan period; and

• The identified supply is not sufficient to meet the Councils identified requirement.

Need

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5.4. Avant Homes is concerned with the proposed level of new housing being planned for in the Local Plan. Policy 3 makes provision for 18,400 dwellings to be delivered between 2015 and 2035, equivalent to 920 net new homes each year. Policy 3 states that there should be sufficient allocations for 15 years supply, which is 13,230 new homes.

5.5. Avant Homes has commissioned Regeneris Consulting to review the OAN and the Economic Forecasts and Housing Needs Assessment (2018). The Regeneris report is attached to these representations. Regeneris conclude that:

• The target delivers the minimum level of housing need for Doncaster based on the standard method (585 dpa) and makes an upward adjustment to support economic growth.

• The upward adjustment was based on evidence produced by PBA which recommended housing need is presented as a range between 585 dpa (the minimum) and 912 dpa. The upper limit was based on matching Jobs growth aspirations of the Sheffield City Region LEP (1,420) over the period 2016 to 2026.

• However, PBA have made unjustified and unrealistic assumptions for a number of factors which all suppress the level of housing required to support future employment growth. In particular, we disagree with their assumptions about commuting, double jobbing and household formation rates.

5.6. Regeneris consider that:

• Doncaster has been one of the fastest growing economies in Yorkshire and Humber. The district has created around 24,000 jobs between 2000 and 2017, representing a growth rate of 1.1% p.a

• Doncaster’s key asset is its connectivity by road, rail and air which has made it a highly attractive location for inward investment, particularly for industrial and logistics occupiers, with over 1.1m sq m of industrial/warehouse space taken up since 2010.

• The strong performance is also due to a significant improvement in key economic indicators, including skills and levels of enterprise. The business

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start-up rate has more than doubled since 2010 and is now in line with the national average. These improvements have removed a key barrier to growth and mean that Doncaster is well placed to continue its high rate of growth.

• The Local Plan has set a target of delivering 481 hectares of employment land between 2015 and 2035 and a number of ELR’s shows there continues to be very strong market demand for industrial space in Doncaster. There is therefore strong potential for Doncaster to accommodate high levels of inward investment in future which would also drive jobs growth.

5.7. Avant Homes have concerns that the proposed housing requirement does not represent an appropriate figure once consideration is given to the potential for economic growth and job formation. Avant Homes continue to consider that an appropriate balance should be sought between employment growth aspirations and the provision of homes.

5.8. The Framework (2019) reaffirms the Governments’ commitment to ‘significantly boosting the supply of homes’ and states that ‘it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed’. It goes on to state ‘ to determine the minimum number of homes need, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify and alternative approach which also reflects current and future demographic trends and market signals’.

5.9. NPPG is clear that the standard method identifies a minimum annual housing need figure and that it does not produce a housing requirement figure Paragraph 002 Reference ID: 2a-002- 20190220. It is also clear that the affordability adjustment within the standard methodology is just to ensure that the minimum housing needs starts to address affordability of homes. It therefore does not fully address affordability issues. Paragraph 006 Reference ID :2a-006- 201902020.

5.10. NPPG goes on to identify the circumstances when it is appropriate to plan for a higher housing need figure than the standard methodology identifies. ‘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 the minimum starting point in determining the number of homes needed in an area…it does not predict the impact of future government policies, changing economic circumstances or other factors that might have an impact on demographic

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behaviour. Therefore there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicate.

5.11. This will need to be assessed prior to and separate from, considering how much of the overall need can be accommodated. 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:

5.12. Growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth

5.13. Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally;

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

5.15. There may, occasionally be situations where previous levels of housing delivery in an area, or previous assessments of need (such as a recently produced SHMA) 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 that the standard model suggests’. Paragraph 010 Reference ID: 2a-010-20190220.

5.16. The Council need to recognise that the development of new housing will bring forward additional economic benefits to the area. The relationship between economic performance in an area and housing is complex, but having the right quantity, quality and balance of housing in an area is necessary for economic growth. The development of new housing can therefore support local economic growth, both through direct job creation through the construction phase of the scheme, but also through the increased population which will create sustainable local jobs from the increased demand for goods and services. This provides an important sustainable development opportunity for Doncaster.

5.17. Importantly the HBF released in July 2018 its report on “the economic footprint of house building in England and Wales”, which shows that house building in England and Wales is now worth £38bn a year and supports nearly 700,000 jobs. House building activity contributes economically in different ways including providing jobs, tax revenues and contributing funding for local infrastructure and communities. House building supports the economic in a wider sense through being drive for economic growth; delivering jobs and economic value;

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supporting labour market mobility; creating skills and employability; enhancing place competitiveness; creating quality of place and reusing brownfield land.

5.18. An important conclusion of the report and the wider economic benefits is that a healthy, well- functioning labour market requires a good supply of housing that is affordable for local people to enable them to move jobs freely and match up skills supply with employer demand. A dysfunctional housing market can inhibit labour market mobility, in turn stifling economic growth.

5.19. Regeneris consider that Doncaster’s housing need over the plan period should be 1,100 dpa to support future economic growth. Regeneris consider that the target of 920 dpa would risk constraining the future economic growth of Doncaster.

5.20. Furthermore, it is evident that the council are seeking to align economic growth with housing growth and have identified provision above the local housing need figure to which the council considers accounts for Job Led growth. However, the jobs led growth figure is based on jobs growth forecast between 2015-2032. It is not clear whether consideration has been given to the additional job growth expected to the end of the plan period. Therefore Avant consider there is potential for the jobs led scenario to underestimate the jobs growth over the full plan period. The associated uplift to the housing requirement will therefore not be sufficient to meet the full needs over the plan period.

5.21. Additionally, the Council have identified a requirement for 481 hectares of employment land based on the Job Led scenario, and accounting for the extended plan period between 2032 and2035. The explanatory text considers that this requirement is met through 117 hectares of land developed between 2015-2018, 201 hectares of land benefiting from planning permission, and 164 hectares of allocated sites. However, there is a discrepancy between the totals in paragraph 4.61 of the Plan and the figures arising from Tables E1 to E8. The sites that benefit from planning permission in tables E1 to E8 equate to 284.09 ha of employment land available within the Plan period. This leads to a total provision of 565.77 hectares of employment land against a requirement of 481 hectares. It should be noted that within the permissions identified in tables E1 to E8 that additional employment land is available, adding to the potential supply. There is therefore a significant mismatch between the level of planned employment provision in Policy 4 and the planned housing provision. Therefore, the housing requirement needs to be uplifted to reflect the identified level of employment land provision.

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5.22. As stated above NPPG indicates that consideration can be given to delivery rates, for the last three years completions have been consistently higher than the proposed local plan target. Net completions amount to 3211 dwellings, with annual completions as follows:

Year Net Completions

2015-16 1,025

2016/17 1,049

2017/18 1,137

Total 3,211

5.23. This demonstrates that there is sufficient demand to support a requirement above 920 dwellings per annum.

5.24. The Councils Economic Forecasts and Housing Needs Assessment (PBA, 2018) considers the housing requirement prior against both the standard methodology, standard methodology with an uplift for economic growth and previous approach for identifying housing need. Following the earlier approach, PBA consider that an aspirational job led figure, based on the SEP ambitions, would equate to a requirement of 1,073. PBA considered that it would be prudent to plan for between 562 and 1073. To ensure that the requirement was realistic. It is worthy of note that the Employment Land Needs Assessment (2019). Considers that the Job led scenario was ambitious but realistic and notes the significant growth in Doncaster within the previous 15 years in line with SCR growth aspirations. And further the evidence of land take up and jobs growth for the period 2015-2018 was on target to meet 1% jobs growth per annum. This would support a target at the higher end of the range.

5.25. There is therefore evidence of both delivery at a higher rate and recently published evidence that indicates a higher need for housing. As stated above NPPG is clear that this evidence should be taken into account when determining the housing requirement.

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5.26. When using the standard method the housing need figure was 585, applying a job led figure to match the SEP led to a requirement of 912 (PBA, 2018). However this is not based on the Jobs growth over the full plan period.

5.27. Avant Homes consider further evidence is required to demonstrate whether the affordable housing needs of Doncaster can be met based on a target of 920. The explanatory text states that the current need for affordable housing, 209 affordable units, represents 23 % of the Local Plan requirement for housing. Paragraph 6.9 states that this does not take into account current completions or viability. The completions affordable completions for the last three years (first three years of the Local Plan) are as follows:

Year Affordable Total Completions Affordable Completions completions (%)

15/16 151 1,088 13.88

16/17 161 1,067 15.09

17/18 166 1,208 13.74

5.28. The total affordable completions falling below the identified affordable need, even when total completions are higher than the proposed Local Plan requirement of 920. Further, Policy 8 identifies a requirement for 23% affordable housing in high/medium value areas and 15% in low value areas. An as indicated in response to Policy 8 and Policy 67, this is demonstrated to be unviable for a number of sites, including all types of sites in low value areas. Avant Homes are therefore concerned that a target of 920 dwellings will not deliver sufficient number and range of affordable homes to meet the identified need for affordable homes in the Borough. In order to deliver 209 affordable dwellings per year, a requirement of at least 1,393 would be required. This assuming the achievement of an average of 15% affordable housing, which represents the highest achieved over the last three years of monitoring.

5.29. Avant Homes consider that there is sufficient evidence to pointing to the need for further uplift in the Local Plan housing requirement, based on the significant mismatch between

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housing and employment land allocations, the need to support the local plans economic ambitions, evidence of delivery and the need to ensure sufficient delivery of affordable housing.

5.30. Avant homes consider that the policy in its current form is not justified and is not consistent with the Framework the Plan in its present form could fail to deliver sustainable development in accordance with policies in the Framework. In these circumstances, we do not consider the Doncaster Local Plan in its current form to be sound.

5.31. However, Avant Homes consider that with a higher requirement, of at least 1,100 to meet the economic growth aspirations, and further uplifts to balance housing allocations with the employment land allocations, and to ensure that the needs for affordable homes can be met (up to 1393) that the Local Plan can be found sound. Avant Homes will continue to work with the Council to develop appropriate modifications to the Local Plan

Housing Supply and Delivery

5.32. Avant Homes is concerned that the Council’s approach to delivering the housing requirement does not appear to reflect national guidance.

5.33. The Council is not demonstrating sufficient flexibility in the supply of housing land to ensure that the Plan can meet identified needs in full. The Framework is clear that plans should be sufficiently flexible to adapt to rapid change, and emphasises the importance of ensuring that a sufficient amount and variety of land can come forward where it is needed.

5.34. PPG is clear that careful attention should be given to providing an adequate supply of land, and the Plan needs to be realistic about what can be achieved and when. Authorities need to ensure that policies setting out contributions expected from development do not undermine the deliverability of the Plan. (Paragraph 59 Reference ID: 61-059-20190315.

5.35. At present based on the Councils figures presented in the Local Plan, a Plan requirement of 18400, completions equating to 3400 and allocations equating to 16,055, there is a flexibility of around 1055 dwellings which equates to 5% of the Local Plan Requirement. Avant Homes consider that this is insufficient given the potential for non-delivery and under delivery of sites, particularly from the dependency on a number of large sites. As set out in our response to a number of policies within the plan and specifically Policies 8, 46, 66 and 67, Avant Homes are concerned that some of the policies may undermine the deliverability of sites, or lead to the

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need for further site specific viability testing impacting on the timing of delivery and therefore there is a need for greater flexibility in the housing supply. Specific sites are identified later in this section.

5.36. Avant Homes have a number of concerns relating to the supply in the Plan in terms of completions, the allocations from permissions and the new allocations.

5.37. It is noted that the supply attributed to completions appears to be resultant from gross completions rather than net completions. The Plan indicates that completions between 2015 and 2018 equate to 3400, However data in the Residential Land Availability Report indicates that net completions amount to 3211. Which would serve to increase the residual requirement based on an OAN of 920 to at least 15,189, and reduce the flexibility in the Plan to 866 dwellings (4.7%).

5.38. With regards to overall supply from permissions and allocations, a housing trajectory has been provided. Avant Homes are concerned that this demonstrates that the Council will struggle to maintain a continuous supply of housing particularly in the later phases of the Plan period. Only four sites are identified as being capable of delivery in the final years of the plan period and two sites delivering beyond the plan period.

5.39. Furthermore, the Council’s HELAA and Residential Land Availability Report have a base date of March 2018, thus a whole monitoring year is presently absent. This evidence base should therefore be updated.

5.40. In terms of existing commitments it appears that the Council assumes 100% delivery and no discount has been applied. Best Practice and Guidance suggests that at least a 10% discount should be applied on sites with extant planning permission but this could vary depending on site specific constraints and complexity. Avant Homes supports the discounting of sites with planning permission but consider it may be beneficial to include a higher level of discount for large sites to take into account unforeseen circumstances and delivery delays. Avant Homes consider therefore that from a commitments pot of 9,488 dwellings a discount of at least circa 948 should be applied, however this could feasibly be higher given the history and constraints of a number of sites.

5.41. Avant Homes is concerned with the reliance on some existing housing sites with planning permission and their potential delivery, particularly as some are fairly historic brownfield sites

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with viability concerns in market challenging areas. There are a considerable number of outstanding planning permissions in poor market areas, some of which are also constrained by flood risk. Evidence of developer interest in such sites should be a fundamental requirement to provide confidence on delivery. For example, a brief review of some sites being shown as commitments shows considerable concern:

No. of Site Ref Site Name Avant Homes Comment Dwellings

There have been a number of planning applications and proposed schemes over the years, but there has been no delivery on site. Countryside PLC has submitted a planning application which the Environment Agency has objected to and recommended refusal. There is conflicting evidence in terms of delivery rates, 838 Hexthorpe 930 with the Local Plan and the HELAA. There are significant flooding constraints affecting the site. No further deliverability evidence has been produced in the Doncaster 5 Year Deliverable Housing Land Supply Statement. The Residential Land Availability Study notes that at 31/03/2018 there were no completions and the site is not currently being developed. This is a Persimmon / Charles Church scheme. However, delivery has become frustrated by the need to deliver infrastructure to complete development. Since there is only one developer on the site the development trajectory is likely to be modest and development of the site is unlikely 843 Manor Farm, Bessacarr 1,009 to be achieved during the plan period. The Residential Land Availability Report indicates 39 completed in 17/18 which is below the rates expected in the Local Plan and HELAA. Which assumes delivery rates of around 70 dwellings a year. This is not realistic based on current delivery.

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No. of Site Ref Site Name Avant Homes Comment Dwellings

The site has outline planning permission for 3,100 homes and no reserved matters have been submitted. The site is in significant multiple ownership and understand that CPO procedures will be employed to facilitate the delivery of requisite infrastructure. Homes England is also assigning public funding to support the development. Given the presence of multiple landowners, the need for considerable public funding, the likelihood of a protracted timeframe to open up the site for development and the 418 Unity/DN7 Initiative 905 absence of confirmed market interest, the site is unlikely to deliver the Council’s prediction of 1015 homes in the plan period. The HELAA does not anticipate a start on site until years 6 to 10. However the local plan indicates a 175 completions in the first five years. Higher rates of delivery are expected in the following years (70 dwellings per annum). These rates are overly optimistic especially when compared to annual completions for individual sites recorded in the residential land availability report. This is a long standing, unimplemented planning permission that has been available but has remained undeveloped. There is no developer 569 Askern Saw Mills 220 interest and consequently the assumed delivery of 220 new homes is optimistic. Indicated in the Residential Land Availability Report that the outline permission has lapsed. This site has significant constraints. There is an outline permission relating to the development of the site. The Local Plan assumes a delivery rate of 984 Former McCormick Tractors 600 56 dwellings per in the first five years and 64 dwellings per annum in the following years. This is overly optimistic and not consistent with the planning status and constraints on site. Site 940 is allocated in the plan for development of up to 280 dwellings (Part E1), Part E2 is identified as a reserved housing site for up to 920 940 E1 and Land east of Poplars Farm 280/920 dwellings. This site does not form a true reserve E2 site. The council have identified a release mechanism which restricts the release of housing to net additional jobs delivered at the airport.

5.42. Avant Homes understands that no allowance has been made for demolitions. No evidence is apparent and Avant Homes consider it would be appropriate for this evidence to be forthcoming.

5.43. The availability of land is crucial. To be considered deliverable the land needs to be available now and in terms of developable there needs to be a reasonable prospect that land will be available at the point envisaged. Avant Homes consider that sites which are not available or

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are unknown should not be included in the Plan or a buffer should be provided due to the uncertainty on delivery.

No. of Site Ref Site Name Avant Homes Comment Dwellings

This site does not have access, therefore cannot be considered to be deliverable. Further, the capacity of the site is unrealistic. This is a 1.5 1028 Tickhill 74 hectare site, a capacity of 44 dwellings would reflect the assumptions on net to gross developable area and density set out in the Viability Study. The delivery rates on the site are overly optimistic. In 2017/18 there were only 49 completions on site 662. Assuming delivery rates based on past performance at this site then it is 662/247 Colliery Site, Rossington 897/237 considered that only 600 dwellings will be capable of coming forward within the Plan period. This is significantly less than the 1127 homes forecast within the Plan. This is a longstanding allocation and there is little evidence available through the council’s evidence 081/343 Thorne 207 base to demonstrate that there is developer interest or that the site will come forward in the short term. This site had permission which has since lapsed. There appears to be little developer interest in 795 Thorne 13 this site. The site is not considered to be deliverable. This is a narrow and constrained infill site, with railway forming the southern boundary of the 510 Thorne 25 site. There is little evidence available through the Councils evidence base to indicate any developer interest in the site. This site is located to the western edge of the settlement and is relatively distant from the key 165/186 Carcroft 300 services and facilities such as the train station, and employment opportunities. Other sites are located nearer to key services.

5.44. A high level assessment of some of the proposed allocations shows that some proposals are at risk and hence one of the reasons why Best Practice suggests a buffer to the housing requirement should be included in the Plan. Furthermore, would appear to have leant heavily on allocating sites that already have planning permission as an alternative to identifying a sufficient supply of new allocation sites to meet its requirement for the plan period. Consequently, a number of settlements with strong sustainability credentials would appear to have insufficient allocations to meet their needs through the life of the plan.

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5.45. It would appear in some instances that there are unrealistic assumptions on gross to net developable site areas and on the resultant yields from proposed allocations, especially when considering some of the development requirements. Avant Homes therefore suggest that further sites should be identified.

5.46. The Council therefore need a wider choice of sites across a number of different areas and market areas to gain traction and increase build rates. To achieve the housing requirement the Council need at least 30-35 housing outlets operating across the Borough for every year of the Plan and Avant Homes do not believe the Plan can deliver this, particularly in the middle to later years.

5.47. Avant Homes considers the Council should be more realistic on the potential delivery on sites, particularly on sites which have not commenced preparations of securing the relevant planning permission and developer interest and on build rates. Avant Homes consider that the sites with no planning permission should not be providing completions until 2023/24 (which is two years post adoption) as there is significant work and preparations to commence on site, including time to prepare and submit the planning application, gain planning permission, discharge conditions, legal agreements, site preparations, and commence house building. This process can take around 2 years.

5.48. Avant Homes would be happy to work through the specific sites in detail with the Council to seek to reach agreement on the HELAA and current housing commitments. Interestingly, in line with the general direction of travel for this Local Plan the new Framework (2019) defines the term Deliverable in the glossary stating that sites can only be considered deliverable where they have detailed planning permission. If they have outline planning permission or are allocated in a plan a site can only be considered if there is clear evidence that housing completions will begin on site within five years. The level of evidence that must be provided to demonstrate that sites are deliverable has therefore been tightened.

5.49. Avant Homes considers that the main risks to the delivery of the housing requirement are slippages in the delivery of allocations, longer lead-in times, reduced housing capacity on sites, sites no longer coming forward as result of viability from policy obligations set out in the Local Plan. Given these risks Avant Homes would suggest a greater flexibility is incorporated into the Local Plan especially in light of Avant Homes’ conclusions on the actual housing requirement.

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5.50. Avant Homes would encourage the Council to review the existing commitments to ensure this is still deliverable, whether there is a housebuilder on board and whether there are any constraints preventing development from coming forward. Avant Homes would also ask the Council to look at the proposed delivery of site allocations to determine whether the delivery rates are appropriate and the sites are deliverable in light of the policy obligations proposed in the Local Plan.

5.51. Taking into account the above, the Council should be making provision for:

Council Figures Avant Homes’ View

Annual Housing Requirement 920 1,100

Total Requirement (2015-2035) – which is 15 years post 18,400 22,000 adoption

Completions 3,400 3,211

Total Commitments 9,488 9,488

Non-Delivery Allowance (at least 10%) 948.8 948.8

Total Allocations 6,567 6,567

Total Supply 18,506 18,317.2

Residual homes to be identified -106.2 3,682.2

5.52. Therefore, on a best case scenario Avant Homes consider as a minimum there needs to be circa 3,682 new homes to be identified in the Plan to account for net completions, and economic growth.

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5.53. This does not account for the uplift required to ensure affordable housing need is met in full, which as indicated in paragraph 5.28, would lead to a requirement of 1,393 dpa and a plan requirement of 27,860. Based on the current supply of 3,211 completions, 9,488 commitments, an allowance for 10% non–implementation, and the currently proposed allocations of 6,567 homes, this would lead to need for a further 9,542 additional homes.

5.54. Significantly, the above scenario does not balance housing provision with the additional employment allocations. The additional employment allocations amount to 83.77 hectares above the requirement, this is the equivalent of an additional 3.5 years supply of land. As a result in order to balance the housing provision with the additional employment supply circa 3,850 additional homes would be required, this amounts to an annual requirement of 1,292.5 dpa. Avant Homes consider circa 7,532 additional homes are required in order to balance the Housing with Employment supply, account for net completions and appropriate non-implementation rates.

Avant Homes’ View

Employment requirement 2015-2035 481 hectares

Annual employment requirement 24 hectares

Employment land developed 2015-2018 117

Sites with planning permission Tables E1 to E8 284.09

New employment allocations Policy 4 164.68

Total Allocations 565.77

Amount of land allocated over the requirement 83.77

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Additional homes required to balance with 3,850 employment land supply

Residual homes to be identified 7,532.2

5.55. These figures assume no changes to the currently identified housing sites, which, in response to policy 3 and policy 6, Avant Homes have raised significant concerns, particularly with regards the deliverability, capacity, and delivery rates of some sites and the overreliance on existing permissions or longstanding allocations. This does not account for additional economic growth associated with the airport.

5.56. Furthermore, there does not appear to be any safeguarded sites or genuinely deliverable reserve sites identified within the Draft Plan. This is concerning given Policy 6 states that the Plan will designated Reserve Development Sites. However, it states that the reserves sites identified are not considered developable in the plan period. Paragraph 4.43 of the Plan indicates that the reserve sites have flood risk mitigation issues or safeguarding issues associated with HS2 preventing them from coming forward. Avant Homes would suggest, in order to assist with flexibility, that safeguarded sites be proposed in accordance with national guidance. The only other reserve site is related to direct job growth at the Airport and is strictly controlled, thus does not provide flexibility for the Plan as a whole.

5.57. The above scenarios do not include a detailed analysis of existing commitments and proposed allocations, however from a high level analysis it is evident that the Council’s trajectory and analysis of sites is optimistic.

5.58. Therefore, with an increased housing requirement, reduced potential from existing planning permissions sites and incorporation of a flexibility allowance, further land will need to be identified.

5.59. Avant Homes consider that the appropriate areas and sites to accommodate growth would be:

• Site 494: Green Lane, Scawthorpe, Doncaster

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• New Site: Melton Road, Newton, Doncaster

• HELAA Site (871): Wadworth Hill, Wadworth

5.60. A brief summary is provided for these sites in response to Policy 6. Technical information and an advocacy report for each site will submitted shortly. The Advocacy Report will show a masterplan and vision for the proposed scheme and illustrates the potential of the scheme. This report will be supported by significant technical information and the report will demonstrate that the sites are available, suitable and achievable and therefore deliverable in accordance with the Framework and PPG.

5.61. Avant homes consider that the policy in its current form is not justified and is not consistent with the Framework the Plan in its present form could fail to deliver sustainable development in accordance with policies in the Framework. In these circumstances, we do not consider the Doncaster Local Plan in its current form to be sound.

5.62. However, Avant Homes consider that with an appropriate uplift to the housing requirement, consideration of net completions, non-implementation rates and the allocation of additional land and safeguarded sites that the Local Plan can be found sound. Avant Homes will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

5.63. To overcome the objection and address soundness matters, the Council should:

• Increase housing requirement to 1,100 to 1,300 dwellings over the plan period.

• Reduce the potential from current commitments and include a non-delivery allowance.

• Identify safeguarded land.

• Allocate:

o Site 494: Green Lane, Scawthorpe, Doncaster

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o New Site: Melton Road, Newton, Doncaster

o HELAA Site (871): Wadworth Hill, Wadworth

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6. Policy 6: Housing Allocations (Strategic Policy)

6.1. Avant Homes objects to Policy 6 and the proposed distribution of housing and that the following sites are not proposed allocations:

• Site 494: Green Lane, Scawthorpe

• HELAA Site 1036: Melton Road, Newton

• HELAA Site (871): Wadworth Hill, Wadworth

6.2. These sites are summarised below and technical information and advocacy reports will be submitted shortly.

Test of Soundness

6.3. Avant Homes considers that the Local Plan is currently unsound.

Which test of soundness are comments about?

X Positively Prepared X Effective

X Justified X Consistency with National Policy

Justification

6.4. Avant Homes is concerned that the Local Plan is not producing sufficient homes across the Borough. Further to comments in relation to Policy 3 Avant Homes recommends that further sites are identified to meet and exceed the requirement but also to provide a sufficient buffer to deal with any under-delivery which is likely to occur from some sites. Such an approach would be consistent with the Framework requirements for the plan to be positively prepared and flexible.

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6.5. Avant Homes is concerned that the proposed distribution of new homes does not reflect the spatial strategy, but importantly does not address the focus for economic and housing growth across the Sheffield City Region and Yorkshire and Humber as a whole.

6.6. The proposed distribution against the Council’s own targets shows a deficiency and a significant under provision in:

• Doncaster • Adwick • Conisbrough – Denaby • Mexborough • Thorne – Moorends • Sprotbrough • Tickhill • Bawtry

6.7. Avant Homes, as explained in response to Policy 2 and the spatial strategy considers that the spatial strategy is incorrect, that it does not provide for the growth of the Borough and does not reflect the role, function and location of the settlements.

6.8. Avant Homes, as explained in response to Policy 2 and 3, considers that there needs to be further provision of housing and a slightly amended approach to the spatial strategy, which focusses growth towards Doncaster. There should be further growth of Rossington to address regeneration and the provision of new infrastructure. There should be growth in Thorne-Moorends, and a regeneration focus in Carcroft-Skellow which should elevate the status of the settlement commensurate to its role and function. New housing should be provided in Tickhill to address the current under provision. Wadworth should accommodate some new housing to reflect its role and function and provision should also be made in the villages to address the rural economy.

6.9. Avant Homes is particularly concerned that there is an under provision of housing in Doncaster, which the spatial distribution, established in policy 2, suggests should be accommodating at least 50% of new homes. This would equate to 9200 Homes based on the requirement of 18400. The total permissions and allocations in Doncaster equate to 7441 homes (not accounting for completions). This is significantly short of that requirement for Doncaster, further the main urban area is identified as the focus for economic and housing growth and should be accommodating more housing.

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6.10. Further Avant Homes are concerned about the deliverability of a number of allocations within the main urban areas. These include but are not limited to the following sites:

6.11. Further Avant Homes object to the allocation of site 838, which whilst benefiting from an extant permission the Residential Land Availability Report 2018 indicates that there are no completions on site and the site is not currently being developed. Further the council have been unable to produce any further deliverability information to support its inclusion within the Doncaster 5 Year Deliverable Housing Land Supply Statement. As a minimum the forecast contribution to the local plan should be reduced.

6.12. Avant Homes object to the allocation of site 843. Avant Homes consider that the delivery rates for this site are unrealistic based on performance at the site. The Residential Land Availability Report states that completions for the last year amounted to 39 dwellings. The local plan is suggesting a delivery rate of 70 dwellings per year. This is significantly over what has been achieved at this site or indeed other sites in Doncaster according to data in the residential land availability report.

6.13. Avant Homes object to the allocation of Site 984. Avant Homes consider that the delivery rates for this site are unrealistic. The Local Plan indicates that this is an outline permission. There are significant constraints, it is a brownfield site that is entirely within Flood Zone 3. However the Local Plan is assuming a delivery rate of 56 dwellings per annum in the first five years and 64 dwellings per annum in year 6-10. This is overly optimistic, and not consistent with the planning status, constraints and likely viability issues associated with site.

6.14. Based on the above it is clear that the deliverability and delivery rates of some of the sites in Doncaster ought to be reviewed to ensure that they reflect the site specific circumstances. Further allocations are required in Doncaster to ensure that the Plans strategy can be delivered.

6.15. As indicated in response to Policy 2 Avant Home are also concerned that the Plan does not provide sufficient support for development in Defined Villages. Avant Homes consider that in line with the provision of the Framework, paragraph 78, which is clear that to promote sustainable development in rural areas, ‘Housing should be located where it will enhance or maintain the vitality of rural communities. Planning Policies should identify opportunities for villages to grow and thrive, especially where this will support local services’.

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6.16. Furthermore, there does not appear to be any safeguarded sites identified within the Local Plan This is concerning given Policy 6 states that the Plan will designated Reserve Development Sites, yet those identified are not considered to be deliverable within the Plan Period due to significant constraints relating to flood risk and HS 2 Safeguarding, thus could not be relied on to maintain the supply of housing should other sites fail to deliver in the Plan period. As indicated in response to Policy 3 Avant Homes suggest, that safeguarded sites be proposed, to provide additional flexibility in accordance with national guidance.

6.17. Avant homes consider that the policy in its current form is not justified and is not consistent with the Framework the Plan in its present form could fail to deliver sustainable development in accordance with policies in the Framework. In these circumstances, we do not consider the Doncaster Local Plan in its current form to be sound.

6.18. However, Avant Homes consider that with the proposed allocations and the deletion or adjustment in anticipated delivery within the plan period of sites 838, 843, and 984 that the Local Plan can be found sound. Avant Homes will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

6.19. To overcome the objection and address soundness matters, the Council should

6.20. Avant Homes consider that the following sites should be deleted or the yield within the plan period should be significantly reduced:

• Site 838

• Site 843

• Site 984

6.21. To address the identified deficiencies in the Plan Avant Homes therefore suggest that the following sites be allocated:

• Site 494: Green Lane, Scawthorpe, Doncaster

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• HELAA Site (1036): Melton Road, Newton, Doncaster

• HELAA Site (871): Wadworth Hill, Wadworth

6.22. A short summary of these sites is in the following sub-section and advocacy reports for Green Lane and Melton Road, and a Delivery Statement for Wadworth are submitted alongside these representations.

Site 494: Green Lane, Scawthorpe, Doncaster

6.23. Avant Homes objects that Site 494 at Green Lane, Scawthorpe site is not allocated and should be identified as a housing site. Avant Homes object that the Council conclude that the site performs the same as other proposed housing allocations but that this site is not needed as “sufficient allocations are now identified”.

6.24. Avant Homes is particularly concerned that there is an under provision of housing in Doncaster, which the spatial distribution suggests should be accommodating at least 50% of new homes. Doncaster is currently short of that requirement, and as indicated above Avant Homes consider that the yield of a number of sites within Doncaster Main Urban Area have been significantly over estimated. Doncaster is the focus for economic and housing growth and should be accommodating more housing. This need cannot be met in other settlements.

6.25. The site at Green Lane, Scawthorpe is located on the western edge of Doncaster close to major employment opportunities along the A1(M). The site is therefore in a sustainable and appropriate location for housing growth. New housing should be located on the western side of Doncaster to ensure Doncaster maximises the economic growth potential of these major inward investors.

6.26. The Green Lane, Scawthorpe site should therefore be allocated to deliver housing in the short term. A robust Green Belt boundary can be created utilising Green Lane and the Roman Road along the western boundary. This is a distinctive and long term urban boundary. To the south of the site is the proposed Broad Axe Field housing allocation (Site 234)

6.27. The site can be accessed through Green Lane and the adjacent Broad Axe Field housing allocation.

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6.28. Avant Homes considers the proposed site is available, suitable and achievable and is therefore in accordance with the Framework a deliverable site able to come forward in the short term. Technical studies are ongoing but initial assessments demonstrate the site’s deliverability.

6.29. The deliverability and benefits of the Green Lane, Scawthorpe site are contained in the attached Advocacy Report:

HELAA Site 1036: Melton Road, Newton, Doncaster

6.30. Furthermore, with the significant under provision in Doncaster, Avant Homes suggests site at Melton Road, Newton as a proposed housing allocation.

6.31. Technical studies are ongoing but initial assessments demonstrate the site’s deliverability.

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6.32. Avant Homes considers the proposed housing allocation is available, suitable and achievable and is therefore in accordance with the Framework a deliverable site able to come forward in the short term.

6.33. The deliverability and benefits of the Melton Road, Newton site are contained in the attached advocacy report.

HELAA Site (871): Wadworth Hill, Wadworth

6.34. Avant Homes objects that no housing allocations are identified in Wadworth and that HELAA Site 871 has not been considered. Wadworth is a large village with services and facilities located close to the southern edge of Doncaster. The settlement can therefore accommodate some new housing and should also be positioned further up the

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settlement hierarchy. Furthermore, opportunities for growth at Tickhill from the Site Options currently considered appear limited with sites rejected due to site constraints. Tickhill and Wadworth are in relative close proximity and have good linkages and therefore the settlements work together. Wadworth is also well related to Doncaster Main Urban Area and the Main Urban Area is accessible via a range of sustainable transport modes. Notwithstanding that there should be allocations in smaller settlements which serve a wide hinterland. Particularly where this will enhance or maintain or enhance the vitality of rural communities. Paragraph 78 of the Framework indicates that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Avant Homes therefore proposes that their site at Wadworth Hill, Wadworth (HELAA Site 871) be allocated for housing.

6.35. Avant Homes considers the proposed housing allocation is available, suitable and achievable and is therefore in accordance with the Framework a deliverable site able to come forward in the short term.

6.36. The deliverability and benefits of the Wadworth Hill, Wadworth site are contained within the attached advocacy report and delivery statement submitted alongside these representations.

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Proposed Change

6.37. To overcome the objection and address soundness matters, the Council should:

• Allocate:

o Site 494: Green Lane, Scawthorpe, Doncaster

o New Site: Melton Road, Newton, Doncaster

o HELAA Site (871): Wadworth Hill, Wadworth

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7. Policy 8: Delivering the Necessary Range of Housing

7.1. Policy 8 seeks to ensure the right range, type, size and tenure of homes are delivered within Doncaster. Avant Homes is concerned with some aspects of this policy, and the robustness of the whole plan viability. Avant Homes therefore consider that the Policy 8 is unsound.

Test of Soundness

7.2. 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

7.3. Avant Homes is concerned with a number of approaches and criteria established within Policy 8.

Housing Mix

7.4. Avant Homes is supportive of the principle of providing a broad mix of housing. However the Local Plan should not dictate housing mix across the borough. The local Plan should achieve this housing mix through identifying the level of provision and the broad distribution of new housing.

7.5. Importantly there does not appear to be an up to date Strategic Housing Market Assessment with the Housing Needs Survey being dated 2015 with an update in 2016. The Economic Forecasts and Housing Needs Assessment does not consider housing mix. The Housing needs survey summary 2019 (ARC4) only appears to deal with the total affordable need and size of

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affordable dwellings, in terms of number of bedrooms. Therefore there is a lack of evidence base for this policy approach. It is acknowledged that Appendix 4 summarises the findings of the housing need survey 2019, however the full study is not publically available. Avant Homes reserve the right to comment further when this becomes available.

7.6. Although SHMA and Appendix 4 of the Plan, derived from the Housing Need Study 2019, considers the broad issues of housing mix, the Local Plan should not seek to control the housing mix, since it would mean that the market would be unable to adjust to changes in the market. Policy 8 seeks to specifically address the housing mix on sites. This aspect of the policy is onerous and prescriptive, particularly as it is seeking to control the size of units, mix and tenure. The policy should be amended to encourage or reflect, rather than require.

7.7. It is unclear from the Whole Plan Viability Study how the identified mix has been taken into account. An average size of dwelling of 92.90 has been assumed for the purposes of the testing. This appears to be based on a general assumption of 30% 2 bed dwellings 40 % 3 bed dwellings, and 30 % 4 bed dwellings. This does not align with the mix sought through the Local Plan, detailed in appendix 4 and derived from the housing needs study 2019.

7.8. Avant Homes recommend that a flexible approach is taken regarding housing mix, which recognises that the need and demand will vary from area to area and site to site, to ensure that the scheme is viable, and provides an appropriate mix for the location. There is a real need to create a housing market in Doncaster that will attract investors to Doncaster and provide an element of aspiration to ensure working people and families are retained within the area. The evidence presented in the plan is time limited, and only identifies current deficits. Avant Homes has been unable to review the full findings of the Housing Needs Study 2019, and reserves the right for further comment in this regard. However, Avant Homes considers that the mix required by policy 8 has not been appropriately tested in terms of viability and considers Policy 8 Part A to be unsound. The policy should be amended to encourage to reflect the identified mix rather than require it.

Affordable housing

7.9. Avant Homes is supportive of the need for affordable housing. The Framework is however clear that affordable housing policies must not only take account of need but also viability. Paragraph 34 of the Framework (2019) established the importance of viability to ensure that

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development identified in the Plan should not be subject to such a scale of obligations and policy burden that their ability to be delivered might be threatened.

7.10. The updated viability (2019), builds upon the earlier assessment and updates it in line with the emerging policies and the revised Framework. The assessment continues to identify three market value areas (low, medium and high) within Doncaster.

7.11. Tables 3-14 of the 2016 Viability Report show the issues of viability for a number of sites. It shows that the schemes in the low value areas were not able to support any level of affordable housing, whilst a number of schemes in the medium value areas would also struggle to provide the 15 percent required by this policy.

7.12. The 2016 Viability report previously concluded that sites located within high value areas are comfortably viable with the Councils proposed affordable housing provision of 25%, together with draft S106 policies. However for sites within medium to low value areas it was noted that the viability pressure was greater, and a reduced requirement should be adopted.

7.13. The 2019 Whole Plan Viability Study assesses the impact of the Plan requirements. Appendices 3 to 10 of the 2019 Whole Plan Viability Study demonstrate viability issues for a number of site typologies, including all typologies in low value areas. Typologies in low value areas were unviable when tested against the base assumptions. The study concluded that in high and medium value areas site typologies were comfortably viable. However, there are some circumstances were there are viability pressures in medium value areas, significantly the additional policy costs and sensitivities were tested against the study’s base assumptions which notably included 15% affordable housing and not 23% sought by Policy 8.

7.14. Avant Homes are concerned that there is little evidence to support an affordable housing target of 15% in low value areas. Avant Homes consider that further viability evidence is required to support the target of 23% in combination with the policy requirements of the plan, including, mix, housing design standards, and density. Further there is limited justification in the Plan or associated evidence for a target of 23% affordable housing. The explanatory text states that the current need for affordable housing represents 23% of the Local Plan requirement for housing. Paragraph 6.9 states that this does not take into account current completions or viability.

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7.15. Avant Homes is concerned that with all the policy requirements the Local Plan details this could undermine the provision of affordable housing through the need for a viability assessment of schemes on a regular basis. The viability assessment shows that a significant proportion of sites will not be able to achieve affordable housing due to viability matters. The Government is keen to avoid such a situation where viability assessments are being submitted regularly to vary planning policy obligations. The Council must be aware of the impact that viability assessments and subsequent negotiation of obligations can have on the delivery of development. This could impact on the delivery of the housing target. Instead, the Council should ensure this policy is appropriately tested to ensure the sites identified and allocated are deliverable.

7.16. The Council should be mindful that it is unrealistic to negotiate every site on a one by one basis because the base-line aspiration of a policy or combination of policies is set too high as this will jeopardise future housing delivery. Therefore, site by site negotiations on these sites should occur occasionally rather than routinely.

Adaptable and Accessible Homes

7.17. Part D of the policy states that new development should aim to include the provision of homes which are adaptable, accessible and suitable for people with a wide range of needs. Avant Homes supports the adaptation of the existing stock and encouraging the provision of adaptable, accessible homes. However, as explained in response to Policy 46 Avant Homes object and does not consider it appropriate to require all developments to include this provision.

Custom and Self Build Homes

7.18. Avant Homes understands the need and supports the delivery of Self-Build and Custom Build housing. Avant Homes understands the idea of increasing the self-build and custom build sector for its potential contribution to the overall housing supply.

7.19. Avant Homes consider that further evidence should be provided in respect of the level of demand in Doncaster for self and custom build and the nature of demand, including, whether those wanting to self-build would actually consider building within a larger housing development. As it stands paragraph 6.3 of the Plan provides very little explanation or evidence to support the policy.

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7.20. Avant Homes consider that the requirements in Policy 8 are not justified and do not provide an appropriate strategy. Avant Homes consider that Policy 8 along with other policy requirements within the Plan could threaten the deliverability of the Plan. 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.

7.21. In these circumstances, we do not consider the Doncaster Local Plan, in its current form, to be sound.

7.22. However, Avant Homes consider that with increased flexibility in Part A, revised affordable housing targets, and increased flexibility in the approach on custom and self build alongside robust evidence supporting the requirements the Local Plan can be found sound. Avant Homes will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

7.23. To overcome the objection and address soundness matters, the Council should:

• Policy 8 Part A should be amended to so that developers are encouraged to reflect the identified mix on schemes rather than require it”.

• Review the approach to affordable housing to ensure it reflects the new Framework (2019) and that the evidence base and viability approach is robust and credible.

• Include a flexible approach on accessible and adaptable homes and ensure the evidence base is robust and credible.

• Include a flexible approach on custom build and self-build homes and ensure the evidence base is robust and credible.

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8. Policy 19: Development affecting public rights of way

8.1. Avant Homes is concerned with aspects of Policy 19.

Test of Soundness

8.2. 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

8.3. Avant Homes is concerned with part D of the policy which states that “unrecorded routes or desire lines that cross development sites” will be treated in the same way as definitive public rights of way.

8.4. Avant Homes considers that such an approach on non-definitive footpaths is onerous and restrictive and could hinder the delivery of schemes. The effect of such a restrictive approach coupled with requirements for on-site open space, national space standards, requirements on mix and other policy standards, there could be implications for potential housing schemes and their delivery and the ability to achieve the housing requirement.

8.5. Avant Homes consider that the Policy as it stands is not justified and does not provide an appropriate strategy. In these circumstances, we do not consider the Doncaster Local Plan, in its current form, to be sound.

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8.6. Avant Homes consider that the policy with increased flexibility or removal of part D of Policy 19 it can be made sound. Avant Homes will continue to work with the Council to develop appropriate wording.

Proposed Change

8.7. To overcome the objection and address soundness matters, the Council should:

• Incorporate flexibility or remove part D of the policy.

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9. Policy 20: Access, design and layout of public rights of way

9.1. Avant Homes is concerned with aspects of Policy 20 and therefore consider that the Policy 20 is unsound.

Test of Soundness

9.2. 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

9.3. Avant Homes is concerned with parts B and C of the policy which specifies the routes and dimensions of public rights of way.

9.4. Avant Homes considers that such an approach is onerous and restrictive and could hinder the delivery of schemes. The requirements for public rights of way to avoid estate roads and where the path is enclosed to be of 3 to 5 metres is over engineered and beyond what is required.

9.5. The effect of such a restrictive approach coupled with requirements for on-site open space, national space standards, requirements on mix and other policy standards, there could be implications for potential housing schemes and their delivery and the ability to achieve the housing requirement.

9.6. Avant Homes consider that the policy in its present form is not justified and consider that the Plan is unsound.

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9.7. Avant Homes consider that the Plan with greater flexibility or the removal of the restrictive elements of Policy 20 the Plan can be made sound. Avant Homes will continue to work with the Council to develop appropriate wording.

Proposed Change

9.8. To overcome the objection and address soundness matters, the Council should:

• Incorporate flexibility or remove the restrictive elements in parts B and C of the policy.

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10. Policy 29: Open Space Provision in New Developments

10.1. Avant Homes is concerned that the level of new greenspace sought on sites will hinder the ability to deliver new housing efficiently and effectively, therefore consider that the Policy 29 is unsound.

Test of Soundness

10.2. 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

10.3. Avant Homes welcome the revision to the requirement in Part A of the policy which previously required 56sqm of open space per family dwelling. The requirement has been slightly reduced and now seeks between 10 and 15% of the site to be open space on schemes over 20 dwellings. The explanatory text indicates that 15% is required where there is an existing deficiency in open space. Avant Homes still consider that coupled with national space standards, requirements on mix and other policy standards, there could be implications for potential housing schemes and their delivery and the ability to achieve the housing requirement.

10.4. Part B of the policy requires that where sites are adjacent or close to a large open spaces as an alternative to on site open space, a commuted sum of 10 – 15% of the residential land value of the site should be provided. This is excessive, the commuted sum should be derived through consideration of specific local deficiencies in open space provision. The level of commuted

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sum could undermine the deliverability of the Plan and is not consistent with the principles of the Framework (paragraph 34). Nor is it consistent with the tests for planning obligations ( paragraph 56 of the Framework), which seek to ensure that planning obligations are necessary to make the development acceptable, directly related to the development and fairly and reasonably related in scale and kind to the development.

10.5. Policy 29 states that greenspace is required on site and that schemes will only be supported where the required open space is provided. However, this is inconsistent with Policy 66 and 67 which states that contributions will be sought and that viability assessments will be considered on a site specific approach stating that “the Council will take a pragmatic and flexible approach to planning obligations”.

10.6. Flexibility therefore needs to be incorporated into Policy 29, in particular part A and B which reflects Policy 66 and 67. The Local Plan at present is internally inconsistent and could undermine the delivery of housing.

10.7. The Plan is its present form is not justified and is not consistent with national policy. It is considered that the Plan could fail to deliver sustainable development in accordance with the policies in the Framework.

10.8. In these circumstances, we do not consider the Doncaster Local Plan, in its current form, to be sound.

10.9. However, we consider that with increased flexibility in line with policy 66 and 67 the Local Plan can be found sound. Avant Homes will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

10.10. To overcome the objection and address soundness matters, the Council should:

• Amend Policy 29 Parts A and B, and the associated explanatory text, specifically paragraphs 10.22 and 10.25, to include flexibility and encourage rather than require; and

• Reduce the level of commuted sum required so that it is consistent with the requirements of the Framework.

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11. Policy 39: Historic Parks and Gardens

11.1. Avant Homes objects to Policy 39 and its accompanying evidence base.

Test of Soundness

11.2. Avant Homes considers that the Local Plan is currently unsound.

Which test of soundness are comments about?

X Positively Prepared X Effective

X Justified X Consistency with National Policy

Justification

11.3. Avant Homes is concerned with the designation of sites of Local Historic Interest and that the designations do not match the historical connections. The evidence base and the policy approach therefore need to be thoroughly reviewed.

11.4. At Cusworth Hall the boundary of the Local Historic Interest expands beyond the Registered Park and Garden to land which is not associated with Cusworth Hall. It is clear from early historic Ordnance Survey maps and earlier cartographic sources that the proposed area of Local Historic Interest sits immediately outside the north eastern extent of the formal parkland of Cusworth Hall. Currently this area has a clear agricultural use with no formal historical connection to the parkland other than the western edge which follows the boundary of part of the Registered Historic Park and Garden.

11.5. The area therefore has no Local Historic Interest other than a limited visual connection which can be managed through other policies in the plan. The area of Local Historic Interest should therefore be reviewed.

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11.6. The Plan is its present form is not justified and is not consistent with national policy. It is considered that the Plan could fail to deliver sustainable development in accordance with the policies in the Framework.

11.7. In these circumstances, we do not consider the Doncaster Local Plan, in its current form, to be sound.

11.8. However, we consider that with increased the suggested amendments to the extent of the Cusworth Hall parks and Gardens of Local Historic Interest the Local Plan can be found sound. Avant Homes will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

11.9. To overcome the objection and address soundness matters, the Council should:

• Amend Cusworth Hall Local Historic Interest to remove the north eastern field.

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12. Policy 46: Housing Design Standards

12.1. Avant Homes is concerned with Policy 46 and consider that the Policy 46 is unsound.

Test of Soundness

12.2. 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

12.3. Avant Homes is concerned that part A of this policy is seeking to implement national space standards without the requisite justification and evidence.

12.4. This policy looks for development to meet national spaces standards as a minimum (for residential). The enhanced standards, as introduced by Government, are intended to be optional and can only be introduced where there is a clear need and they retain development viability. As such they were introduced on a ‘need to have’ rather than a ‘nice to have’ basis.

12.5. PPG (ID 56-020) identifies the type of evidence required to introduce such a policy. It states that ‘where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas.

12.6. Need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.

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12.7. Viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.

12.8. Timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions’.

12.9. Avant Homes welcomes the provision of new evidence on Housing Design Standards Policy. Avant Homes consider that standards can, in some instances, have a negative impact upon viability, increase affordability issues and reduce customer choice. In terms of choice some developers will provide entry level two, three and four-bedroom properties which may not meet the optional nationally described space standards but are required to ensure that those on lower incomes can afford a property which has their required number of bedrooms. The housebuilding industry knows its customers what type and size of housing is in demand. The use of Nationally Described Space Standards, can therefore impact on the delivery of affordable products, and can serve to stifle innovative design.

12.10. On NDSS Avant Homes would encourage the Council to recognise the larger land take such houses will require more land take. Therefore to deliver this would reduce the yield of sites and could have potential implications on the site yields identified by the Council on identified and allocated sites, ultimately resulting in the Council failing to meet their housing targets.

12.11. Avant Homes note that the viability assessment has applied an average house size which is stated to reflect NDSS, However Avant Homes note that the mix tested does not reflect the Policy 8 requirement. Further the viability demonstrates that site typologies in low value areas are unviable based on the base assumptions, and viability is worsened with addition of other planning requirements of the Local Plan, and in some circumstances some typologies in medium value areas were demonstrated to be unviable. The 23% affordable housing requirement has not been tested in combination with all the requirements of Policy 46, Avant Homes consider that there needs to be greater flexibility in Policy 46 with regards to the use of NDSS.

12.12. Avant Homes is also concerned that part B of this policy states that 65% of all new homes on housing developments of 10 or more units should be built to Part M4(2) of the Building

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Regulations i.e. accessible and adaptable dwellings. This is a significant increase in the requirement expressed in the earlier draft which required 30% of all housing to meet the standards of Building regulation requirement M4 (2).

12.13. Avant Homes is generally supportive of providing homes for older and disabled persons. However, if the Council wishes to adopt the higher optional standards for accessible and adaptable homes the Council should only do so by applying the criteria set out in the PPG. The SHMA, Economic Forecasts and Housing Needs Assessment and subsequent Housing Design Standards Policy Evidence paper unfortunately does not provide sufficient evidence and does not justify the Council’s position identified in the policy. The Housing Needs Assessment 2019, whilst referred to in the background paper and Local Plan was not available at the time of writing. Avant Homes reserve the right to comment further when this is made available.

12.14. It is important that if the Council are seeking the higher optional standards that the evidence is forthcoming. PPG (ID 56-07) identifies the type of evidence required to introduce such a policy, including the likely future need; the size, location, type and quality of dwellings needed; the accessibility and adaptability of the existing stock; how the needs vary across different housing tenures; and the overall viability.

12.15. The Written Ministerial Statement dated 25th March 2015 stated that:

12.16. The optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG.

12.17. NPPG states that where a local planning authority adopts a policy to provide enhanced accessibility or adaptability they should do so only by reference to requirement M4(2) and / or M4(3) of the optional requirements in the Building Regulations and should not impose any additional information requirements (for instance provision of furnished layouts) or seek to determine compliance with these requirements, which is the role of the Building Control Body. This is to ensure that all parties have the clarity and certainty of knowing which standards they have to deal with and can factor these into their plans. For developers, this ensures that the design and procurement complications that previously arose from a series of different standards in different areas are avoided. It was recognised that it was not appropriate to apply Category 2 or 3 standards to all new homes as not all people who buy or move in to

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new homes need or wish to have such provision. Category 2 and 3 standards were therefore made “optional” with the position being that the case for requiring such standards in future new homes should be made through the adoption of local plan policies that have properly assessed the level of requirement for these standards in the local area, also taking into account other relevant factors including the impact on project viability.

12.18. Avant Homes does not dispute the population is ageing. However, it is unclear how this ageing population and potential future need reflects in the need for 65 percent of all new homes on sites of 10 or more dwellings to be provided at M4(2) standards. The optional higher M4(2) standard should only be introduced on a “need to have” rather than a “nice to have” basis. Although there is evidence of an ageing population having regard to the PPG this does not amount to the justification required for the Council to include the optional standard as specified in Policy 46.

12.19. The Councils housing Design Standards Policy Evidence Paper evidences the ageing population, indicating that the percentage of over 65’s grows from 18.7% to 25%, Not all people over 65 will require a new home or adapted home. Indeed the paper recognises this in paragraph 2.53 where it states “not all of this demand will be met through new builds, and existing stock will play some part”. The paper notes considers the level of people with Limiting Long Term Illnesses or Disabilities and expects just less than 40% of households will have a person with a long term health problem or disability, the majority of people with a long term health problem or disability are over 65 (60%). Thus there is not sufficient evidence to support a requirement of 65% based on evidence of need.

12.20. It is important that the Council recognises the viability implications of requiring all houses to meet these enhanced standards. The whole plan viability evidence notes that all typologies in low value areas are unviable before the consideration of the impact of M4(2) and M4(3) standards, It also demonstrates that the application of M4(2) and M4(3) some typologies are unviable in medium value areas, when tested against a base assumption for affordable housing of 15% and not 23% as sought through Policy 8, Therefore, Avant Homes consider that this could result in stalled development where time is taken to debate viability issues. The Council must be mindful that it is unrealistic to negotiate every site on a one by one basis because the base-line aspiration of a policy or combination of policies is set too high as this will jeopardise future housing delivery. Avant Homes would urge the Council to reduce the percentage requirements to ensure the deliverability of any policy. The policy must not be set at such a

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scale that will threaten development to be in line with the Framework and guidance established in PPG.

12.21. Avant Homes consider that the requirements in Policy 46 are not justified and does not provide an appropriate strategy. The Plan is its present form could fail to deliver sustainable development in accordance with the policies in the Framework and is not consistent with national policy.

12.22. In these circumstances, we do not consider the Doncaster Local Plan, in its current form, to be sound.

12.23. However, Avant Homes consider that with increased flexibility in Part A in relation to NDSS, and a reduction of the target in part B to reflect evidence on need the Local Plan can be found sound. Avant Homes will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

12.24. To overcome the objection and address soundness matters, the Council should:

• Remove or increase the flexibility in part A of the policy which refers to national space standards

• Remove or significantly reduce the requirement in Part B of the policy which requires 65% of all new homes to be accessible and adaptable.

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13. Policy 66: Developer Contributions

13.1. Avant Homes is concerned with aspects of Policy 66.

Test of Soundness

13.2. Avant Homes considers that the Local Plan is unsound.

Which test of soundness are comments about?

X Positively Prepared X Effective

X Justified X Consistency with National Policy

Justification

13.3. Avant Homes is supportive of the need for developer contributions. The Framework is, however, clear that the derivation of developer contributions must not only take account of need but also viability. Paragraph 34 of the Framework (2019) established the importance of viability to ensure that development identified in the Plan should not be subject to such scale of obligations and policy burden that their ability to be delivered might be threatened.

13.4. Appendices 3-10 of the Viability Report show the issues of viability for a number of sites. It shows that the schemes in the low value areas were not able to support provision of 15% affordable housing. In some circumstances some site typologies in the medium value areas would also be unviable. The whole plan viability report concluded that generally schemes in high and medium value areas were demonstrated to be viable. However, it should be noted that this did not consider the cumulative/in combination impact of all of the policy requirements and assessed other Plan requirements against the delivery of 15% affordable housing and not 23% affordable housing as sought by Policy 8.

13.5. Avant Homes is concerned that with all the policy requirements the Local Plan details this could undermine the delivery of housing through the need for a viability assessment of schemes on a regular basis. The viability assessment shows that a significant proportion of

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sites will not be able to achieve affordable housing due to viability matters. The Government is keen to avoid such a situation where viability assessments are being submitted regularly to vary planning policy obligations. The Council must be aware of the impact that viability assessments and subsequent negotiation of obligations can have on the delivery of development. This could impact on the delivery of the housing target. Instead, the Council should ensure this policy is well tested to ensure the sites identified and allocated are deliverable.

13.6. The Council should be mindful that it is unrealistic to negotiate every site on a one by one basis because the base-line aspiration of a policy or combination of policies is set too high as this will jeopardise future housing delivery. Therefore, site by site negotiations on these sites should occur occasionally rather than routinely.

13.7. Avant Homes are concerned that the policy requirements of the Plan are not justified and are not consistent with the Framework.

13.8. In these circumstances, we do not consider the Doncaster Local Plan, in its current form, to be sound.

Proposed Change

13.9. To overcome the objection and address soundness matters, the Council should:

• Review and update the viability assessment and modify the policy requirements to reflect the findings and representations contained herein.

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14. Policy 67: Development Viability

14.1. Avant Homes is concerned with aspects of Policy 67.

Test of Soundness

14.2. Avant Homes considers that the Local Plan is unsound.

Which test of soundness are comments about?

X Positively Prepared X Effective

X Justified X Consistency with National Policy

Justification

14.3. Avant Homes is supportive of the need for developer contributions. The Framework is, however, clear that the derivation of developer contributions must not only take account of need but also viability. Paragraph 34 of the Framework (2018) established the importance of viability to ensure that development identified in the Plan should not be subject to such scale of obligations and policy burden that their ability to be delivered might be threatened.

14.4. Appendices 3-10 of the Viability Report (2019) show the issues of viability for a number of sites. It shows that the schemes in the low value areas were not able to support 15% affordable housing, prior to consideration of other policy requirements. In some circumstances schemes in the medium value areas would also struggle to provide the 15 percent required by this policy, when other policy requirements were considered. It should be noted that the Policy 8 requirement for affordable housing is 23% for high and medium value areas.

14.5. Avant Homes is concerned that with all the policy requirements the Local Plan details this could undermine the delivery of housing through the need for a viability assessment of schemes on a regular basis. The viability assessment shows that a significant proportion of sites will not be able to achieve affordable housing due to viability matters. The Government is keen to avoid such a situation where viability assessments are being submitted regularly to vary planning policy obligations. The Council must be aware of the impact that viability

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assessments and subsequent negotiation of obligations can have on the delivery of development. This could impact on the delivery of the housing target. Instead, the Council should ensure this policy is well tested to ensure the sites identified and allocated are deliverable.

14.6. The Council should be mindful that it is unrealistic to negotiate every site on a one by one basis because the base-line aspiration of a policy or combination of policies is set too high as this will jeopardise future housing delivery. Therefore, site by site negotiations on these sites should occur occasionally rather than routinely.

14.7. Furthermore, Avant Homes considers that there may be some circumstances where this policy and the use of trigger points in Part B can be utilised to bring forward the delivery of homes. However, Avant Homes have significant concerns around the implementation of this policy and how frequently it will be used. The use of trigger points could add further burdens to any developer who will need to reproduce viability assessments at a potentially regular basis, going against Government initiatives which are looking to reduce the need for viability assessments. Avant Homes considers that this policy causes unnecessary uncertainty and additional risk for developers, and therefore the policy could become an impediment to the development process and compromise the deliverability of large sites particularly those phased and implemented over long time periods.

14.8. Avant Homes are concerned that the whole plan viability does not fully consider the in combination impacts of the Plan requirements. It is also considered that Part B does not provide sufficient certainty. Avant Homes considers that the Plan is not justified and are not consistent with the Framework.

14.9. In these circumstances, we do not consider the Doncaster Local Plan, in its current form, to be sound.

14.10. Avant Homes consider that with increased flexibility in the Plan requirements and review of the viability assessment the Plan can be made sound. Avant Homes will continue to work with the Council to develop appropriate modifications.

Proposed Change

14.11. To overcome the objection and address soundness matters, the Council should:

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• Review and update the viability assessment.

• Provide clarity on Part B or remove.

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Appendix 1: Regeneris Report

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Review of Doncaster's Housing Requirement

A Draft Report by Hatch Regeneris 18 September 2019

Spawforths

Review of Doncaster's Housing Requirement

18 September 2019 www.hatchregeneris.com

Review of Doncaster's Housing Requirement

Contents Page

1. Introduction 1

2. Policy and Methodological Context 2

3. The Economic Performance of Doncaster 7

4. Our View of Need in Doncaster 10 Evidence base for current housing policy 10 Alternative assessments of housing need in Doncaster 11 What explains the difference between the assessments of need? 11 Conclusions 17

5. Summary of Key Points 19

Review of Doncaster's Housing Requirement

1. Introduction

1.1 Doncaster Council is consulting on the Publication Version of its Local Plan which will shape development in the borough between 2015 and 2035. Policy 3 of the Draft Plan states that at least 920 (net) new homes per annum will be delivered over the plan period (18,400 homes in total). 1.2 Hatch Regeneris has been appointed by Spawforths, on behalf of a consortia of housebuilders, developers and landowners to review the available evidence and provide advice on whether this level of provision will be sufficient to meet the needs of the future population and economy of Doncaster. 1.3 Hatch Regeneris are experts in assessing housing need and have prepared NPPF/PPG compliant evidence in over 50 local authority areas in England. 1.4 The report is structured as follows: • Section 2 reviews the current planning policy and guidance which sets out how housing need should be assessed • Section 3 reviews the recent economic performance of Doncaster to understand the potential for future growth. • Section 4 reviews recent housing need assessments undertaken for Doncaster and provides our conclusions on the level of housing required to support economic growth. • Section 5 summarises the key findings and conclusions.

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Review of Doncaster's Housing Requirement

2. Policy and Methodological Context

• Government is committed to delivering more housing and delivering economic growth. This is made clear in NPPF and in numerous other policy statements. • Rebalancing the UK economy is another central objective of government policy. Growing the economic prosperity of the North of England is a primary policy goal. • The revised NPPF and PPG has set out a standard method for determining the minimum level of housing that local planning authorities need to deliver. This removes the requirement to align housing policies with the future economic growth of an area. LPAs can still make an upward adjustment to support growth although this will now be discretionary. • Criticism of the new approach centres on the risk it will “lock” areas into a cycle of low inward migration and low housing delivery. There are also concerns that the standard method will work against the aim of narrowing the north-south divide by under- providing the housing required to support growth in northern economies.

Planning Policy

2.1 The revised National Planning Policy Framework (NPPF) was published in February 2019. This retains the three overarching objectives contributing to sustainable development from earlier versions; building a strong, responsive and competitive economy, supporting strong, vibrant and healthy communities and protecting and enhancing the environment. 2.2 The revised framework also retains the explicit and unambiguous target to significantly boost the supply of housing (para 59) but introduces a new standard method for determining the minimum number of homes needed in local areas (see below). The framework continues to highlight the importance that local planning authorities adopt policies which support economic growth in their area, stating “Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development” (para 80). It also states that planning policies should “seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment” (para 81).

Addressing the North-South Divide

2.3 The UK Government has also stated its intentions to address regional imbalances in the UK economy. The 2018 Industrial Strategy White Paper recognised that regional disparities in the UK are wider than in other western European nations and states that “many places are not reaching their full potential”. The strategy contains many measures orientated towards addressing regional disparities across broad areas like skills, transport and research and development.

2.4 The Government’s commitment to rebalancing the UK economy has been seen in policy measures, such as the establishment and strengthening of Metro Mayors across city regions, the opening of regional transport bodies like Transport for the North to link regional transport priorities with economic ones and committing funds, such as the £400m Northern Powerhouse Investment Fund. 2.5 The Northern Powerhouse Strategy was published in 2016. This set out the Government’s intention to continue developing the Northern Powerhouse. It outlines the Government's strategy to tackle productivity barriers and realise the full economic potential of the North

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of England, including investment in transport infrastructure, measures to raise skill levels and ensure the North is an excellent place to start a business. 2.6 In 2019, the new Prime Minister Boris Johnson showed his continued commitment to the Northern Powerhouse by confirming the Government will fund a new high speed, trans- Pennine rail line between Manchester and Leeds.

How should housing need be calculated?

2.7 As stated above, the new NPPF introduces a new simplified method for determining the minimum level of housing needed in an area, which replaces the previous method.

The previous method

2.8 Under the earlier planning framework and guidance, the objectively assessed need for housing was calculated using a three step process: • Establish the demographic starting point: plan-makers needed to use the latest available household projections to establish the baseline level of housing need. They could then make adjustments specific to their local circumstances based on alternative assumptions about demographic projections and household formation. • Consider whether an uplift was required to support employment growth: an adjustment to the starting point should be considered to ensure that sufficient housing is provided to meet the needs of the economy. This was based on an assessment of the projected labour supply compared to future jobs growth. • Consider whether an uplift is required to address market signals: a further adjustment should be applied if there is evidence of an imbalance between the demand for and supply of housing. Relevant indicators include house prices, rents affordability and overcrowding.

The new standard method

2.9 The new standard method for calculating local authorities’ housing need is based on a simple formula. This involves the following steps: • Step 1: Setting the baseline: the 2014 based household projections continue to be used as the demographic baseline for each local authority area1. This should be based on the average annual household growth over a 10 year period. • Step 2: An adjustment to take account of affordability: the baseline should be adjusted using a formula based on the affordability ratio (the ratio of median house prices to median earnings). For each 1 per cent increase in the affordability ratio above four, this would result in a quarter of a per cent increase in need above projected household growth.

1 Although more recent projections have now been published (the 2016 based projections prepared by ONS), these pointed to a much lower level of housing need across the UK. The revised PPG therefore states that “the 2014-based household projections are used within the standard method to provide stability for planning authorities and communities, ensure that historic under-delivery and declining affordability are reflected, and to be consistent with the Government’s objective of significantly boosting the supply of homes”.

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• Step 3: Capping the level of any increase: the standard method caps the level of any increase at 40%. For those authorities that have adopted their plan in the last five years, this cap is applied to the annual requirement figure in the local plan. For those that do not have an up-to-date local plan it is capped at 40% above whichever is higher of the projected household growth for their area over the plan period, or the annual housing requirement figure set out in their local plan. 2.10 The main change to the previous method is that local plan makers are no longer compelled to align their housing need figure with anticipated jobs growth. This would now be a discretionary policy decision for the local planning authority: “the standard method for assessing local housing need provides the 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 actual housing need may be higher than the figure identified by the standard method.” (paragraph 10). 2.11 Based on the standard method, the minimum housing need for Doncaster is 563 dpa. Although Doncaster is free to set a higher number which may be based on expected future jobs growth.

Response from Housebuilding Industry

2.12 Since the standard method was first proposed, a number of stakeholders from the planning or housebuilding industry have raised concerns about the changes. The key points are summarised below.

Removing the link between housing need and economic growth could stifle growth in some areas and widen regional disparities in economic performance

2.13 The main concern amongst stakeholders from the development industry was that removing the need to consider future jobs growth from the housing need assessment will result in housing policies that constrain economic growth. This is a particular risk in large areas of the north of England and the midlands where housing is more affordable than London and the south east, but which face major labour market challenges as a result of an ageing population. 2.14 In these areas, new housing is needed to address labour shortages, regenerate former industrial areas and to support the Government’s aspirations to rebalance the economy away from the overheating south east. A number of responses raised concerns that the standard method will work against these aims:

• “the failure of the methodology to factor economic growth into Objectively Assessed Needs calculations subsequently leads to a significant suppression of housing growth across the North of England which would stifle current economic growth” – Johnson & Mowat on behalf of the Leeds City Region Developers Consortium

• “the proposed methodology is inconsistent with the Government’s aim to boost growth in the Northern Powerhouse and Midlands Growth Engine, stifling growth in these areas.” – Bidwells

• “the draft methodology… will boost the housing requirement in the South and East, while depressing it in the North. We believe this contradicts wider economic policies such as the industrial strategy and Northern Powerhouse which aim to rebalance the UK economy”. – Northern Housing Consortium

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• “the outcome of the new approach will be additional housing growth pressure on London and the greater south east, and continuing limitations on the contribution that housing growth could make to rebalancing England’s economy” – Regeneris

• “We believe that if the methodology is introduced in its current form it could seriously damage some areas of the UK, especially northern cities such as Leeds and Manchester… In order for the methodology to work outside of London there needs to be some level of account taken for future growth projections” – British Property Federation • “There is the possibility that growth objectives of many northern towns and cities will be undermined, with implications for the Northern Powerhouse”. Indigo Planning • “There are flaws that, if left unchecked, could lead to less housing being built in some areas and a widening of the North-South divide – the opposite of the Government’s intentions. Unless authorities are progressive in their thinking and understand the link between housing and the economy, the methodology could have dire consequences, not only for economic growth but also their regeneration ambitions and affordability” – White Young Green (WYG) • “Action will need to be taken to ensure that the relatively lower levels of need in the north of England do not undermine future economic well-being” - Lichfields

There is a risk of carrying forward past constraints

2.15 Household forecasts are based on recent population trends and household formation rates which are both influenced by past rates of housing delivery, affordability and economic trends. By relying on the 2014 based household projections for the demographic baseline, there is therefore a risk that past underperformance caused by economic conditions or a failure to meet housing targets are projected forward under the new method.

2.16 This leads the BPF to warn that the methodology risks “locking in recessionary trends across much of the north and Midlands”. WYG state: “It fails to recognise that areas that have previously delivered low levels of housing growth will effectively be given a mandate to continue doing so. Similarly, areas of higher growth are more likely to see a continuation of this trend. This is because, as recognised in the PPG, the household projections are based on past demographic trends and household formation rates. If migration has been constrained by supply, this constraint will be projected into the future. The uplift is unlikely to adequately compensate for this”.

There is a risk that housing and employment land policies are not joined up

2.17 The previous approach set out in PPG encouraged plan makers to consider housing and economic development needs alongside one another and to use consistent assumptions about jobs growth. 2.18 In contrast the proposed approach, which no longer requires any consideration of economic trends, means some councils may adopt housing and economic development policies which are inconsistent or in direct conflict with one another. The BPF argue that “this undermines a plan-led approach whereby you plan to meet housing and economic needs together, rather than planning for one and letting the other fall behind”.

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Implications for this review

2.19 The standard method provides the statutory methodology for determining the minimum level of housing that Doncaster should provide over the plan period. This is calculated as being 563 dpa. This review does not question this figure. 2.20 However, as stated above, Doncaster is free to identify a higher number to support economic growth. The focus of this review is on identifying what this higher number should be. Although this is no longer a statutory requirement, it is still important that Doncaster’s housing target is aligned with other policies to support economic growth in the draft Local Plan (eg its employment land provision) and that it addresses some of the potential barriers to future growth, such as its ageing population.

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3. The Economic Performance of Doncaster

• Doncaster has the fastest growing economy in Yorkshire and Humber and one of the fastest growing in the north of England. The district has created around 24,000 jobs between 2000 and 2017, representing a growth rate of 1.1% p.a. • Doncaster’s key asset is its connectivity by road, rail and air which has made it a highly attractive location for inward investment, particularly for industrial and logistics occupiers, with over 1.2m sq m of industrial/warehouse space taken up since 2010. • The strong performance is also due to a significant improvement in key economic indicators, including skills and rates of enterprise. The business start-up rate has more than doubled since 2010 and is now in line with the national average. These improvements have removed a key barrier to growth and mean that Doncaster is well placed to continue its high rate of growth. • The draft Local Plan has set a target of delivering 481 hectares of employment land between 2015 and 2035 and the 2018 ELR and 2019 update shows there continues to be very strong market demand for industrial space in Doncaster. There is therefore strong potential for Doncaster to accommodate high levels of inward investment in future which would also drive jobs growth.

3.1 Doncaster is one of the fastest growing economies in the north of England. Real Gross Value Added (GVA)2 increased at a rate of 2.5% p.a. between 2000 and 2017, which is significantly higher than the national and regional average (1.7% p.a. and 1.4% p.a. respectively) and higher than any other district in Yorkshire and Humber (see Figure 3.1). Figure 3.1 Annual average growth rate in Gross Value Added for local authorities in Yorkshire and Humber (2000 to 2017, 2016 prices)

Source Nominal and real regional gross value added (balanced) by industry, Office for National Statistics

2 GVA is the measure of the value of goods and services produced in an area, industry or sector of an economy

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3.2 This growth has driven increased demand for labour in Doncaster, creating around 24,000 new jobs between 2000 and 2017. Figure 3.1 shows that the rate of jobs growth in Doncaster has matched the national average and outperformed the average for Y&H. This has been driven by a number of sectors including logistics, retail, professional and business services and the public sector. Figure 3.2 Employment change index, 2000-2017 (2000=100)

Source Jobs density data, Nomis

3.3 Table 3.1 shows how this translates to average annual growth rates over different time periods. Over each time period, Doncaster has achieved a minimum annual growth rate of 0.8% p.a. Average annual growth was lower over the ten-year period because it is skewed by the economic downturn which occurred between 2008 and 2011.

Table 3.1 Jobs growth rates over different time periods Doncaster Y&H GB 5 year (2012-2017) 2.8% 2.1% 2.1% 10 year (2007-2017) 0.8% 0.8% 1.2% 15 year (2007-2017) 1.1% 0.8% 1.1% Source: Jobs density data, Nomis

3.4 Doncaster’s strong performance has been driven by a number of factors. The borough has excellent connectivity across a number of modes of transport, including road, rail and air, which has made it a highly attractive location for inward investment. 3.5 Doncaster has also been extremely successful in addressing some of the challenges which have acted as a constraint on growth in the past. Figure 3.2 shows how the business start- up rate, measuring levels of enterprise in Doncaster, has risen from four new businesses per 1,000 working age people in 2010 to over 10 businesses in 2016. Doncaster’s residents now display levels of enterprise in line with the national average and well above the average for Yorkshire. Doncaster has also seen a significant improvement in the skills

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of its workforce, particularly among younger residents. The Annual Population Survey shows that the proportion of people with no qualifications (a key barrier to growth) fell from over 15% in 2010 to just 9% in 2018, bringing it in line with the average for Yorkshire and much closer to the national average. Figure 3.3 Business start up rate, 2010-2016

Source ONS Business Demography and mid-year population estimates

3.6 The strong performance of Doncaster is due in part to the actions taken as part of the Doncaster Economic Growth Plan. This outlined a number of measures to promote new business and improve skills. Policies to support start-ups included access to start-up advisors and mentors with established local businesses. Skills measures included an apprenticeships programme and improved careers advice and guidance. 3.7 The improvement in its skills and business base led to Doncaster being recognised as one of the fastest improving cities in PWC’s Good Growth for Cities Index. As key drivers of productivity and economic performance these improvements have also addressed barriers to growth and positioned Doncaster to achieve high levels of growth in the future. 3.8 The Economic Growth Plan also outlined measures to increase inward investment by improving response times to planning decisions and increasing the stock of modern industrial and office premises. Analysis of take-up of new business floorspace shows that Doncaster is a highly attractive location for investors, particularly for industrial and distribution occupiers. Over 1.2m sq m of industrial space has been taken up since 2010, representing 37% of gross take-up in South Yorkshire (despite only accounting for 20% of its population). This is therefore a key source of competitive advantage for Doncaster. 3.9 The draft Local Plan seeks to build on this competitive advantage by setting a target of delivering 481 hectares of employment land over the plan period (2015 to 2035). The 2018 Employment Land Review and 2019 update also provide market evidence that new industrial and logistics space is in high demand and viable to deliver. 3.10 In summary, there are a number of grounds to be optimistic for the future growth of Doncaster. The district’s strong record of jobs growth, significant improvement in key economic indicators and large supply of high quality sites for inward investment all mean Doncaster is well positioned to achieve high levels of growth over the plan period

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4. Our View of Need in Doncaster

• The Publication Local Plan sets a target of delivering 920 dpa between 2015 and 2032. The target delivers the minimum level of housing need for Doncaster based on the standard method (585 dpa) and makes an upward adjustment to support economic growth. • The upward adjustment was based on evidence produced by PBA which recommended housing need is presented as a range between 585 dpa (the minimum) and 912 dpa. The upper limit was based on matching the jobs growth aspirations of the Sheffield City Region LEP (1,420 jobs per annum) over the period 2016 to 2026. The Council has adopted a figure slightly above this range. • Lichfields has produced an alternative assessment of housing need as part of a planning appeal in Doncaster. This assumes a lower rate of jobs growth (741 to 1,182 jobs per annum) but arrives at a much higher level of housing need (1,370 dpa). • We conclude that PBA has made unjustified and unrealistic assumptions for a number of factors which all suppress the level of housing required to support future employment growth. In particular, we disagree with their assumptions about commuting, double jobbing and household formation rates. • We also disagree with a number of the assumptions made by Lichfields and conclude that they overestimate the housing needed to support the level of growth in their scenarios. • We conclude that Doncaster would need to deliver between 1,000 and 1,100 dpa between 2015 and 2032 to support future economic growth. This is based on our review of the assumptions made in the two reports and our professional judgement but would need to be tested through a detailed modelling exercise. • In summary, the housing target of 920 dpa meets the minimum level of housing required as set out in the standard method but would risk constraining the future economic growth of Doncaster. For this reason we strongly recommend that the Council considers making a further upward adjustment.

Evidence base for current housing policy 4.1 The housing target of 920 dpa is based on evidence produced by Peter Brett Associates (PBA) in its report Economic Forecasts and Housing Needs Assessment (June 2018). This report presents a number of demographic and economy-led scenarios to estimate the housing required in Doncaster over the plan period. This assessment drew heavily on economic modelling and assumptions developed by Experian in their local economic forecasting model. We therefore refer to this assessment as the PBA/Experian report. 4.2 The report recommends housing need is presented as a range between 585 dpa and 912 dpa (the Council has adopted a figure slightly above this range). This is based on the following: • 585 dpa is the minimum level of housing required in Doncaster based on the standard method. This is based on the 2014 household projections (using the 2016 based projections reduces this to 572). • 912 dpa is the level of housing that PBA estimate is required to meet the jobs growth aspirations of the Sheffield City Region. This is based on the period 2016 to 2026,

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which is different to the plan period (2015 to 2035) but aligns with the time period used in the standard method. Alternative assessments of housing need in Doncaster 4.3 We have also reviewed an alternative assessment of housing need in Doncaster. This was based on the Proof of Evidence of Fiona Braithwaite (Lichfields) for a planning appeal in Doncaster on behalf of Faith Homes3. We refer to this as the Lichfields report. This assessment was undertaken in line with the previous methodology for objective assessments of need (ie prior to the introduction of the standard method). However the scope of this assessment was similar to the PBA/Experian report in that it sought to determine the level of housing required to support economic growth in Doncaster. 4.4 The assessment tested a wide range of different demographic and economic scenarios to determine housing need. It concluded that a range of 1,200 dpa to 1,541 dpa “provides the most reliable indicator of future housing need within Doncaster” over the period 2015 to 2032. It therefore arrived at a range where the minimum level of need was some 288 dpa higher than the maximum identified by PBA over the same time period. What explains the difference between the assessments of need? 4.5 We have critically reviewed both of the reports and their underpinning assumptions to understand the reasons why their estimates of housing need are so different. We use this analysis to reach conclusions on the level of housing required to support future jobs growth in Doncaster. This section looks at each of the key assumptions in turn.

Jobs growth assumptions

4.6 PBA/Experian run two jobs-led scenarios: • Experian Baseline (Dec 2017): based on average growth of 830 jobs per annum • Policy led: this assumes average growth of 1,420 jobs per annum and is based on the jobs growth targets in the emerging Strategic Economic Plan (SEP) for the Sheffield City Region (SCR). 4.7 PBA conclude that the policy-led scenario should not be used to calculate the objectively assessed need under the previous planning framework and guidance. This is because “the OAN should be based on a realistic expectation of future jobs rather than aspiration, and the Guidance specifies that the aspirations of Strategic Economic Plans should not be treated as part of the development plan”. It goes on to state that “the policy led scenario is recognised as ambitious and hence the jobs growth and housing demand that it predicts may not materialise” and recommends that the Council adopt a lower number, halfway between the baseline and policy-led scenarios. 4.8 Lichfields run a large number of jobs-led scenarios but the preferred scenarios (those used to identify the OAN) are: • Experian Baseline (Jan 2017): based on average growth of 741 jobs per annum

3 Land off Westminster Drive, Dunsville, Doncaster. Prrof of Evidence of Fiona Braithwaite Planning Inspectorate No. Appeal AAP/F4410/W/16/3158500

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• Policy led: this assumes average growth of 1,182 jobs per annum. This is also based on SCR’s jobs growth target, however it is based on an earlier target to PBA/Experian’s policy-led scenario. 4.9 This means that PBA/Experian assume a higher level of jobs growth than Lichfields but arrive at a lower housing need figure. Therefore the jobs growth assumptions do not explain the large difference in the conclusions about the level of housing need. 4.10 While we agree with PBA that the objectively assessed need for housing should not be based on unfounded policy aspirations, we disagree that jobs growth of 1,420 jobs per annum is an unrealistic level of growth. This level of growth is based on employment growing at a rate of 1% p.a. which is in line with the long term average growth rate in Doncaster (see Table 3.1). 4.11 Furthermore, this rate of growth is consistent with the Local Plan target of delivering 481 hectares of employment land over the plan period 2015 to 2035. This target is based on Doncaster achieving a jobs growth rate of 1% p.a. over the plan period and the Local Plan states that this is a realistic and evidence based target: “It is considered therefore that there is sufficient previous evidence of investment, land development and analysis on (sic) the Doncaster Employment Land Review (2018) (Colliers) that enough land should be allocated for a 1% jobs growth”. 4.12 We therefore conclude that a growth rate of 1,420 jobs per annum represents a sound basis for planning housing. This is consistent with past trends and would ensure a greater alignment with the Council’s employment land policies.

Economic activity rates

4.13 The key factor explaining the difference between PBA’s and Lichfields’ assessment of housing need is their assumptions about economic activity rates; the proportion of Doncaster’s population who are either in work (employed) or seeking work (unemployed). The level of housing need is highly sensitive to the assumed change in economic activity rates in a jobs-led scenario because it determines what proportion of future jobs growth could be taken by local Doncaster residents. If the proportion of people who are economically active is flat or falling, then it implies that a larger share of future jobs growth will need to be taken by in-migrants, which increases demand for housing. 4.14 Lichfields and PBA have used different sources for their assumptions on future change in economic activity rates: • Lichfields align their assumptions with the Office for Budget Responsibility (OBR)’s 2017 projections of economic activity rates for the UK, which they then rebase to take in to account the current conditions in Doncaster. The same assumptions are applied in all of the jobs-led scenarios. • PBA use the assumptions which are built in to Experian’s model for local economic forecasting. The assumptions made about economic activity are more dynamic in that they respond to changes in the economy (eg if demand for labour grows then economic activity rates increase in response) 4.15 When applied to the same 2014 based sub-national population projections, the two sets of assumptions result in two very different projections of future change in the labour supply. PBA/Experian forecast an increase of 5,000 resident workers, while Lichfields forecast a fall of 1,400. The difference between these two (6,400 workers) helps to explain why they arrive at such different conclusions about the need for housing. In Lichfields’ scenarios the shortfall of local workers means that Doncaster needs to attract in-migrants to support jobs growth.

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Table 4.1 Projected Change in Labour Supply in Doncaster based on 2014 Sub-national Population Projections 2015 to 2032 2015 2032 Change Peter Brett Associates 148,200 153,200 +5,000 Lichfields 148,700 147,300 -1,400 PBA numbers from Table 2.1 in Economic Forecasts and Housing Needs Assessment, July 2018. Lichfields numbers from Land off Westminster Drive, Dunsville, Doncaster, Appendices to the Proof of Evidence of Fiona Braithwaite, Appendix 7: Modelling Outputs, Scenario A1: 2014 Baseline

4.16 The main difference between the two assessments relates to the assumptions made about the economic activity rates of 16 to 64 year olds • Lichfields use the evidence from OBR to apply assumed change in economic activity rates for five year age groups. The net effect of these changes is a slight increase in the economic activity rate from 74.6% to 75.5%4. • In contrast, PBA/Experian assume the economic activity rate for 16 to 64 year olds increases at a much faster rate. The scale of the increase is different in each of the scenarios but ranges from a 5.3 percentage point increase in the baseline demographic scenario (based on SNPP 2014) to 5.6 percentage points in the jobs- led scenario. 4.17 The scale of the increase is enough to offset Doncaster’s declining working age population and increase the size of the workforce over the plan period. 4.18 While we would normally support the assumptions used by Lichfields, analysis of recent data on economic activity rates show that PBA/Experian’s assumptions are justified. Although economic activity rates have fluctuated over time, the long term trend shows that economic activity rates have been increasing by around 0.4 percentage points per annum which is consistent with PBA’s assumptions.

Workers with more than one job

4.19 Neither the Lichfields nor the PBA/Experian reports explain their assumptions about the proportion of workers with more than one job. However this can have a significant effect on the level of housing need. If it is assumed that the proportion of workers with more than one job increases over time, it implies a smaller number of workers are required to support jobs growth than if the rate remains constant. This reduces the level of in-migration which in turn supresses the demand for housing. 4.20 Although PBA/Experian do not address the issue of “double jobbing” in their report, they do implicitly assume that the rate will increase from 3.6% to around 6% in each of their scenarios based on the ratio of ‘Workplace Jobs’ to ‘Workplace based Employment’. This has a significant effect on the number of people required to fill jobs; if they assumed that the rate remains constant then Doncaster would need to find an additional 3,300 people in the baseline scenario and an additional 3,400 people in the policy-led scenario. Assuming that these additional people could not be attracted through increased in-commuting (since that would be depriving neighbouring areas of workers), the shortfall would need to be addressed by increased in-migration to Doncaster which would increase demand for housing.

4 This is approximate. The Lichfields assessment states that OBR 2017 rates have been used and rebased to Doncaster using data from the Census and Annual Population Survey. However they do not present the calculations, the specific assumptions which have been applied for different age groups and genders in Doncaster or how this translates to an overall economic activity rate for 16 to 64 year olds. We have tried to recreate Lichfield’s calculations and arrived at a broadly similar result as them.

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Table 4.2 PBA/Experian assumptions for double-jobbing 2015 Baseline Policy-led Scenario 2032 scenario 2032 Workforce Jobs 134,000 147,800 160,600 Workplace based Employment 129,300 139,400 151,600 % of workers with more than 3.6% 6.0% 5.9% one job 4.21 The source of PBA/Experian’s assumption on double jobbing is not clear, nor is it justified. APS data shows that around 3% of people in employment in Doncaster in 2015 had more than one job. However there is no evidence that this is increasing over time. Figure 4.2 shows the change in the double-jobbing rate for Doncaster and Yorkshire and Humber (this is included because the margins of error are much lower at regional level). This shows that the rate has fluctuated over time but has only risen above 3% on a small number of occasions. The data for Yorkshire is more consistent but shows that the double jobbing rate has consistently been between 3% and 4%. At no point has it got close to 6%. Figure 4.1 Percentage of residents with more than one job

Source APS

4.22 Lichfields do not state their assumptions about double-jobbing. However it appears from their modelling outputs in Appendix 7 that they assume each new job will require one worker; effectively assuming a double jobbing rate of zero. This is also incorrect as the evidence above shows. A more reasonable assumption would be that the double jobbing rate is set at around 3% and then held constant for the duration of the plan period.

Commuting

4.23 The assumptions made about commuting can also have a significant effect on the estimated population and housing required to support future jobs growth. For example, if it is assumed that the net balance of out-commuters and in-commuters declines (sometimes referred to as “reclaiming commuters”), it means a larger number of new jobs can be filled from the local labour market, which reduces the need to attract in-migrants. 4.24 The two assessments for Doncaster make the following assumptions:

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• Lichfields assume that the commuting ratio (the ratio of employed residents to workforce jobs located in Doncaster) remains constant throughout the plan period. They do not state what the ratio is, but based on the data sources used it appears they have assumed a ratio of 0.99. This would mean that Doncaster is a net importer of commuters although only by a very small margin. • PBA/Experian use the assumptions built in to Experian’s local economic forecasting model. It is not explained how commuting is calculated, however we assume this is essentially a balancing item which goes up and down based on forecast demand and supply in Doncaster and neighbouring areas. Their model shows that Doncaster’s commuting balance is negative, indicating that more people commute out than commute in. This is the reverse of Lichfields’ assumption which is explained by the fact that Experian apply an additional assumption about double jobbing, which means the number of people working in Doncaster is lower than the number of jobs. In both of the scenarios it is assumed that the net outflow of commuters will fall, which means there are more workers available to fill jobs created in Doncaster. 4.25 These different assumptions provide another reason for the large differences between PBA’s and Lichfields’ housing need results. By making the assumption that Doncaster will reclaim commuters, the estimated number of additional people required to meet jobs growth is reduced. We estimate that if the commuting ratio was kept constant, Doncaster would need to find an additional 2,700 employed residents to fill jobs in the baseline scenario and an additional 3,200 employed residents in the policy led scenario. 4.26 PBA explain the change in commuting patterns by stating that “this results from the tightening labour market”. In other words local demand for labour increases relative to local supply. However, commuting patterns are not just dependent on labour market conditions in Doncaster. They also depend on conditions in neighbouring areas. The complex range of factors which could influence commuting patterns (eg demographic change, jobs growth etc in multiple areas) means it is very difficult to predict how they will change in future. By assuming that the net outflow from Doncaster reduces, the model is essentially depriving neighbouring areas of workers by reducing a source of labour supply. 4.27 Guidance issued by the Planning Advisory Service (drafted by PBA itself) warns against making these sorts of assumptions unless they have been agreed with the neighbouring authorities that it affects: ““Another risky approach is to plan for recalling commuters, so the ratio of workplace jobs to resident workers – and hence to population and number of dwellings – is assumed to rise over the plan period. Like increasing activity rates, this assumption means that more jobs can be accommodated for a given number of dwellings, or a given number of jobs needs fewer dwellings. But the expected shift in commuting should be believable, and acceptable to the other local authorities affected by it. Strategies of recalling commuters should not be adopted unilaterally; they require cross-boundary agreement in line with the Duty to Cooperate.” 4.28 PBA could argue that their assumptions about commuting are internally consistent with Experian’s local economic forecasting model and its calculations about the commuting balance between different authorities. However these assumptions have not been agreed with neighbouring authorities. In fact there is evidence that they are inconsistent with some neighbouring authorities’ assumptions about commuting in their own housing need assessments. For example in Barnsley, which shares strong commuting links with Doncaster5, the OAN assumed a reduction in out-commuting down to 2001 levels. PBA

5 The 2011 Census showed that around 3,100 residents of Barnsley commuted to work in Doncaster, making it the third largest source of external labour for Doncaster (after Rotherham and Bassetlaw)

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was highly critical of this assumption stating “setting aside the practicality of recalling these workers that are likely to be in employment elsewhere in the region, the approach is based on the notion that another Council must increase its housing by an equal number to offset this return of commuters to Barnsley”. 4.29 This means that the housing need models in two neighbouring authorities are both based on the assumption that they will be able to reclaim commuters. If this pattern was repeated across South Yorkshire, it would result in housing policies which cause an undersupply of labour relative to the needs of the economy. For this reason we believe the assumptions are unjustified.

Household Formation Rates

4.30 A further factor explaining the difference in results is in the assumptions made for household formation (the probability that a person of a given age/gender will form a household). Both Lichfields and PBA apply the household formation rates underpinning the 2014 based household projections developed by CLG. However Lichfields apply an additional sensitivity test which assumes that household formation rates for 15 to 34 year olds partially catch up to earlier household formations forecasts produced in 2008. The justification for this is that there is some evidence that household formation among younger age groups have been suppressed by the economic downturn, stricter lending requirements and the poor affordability of housing in some parts of the country. This adjustment increases the average housing requirement by between 60 and 80 dwellings per annum in the two “preferred” scenarios. 4.31 We believe an upward adjustment to household formation rates for younger people in Doncaster is justified. However we disagree with the method used by Lichfields which assumes a partial catch up to household formation rates used in the 2008 projections (now ten years out of date). A more reasonable adjustment would be that they continue on the trajectory forecast in the 2014 household projections between 2015 and 2024 rather than falling again after this date. By the end of the plan period this would mean the household formation rate is around 46.7% rather than 45.2%. We estimate this would increase the number of households by around 40 per annum in PBA’s baseline demographic scenario and 60 per annum in the policy-led scenario.

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Figure 4.2 Household Formation Rates for 25 to 34 year olds

Source CLG 2014 Household Projections

Timescale

4.32 The final reason why we consider PBA’s housing need estimate to be too low to support economic growth is the time period used. Paragraph 4.29 of the report presents two estimates of housing need for the policy-led scenario based on different time periods: • For the plan period 2015-32: 1,073 dpa • For 2016-26, the assessment period used in the new standard method: 912 dpa. 4.33 They explain the main reason for the difference is that the gap between labour demand (jobs growth) and labour supply (due to change in population and economic activity) gets larger over time. So the longer the forecast period the greater is the need to attract new workers to Doncaster. 4.34 PBA use the lower figure because it aligns with the ten year period used in the standard method. However there is no reason why these two should align. Given that the housing target will apply throughout the plan period adopting the lower figure risks labour supply becoming increasingly out of step with labour demand. Conclusions 4.35 We have identified flaws in a number of assumptions used by PBA/Experian and Lichfields. In the case of PBA/Experian, these have all suppressed the level of housing required to support future economic growth. We also disagree with a number of the assumptions made by Lichfields and conclude that they overestimate the housing needed to support the level of growth in their scenarios. 4.36 Based on the above, we conclude that Doncaster would need to deliver in the region of 1,100 dpa between 2015 and 2032 to support future economic growth. This lies between the two estimates made by PBA/Experian and Lichfields. This is based on our review of the assumptions made in the two reports and our professional judgement but would need to be tested through a detailed modelling exercise.

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4.37 In summary, the housing target of 920 dpa meets the minimum level of housing required as set out in the standard method but would risk constraining the future economic growth of Doncaster. For this reason we strongly recommend that the Council considers making a further upward adjustment.

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Review of Doncaster's Housing Requirement

5. Summary of Key Points

5.1 Doncaster Borough Council is consulting on its Draft Local Plan which will shape development in the borough between 2015 and 2032. Hatch Regeneris has been appointed by Spawforths, on behalf of a consortia of housebuilders, developers and landowners to review the available evidence and provide advice on whether this level of provision will be sufficient to meet the needs of the future population and economy of Doncaster.

Policy and methodological context

• The UK Government is committed to delivering more housing and delivering economic growth. This is made clear in NPPF and in numerous other policy statements. • Rebalancing the UK economy is another central objective of government policy. Growing the economic prosperity of the North of England is a primary policy goal. • The revised NPPF and PPG has set out a standard method for determining the minimum level of housing that local planning authorities need to deliver. This removes the requirement to align housing policies with the future economic growth of an area. LPAs can still make an upward adjustment to support growth although this will now be discretionary. • Criticism of the new approach centres on the risk it will “lock” areas into a cycle of low inward migration and low housing delivery. There are also concerns that the standard method will work against the aim of narrowing the north-south divide by under-providing the housing required to support growth in northern economies. • Applying the formula for the standard method in Doncaster would result in a housing requirement of 572 dpa.

The economic performance of Doncaster

• Doncaster has been one of the fastest growing economies in Yorkshire and Humber. The district has created around 24,000 jobs between 2000 and 2017, representing a growth rate of 1.1% p.a. • Doncaster’s key asset is its connectivity by road, rail and air which has made it a highly attractive location for inward investment, particularly for industrial and logistics occupiers, with over 1.1m sq m of industrial/warehouse space taken up since 2010. • The strong performance is also due to a significant improvement in key economic indicators, including skills and levels of enterprise. The business start-up rate has more than doubled since 2010 and is now in line with the national average. These improvements have removed a key barrier to growth and mean that Doncaster is well placed to continue its high rate of growth. • The draft Local Plan has set a target of delivering 481 hectares of employment land between 2015 and 2035 and a number of ELRs shows there continues to be very strong market demand for industrial space in Doncaster. There is therefore strong potential for Doncaster to accommodate high levels of inward investment in future which would also drive jobs growth.

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Review of Doncaster's Housing Requirement

Our view of need in Doncaster

• The draft Local Plan sets a target of delivering 920 dpa between 2015 and 2032. The target delivers the minimum level of housing need for Doncaster based on the standard method (585 dpa) and makes an upward adjustment to support economic growth. • The upward adjustment was based on evidence produced by PBA which recommended housing need is presented as a range between 585 dpa (the minimum) and 912 dpa. The upper limit was based on matching the jobs growth aspirations of the Sheffield City Region LEP (1,420 jobs per annum) over the period 2016 to 2026. The Council has adopted a figure slightly above this range. • Lichfields has produced an alternative assessment of housing need as part of a planning appeal in Doncaster. This assumes a lower rate of jobs growth than PBA (741 to 1,182 jobs per annum) but arrives at a much higher level of housing need (1,370 dpa). • We conclude that PBA has made unjustified and unrealistic assumptions for a number of factors which all suppress the level of housing required to support future employment growth. In particular, we disagree with their assumptions about commuting, double jobbing and household formation rates. • We also disagree with a number of the assumptions made by Lichfields and conclude that they overestimate the housing needed to support the level of growth in their scenarios. • We conclude that Doncaster would need to deliver between around 1,100 dpa between 2015 and 2032 to support future economic growth. This is based on our review of the assumptions made in the two reports and our professional judgement but would need to be tested through a detailed modelling exercise. • In summary, the housing target of 920 dpa meets the minimum level of housing required as set out in the standard method but would risk constraining the future economic growth of Doncaster. For this reason we strongly recommend that the Council considers making a further upward adjustment.

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www.hatchregeneris.com London: Manchester:

Doncaster MELTON ROAD, NEWTON Strategic Location Plan

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Thorne Askern River Dun Navigation

A19 Carcroft M180 Hatfield

Adwick le Street River DonEdenthorpe Bentley

Armthorpe A1(M) M18 Doncaster

Sprotborough Walton

Denaby Main Finningley

Conisborough New Edlington Rossington Doncaster Sheffield Airport A638

Braithwell

Tickhill

ii Introduction

The land at Melton Road, Newton presents a sustainable development opportunity to provide new housing for Doncaster. The site is being promoted by Avant homes as a development opportunity that can deliver approximately 275 dwellings.

Background closest secondary schools are Don Valley Objectives This advocacy document has been produced Academy and Ridgewood School within The key objectives of the scheme are to: for the site at Melton Road, Newton. 2km and 1.5km, respectively. These offer • Bring forward suitable Green Belt land secondary and sixth form education. for development. The site is being advocated to Doncaster • Provide new public open space and Metropolitan Borough Council (DMBC) The site is accessed from Melton Road improve pedestrian and vehicular as part of the Local Plan Review. This which provides direct routes into linkages document presents information to support Doncaster Town Centre, approximately 2.5 • Deliver in the region of 275 new homes the allocation of this site and to underline miles to the east. to meet the needs of the Borough. the site’s deliverability credentials. • Support an attractive neighbourhood The site is adjacent to existing housing in Doncaster. The site is located to the west of Newton to the east with the A1(M) froming the in an area currently designated as Green western boundary to the site. Scope Belt. It is circa 13.2 Ha in area. The site The scope of this document is to set out is accessed from Melton Road which is The northern boundary follows the existing the credentials for land at Melton Road, well served by bus services and is only 2.5 hedgerows and the edge of the Registered Newton as a residential development miles from Doncaster Town Centre. To the Park and Garden around Cusworth Hall. opportunity and to seek its allocation west is the village of Sprotborough which The boundaries of the site are therefore as a housing site through the Local Plan also provides local facilities. To the east on robust. Review. This is set in the context of the Sprotborough Road there is also a local opportunity that the site provides to supermarket, less than a mile from the site. The site represents a highly sustainable contribute towards delivering new housing development opportunity with access to for Doncaster and the economic growth The site is to the south of Cusworth Hall existing facilities and services. It is a logical aspirations for the wider Borough. and the Registered Park and Garden which extension to the urban area of Doncaster form the setting for this listed building is to and supports the continued housing and the north of the site. economic growth of the town.

There is Richmond Hill Primary School close to the entrance to the site. The

Melton Road, Newton - Site Advocacy - Sept 2019 1 P0-MP-SPA-RP-P4234-0001-0001 DMBC UDP Map 3 and 6 Combined 1998: Doncaster North

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Site Adjacent Site

Key

Site

Adjacent Site 2 Planning and Housing Need

There is a significant and recognised housing crisis within the UK. The country needs to provide around 300,000 homes per year to keep up with population growth and to start to tackle years of undersupply. Within Yorkshire significant stresses on housing supply also exist. The Local Authorities in Doncaster, Wakefield, Barnsley, Rotherham, Sheffield, Selby and Leeds need to provide at least 11,670 new homes per year cumulatively.

The revised National Planning Policy level of new housing needs to reflect the system plays a crucial role in this approach Framework, 2019 (The Framework) ambitions of the Strategic Economic Plan. to facilitating new development proposals. states that local authorities should meet Furthermore, the SCR Integrated NPPG recognises that a wide range of their objectively assessed housing needs Infrastructure Plan states: settlements should play a role in delivering in full and boost significantly the supply sustainable development in rural areas, A quality housing offer has a crucial role to play in the of housing. The Local Plan – Publication future economic growth of the City Region. It is essential and does not support blanket policies that Version recognises the need to deliver a to attract and retain a skills base that supports inward restrict housing development in some types sufficient supply of housing and support investment as meeting existing and future community of settlement without robust evidence. economic development and growth now needs and retention of Sheffield City Region (SCR) talent. to create sustainable communities. It has been identified that between 70,000 and 100,000 Doncaster is a sub-regional centre additional homes are needed in SCR. To support the providing a sustainable location comprising The Borough of Doncaster is located on proposed economic growth over the next 10 years. These a wide variety of housing, commercial will have the dual benefit of providing accommodation the crossroads of the main arterial routes that underpins the proposed increase in employment and employment opportunities and good of the A1(M) and M18 Motorways as well (70,000 jobs), as well as the wider economic benefits rail and road connections to the wider as being a major station on the East Coast that housing investment brings. area. Newton is located on the edge of Mainline and on a key route between the the Doncaster Main Urban Area within the Region and the east coast ports. Doncaster The current wider economic context in emerging Doncaster Local Plan. The Main is an integral part of the Sheffield City the country is also relevant. The economic Urban Area is required to provide 50% of Region (SCR) and its ambitious growth decline and associated recovery, its impact the housing growth (6,805-7,315 homes). aspirations. The SCR Strategic Economic on the housing market and increasing Plan sets out the plan to transform the housing crisis means schemes that assist The Melton Road site therefore represents local economy over the next decade. At economic and housing growth, are high an opportunity to provide quality housing the heart of the plan is the creation of on the Governments priorities. The in a sustainable location to go towards 70,000 new private sector jobs and 6,000 Localism Act, The Framework, Ministerial meeting the housing needs of delivering new businesses. statements and budgets recognise the much needed new homes within Doncaster. importance of housing and significant Therefore to achieve the aspired growth economic imperative of encouraging new that the SCR is seeking to achieve and development proposals within appropriate is securing government funding for the and sustainable locations. The planning

Melton Road, Newton - Site Advocacy - Sept 2019 3 P0-MP-SPA-RP-P4234-0001-0001 Available

Avant Homes control the land at Melton Road, Newton. The land is therefore available in accordance with national guidance. The site is a logical location to grow Newton and Avant Homes have direct frontage onto Melton Road. There are no landownership, legal or other constraints which would restrict the availability of the site for housing use. The site is therefore available and does not rely on third party land to be delivered.

4 Suitable: Green Belt

The housing needs of Doncaster are putting severe pressure on the local authority to review the Green Belt. To meet the housing requirement Doncaster Council recognises that some Green Belt land will need to be released for new housing land. There is opportunity to review the Green Belt in the surrounding area to positively use the Green Belt and meet the housing need for Doncaster.

Belt boundaries for the emerging Local Plan analysis that development of the site would and beyond to provide the new boundaries not have a material impact on the Green with some permanence. Belt. The development of this site will not have a significant impact on any of the The site performs a limited Green Belt reasons for the Green Belt designation in function and the release of this site and the area. The new Green Belt boundaries the adjacent site would help to establish will be drawn to provide a long term robust

Site a more appropriate and robust Green boundary. The development will not result Belt boundary utilising the A1(M). The in the coalescence of neighbouring towns, development of the site will have limited and will not encroach on the countryside impact on the openness of the Green Belt. nor affect the setting and special character The site is bounded by the urban area to of an historic town. Therefore, although the east and the A1(M) to the west. The the site is in the Green Belt it is a logical A1(M) therefore separates the site from scheme with significant major benefits. Sprotborough. In the Borough of Doncaster approximately Green Lane, Scawthorpe is a site that does 46% of the area is designated as Green Belt. The proposed Green Belt boundary would not perform any of the five Green Belt This is the western part of the Borough accord with the Framework and ensure functions and as such is an appropriate site which forms part of the South Yorkshire the Green Belt is well defined for the long- for release to deliver additional housing Green Belt surrounding urban areas. term. The A1(M) is a distinct feature beyond allocations for the Borough and the which the urban edge will not encroach, Doncaster Main Urban Area. The Framework considers that Green Belt thus ensuring permanency is maintained. boundaries can change “in exceptional circumstances” as part of a Local Plan The Melton Road site is therefore a unique review. Such a circumstance exists through opportunity to meet the housing need the significant need to provide housing in and economic growth aspirations whilst Doncaster. To meet the housing need and delivering significant benefits for the area. economic growth aspirations the Council has stated it will need to revise the Green It is clear from the site location plans and

Melton Road, Newton - Site Advocacy - Sept 2019 5 P0-MP-SPA-RP-P4234-0001-0001 Canal Lane Comprehensive Settlement Analysis Plan 1:7,500

To Scawsby/ Bentley Rise

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Darnum Retail Park

Wheatley Hills RUFC

Cusworth Hall Keepers Museum & Cottage Park (Grade II) Cusworth Hall (Grade I)

Trans Pennine Trail

Cusworth Motte Castle Sprotborough Road (Scheduled Ancient Sainsbury’s Monument) Local

KEY Parish • Education Council • Healthcare • Community (Churches, Sports, etc) Nelson GP Adjacent Practice • Retail Site

• Industrial/Commercial A1(M) • Public Open Space (Formal eg Sports) Richmond • Commercial Facilities Hill Primary • Pubs/ restaurants School • Local or District Centre • Bus route and stops • Public Footpaths • Listed Building (Grade II) Melton Road • Registered Park and Garden • Public Open Space (Informal) River Don

6 Suitable: Settlement Analysis

The Melton Road site is located to the north of Newton in urban Doncaster. The site is within walking distance to Melton Road which leads to Doncaster city centre. Along the Melton Road/ Sprotborough Road there are a number of community facilities and bus services. To the north of the site is Cusworth Hall and the Registered Park and Garden designation which surrounds it.

The proposed site is located to the north Cusworth Hall is a Grade I listed building ACCESS TO FACILITIES of Newton and Sprotborough adjacent to raised on a hill to the north of the site and Facility Distance Approx. Location the urban area and a number of existing set within a Registered Park and Garden. to journey closest time facilities. Cusworth Hall Conservation Area also (miles) (mins) protects the immediate setting of the listed Supermarket 1.5 miles 12 mins York Road Newton has a number of existing building and is located adjacent to the Bus facilities which are located on or close to site. The raised nature of Cusworth Hall Local Shop(s) 0.6 miles 12 mins Sprotbrough walk Road Sprotborough Road to the south-east of highlights the buildings importance in the Post Office 0.7 miles 13 mins Sprotbrough the site including convenience shopping, landscape. The Keepers Cottage (Grade II) walk Road medical and a primary school and nursery. is located adjacent to the eastern area of Library 0.5 miles 10 mins Sprotbrough There are also employment opportunities the site. The grounds of Cusworth Hall are walk Road within and around Danum Retail Park, open to the public and the Hall is now a Town Centre 2.3 miles 16 mins Doncaster Bus along Pipering Lane and Barnsley Road, local museum. GP Surgery 0.6 miles 12 mins Newton There are also regular buses to Doncaster walk Lane Town Centre. The A1(M) forms the western boundary to Hospital 3.2 miles 29 mins Doncaster the site. In the south the motorway is in Bus Royal Inf. There a primary school (Richmond Hill) cutting however it rises above the site to Dentist 0.9 miles 16 mins Somersby Walk Avenue and nursery (Sunny Bright Day Nursery) the north. Nursery 0.3 miles 6 mins Melton within 5 mins walk of the site. The closest Walk Road secondary school Ridgewood School to To the east of Cusworth Hall is anchorage Primary School 0.2 miles 5 mins Melton the north (1.3 miles). Lane and Newlands Park which provides Walk Road outdoor sports, recreation and children’s Secondary 1.3 miles 30 min Ridgewood / School Walk Barnsley Rd The bus services along Melton Road and play facilities. Park / 0.3 miles 6 mins Anchorage Sprotborough Road provide services every Playground Walk Lane 30 minutes to Doncaster Town Centre. The Trans Pennine Trail also runs along the Sports Pitches 0.3 miles 6 mins Anchorage eastern boundary of the site. Walk Lane Bus Stop 0.02 miles 1 mins Melton Doncaster Railway Station is 2.3 miles from Walk Road the site and can be reached following a 16 Train Station 2.3 miles 16 mins Doncaster minute bus ride from York Road. Bus

Melton Road, Newton - Site Advocacy - Sept 2019 7 P0-MP-SPA-RP-P4234-0001-0001 Site Photograph Location Plan

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1 2 Adjacent Site

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8 Site Photographs

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View of the site towards the eastern boundary defined by the existing housing.

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Site view towards the western boundary defined by A1(M)

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Site view towards western boundary. showing View from the western boundary looking north across the site towards Cusworth Hall on the level change other side of the valley.

Melton Road, Newton - Site Advocacy - Sept 2019 9 P0-MP-SPA-RP-P4234-0001-0001 Site Photograph Location Plan

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Adjacent Site

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View towards the site from Melton Road View towards Cusworth Hall from within the site

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View towards the A1(M) from the entrance to the site showing the pylons.

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The rear of properties which back onto the View from the rear of neighbouring site. properties towards the site entrance

Melton Road, Newton - Site Advocacy - Sept 2019 11 P0-MP-SPA-RP-P4234-0001-0001 Site Issues & Opportunities Plan

25m AOD

30m AOD Adjacent Site

35m AOD

35m AOD

KEY Opportunity for Vehicular Access Existing Footpath Existing Bus Stops Hedgerows A1(M) Noise Source Historic Park and Garden Overhead Powerline Route Views towards Cusworth Hall

12 Achievable: Site Issues & Opportunities

The Melton Road site at Scawthorpe provides a number of opportunities which any proposed development can utilise in order to add to the Newton neighbourhood and to integrate the development into Doncaster.

The Site new housing on the setting of the Listed Drainage The total site is approximately 13.2ha Buildings and Registered Park and Garden. There are areas of localised flooding to the located to the west of Newton. north of the site. The development should Access seek to reduce the run-off from the site to Topography Melton Road provides the vehicular access green field levels in order to mitigate the The majority of the site is level however opportunity from the site. risk of flooding in the surrounding area. the northern portion drops away into the valley. A public right of way also passes through Air Quality the site linking Sprotborough to Cusworth The site is not located within, or in The site abuts to the established housing via a subway underneath the A1(M). There the vicinity of an existing Air Quality development on the east and has long may be opportunity to improve this route. Management Area (AQMA). However the distance views to the north towards site is adjacent to the A1(M), which is likely Cusworth Hall. Ecology to be the main sources of pollution locally. Having been utilised for farming the site Heritage itself lacks significant habitat. The areas The development should be shaped to Cusworth Hall is a Grade I listed building of habitat are limited to the hedgerows mitigate the impacts of air pollution of set upon the hill on the other side of the which bound the site. The main ecology residents. valley from the site. This building and the in the area is within the woodland which surrounding conservation area are visible surrounds Cusworth Hall to the north. Noise from the site, in a similar way to how it There is opportunity to create a habitat To the western boundary the dominant is visible from the existing housing. The corridor alongside the A1(M) through the sources of noise was the road traffic Grade II listed buildings which accompany site. from the A1(M). Careful consideration Cusworth Hall are screened from the site. will need to be given to the design of the Transport site together with appropriate boundary The Registered Park and Garden which The site is well served by existing bus mitigation, glazing and ventilation. With a surrounds Cusworth Hall includes the services with regular services on Melton suitable mitigation in place internal daytime fields to the north of the site. Care will Road linking the site with central Doncaster. and night time noise level criteria could be be taken to create a buffer on the edge met across the entire site. of the site to mitigate the impacts of the

Melton Road, Newton - Site Advocacy - Sept 2019 13 P0-MP-SPA-RP-P4234-0001-0001 Illustrative Masterplan - not to scale

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SUDS at lowest point of site Public Open Space reinforces Woodland separation from buffer created Cusworth Hall to edge of Historic Park and Garden

Terraced Adjacent Properties Site create acoustic buffer

Opportunity for connection to Woodland adjacent site buffer to A1(M)

A1(M)

CLIFTON DRIVE

DEAN CLOSE

Site entrance

MELTON ROAD 14 Deliverable

The land at Melton Road, Newton provides a residential development opportunity in a sustainable location close to shops, services and community facilities to meet the needs of urban Doncaster. the site is currently located within the Green Belt and is available, suitable and achievable in accordance with the Framework.

Availability opportunities for sustainable travel to Economics The land is being promoted by Avant Homes, work in Doncaster and beyond with access The relationship between economic as developer. The site is therefore available to Doncaster Railway Station. performance in an area and housing is in accordance with the Framework and the complex, but having the right quantity, National Planning Practice Guidance (PPG). The development will provide additional quality and balance of housing in an area quality development that will benefit is necessary for economic growth. The Suitability the Doncaster and wider district with development of the Melton Road scheme The proposed site utilises a distinct economic, environmental and social can therefore support local economic element of the existing Green Belt which benefits. It is therefore considered that the growth, both through direct job creation is separated from the wider Green Belt development is suitable. through the construction phase of the by the A1(M) and the Registered Park and scheme, but also through the increased Garden which encompasses Cusworth Achievable population which will create sustainable Hall. The development of the site will be The technical assessments undertaken to local jobs from the increased demand an efficient use of land to provide quality date indicate that there are no technical for goods and services. This provides development and new homes for the issues that would prevent development or an important sustainable development Doncaster Main Urban Area. The site is are insurmountable. The site is therefore opportunity in Doncaster. identified for development within the Draft considered to be achievable. Doncaster Local Plan. Summary The indicative masterplan shows how a mix The site at Melton Road provides a The site is located in a highly sustainable of housing can be accommodated within development opportunity that is available, location and has residential development the site, alongside connectivity, landscaping suitable and achievable and therefore it is to the east. The site is within easy walking and drainage features. considered that the site is deliverable, in distance to Local Centre facilities within accordance with national planning policy Newton as well as greater facilities within and guidance. It is promoted by Avant Doncaster Town Centre, a short bus ride Homes and is deliverable within the plan away. There are a large number of primary period. schools in the vicinity of the site with Secondary Schools slightly further afield.

The site is well served by buses providing

Melton Road, Newton - Site Advocacy - Sept 2019 15 P0-MP-SPA-RP-P4234-0001-0001 Key Design Principles Plan - not to scale

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Adjacent Site

A1(M)

CLIFTON DRIVE

DEAN CLOSE

KEY Main Access Road Key Pedestrian Route Public Open Space Landscape for Heritage and Acoustic Buffer MELTON ROAD Vehicular Access 16 Opportunity for connection to adjacent site Development Principles

The approach of the masterplan is to provide housing which integrates with the surrounding area making the most of the surrounding landscape and the pedestrian links. The edge of the Registered Park and Garden will be reinforced. Opportunity for connection is created to the adjacent site, allowing for a comprehensive urban extension to Newton, Doncaster.

A number of principles have been identified Ecology Residential Design above as a result of the baseline assessment. The illustrative masterplan has sought to Creation of a high quality residential provide a buffer separating the development extension to Newton having its own The following key design principles inform from the A1(M). This buffer can be planted distinct identity of appropriate scale and the design concept and are present in the with appropriate native species to create a character for the site. More generic design final scheme. They are as illustrated on the habitat corridor. principles which will be applied to the plan opposite: scheme are as follows: Access Highways Layout The masterplan allows for pedestrian/ • Character - a place with its own The main vehicular site access will be cycle linkages through the site to the identity located on Melton Road. existing public right of way to the north. • Continuity and enclosure - where Drainage This route will provide opportunity for public and private spaces are clearly It is proposed that the Sustainable Urban the new residents to walk to between distinguished Drainage solution be provided as swales at Sprotborough and Cusworth Hall from the • Quality of the public realm - a place the lowest point of the site. site. Cycle routes will link the development with attractive outdoor areas to Melton Road with access from here into • Ease of movement - a place that is easy Doncaster. to get to and move through Public Open Space • Legibility - a place that is easy to The main public open space (POS) within navigate the development lies on the northern edge • Diversity - a place that offers variety of the site reinforcing the separation of and choice the new homes from the Registered Park and Garden and Cusworth Hall. Trees will be used within the scheme to identify key pedestrian routes.

Melton Road, Newton - Site Advocacy - Sept 2019 17 P0-MP-SPA-RP-P4234-0001-0001 Illustrative Masterplan - not to scale

Adjacent Site

A1(M)

CLIFTON DRIVE

DEAN CLOSE

MELTON ROAD 18 Conclusion

The land at Melton Road provides an opportunity to deliver new housing in a sustainable location to meet the needs of the Doncaster Main Urban Area and the wider Borough. The site is available, suitable and achievable in accordance with the Framework and represents a sustainable residential opportunity on the edge of an established residential area.

There is a need for Doncaster Council constraints, that could not be suitably Road scheme can therefore support local to review their Green Belt boundaries mitigated, that would prevent this site economic growth, both through direct job to meet the housing need and demand in coming forward within the plan period. creation through the construction phase of the area. This Advocacy Report supports As such, the development of the site, as the scheme, but also through the increased the Draft allocation of the site and agrees shown within the indicative masterplan, is population which will create sustainable that there are exceptional circumstances considered achievable. local jobs from the increased demand supporting the release of the site from the for goods and services. This provides Green Belt due to the urgent need to meet The indicative masterplan shows how a mix an important sustainable development Doncaster’s housing need and ambitions of housing can be accommodated within opportunity in the Doncaster Borough. for growth. the site, alongside connectivity, landscaping and drainage features. The scheme is being It has therefore been shown that the site Avant Homes control the site and are promoted by the landowner and will go at Melton Road provides a development promoting it for inclusion in the Local towards meeting the housing requirement/ opportunity that is available, suitable and Plan. The site is therefore available for need in the area. achievable and that it is considered that development within the plan period. The the site is deliverable, in accordance with site is in a sustainable area close to a Furthermore, the development of the site national planning policy and guidance. range of services and facilities and public will bring forward additional economic It is promoted with interest from a transport routes. The site is therefore benefits to the area. The relationship national house builder (Avant Homes) suitable for residential development. between economic performance in an area and is deliverable within the plan period. and housing is complex, but having the right The scheme has significant housing and The technical work undertaken to date quantity, quality and balance of housing economic benefits for the area and is has influenced the indicative masterplan. It in an area is necessary for economic therefore eminently suitable for allocation. has also shown that there are no known growth. The development of the Melton

Melton Road, Newton - Site Advocacy - Sept 2019 19 P0-MP-SPA-RP-P4234-0001-0001 Key Benefits

Optimum location to assist in the continued growth of the Doncaster Main Urban Area

The delivery of circa 275 new homes in a range of house types, sizes and tenure

Circa 963 new jobs (direct and in-direct) from the construction of the residential scheme alone

GVA Gross Value Added of around £19.6 million

Circa £6.8 million Annual Household Expenditure

At least £1.4 million of first occupation expenditure

P0-MP-SPA-P4225-1RP-0001-0001 Doncaster WADWORTH HILL, WADWORTH Strategic Location Plan

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Thorne Askern River Dun Navigation

A19 Carcroft M180 Hatfield

Adwick le Street River DonEdenthorpe Bentley

Armthorpe A1(M) M18 Doncaster

Sprotborough Walton

Denaby Main Finningley

Conisborough New Edlington Rossington Doncaster Sheffield Airport A638

Braithwell

Tickhill

ii Introduction

The land at Wadworth Hill, Wadworth presents a sustainable development opportunity to provide much needed new housing for Wadworth and Doncaster. The site is being promoted by Avant Homes as an opportunity that can deliver circa 225 dwellings.

The land at Wadworth Hill, Wadworth Immediately to the east/north east is the Scope presents a sustainable development A1(M) and to the west is the A60. Existing This Advocacy Report will set out the opportunity to provide much needed new residential development is located to the context and ambitions for the site at housing for Wadworth and Doncaster. The south west with fields and allotments to Wadworth Hill, Wadworth. site is being promoted by Avant Homes as the south east. The A60 provides access an opportunity that can deliver circa 225 to Doncaster and Tickhill, and has good Before analysing and explaining the sites dwellings. access to bus routes serving Doncaster. justification for Green Belt release, The site is close to junction 3 of the M18, demonstrating that the site is sustainable, This advocacy document has been produced providing access to the wider region. available, suitable, achievable and for the site at Wadworth Hill, Wadworth. Within Wadsworth the site approximately therefore deliverable in the context of the The site is being advocated to Doncaster 280m to Wadworth Village centre, and just National Planning Policy Framework (the Metropolitan Borough Council as part of over 630m to Wadworth primary school. Framework). the Local Plan review. This documents presents information to support the sites The site comprises five pasture fields, which An indicative masterplan for the site shows release from the Green Belt and allocation are delineated by mature hedgerows, some the potential for the site including green for residential development by assessing with mature trees within them, particularly infrastructure, movement and connectivity. its credentials against the five greenbelt the fields to the north. The site slope from The masterplan shows a scheme based tests and demonstration of sustainability, south to north. on the number of technical assessments suitability and delivery. including highways, ecology, flood risk and Objectives drainage, noise, air quality and heritage. The Site The key objectives of the scheme are to: The proposal provides significant benefits The site is to the southwest of Doncaster, • Bring forward suitable Green Belt land which are explained throughout the on the north eastern fringe of the for development report including the provision of a range village of Wadworth in an area currently • Deliver in the region of 225 new homes and choice of house types and tenure, job designated as Green Belt. It is physically to meet the needs of the Borough. creation and economic growth. separated from the wider Green Belt by • Support an attractive extension to the the A1(M). The site is circa 7.9 hectares village of Wadsworth and can accommodate in the region of 240 • Provide new public open space. dwellings across the whole site. • Support existing facilities

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 1 P0-MP-SPA-RP-P4240-0001-0002 DMBC UDP Map 4 and Wadworth inset Combined 1998: Doncaster North

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KEY Site 2 Planning and Housing Need

There is a significant and recognised housing crisis within the UK. The country needs to provide around 300,000 homes per year to keep up to with population growth and start to tackle years of undersupply. Within Yorkshire significant stresses on housing supply also exist. The Local Authorities in Doncaster, Wakefield, Barnsley, Rotherham, Sheffield, Selby and Leeds need to provide at least 11,670 new homes per year cumulatively.

The revised National Planning Policy Furthermore, the SCR Integrated sustainable development in rural areas, Framework, 2019 (The Framework) Infrastructure Plan states: and does not support blanket policies that states that local authorities should meet restrict housing development in some types A quality housing offer has a crucial role to play in the their objectively assessed housing needs future economic growth of the City Region. It is essential of settlement without robust evidence. in full and boost significantly the supply to attract and retain a skills base that supports inward of housing. The Local Plan – Publication investment as meeting existing and future community Doncaster is a sub-regional centre Version recognises the need to deliver a needs and retention of Sheffield City Region (SCR) talent. providing a sustainable location comprising sufficient supply of housing and support It has been identified that between 70,000 and 100,000 a wide variety of housing, commercial and economic development and growth now additional homes are needed in SCR. To support the employment opportunities and good rail to create sustainable communities. proposed economic growth over the next 10 years. These and road connections to the wider area. will have the dual benefit of providing accommodation that underpins the proposed increase in employment Wadworth is located just beyond the The Borough of Doncaster is located on (70,000 jobs), as well as the wider economic benefits Doncaster Main Urban Area within the the crossroads of the main arterial routes that housing investment brings. emerging Doncaster Local Plan. The Main of the A1(M) and M18 Motorways as well Urban Area is required to provide 50% of as being a major station on the East Coast The current wider economic context in the housing growth (6,805-7,315 homes). Mainline and on a key route between the the country is also relevant. The economic Wadworth is identified as a defined village, Region and the east coast ports. Doncaster decline and associated recovery, its impact and noted as being one of the highest is an integral part of the Sheffield City on the housing market and increasing scoring settlements in the Settlement Region (SCR) and its ambitious growth housing crisis means schemes that assist Background Paper and is well connected aspirations. The SCR Strategic Economic economic and housing growth, are high to the Main Urban Area via a range of Plan sets out the plan to transform the on the Governments priorities. The sustainable transport options. Wadworth local economy over the next decade. At Localism Act, The Framework, Ministerial has the potential to support the delivery of the heart of the plan is the creation of statements and budgets recognise the housing in the Borough, providing choice. 70,000 new private sector jobs and 6,000 importance of housing and significant new businesses. economic imperative of encouraging new The Wadworth site represents an development proposals within appropriate opportunity to provide a range of housing Therefore to achieve the aspired growth and sustainable locations. The planning in a suitable and sustainable location to go that the SCR is seeking to achieve and system plays a crucial role in this approach towards delivering the much needed new is securing government funding for the to facilitating new development proposals. homes in the Borough and supporting the level of new housing needs to reflect the NPPG recognises that a wide range of long term viability and vitality of Wadworth. ambitions of the Strategic Economic Plan. settlements should play a role in delivering

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 3 P0-MP-SPA-RP-P4240-0001-0002 Available

Avant Homes control the land at Wadworth Hill, Wadworth. The land is therefore available in accordance with national guidance. The site is a logical location to grow Wadworth and Avant Homes have direct frontage onto the A60. There are no landownership, legal or other constraints which would restrict the availability of the site for housing use. The site is therefore available and does not rely on third party land to be delivered.

4 Suitable: Green Belt

The housing needs of Doncaster are putting severe pressure on the local authority to review the Green Belt. To meet the housing requirement Doncaster Council recognises that some Green Belt land will need to be released for new housing land. The proposed housing allocation to the northern fringe of Wadworth is an opportunity to review the Green Belt and positively use the Green Belt to meet the housing needs for the area.

The site at Wadworth performs a limited The new Green Belt boundary will be Green Belt Function and its release would drawn to provide a long term robust help to establish a more appropriate and boundary. The development will not result robust green belt boundary utilising the in the coalescence of neighbouring towns, existing natural and manmade features and will not encroach on the countryside. including the A1(M) and A60. The site will It will not affect the setting and special Site have limited impact on the openness of the character of a historic town. Green Belt, due to the topography of the area and significant tree and hedgerows to The Wadworth site does not perform any the boundaries. of the five Green Belt functions, and the boundaries are clearly defined using physical The proposed Green Belt boundary would features that are readily recognisable. The accord with the Framework and ensure site is contained and further landscaping the Green Belt is well defined for the and careful consideration of the building long-term. The A60 and A1(M) are distinct heights, mass, and siting will further limit any In the Borough of Doncaster approximately features beyond which the settlement potential visual impact of the development 46% of the area is presently designated as edge will not encroach, thus ensuring As such is an appropriate site for release Green Belt. The Framework considers that permanency is maintained. to deliver additional housing allocations for Green Belt boundaries can be changed in the Borough. ‘exceptional circumstances’ as part of Local It is an opportunity to meet the housing Plan review. Exceptional circumstances need and economic growth aspirations exist through the significant need to whilst delivering significant benefits for the provide housing to meet the housing need area and the village. and economic growth aspirations. The council has stated it will revise the Green It is clear from the site location plans and Belt boundaries for the emerging Local Plan analysis that the development of the site and beyond to provide new boundaries would not have a material impact on the with some permanence. Green Belt. The development would not have an impact on any of the reasons for Green Belt designation.

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 5 P0-MP-SPA-RP-P4240-0001-0002 Canal Lane Comprehensive Settlement Analysis Plan 1:7,500

A1(M) M18 North East KEY N Education Healthcare Community (Churches, Sports, etc) Retail J 35 Industrial/Commercial Public Open Space (Formal eg Sports) Commercial Facilities To Doncaster Pubs/ restaurants Local or District Centre Bus route and stops Public Footpaths Listed Buildings Conservation Area Parks and Gardens of Special or Local Historic Interest

M18 West

A1(M)

6

A1(M) South To Tickhill Suitable: Settlement Analysis

The Wadworth Hill site is located to the north east of Wadworth a large village in Doncaster Borough. The site abuts Wadworth Hill (A60) which leads to Doncaster to the north and Tickhill to the south. Along the A60 there are a number of community facilities and bus services.

Wadworth is a large elevated village and Wadworth has a small range of local shops ACCESS TO FACILITIES civil parish in the Metropolitan Borough including a Foodstore, Chinese Takeaway, Facility Distance Approx. Location of Doncaster. It is organised around the Butchers shop, Coffee shop and a Pub. to journey closest time Church of St. John the Baptist, which has They also have a local community centre (miles) (mins) medieval origins, and the mid-18th century and local church all of which are in easy Local Shop 0.19 miles 4 mins walk Wadworth Wadworth Hall (both Grade I listed). walking distance of the site. Slightly further Supermarket 1.98 miles 3 mins drive Woodfield afield lies New Edlington to the Northwest Way, Doncaster The elevated position of the village means and Balby to the north which offer a Post office 4 miles 8 mins drive Edlington that the church spire is visible across a wider range of facilities including Doctors, Library 4 miles 8 mins drive Edlington wide area and there are views out of the Dentists, Opticians and Hospital. GP 4 miles 8 mins drive Edlington conservation area to the north and east Hospital 2 Miles/ 4 4 / 8 mins Tickhill Road towards Doncaster. Primary education is provided by Wadworth miles drive Hospital/ Primary School which lies to the south Doncaster Royal The site abuts Wadworth Hill (A60) which of the village and is approximately 7 - 10 infirmary leads to Doncaster to the north and minutes walk (500m) from the site. The Dentist 4 miles 8 mins drive Edlington Tickhill to the south. Along the A60 there closest secondary school is the Sir Thomas Nursery 0.8 miles 16 mins walk Loversall are a number of community facilities and Wharton Academy in Edlington which lies Primary 0.4 miles 9 mins walk Wadworth bus services. to the west of the site approximately 20 - School Secondary 1.6 miles 9 mins drive Edlington 25 minutes cycle. School The proposed site is located to the north of Park/ 0.37 miles 6 mins walk Osberton Wadworth. The site is contained between There are numerous bus services which Playground Street/ the A1(M) to the north-east, the A60 to the pass close to the site connecting the area Wadworth Hall Lane west and housing to the south. It does not with central Doncaster. The bus services Sports 0.35 miles 6 mins walk Wadworth impinge on Wadworth Conservation Area. along the A60 (Doncaster Road) and Pitches Hall Lane A Public Right of Way crosses the site. Wadworth Hill, adjacent to the site, provide Bus Stop 0 Next to the A60 passing under the A1M before connecting bus services every 12 minutes throughout site Wadworth Hill, Site to Sewage Works at Burn Hill. the day into Doncaster Town Centre. entrance. Train Station 3.7m 15 mins bus Doncaster Doncaster Railway Station is approximately 4.5 miles from the site and can be reached following a 15 minute bus ride.

Wadworth Hill, Wadworth 7 P0-MP-SPA-RP-P4240-0001-0002 Site Photograph Location Plan

N

7

2 1 4 6

3 5

8 Site Photographs

1 2

View across the site towards the northern boundary. View along Wadworth Hill Road.

3 4

Panoramic view of the site towards the northern boundary from public right of way. View east, towards the A1(M) from the site

5 6 7

View from the eastern boundary looking View alongside the A1(M) View of the site from within the site looking north south towards the public right of way

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 9 P0-MP-SPA-RP-P4240-0001-0002 Site Photograph Location Plan

N

12

11

10

8 13 9

14 15

10 Site Photographs

8 9

View of the site towards the northern View of the hedge defined pasture field and woodland lining the A60. boundary.

10 11 12

View of A60 along the western site boundary View of northern boundary of the site along View of A1(M) towards north. at the junction with White Cross Lane. A1(M).

13 1412 15

View off Wadworth Hill Road towards the View of the playground located at the Panoramic view across the farming fields of sites current access point southern boundary with the site. the site from the southern corner.

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 11 P0-MP-SPA-RP-P4240-0001-0002 Site Issues & Opportunities Plan

N KEY Opportunity for Vehicular Access Footpath Existing Bus Stops Existing Green Spaces and Routes Tree Belt Hedgerow A1(M) Noise Source Sewerage Works and Pumping Station Sewerage pipe (approx. route) Conservation Area Listed Building Historic Park and Garden Public House Shops Church

20m AOD

30m AOD

35m AOD

40m AOD

12 Achievable: Site Issues & Opportunities

The total site is approximately 7.5 hectares located on the northern edge of Wadworth. The site is bounded by the A60 on the west, and to the north/north-west by the A1(M), existing residential development bounds the site to the west/south-west with further arable land to the east. There are established hedgerows and trees to the site boundaries particularly the boundary with the A1(M) and A60.

Topography Transport Air Quality The site slopes from the south/south west The site is well served by existing bus Mitigation will be provided the A1(M) to north with the southern boundary services with regular services along the and the sewerage pumping station and being approximately 43m dropping to A60 linking the site with Doncaster, Tickhill wastewater treatment works to minimise approximately 22m at the northern most and Worksop. the impact of air quality concerns. corner of the site. The A60 Wadworth Hill Road rises in relation to the site levels Ground conditions Heritage. towards the northern corner of the site Current investigations do not highlight Wadworth Conservation Area and St John where it crosses over the A1(M) on an any areas of concern regarding ground the Baptist Church (Grade 1 listed building) over bridge. conditions. are located within the vicinity of the site. However, visibility to the church from the Access Drainage site will be limited due to the intervening, The A60 is a long road abutting the edge of Infiltration drainage techniques are unlikely existing buildings and trees.Where possible the site to the west providing opportunities to be successful on the site due to the views to the church tower will be created. for highway access. There are opportunities underlying ground conditions. Connections to provide further pedestrian access to to the local surface water sewer system Ratten Row and or Osberton Street. along with attenuation will be the most appropriate solution for the site. Ecology The main ecology/habitats are within Noise hedgerows surrounding the site and Mitigation will be provided along the bounding individual fields. Hedgerows will boundary of the site with the A1(M) be maintained where practicable. to minimise the impact of noise on the residential development.

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 13 P0-MP-SPA-RP-P4240-0001-0002 Achievable

Ecology Flood Risk and Drainage

The site comprises a number of grassland fields separated by The site is not at risk of flooding, it is located within Flood Zone 1 hedgerows and fence lines. The grasslands did not show signs by the Environment Agency. of recent management and had become relatively diverse. The hedgerows were dominated by native species. Scattered scrub and The site falls south to north and the government flood mapping trees present around the site. shows that the south-western boundary to have a low risk of surface water flooding however the risk of this is low. There was no evidence of protected species found during the survey. As the site is greenfield, surface water runoff shall be restricted to The hedgerows comprised of over 80% native species and would the existing greenfield runoff rate for the site. therefore be classed as a Priority Habitat. Trees, scrub and hedgerows provide potential for nesting birds and nesting birds could use the A Severn Trent Foul Sewer crosses the site, and this will be either grassland. The report notes that hedgerows should be retained incorporated into the proposed site layout or diverted. where possible and replacement planting should be considered. Two trees at the site were noted to contain features potentially suitable Sustainable Drainage Systems of Infiltration drainage is unlikely to for roosting bats and should be retained if practical. be viable for this site based on the borehole logs, the presence of watercourses and the evidence of overland surface water flows. This Use of native species in any proposed landscaping, incorporation of does not preclude the use of preamble surface, conveyance swales, bat and bird boxes into new buildings. The site will need to consider and rain gardens to improve water quality prior to attenuation and the net gain in biodiversity for the site. subsequent discharge to a watercourse/public sewer.

There are no ecological constraints which would prevent the Based on the information currently available the site is suitable for development of the site. development.

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 14 P0-MP-SPA-RP-P4240-0001-0002 Achievable

Air Quality Noise

The site is not located within, or in the vicinity of an existing Air Noise monitoring was undertaken at two locations, one to the Quality Management Area (AQMA). Being in a rural area background western boundary of the site and one at the eastern corner of the pollutant concentrations are likely to be well below the current site. To the western boundary the dominant sources of noise was air quality standards. However the site is adjacent to two major the road traffic from the A60 and A1(M). To the east the dominant roads the A1(M) and A60, which are likely to be the main sources source of noise was road traffic on the A1(M). of pollution locally. Careful consideration will need to be given to the design of the The development should be shaped to mitigate the impacts of air site together with appropriate boundary mitigation, glazing and pollution of residents. ventilation. With a suitable mitigation in place internal daytime and night time noise level criteria could be met across the entire site.

The following mitigation may provide suitable solutions to noise Odour concerns: To the west of the site: the installation of acoustic barrier either There is a sewerage pumping station located at the southern around the site perimeter or garden areas, through careful boundary of the site and a wastewater treatment works circa consideration of siting of dwellings with proposed gardens on the 200m to the east of the site. Which could potentially lead to odour screened side of dwellings and the introduction of a buffer zone impacts on future residents. between the road and proposed dwellings, A buffer from the A1(M) and the installation of an acoustic barrier The careful design and layout of the site will mitigate the impacts of along the boundary of the A1(M). any odour for future residents.

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 15 P0-MP-SPA-RP-P4240-0001-0002 APPROX

Site Access

Access Location Plan

Estate Car (2006)

Viewport 1 Estate Car (2006)

Estate Car (2006) Estate Car (2006)

Viewport 1 (NTS)

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 16 P0-MP-SPA-RP-P4240-0001-0002

Notes Key Plan Issues & Revisions Client Project Title Drawing Title Rev Date Details of issue / revision RevDrw 1. Do not scale this drawing. All dimensions must be 4.71 Avant Homes Ltd Land Off Wadworth Hill, Swept Path Analysis: checked/ verified on site. If in doubt ask. P1 01.07.19 PRELIMINARY ISSUE MANB Wadworth, Doncaster Estate Car Access and 2. This drawing is to be read in conjunction with all CONSULTANCY | ENVIRONMENT INFRASTRUCTURE | BUILDINGS relevant architects, engineers and specialists drawings 0.885 2.755 and specifications. Egress Birmingham | 0121 233 3322 Estate Car (2006) Overall Length 4.710m Leeds | 0113 233 8000 3. All dimensions in millimetres unless noted otherwise. All Overall Width 1.804m levels in metres unless noted otherwise. Overall Body Height 1.442m London | 020 7234 9122 Min Body Ground Clearance 0.207m Max Track Width 1.756m Manchester | 0161 233 4260 4. Any discrepancies noted on site are to be reported to Lock to lock time 4.00s Kerb to Kerb Turning Radius 5.950m Nottingham | 0115 924 1100 Drawn: N Bell Reviewed: M Addison Drawing Status Project - Originator - Zone - Level - Type - Role - Number Status Rev the engineer immediately. www.bwbconsulting.com © Copyright BWB Consulting Ltd BWB Ref: LDP 2312 Date: 01.07.19 Scale@A3: 1:250 PRELIMINARY WHD-BWB-GEN-XX-DR-TR-110 S2 P1 U:\LDP\LDP2312_Wadworth Hill, Doncaster\02. Project Delivery\01. WIP\Drawings\WDH-BWB-GEN-XX-DR-TR-100_Access Arrangements_S2_P2.dwg Achievable: Highways and Access

The Access Strategy considers how the site is to be accessed and identified that a single point of access can be provided from Wadworth Hill (A60). This access can be designed to align with local design guidance, South Yorkshire Residential Design Guide (July 2015) and manual for roads and bridges. The overall strategy will provide the site with pedestrian and cycle connectivity in order to integrate the development with Wadworth.

Pedestrian Infrastructure and Cycle Infrastructure and Accessibility Highways Accessibility The Doncaster cycling map shows that The A60 to the west of the site is a two There is an established network of footways there are a network of cycle routes in way single carriageway with a 60 mph on the residential streets surrounding the the vicinity of the site, consisting of a mix speed limit which reduces to 30 mph to the site. There is a continuous footway along of advisory routes and traffic free paths, south of the site towards the village. Access the western side of the A60 towards connecting Wadworth with Rossington, is proposed to be 30m north of Rockcliffe Loversall. The footway on the eastern side New Edlington and Doncaster. Presenting Drive Junction this maintains sufficient of the A60 is approximately 1.3m wide and opportunities for future residents to access stagger distance away from the junction to ends near the bus stop opposite Rockcliffe local amenities by cycling. avoid potential road safety issues. Drive. A suitable vehicular access to the site A review of the Council’s definitive map can be achieved. This will tie in with the shows that there is a public right of way existing footway along the A60 and future through the site. The will be incorporated secondary/emergency access to the north. into the layout or diverted. The appropriate visibility splays can be achieved within the extent of the adopted highway. It may be necessary to relocate the existing south bound bus stop.

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 17 P0-MP-SPA-RP-P4240-0001-0002 Wadworth Hill, Doncaster Environmental Appraisal DesignatedJune 2019 Heritage Assets

Site Boundary

1 Conservation Area 5 9 Listed Assets 4 Grade I Grade II Grade II* 1 Scheduled Asset 4 12 Asset Number

7 1 3 2 8 1 1 3 5 2 6 1 1 0 1

Wadworth Hill, Doncaster Environmental Appraisal June 2019

Table 7.1 Designated Heritage Assets Figure 7.1 Designated Heritage Assets BWB No. National Heritage List No. Description Designation Status

Listed Assets Page | 34

1 1151504 St John the Baptist Church Grade I

2 1151505 Long Farmhouse Grade II

3 1151506 West Lodge (now dwelling), Wadworth Hall Grade II*

White Cross Grange Farmhouse, White Cross 4 1151508 Grade II Lane

Two barns south west of Long Farmhouse, Carr 5 1151512 Grade II Lane

6 1193312 New Farmhouse, Carr Lane Grade II

7 1193412 Sundial 20m S of Wadworth Hall Grade II

8 1193428 East Lodge (now dwelling), Wadworth Hall Grade II*

9 1193466 White Cross Farm buildings, White Cross Lane Grade II

Former wagon shed to southwest of Long 10 1240118 Grade II Farmhouse, Carr Lane

11 1314832 Pigsty south of Long Farmhouse, Carr Lane Grade II

12 1314863 Wadworth Hall Grade I

13 1314864 Gate Piers and Walls, Wadworth Hall Grade II

Scheduled Assets

14 1004824 Edlington Wood Roman Settlement Scheduled

15 1004834 Edlington Wood Double Dyke Scheduled

18

Page | 36

Achievable: Heritage

Wadworth is a historic village with an extensive Conservation Area and a number of listed buildings within it. The site is separated from the Conservation area by more recent development and the location at the bottom of the hill limits the opportunities for views to the historic buildings.

The village of Wadsworth lies to the south St John the Baptist Church Wadworth Conservation Area west of the site. The historic core has Whilst not within the immediate setting The site holds limited prominence in the retained its early post medieval character, of the Grade 1 listed church of St John context of the conservation area given the and is a designated conservation area. the Baptist the site is close to the church intervening landscape form. New housing estates have been formed and the eastern arm of the Conservation along the southern, western boundaries of Area of Wadworth and forms part of the Open space will be utilised to maintain the site, between the site and the historic extended historic landscape setting to it. views into the eastern arm of the core of Wadworth. Development will not The main body of the church is screened conservation area. directly impact upon the significance of any from views within the site. There are designated heritage asset. some views of the very upper section of the church tower from within the site, The proposed site is in an area which has but these are interrupted by intervening some evidence of early prehistoric activity, landscape form and tree cover. including evidence for occupation found at Edlington Woods which lies to the The proposed development will not impact northwest. There have been a number of upon the building or diminish the values crop marks found within the wider area, attributable to the immediate setting of the dating to the Iron age and Romano British Church. period. Any impacts on the wider historic openness By the medieval period the site was in to the setting of the church and views of agricultural use. This use continues to today. the upper sections of the tower will be Other than the enclosure of the field little mitigated through careful consideration of activity has occurred within the site other the siting, building orientation and building than the construction of the Doncaster scale in order to maintain views to the Bypass in the late 1950’s and early 60’s. church tower were possible. Stripping activities associated within this may have some localised impact on the potential archaeological deposits/features.

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 19 P0-MP-SPA-RP-P4240-0001-0002 Key Design Principles Plan 1:2,500

N

BUFFER TO A1(M) PROVIDES SCREENING AND SUDS

CONNECTION BUFFERTO A60 PROVIDED BY EXISTINGTREE BELT TO PUBLIC RIGHT OF WAY

BUILDINGS FACE ONTO OPEN SPACE AND LOOK INTO CONSERVATION AREA

POS PROVIDES CONNECTION CONTINUATION TO PUBLIC WITH EXISTING RIGHT OF WAY GREEN SPACE KEY • Main Access Road • Key Pedestrian Route • Public Open Space • Wildlife Buffer

20 • Vehicular Access Development Principles

The approach to the masterplan is to provide housing that integrates with the surroundings and makes the most of the surrounding landscape, heritage assets and pedestrian links. The existing green buffer to the A1(M) and the A60 will be enhanced. These elements of the masterplan will help to integrate the development with the village of Wadsworth.

A number of principles have been to enhance the buffers to the A1(M) and Noise and Air Quality identified above as a result of the baseline A60. Open spaces through the site will be The masterplan creates a buffer area assessments. The following key design created through the careful orientation of alongside the A1(M) and around the principles inform the design concept and buildings to open up views to the tower of sewerage pumping station to mitigate are present in the final scheme. They are St John the Baptist Church, which will serve against potential noise, air quality and illustrated on the plan opposite: to enhance legibility within the scheme odour impacts. itself and to its surroundings Highways Layout Residential Design The main vehicular access will be on Ecology Creation of a high quality residential A60, with internal loop, with secondary The masterplan has sought to enhance extension to Wadworth with its own access on A60 proposed to support the the existing boundary treatment. Retaining distinct identity of appropriate scale and development of the whole site. hedgerows where appropriate and where character for the site. More generic design enhancement is necessary this can be principles which will be applied to the planted with appropriate native species. scheme are as follows: Drainage The hedgerows to the open space at the It is proposed that the sustainable drainage south of the site will be retained. • Character – a place with its own solution include permeable surfaces, identity conveyance swales, rain gardens prior to Access • Continuity and enclosure – where attenuation and discharge to the nearby The masterplan allows for pedestrian/ public and private spaces are clearly watercourse, where possible, and public cycle linkages through the site to existing distinguished. sewers. residential streets, and the wider footpath • Quality of the public realm – a place and cycle network, encouraging sustainable with attractive outdoor area Trees and Public Open Space movement in the area. • Ease of Movement – a place that is east The main public open space will be to the to move through south of the site, supporting visual links to • Legibility – a place that is easy to be made with the conservation area. Trees navigate will be used within the scheme to identify • Diversity – a place that offers variety key pedestrian routes, and will be used and choice

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 21 P0-MP-SPA-RP-P4240-0001-0002 Indicative Phasing Plan 1:2,500

WADWORTH HILL (A60)

KEY • Phase 1 22 • Phase 2 Viability and Phasing

Avant Homes pride themselves on delivering high quality homes and places where people want to live. Avant Homes have an excellent track record of delivery and have ambitious plans to delivery 4000 homes/per annum for sale in the UK. Wadworth Hill, Wadworth can be phased to deliver 110 homes initially with a further 115 in a later phase.

Avant Homes intend to dovetail the There are no anticipated infrastructure Viability planning application and site development delivery requirements that will impact The Framework places great emphasis with the Local Plan timetable this will on the timescales for delivery. Whilst the upon the importance of viability (para 67) enable the delivery of housing within the whole site is capable of being delivered and considers that policies should “take local plan period. Avant Homes will submit within the Plan period, the indicative into account availability, suitability, and likely a planning application early Autumn 2020. masterplan, demonstrates that the site economic viability”. Planning permission including section can also be logically phased. Avant Homes 106 would be expected in April 2021. consider that the first phase of around With regards to viability and plan making On site groundworks would be expected 100 dwellings can come forward early in the Guidance states that: “…Policy to commence in May 2021 with the first the Plan period, and if the whole site is not requirements should be informed by…a legal completion to follow in autumn 2022. allocated, the remainder of the site should proportionate assessment of viability that takes Delivery is expected to be through a single be safeguarded or reserved. The phase into account all relevant policies, and local and outlet on site delivering in the region of 2 site is deliverable and therefore can be national standards, transparent and publicly 30-35 dwellings a year. The scheme can released within the Plan period to ensure available.” It is therefore important then therefore be delivered within the first half a sufficient supply of housing is maintained. that requests from the Local Authority of the plan period. are proportionate considering the stage of There are no anticipated infrastructure Local Plan production and potential costs in delivery requirements that will impact on terms of commissioning technical reports the timescales for delivery. associated with demonstrating viability.

Avant Homes do not consider from the information presently available that there are any insurmountable viability issues on this site which will prevent its development for much needed housing.

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 23 P0-MP-SPA-RP-P4240-0001-0002 Illustrative Masterplan 1:2,500

N

Emergency Access Opportunity

SUDS at lowest point of site

New tree planting within buffer from

WADWORTH HILL (A60) A1(M)

Terraced propertoes provide acoustic screening

Vehicular entrance POS provides separation from sewerage pumping station

Housing looking over POs towards conservation area Public Open Space connects into existing routes and playground

24 Deliverable

The land at Wadworth Hill, Wadworth provides a residential development opportunity in a sustainable location close to shops, services and community facilities to meet the needs of urban Wakefield. the site is currently located within the Green Belt and is available, suitable and achievable in accordance with the Framework.

Availability of primary and a secondary schools in the Economics The land is being promoted by Metroland vicinity of the site. The relationship between economic Ltd as landowner. The site is therefore performance in an area and housing is available in accordance with the Framework The site is well served by buses providing complex, but having the right quantity, and the National Planning Practice opportunities for sustainable travel to quality and balance of housing in an area Guidance (PPG). work in Doncaster and beyond with access is necessary for economic growth. The to Doncaster Railway Station. development of Alverley Lane scheme can Suitability therefore support local economic growth, The proposed site utilises a distinct The development will provide additional both through direct job creation through element of the existing Green Belt which quality development that will benefit the construction phase of the scheme, is separated from the wider Green Belt by the Doncaster and wider district with but also through the increased population he disused railway line to the south which economic, environmental and social which will create sustainable local jobs provides a topographic feature separating benefits. It is therefore considered that the from the increased demand for goods the site from the wider Green Belt as well development is suitable. and services. This provides an important as screening views between the site and sustainable development opportunity in the wider Green Belt. The development Achievable Doncaster. of the site will be an efficient use of land A range of technical work has been to provide quality development and new undertaken and is set out elsewhere in Summary homes for the Doncaster Main Urban Area. this document. The assessments indicate The site at Alverley Lane provides a The site is identified for development that there are no technical issues that development opportunity that is available, within the Draft Doncaster Local Plan. would prevent development or are suitable and achievable and therefore it is insurmountable. The site is therefore considered that the site is deliverable, in The site is located in a highly sustainable considered to be achievable. accordance with national planning policy location and has residential development and guidance. It is promoted by Metroland to the north, east and west. The site is The indicative masterplan shows how a Ltd with interest in development from within easy walking distance to Springwell mix of housing can be accommodated Persimmon Homes and Ongo and is Lane Local Centre with a range of facilities within the site, alongside connectivity, deliverable within the plan period. provided there as well as greater facilities landscaping and drainage features. The site within Doncaster Town Centre, a short has interest from Persimmon Homes and bus ride away. There are a large number Ongo (Registered Provider).

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 25 P0-MP-SPA-RP-P4240-0001-0002 Illustrative Masterplan 1:2,500

WADWORTH HILL (A60)

26 Conclusion

The land at Wadworth Hill provides an opportunity to deliver new housing in Wadworth to meet the needs of Wadworth supporting its long term vitality and viability and meet the needs of the wider Borough. The site is available, suitable and achievable in accordance with the Framework. It presents a deliverable residential opportunity on the edge of an existing village.

There is a need for Doncaster council to coming forward within the plan period. which will create sustainable local review their Green Belt boundaries to As such the development of the site as jobs from the increased demand for meet housing need and demand in the shown in the indicative masterplan is goods and services. This provides area. This advocacy supports the allocation considered achievable. important sustainable development in of the site and agrees and considers that there are exceptional circumstances the Borough but importantly support supporting the release of the site from The indicative masterplan shows how a the long term vitality and viability of the Green Belt due to the need to meet mix of housing can be accommodated Wadworth including the viability of the Doncaster’s housing need and ambitions within the site, alongside connectivity, Primary School (capacity 210, current for growth. No robust reason to restrict landscaping and drainage features. The no. of pupils 149 (July 19)). the development of Large Villages such as scheme is being promoted by Avant and Wadworth. Support Vitality and viability. will go towards meeting the housing It has therefore been shown that requirement/ need in the area. the site at Wadworth Hill provides Avant Homes are promoting the site a development opportunity that is for inclusion in the Local Plan. The site The development will bring forward available, suitable, and achievable and it is therefore available for residential additional economic benefits to the area. is considered deliverable, in accordance development within the Plan period. The relationship between economic with the national planning policy and The site is in a suitable location, close performance in an area and housing is guidance. It is promoted by Avant to a range of facilities and services and complex but having the right quantity, homes, the fastest growing house public transport routes and is suitable quality, and balance of housing in an builder in the UK and is deliverable for residential development. area is necessary for economic growth. within the plan period. The scheme The development of the Wadworth Hill has significant housing and economic The technical work undertaken to date scheme can support local economic benefits for the area and therefore has influenced the indicative masterplan. growth through both direct job growth suitable for allocation. It has shown that there are no known through the construction phase but constraints, that could not be suitably also through increased population mitigated or that would prevent this site

Wadworth Hill, Wadworth - Delivery Statement - Sept 2019 27 P0-MP-SPA-RP-P4240-0001-0002 Key Benefits

Optimum location to assist in the continued growth of the Doncaster Borough

The delivery of circa 225 new homes in a range of house types, sizes and tenure

Circa 790 new jobs (direct and in-direct) from the construction of the residential scheme alone

GVA Gross Value Added of around £16.03 million

Circa £5.57 million Annual Household Expenditure

At least £1.13 million of first occupation expenditure

P0-MP-SPA-P4225-1RP-0001-0001 Doncaster GREEN LANE, SCAWTHORPE Strategic Location Plan

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Thorne Askern River Dun Navigation

A19 Carcroft M180 Hatfield

Adwick le Street River DonEdenthorpe Bentley

Armthorpe A1(M) M18 Doncaster

Sprotborough Walton

Denaby Main Finningley

Conisborough New Edlington Rossington Doncaster Sheffield Airport A638

Braithwell

Tickhill

ii Introduction

The land at Green Lane, Scawthorpe presents a sustainable development opportunity to provide new housing for Doncaster. The site is being promoted by Avant Homes as a development opportunity that can deliver approximately 500 dwellings.

Background Primary School within 5 minutes walk of extension to the urban area of Doncaster This advocacy document has been produced the site and both Don Valley Academy and and supports the continued housing and for the site at Green Lane, Scawthorpe. Ridgewood School within 0.5 miles offering economic growth of the town. secondary and sixth form education. The site is being advocated to Doncaster Objectives Metropolitan Borough Council (DMBC) The A638 Great North Road / York Road The key objectives of the scheme are to: as part of the Local Plan Review. This is close to the site and provides direct • Bring forward suitable Green Belt land document presents information to support routes into Doncaster Town Centre, for development. the allocation of this site and to underline approximately 2.5 miles to the south- • Provide new public open space and the site’s deliverability credentials. east. Barnsley Road (A630) to the south improve pedestrian and vehicular provides access to the A1(M) Junction linkages The site is located to the north-west of 37 less than 2.5 miles from the site to • Deliver in the region of 500 new homes Scawthorpe in an area currently designated the west. Great North Road (A638) also to meet the needs of the Borough. as Green Belt. It is circa 20 Ha in area. continues through Adwick le Street to the • Support an attractive neighbourhood The site is within 5 mins walk (400m) north before providing access to the A1 in Doncaster. from Great North Road / York Road with Junction 38 just over 3.5 miles from the good access to major bus routes. It is also site. This gives the site easy access to local Scope approximately 1 mile from Scawsby local and regional employment opportunities. The scope of this document is to set out centre. the credentials for land at Green Lane, The site is adjacent to existing housing to Scawthorpe as a residential development The site is to the north of a site which is the south-east. Green Lane forms a strong opportunity and to seek its allocation being promoted through the Local Plan and northern boundary to the site. The Roman as a housing site through the Local Plan was previously a Draft local Plan allocation. Ridge to the west also forms a robust Review. This is set in the context of the The Green Lane site completes the urban boundary for heritage reasons as well as opportunity that the site provides to block with this allocation utilising Green due to the significant planting alongside it. contribute towards delivering new housing Lane and the Roman Ridge to provide a for Doncaster and the economic growth new robust Green Belt boundary. The site represents a highly sustainable aspirations for the wider Borough. development opportunity with access to The site is well conThere is Rosedale existing facilities and services. It is a logical

Green Lane, Scawthorpe - Site Advocacy - Sept 2019 1 P0-MP-SPA-RP-P4226-0001-0001 DMBC UDP Map 3 Combined 1998: Doncaster North

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Site

Key

Site

Adjacent Site 2 Planning and Housing Need

There is a significant and recognised housing crisis within the UK. The country needs to provide around 300,000 homes per year to keep up with population growth and to start to tackle years of undersupply. Within Yorkshire significant stresses on housing supply also exist. The Local Authorities in Doncaster, Wakefield, Barnsley, Rotherham, Sheffield, Selby and Leeds need to provide at least 11,670 new homes per year cumulatively.

The revised National Planning Policy level of new housing needs to reflect the system plays a crucial role in this approach Framework, 2019 (The Framework) ambitions of the Strategic Economic Plan. to facilitating new development proposals. states that local authorities should meet Furthermore, the SCR Integrated NPPG recognises that a wide range of their objectively assessed housing needs Infrastructure Plan states: settlements should play a role in delivering in full and boost significantly the supply sustainable development in rural areas, A quality housing offer has a crucial role to play in the of housing. The Local Plan – Publication future economic growth of the City Region. It is essential and does not support blanket policies that Version recognises the need to deliver a to attract and retain a skills base that supports inward restrict housing development in some types sufficient supply of housing and support investment as meeting existing and future community of settlement without robust evidence. economic development and growth now needs and retention of Sheffield City Region (SCR) talent. to create sustainable communities. It has been identified that between 70,000 and 100,000 Doncaster is a sub-regional centre additional homes are needed in SCR. To support the providing a sustainable location comprising The Borough of Doncaster is located on proposed economic growth over the next 10 years. These a wide variety of housing, commercial will have the dual benefit of providing accommodation the crossroads of the main arterial routes that underpins the proposed increase in employment and employment opportunities and good of the A1(M) and M18 Motorways as well (70,000 jobs), as well as the wider economic benefits rail and road connections to the wider as being a major station on the East Coast that housing investment brings. area. Scawthorpe is within the Doncaster Mainline and on a key route between the Main Urban Area within the emerging Region and the east coast ports. Doncaster The current wider economic context in Doncaster Local Plan. The Main Urban is an integral part of the Sheffield City the country is also relevant. The economic Area is required to provide 50% of the Region (SCR) and its ambitious growth decline and associated recovery, its impact housing growth (6,805-7,315 homes). aspirations. The SCR Strategic Economic on the housing market and increasing Plan sets out the plan to transform the housing crisis means schemes that assist The Green Lane site therefore represents local economy over the next decade. At economic and housing growth, are high an opportunity to provide quality housing the heart of the plan is the creation of on the Governments priorities. The in a sustainable location to go towards 70,000 new private sector jobs and 6,000 Localism Act, The Framework, Ministerial meeting the housing needs of delivering new businesses. statements and budgets recognise the much needed new homes within Doncaster. importance of housing and significant Therefore to achieve the aspired growth economic imperative of encouraging new that the SCR is seeking to achieve and development proposals within appropriate is securing government funding for the and sustainable locations. The planning

Green Lane, Scawthorpe - Site Advocacy - Sept 2019 3 P0-MP-SPA-RP-P4226-0001-0001 DMBC UDP Map 3 1998 with Green Belt highlighted and Site Identified

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Site

Key

Site

Adjacent Site 4 Available and Suitable: Green Belt

The housing needs of Doncaster are putting severe pressure on the local authority to review the Green Belt. To meet the housing requirement Doncaster Council recognises that some Green Belt land will need to be released for new housing land. There is opportunity to review the Green Belt in the surrounding area to positively use the Green Belt and meet the housing need for Doncaster.

Available The site performs a limited Green Belt allocation, there are sites that perform slightly Avant Homes control the land at Green function and the release of this site and better through the Sustainability Appraisal Lane, Scawthorpe. The land is therefore the adjacent site would help to establish a and sufficient allocations now identified”. It available in accordance with national more appropriate and robust Green Belt is considered that Green Lane and the guidance. The site and the adjacent site boundary utilising Green Lane and the adjacent site are both appropriate housing to the sout are a logical location to grow Roman Ridge. The sites development will sites. Doncaster and Avant Homes have direct have limited impact on the openness of the frontage onto Green Lane. There are no Green Belt. The site and the adjacent site It is clear that development of the site landownership, legal or other constraints to the south are bounded the urban area. would not have a material impact on the which would restrict the availability of the Green Belt. The development of this site site for housing use. The site is therefore The proposed Green Belt boundary is will not have a significant impact on any of available and does not rely on third party would accord with the Framework and the reasons for the Green Belt designation land to be delivered. ensure the Green Belt is well defined for in the area. The new Green Belt boundaries the long-term. Green Lane and the Roman will be drawn to provide a long term robust Suitable: Green Belt Ridge are distinct features beyond which boundary. The development will not result In the Borough of Doncaster approximately the urban edge will not encroach, thus in the coalescence of neighbouring towns, 46% of the area is designated as Green Belt. ensuring permanency is maintained. and will not encroach on the countryside This is the western part of the Borough nor affect the setting and special character which forms part of the South Yorkshire The Green Lane site is therefore a unique of an historic town. Therefore, although Green Belt surrounding urban areas. opportunity to meet the housing need the site is in the Green Belt it is a logical and economic growth aspirations whilst scheme with significant major benefits. The Framework considers that Green Belt delivering significant benefits for the area. boundaries can change “in exceptional When identifying the adjacent site at Draft Green Lane, Scawthorpe is a site that does circumstances” as part of a Local Plan Local Plan Stage the Council has stated that not perform any of the five Green Belt review. Such a circumstance exists through “The site has been found to have a moderate functions and as such is an appropriate site the significant need to provide housing in case for inclusion in further site selection work for release to deliver additional housing Doncaster. To meet the housing need and by the Phase 3 Green Belt Review” and that allocations for the Borough and the economic growth aspirations the Council the Green Lane site (although rejected Doncaster Main Urban Area. has stated it will need to revise the Green along with the adjacent site) “has been Belt boundaries for the emerging Local Plan identified as performing the same through the and beyond to provide the new boundaries Green Belt Review Phase 3 as other sites at with some permanence. the settlement which are being proposed for

Green Lane, Scawthorpe - Site Advocacy - Sept 2019 5 P0-MP-SPA-RP-P4226-0001-0001 Canal Lane Comprehensive Settlement Analysis Plan 1:5,000

To Adwick-le-Street and A1 Junction38 KEY N Great North Road • Education • Healthcare Park and Ride • Community (Churches, Sports, etc) • Retail • Industrial/Commercial 40m AOD 30m AOD • Public Open Space (Formal eg Sports) • Commercial Facilities • Pubs/ restaurants To Pickburn and Brodsworth Hall • Local or District Centre • Bus route and stops • Public Footpaths • Listed Building (Grade II) • Public Open Space (Informal)

SITE

Roman Ridge

30m AOD

A638 York Road

Adjacent Potential Housing Site

20m AOD

To the A1 Junction 37

Barnsley Road ALDI

40m AOD

6 45m AOD

To Doncaster Town Centre Suitable: Settlement Analysis

The Green Lane site is located to the west of Scawthorpe in Doncaster borough. The site is within walking distance to Great North Road which leads directly to Doncaster city centre. Along the Great North Road there are a number of community facilities. There are also numerous bus services which pass close to the site connecting the area with central Doncaster.

The proposed site is located on the north- which are located approxiamtley 10min- to ACCESS TO FACILITIES west edge of Scawthorpe adjacent to 24 minutes walk. Facility Distance Approx. Location the urban area and a number of existing to journey closest time facilities. The bus services along York Road, close to (miles) (mins) the site providing up to five buses in half Supermarket 1 mile 10 mins Barnsley The Great North Road / York Road (A638) an hour into Doncaster Town Centre in Bus Road and Barnsley Road (A635) provides a morning hours. Local Shop(s) 1 mile 10 mins Barnsley Bus Road number of services and facilities including Post Office 3 miles 28 mins Nether convenience and retail shopping. There are Doncaster Railway Station is 3.5 miles from Bus Hall also medical facilities at Amersall Road, the site and can be reached following a 23 Library 1 mile 20 mins Amersall employment opportunities within and minute bus ride from York Road. Bentley Walk Road around Danum Retail Park, along Pipering Railway Station is 1.6 miles from the site Town Centre 2.5 miles 23 mins Doncaster Bus Lane and Barnsley Road, There are also and can be reached following a 7minute car GP Surgery 1 mile 20 mins Amersall regular buses to Doncaster Town Centre drive from Green Lane. Walk Road and a Park and Ride facility within walking Hospital 3.8 miles 40 mins Doncaster distance of the site. Doncaster station is extremely well Bus Royal Inf. connected by the East Coast Mainline Dentist 1.4 miles 15 mins Halifax Bus Crescent There is number of primary schools to the with services to London (2 hrs), Leeds (33 Nursery 1.8 miles 15 mins Grove south of the site within the walking distance: mins), Newcastle (1:30 hrs), Manchester Bus Avenue Stone Hill School (0.8miles), Rosedale Airport (1:44 hrs), York (20 mins), Sheffield Primary School 0.4 miles 5 mins Rosedale Primary School (0.8miles), Scawthorpe (26 mins), Penzance (7:45 hrs) and Hull Walk Primary Sunnyfields Primary School (1.2 mile).The (50 mins) among other places. The ease Secondary School 0.4 miles 5 min Don Valley Walk Academy Castle Hills Primary School (0.9 mile) to of access to the station from the site using Park / Playground 1.3 miles 15 mins Roman the east of the site is approximately 20 public transport adds to the sustainability Bus Ridge minutes walk from the site. of the site. Sports Pitches 1.3 miles 13 mins Langdale Bus Drive Bus Stop 0.2 miles 4 mins Tickhill The closest secondary school is Don Walk Road Valley Academy (0.4 mile) to the east and Train Station 2.5 miles 23 mins Doncaster Ridgewood School (1.2 mile) to the south Bus

Green Lane, Scawthorpe - Site Advocacy - Sept 2019 7 P0-MP-SPA-RP-P4226-0001-0001 Site Photograph Location Plan

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2 1 3 4 4

5

Adjacent Site 6

8 Site Photographs

1

View from the Green Lane looking towards the eastern boundary of the site. The image shows on the left the existing housing stock and open views of the site with the hedge on horizon identifying the southern boundary of the site.

2 3

The existing housing stock off Green Lane dominated by the feature of water tower. View from the site off Green Street toward the nearby agricultural land.

4 5 6

Western boundary of the site is framed by View from the site Roman Ridge towards the View of the site from Sycamores Drive. Roman Ridge. site.

Green Lane, Scawthorpe - Site Advocacy - Sept 2019 9 P0-MP-SPA-RP-P4226-0001-0001 Site Photograph Location Plan

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14

13

10

9 8

Adjacent Site

7

11 10

9 Site Photographs

7 8

New housing development accommodating Site view off Roman Ridge towards the southern boundary defined by hedge seen on the horizon. predominately bungalows at the boundary with the site.

9 10 11

View along the hedgerow crossing the site Image of the housing stock at Charter Drive. Distant view of the site off Barnsley Road. towards the housing off Charter Drive.

12 1312 14

Typical housing stock located between York Large detached dwellings at Charter Drive. York Road with the mature tree line and large Road and Barnsley Road. detached residential properties along it.

Green Lane, Scawthorpe - Site Advocacy - Sept 2019 11 P0-MP-SPA-RP-P4226-0001-0001 Site Issues & Opportunities Plan 1:2,500

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Green Lane

30m AOD

35m AOD

Don Valley Academy

Roman Ridge 30m AOD

Adjacent 25m AOD Site

KEY Residential Opportunity for Vehicular Access Development under construction Public Right Of Way-Roman Ridge Existing Residential Units Employment Uses Footpath Opportunity for connection to Public Right of Way 20m AOD Landmark Feature Closest Existing Bus Stops Existing Green Spaces and Routes Obscured Views Desirable views from site Hedge

12 Achievable: Site Issues & Opportunities

The Green Lane Site at Scawthorpe is provides a number of opportunities which any proposed development can utilise in order to add to the Scawthorpe neighbourhood and to integrate the development into Doncaster.

The Site Access services with regular services on Great The total site is approximately 20ha located There is opportunity for vehicular access North Road linking the site with central to the north west of Scawthorpe. from Green Lane on the northern boundary Doncaster. of the site. There is also opportunity Topography for the site to be accessed through the Facilities The site slopes gently from the high point adjacent land to the south to deliver a The site is extremely well located to allow on the northern boundary to the low point comprehensive development for the area. for the new residents to live sustainably. in the south-western corner. The southern There is easy access to schools, shops, boundary is defined by a matured hedge The Roman Ridge on the western libraries, etc within 10 mins walk of the separating the site from the potentially boundary of the site provides opportunity site. Connections to these facilities will be future developable land. The Roman Ridge for pedestrian and cycle connections into facilitated within the development. along the western boundary with the Doncaster from the site. existing vegetation screens the views to the adjacent farm land. Ecology As part of an active farm the site has very The site abuts to the established housing little ecological value across the majority. development on the east. However there are areas, at the edges where hedgerows and trees provide From the northern boundary of the site opportunity for habitat. there are long distance views north Transport The site is well served by existing bus

Green Lane, Scawthorpe - Site Advocacy - Sept 2019 13 P0-MP-SPA-RP-P4226-0001-0001 Illustrative Masterplan - not to scale

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Housing overlooking GREEN LANE Green Lane and fields to the north

SUDS at lowest point of site

Housing Housing overlooking YORK ROAD overlooking public open Roman Ridge space with views into Doncaster

Opportunities for pedestrian and cycle connections to the Roman ROMAN RIDGE Ridge

ADJACENT DEVELOPMENT SITE Public Open Space forms a focus for the new and existing residents

14 Deliverable

The land at Green Lane, Scawthorpe provides a residential development opportunity in a sustainable location close to shops, services and community facilities to meet the needs of urban Doncaster. The site is currently located within the Green Belt and is available, suitable and achievable in accordance with the Framework.

Availability a range of facilities provided in these Economics The land is being promoted by Avant Homes, locations. There are also greater facilities The relationship between economic as developer. The site is therefore available within Doncaster Town Centre, a short performance in an area and housing is in accordance with the Framework and the bus ride away. There are a large number complex, but having the right quantity, National Planning Practice Guidance (PPG). of primary and a secondary schools in the quality and balance of housing in an area vicinity of the site. is necessary for economic growth. The Suitability development of the Green Lane scheme can The proposed site utilises a distinct element The site is well served by buses providing therefore support local economic growth, of the existing Green Belt which forms a opportunities for sustainable travel to both through direct job creation through wedge between the urban neighbourhood work in Doncaster and beyond with access the construction phase of the scheme, areas of Scawthorpe and Scawsby. The to Doncaster Railway Station. but also through the increased population allocation of this site along with the site which will create sustainable local jobs to the south, being advocated by Strata The development will provide additional from the increased demand for goods Homes forms a logical “rounding” of the quality development that will benefit and services. This provides an important urban area in an area of doncaster where the Doncaster and wider district with sustainable development opportunity in new homes are attractive to the market. economic, environmental and social Doncaster. Green Lane and the Roman Ridge Road benefits. It is therefore considered that the form robust boundaries to contain the development is suitable. Summary growth of Doncaster in this area and The site at Green Lane provides a maintain separtion from Highfields, to the Achievable development opportunity that is available, north. The development of the site will be The technical assessments undertaken to suitable and achievable and therefore it is an efficient use of land to provide quality date indicate that there are no technical considered that the site is deliverable, in development and new homes for the issues that would prevent development or accordance with national planning policy Doncaster Main Urban Area. are insurmountable. The site is therefore and guidance. It is promoted by Avant considered to be achievable. Homes and is deliverable within the plan The site is located in a highly sustainable period. location and has residential development to The indicative masterplan shows how a mix the south, east and west. The site is within of housing can be accommodated within easy walking distance to local facilities at the site, alongside connectivity, landscaping Barnsley Road and Amersall Road with and drainage features.

Green Lane, Scawthorpe - Site Advocacy - Sept 2019 15 P0-MP-SPA-RP-P4226-0001-0001 Key Design Principles Plan - not to scale

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GREEN LANE

YORK ROAD

ROMAN RIDGE

ADJACENT DEVELOPMENT SITE

KEY Main Access Road Key Pedestrian Route Public Open Space Landscape for Heritage and Acoustic Buffer Vehicular Access 16 Opportunity for connection to adjacent site Development Principles

The approach of the masterplan is to provide housing which integrates with the surrounding area making the most of the surrounding landscape and the pedestrian links. The Roman Ridge to the east of the site will be reinforced and providing a buffer separating the development from the disused railway embankment. These elements of the masterplan will help to integrate the extended urban edge into Scawthorpe.

A number of principles have been identified Public Open Space Residential Design above as a result of the baseline assessment. The main public open space (POS) within Creation of a high quality residential the development lies on the southern extension to Scawthorpe having its own The following key design principles inform edge of the site. This will enable the public distinct identity of appropriate scale and the design concept and are present in the open space to function as a resource for character for the site. More generic design final scheme. They are as illustrated on the the wider community and support the principles which will be applied to the plan opposite: integration of the two development sites scheme are as follows: into the existing neighbourhoods. Being • Character - a place with its own alongside the Roman Ridge pedestrian Highways Layout and cycle route will enable connections identity The main vehicular site accesses will be between the development and the Roman • Continuity and enclosure - where located on Green Lane with internal loop Ridge. public and private spaces are clearly roads within the proposed development. distinguished • Quality of the public realm - a place Drainage Access with attractive outdoor areas The masterplan allows for pedestrian/ It is proposed that the Sustainable Urban • Ease of movement - a place that is easy cycle linkages through the site to the Drainage solution be at the lowest point of to get to and move through the site and stored within swales. Roman Ridge on the western boundary. This route will provide opportunity for the • Legibility - a place that is easy to new residents to walk or cycle to the Local navigate facilities and into Doncaster. Ecology • Diversity - a place that offers variety The proposed development seeks to and choice reinforce the existing habitat routes through the site along the edges with additional hedge and tree planting.

Green Lane, Scawthorpe - Site Advocacy - Sept 2019 17 P0-MP-SPA-RP-P4226-0001-0001 Illustrative Masterplan - not to scale

GREEN LANE

YORK ROAD

ROMAN RIDGE

ADJACENT DEVELOPMENT SITE

18 Conclusion

The land at Green Lane provides an opportunity to deliver new housing in a sustainable location to meet the needs of the Doncaster Main Urban Area and the wider Borough. The site is available, suitable and achievable in accordance with the Framework and represents a sustainable residential opportunity on the edge of an established residential area.

There is a need for Doncaster Council constraints, that could not be suitably Lane scheme can therefore support local to review their Green Belt boundaries to mitigated, that would prevent this site economic growth, both through direct job meet the housing need and demand in the coming forward within the plan period. creation through the construction phase of area. This Advocacy Report proposes the As such, the development of the site, as the scheme, but also through the increased allocation of the site and that there are shown within the indicative masterplan, is population which will create sustainable exceptional circumstances supporting the considered achievable. local jobs from the increased demand release of the site from the Green Belt due for goods and services. This provides to the urgent need to meet Doncaster’s The indicative masterplan shows how a mix an important sustainable development housing need and ambitions for growth. of housing can be accommodated within opportunity in the Doncaster Borough. the site, alongside connectivity, landscaping Avant Homes control the site and are and drainage features. The scheme is being It has therefore been shown that the site promoting it for inclusion in the Local promoted by Avant Homes and will go at Green Lane provides a development Plan. The site is therefore available for towards meeting the housing requirement/ opportunity that is available, suitable and development within the plan period along need in the area. achievable and that it is considered that with the adjacent site to the south. The the site is deliverable, in accordance with sites are in a sustainable area close to a Furthermore, the development of the site national planning policy and guidance. It range of services and facilities and public will bring forward additional economic is promoted by a national house builder transport routes. The site is therefore benefits to the area. The relationship (Avant Homes) and is deliverable within suitable for residential development. between economic performance in an area the plan period. The scheme has significant and housing is complex, but having the right housing and economic benefits for the The technical work undertaken to date quantity, quality and balance of housing area and is therefore eminently suitable for has influenced the indicative masterplan. It in an area is necessary for economic allocation. has also shown that there are no known growth. The development of the Green

Green Lane, Scawthorpe - Site Advocacy - Sept 2019 19 P0-MP-SPA-RP-P4226-0001-0001 Key Benefits

Optimum location to assist in the continued growth of the Doncaster Main Urban Area

The delivery of circa 500 new homes in a range of house types, sizes and tenure

Circa 1,750 new jobs (direct and in-direct) from the construction of the residential scheme alone

GVA Gross Value Added of around £35.61 million

Circa £12.38 million Annual Household Expenditure

At least £2.5 million of first occupation expenditure

P0-MP-SPA-P4226-1RP-0001-0001

20