Metroland (05216)

From: Spawforths on behalf of Metroland Sent: 30 September 2019 17:04 To: Local Plan Subject: Doncaster Local Plan Representations Importance: High

Please find attached representations to the Doncaster Local Plan on behalf of Metroland, in respect of their interests in Doncaster.

The representation covers the following matters:

 General Comments  Policy 6 - Housing Allocations, o Site 115: Alverley Lane, Balby; MUA  Policy 8 - Delivering the Necessary Range of Housing.  Policy 14 - Promoting Sustainable Transport in New Developments  Policy 19 - Development Affecting Public Rights of Way  Policy 20 - Access, Design and Layout of public rights of Way  Policy 27 - Green Infrastructure  Policy 29 - Open Space in New Developments.  Policy 42 - Character and Local Distinctiveness  Policy 43 - Good Urban Design  Policy 46 - Housing Design Standards  Policy 66 - Developer Contributions  Policy 67 - Development viability  Housing Site 115; Alverley Lane, Balby; MUA

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 Metroland (Alverley Lane, Balby)

September 2019

Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019

1. Introduction

1.1. Spawforths have been instructed by Metroland to submit representations to the Doncaster Local Plan 2015-2035 Publication Version and for their site at Alverley Lane, Balby (Site 115).

1.2. Metroland welcomes the opportunity to contribute to the Doncaster Local Plan and are keen to further the role of Doncaster within the Sheffield City Region, South Yorkshire and the Yorkshire and Humber Region as a whole.

1.3. Metroland have a significant land interest in the area which can positively contribute towards the economic and housing growth agenda.

1.4. Metroland would like to make comments on the following policies in the Doncaster Local Plan 2015-2035 Publication Draft:

• General Comments • Policy 6 - Housing Allocations,

o Site 115: Alverley Lane, Balby; MUA • Policy 8 - Delivering the Necessary Range of Housing. • Policy 14 - Promoting Sustainable Transport in New Developments • Policy 19 - Development Affecting Public Rights of Way • Policy 20 - Access, Design and Layout of public rights of Way • Policy 27 - Green Infrastructure • Policy 29 - Open Space in New Developments. • Policy 42 - Character and Local Distinctiveness • Policy 43 - Good Urban Design • Policy 46 - Housing Design Standards • Policy 66 - Developer Contributions • Policy 67 - Development viability • Housing Site 115; Alverley Lane, Balby; MUA

1.5. In each case, observations are set out below with reference to the provisions of the Framework and amendments are suggested to ensure that the Local Plan is made sound.

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1.6. Metroland welcome the opportunity for further engagement and the opportunity to appear at the Examination in Public.

1.7. We trust that you will confirm that these representations are duly made and will give due consideration to these comments.

1.8. Please do not hesitate to contact us to discuss any issues raised in this Representation further.

Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019

2. National Planning Policy Context and Tests of Soundness

2.1. The Government's core objectives as established through the 2018 National Planning Policy Framework (the 2019 Framework) are sustainable development and growth. Paragraph 11 of the Framework stresses the need for Local Plans to meet the objectively assessed needs of an area. The 2019 Framework sets out to boost significantly the supply of homes and that a sufficient amount and variety of land can come forward where it is needed. In terms of building a strong and competitive economy the 2019 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2019 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes.

2.2. In relation to Local Plan formulation, paragraphs 15 to 37 of the Framework states that Local Plans are the key to delivering sustainable development which reflects the vision and aspirations of the local community. The Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where.

2.3. In relation to the examination of Local Plans, paragraph 35 of the Framework sets out the tests of soundness and establishes that:

2.4. The Local Plan and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sounds. Plans are ‘sound’ if they are:

Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development

Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

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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 Metroland in light of this planning policy context.

Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019

3. General Comments

3.1. Metroland 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. Metroland 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. Metroland is concerned that the Local Plan does not reflect the Framework (2019). Metroland 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 further evidence is required to justify key policies.

3.4. Metroland 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.

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

Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019

3.6. However, Metroland consider that the plan can be made sound subject to proposed changes as set out within the following sections of these representations. Metroland will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

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

• 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.

Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019

4. Policy 6: Housing Allocations (Strategic Policy)

4.1. Metroland is supportive of Policy 6 and its allocation of the Alverley Lane, Balby; MUA site (Site 115).

Test of Soundness

4.2. Metroland considers that the Doncaster Local Plan – Publication Version 2015-2035 is sound.

Which test of soundness are comments about?

X Positively Prepared X Effective

X Justified X Consistency with National Policy

Justification

4.3. Metroland supports the allocation of their site at Alverley Lane, Balby; MUA and its identification as a proposed housing site. Technical studies are ongoing but initial assessments demonstrate the site’s deliverability.

4.4. Metroland 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.

4.5. The deliverability and benefits of the Alverley Lane, Balby; MUA are set out in Section 18 and summarised below.

4.6. The proposal is an appropriate site to provide for the housing needs of Doncaster in the short term. The allocation of the site would confirm its potential to help continue the provision of a balanced housing supply in the Borough in sustainable locations. The site can deliver a full range and mix of housing and a sustainable community. Development of the site would deliver housing and affordable housing. Doncaster needs to have a robust housing trajectory and the

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site at Alverley Lane, Balby would assist with this delivery in the short term. The site is situated within a prime location suitable for residential development and as such would facilitate the development of land in a more effective and efficient manner. Development of the site would not harm or undermine the areas wider policy objectives, but seeks to reinforce the need to develop sites within sustainable locations as a priority.

4.7. Metroland would reiterate that Doncaster have recognised that some greenbelt land will need to be released in order to meet its housing needs. As indicated in the Advocacy previously submitted the land at Alverley Lane, Balby does not perform any of the five green belt functions, as set out in the Framework (paragraph 134), and its release from the greenbelt can be justified.

4.8. The submitted Advocacy document also summarised the technical work that had been undertaken. This concludes that a safe and suitable access can be made and confirms the highways networks ability to accommodate the proposed development. With regards to flooding and drainage the site is in Flood Zone 1 and is not in an area at risk from flooding. The drainage work identified a drainage strategy for the site. It confirmed attenuation was required on site and that the proposed location was suitable. The ecological survey confirmed that there are no ecological constraints and that the site is of low ecological value. Development of the site offers the opportunity to enhance the ecological value through new planting. Further there are no known infrastructure capacity issues that would preclude the development of this site.

4.9. The proposed allocation policy should therefore be flexible to reflect this evidence base and ensure delivery of the scheme. The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.

4.10. Metroland supports the allocation of Site 115 consider that the Policy 6 is Sound in this regard.

Proposed Change

No Change

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5. Policy 8: Delivering the Necessary Range of Housing (Strategic Policy)

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

Test of Soundness

5.2. Metroland 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

5.3. Metroland is concerned with a number of approaches and criteria established within Policy 8.

Housing Mix

5.4. Metroland 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.

5.5. 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 affordable dwellings, in terms of number of bedrooms. Therefore there is a lack of evidence

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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. Metroland reserve the right to comment further when this becomes available.

5.6. 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.

5.7. 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.

5.8. Metroland 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. Metroland 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, Metroland 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

5.9. Metroland 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 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.

Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019

5.10. 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.

5.11. 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.

5.12. 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. It is noted that the value areas have changed within the update. Areas previously identified as lower value areas have now been identified as medium to high in some cases.

5.13. 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.

5.14. Metroland are concerned that there is little evidence to support an affordable housing target of 15% in low value areas. Metroland 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.

5.15. Metroland 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

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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.

5.16. 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

5.17. 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. Metroland supports the adaptation of the existing stock and encouraging the provision of adaptable, accessible homes. However, as explained in response to Policy 46 Metroland object and does not consider it appropriate to require all developments to include this provision.

Custom and Self Build Homes

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

5.19. Metroland 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.

5.20. Metroland consider that the requirements in Policy 8 are not justified and do not provide an appropriate strategy. Metroland 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

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fail to deliver sustainable development in accordance with the policies in the Framework and is not consistent with national policy.

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

5.22. However, Metroland 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. Metroland will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

5.23. 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;

• Revise the approach to affordable housing to ensure that the evidence base and viability is robust and credible; and

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

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6. Policy 14 – Promoting Sustainable Transport in New Developments

6.1. Metroland are concerned with aspects of Policy 14, Metroland consider that Policy 14 is unsound.

Test of Soundness

6.2. Metroland 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

6.3. Metroland is supportive of the principles of Policy 14, However Metroland are concerned with aspects of the policy.

6.4. Metroland are concerned with part A-4 which seeks to ensure that appropriate levels of parking provision are made in accordance with the standards contained within Appendix 6.

6.5. Appendix 6 notes, that for residential development, parking provision will be considered on a case by case basis. Metroland considers that Policy 14 part A 4 should be revised to ensure that the policy is flexible in relation to residential development, and ensure that the policy is consistent with the text within Appendix 6.

6.6. Further, Metroland are concerned with Part B of the policy which requires post development monitoring of traffic and mitigation measures in the event that traffic levels agreed through the original permission are later exceeded.

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6.7. Metroland consider that this is onerous and increases uncertainty for developers in relation to the cost of the development. It is unclear how this requirement will be enforced.

6.8. Policy 14, in its current form, is not justified and does not provide an appropriate strategy and is not consistent with national policy.

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

6.10. However, we consider that with increased flexibility in part A 4 in line with the text within Appendix 6, and removal of the requirement for post development monitoring and mitigation under part B the Plan can be found sound. Metroland will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

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

• Provide greater flexibility residential development in Policy 14 Part A 4 and improve consistency with Appendix 6.

• Remove the part B requirement for post development monitoring of traffic and mitigation.

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7. Policy 19: Development affecting Public Rights of Way

7.1. Metroland is concerned with aspects of Policy 19.

Test of Soundness

7.2. Metroland 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. Metroland 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.

7.4. Metroland 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.

7.5. Metroland 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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7.6. Metroland consider that the policy with increased flexibility or removal of part D of Policy 19 it can be made sound. Metroland will continue to work with the Council to develop appropriate wording.

Proposed Change

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

• Incorporate flexibility or remove part D of the policy.

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

8.1. Metroland is concerned with aspects of Policy 20 and therefore consider that the Policy 20 is unsound.

Test of Soundness

8.2. Metroland 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. Metroland is concerned with parts B and C of the policy which specifies the routes and dimensions of public rights of way.

8.4. Metroland 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.

8.5. 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.

8.6. Metroland consider that the policy in its present form is not justified and consider that the Plan is unsound.

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

Proposed Change

8.8. 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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9. Policy 27: Green Infrastructure

9.1. Metroland is concerned with some aspects of Part A of Policy 27, that require a green infrastructure masterplan on schemes that provide 30 family dwellings or more. Metroland consider that this is unnecessarily onerous for schemes at this scale and consider that the Policy 27 is unsound.

Test of Soundness

9.2. Metroland 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. Metroland is concerned with part A of the policy which requires a green infrastructure masterplan for schemes of over 30 family dwellings. Whilst Metroland understands the aims and objectives of the policy, Metroland consider that the requirement for a Green Infrastructure Masterplan on schemes of this scale is unnecessarily onerous. The requirement to provide a masterplan will add to cost and impact on timescales for delivery, potentially adding up to a year to the planning process. .

9.4. Flexibility therefore needs to be incorporated into Policy 27 so that the policy encourages rather than requires the provision of a masterplan for schemes over 30 family dwellings or the threshold should be significantly increased.

9.5. The requirement is not justified, it is unnecessarily onerous and does not provide an appropriate strategy. The Plan is its present form could fail to deliver sustainable development

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in accordance with the policies in the Framework and is not consistent with national policy.

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

9.7. However, we consider that with increased flexibility in Part A of the Policy the Local Plan can be found sound. Metroland will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

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

• Amend Policy 27 to include flexibility and “encourage” rather than “require” a green infrastructure masterplan or review the threshold that the policy applies.

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10. Policy 29: Open Space Provision in New Developments

10.1. Metroland 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. Metroland 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. Metroland 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. Metroland 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 sum could undermine the deliverability of the Plan and is not consistent with the principles of

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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. Metroland 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 42: Character and Local Distinctiveness

11.1. Metroland is concerned with aspects of Policy 42 therefore consider that the Policy 42 unsound.

Test of Soundness

11.2. Metroland 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

11.3. Metroland support the principles of Policy 42, however are concerned with aspects which require the adaptation of standard house types to complement or reinterpret the local character.

11.4. This could impact on viability and therefore the deliverability of schemes. It is not clear how the whole plan viability has taken into account the requirement for high quality design. Metroland consider this requirement will inevitably lead to increases in professional fees and build costs, associated with use of high quality materials. Metroland consider additional sensitivity testing is required to consider the impacts this policy.

11.5. The requirement is 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.

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

11.7. However, we consider that with increased flexibility and review of the viability evidence the Local Plan can be found sound. The Metroland will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

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

• Test the impact of the policy on viability, and revise the policy to reflect the findings.

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12. Policy 43: Good Urban Design

12.1. Metroland is concerned with aspects of Policy 42 therefore consider that the Policy 43 unsound.

Test of Soundness

12.2. Metroland 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. Metroland support the principles of Policy 43, however are concerned with aspects of the policy which expects the use of established design tools. For major applications of over 0.5hectares or 10 or more residential units this, is stated “this should include making use of pre- application engagement with the Council and affected community, and utilising design review”.

12.4. There are some internal inconsistencies within the policy and explanatory text. The explanatory text in paragraph 12.10 indicates that the use design advice and design review are encouraged. The policy should be revised to provide certainty for developers, applicants and the community.

12.5. A requirement for design review could impact on timescales and the deliverability of schemes. Metroland consider that the policy should be flexible and should “encourage” the use of design review rather than “expect” or “require”, and reflect the wording within the explanatory text to provide greater clarity.

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12.6. The requirement is 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.

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

12.8. However, we consider that with increased flexibility the Local Plan can be found sound. The Metroland will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

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

• Modify the policy wording to reflect the explanatory text in paragraph 12.10 to provide greater consistency and clarity and “encourage” rather than expect the use of design review.

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13. Policy 46: Housing Design Standards

13.1. Metroland is concerned with Policy 46 and consider that the Policy 46 is unsound.

Test of Soundness

13.2. Metroland 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

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

13.4. 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.

13.5. 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.

13.6. 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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13.7. 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.

13.8. 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’.

13.9. Metroland welcomes the provision of new evidence on Housing Design Standards Policy. Metroland 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. As such Metroland consider that NDSS should only be applied to affordable housing and not to open market.

13.10. On NDSS Metroland 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.

13.11. Metroland note that the viability assessment has applied an average house size which is stated to reflect NDSS, However Metroland 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, Metroland consider that there needs to be greater flexibility in Policy 46 with regards to the use of NDSS.

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13.12. Metroland 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 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).

13.13. Metroland 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. Metroland reserve the right to comment further when this is made available.

13.14. 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.

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

13.16. 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.

13.17. 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

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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 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.

13.18. Metroland 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.

13.19. 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.

13.20. 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, Metroland 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

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

13.21. Metroland 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.

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

However, Metroland 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. Metroland will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

13.23. 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 homes.

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14. Policy 66: Developer Contributions

14.1. Metroland is concerned with aspects of Policy 66.

Test of Soundness

14.2. Metroland 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. Metroland 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.

14.4. 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.

14.5. Metroland 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

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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.

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. Metroland are concerned that the policy requirements of the Plan are not justified and are not consistent with the Framework.

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

Proposed Change

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

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

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15. Policy 67: Development Viability

15.1. Metroland is concerned with aspects of Policy 67.

Test of Soundness

15.2. Metroland 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

15.3. Metroland 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.

15.4. 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.

15.5. Metroland 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 assessments

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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.

15.6. 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.

15.7. Furthermore, Metroland 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, Metroland 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. Metroland 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.

15.8. Metroland 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. Metroland considers that the Plan is not justified and are not consistent with the Framework.

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

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

Proposed Change

15.11. 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 Part B.

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16. Housing Sites; Site 115, Alverley Lane, Balby, MUA

16.1. Metroland is supportive of Policy 6 and its allocation of the Alverley Lane, Balby, Doncaster site (site 115). However Metroland are concerned about the justification for some of the site specific requirements set out within Appendix 2 Development Requirements Site 115. Metroland therefore consider that the Development Requirements are unsound.

Test of Soundness

16.2. Metroland 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

16.3. Metroland supports the allocation of the Alverley Lane, Balby and its identification as a proposed housing site. An Advocacy Report and illustrative masterplan is attached to these representations which demonstrates the site’s deliverability. An overview of the proposals is provided in Section 17.

16.4. The proposal is an appropriate site to provide for the housing needs of Doncaster in the short term. The allocation of the site would confirm its potential to help continue the provision of a balanced housing supply in the Borough in sustainable locations. The site can deliver a full range and mix of housing and a sustainable community. Development of the site would deliver housing and affordable housing. Doncaster needs to have a robust housing trajectory and the site at Alverley Lane, Balby would assist with this delivery in the short term. The site is situated within a prime location suitable for residential development and as such would

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facilitate the development of land in a more effective and efficient manner. Development of the site would not harm or undermine the areas wider policy objectives, but seeks to reinforce the need to develop sites within sustainable locations as a priority.

16.5. The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.

16.6. Metroland are concerned that the Development Requirements established in appendix 2 of the Local Plan are not sufficiently effective or justified. There is a requirement to for a set back from the southern boundary. The extent of the setback is unclear and could potentially impact on the site capacity and deliverability. It is not clear what density or net to gross ratio has been assumed by the council when calculating the capacity of the site. However it is clear that it is lower than the gross to net ratio and or density that form the viability assumptions in the whole plan viability report. Thus there may be a requirement for site specific viability testing.

16.7. Further Metroland are concerned that the sites locations is now considered to be in a Medium to high value area. It was previously identified as being within a low value area. There is therefore a requirement for 23% affordable housing. The adjacent area is identified within a medium value area. The viability report considers average sales values of £2,100 per sq. m. for medium value areas, and £2,350 per sq.m. in high value area. Metroland are concerned that the identification of the site within a medium -high value area does not reflect the sales values expected to be achieved at site 115.

16.8. Metroland is concerned that with all the policy requirements the local plan details, and limited refinement of value areas that this could undermine the delivery of housing through increased need for viability assessments, and the associated impact on delivery through extended negotiations. The Council should review the baseline aspirations of individual policies and the policies in combination to ensure that they are not too high and ensure that the requirements are well tested.

16.9. Metroland consider that the requirements in their current form are not fully justified or effective. The plan in its current form could fail to deliver sustainable development in accordance with the policies in the framework.

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

16.11. However, Metroland consider that with increased clarity, and justification for the development requirements and a review viability evidence and subsequent review of the sites capacity, the Local Plan can be found sound. The Metroland will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

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

16.13. Review the development requirements, site capacity and whole plan viability to provide greater clarity and justification for the site requirements.

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17. Land at Alverley Lane, Balby

17.1. Metroland have previously submitted an Advocacy Report and illustrative masterplan to support the allocation of the Land at Alverley Lane, Balby. This submission is reiterated here to support of Housing Site 115.

Justification

17.2. Metroland supports the allocation of the Alverly Lane, Balby site. An Advocacy Report and illustrative masterplan has been previously submitted and is re-attached to these representations. The Advocacy Report demonstrates the site’s deliverability.

17.3. Metroland considers the proposed housing allocation is available, suitable and achievable and therefore in accordance with the Framework. It is a deliverable site that is able to come forward in the short term.

17.4. The deliverability and benefits of the Alverley Lane, Balby is as follows:

Overview of proposals

17.5. The site is located on the edge of an established residential area and benefits from easy access to the full range of services and facilities located within Balby, Doncaster. The site lies adjacent to the Edlington/Dearne Valley Railway Embankment Local Wildlife Site. The site is approximately 6.5ha gross and could accommodate in the region of 220 new homes.

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Deliverability

17.6. The site at Alverley Lane provides a development opportunity that is available, suitable and achievable and therefore it is considered that the site is deliverable, in accordance with national planning policy and guidance. It is promoted by Metroland Ltd with interest in development from Persimmon Homes and Ongo Homes and is deliverable within the plan period.

Availability

17.7. The land is being promoted by Metroland Ltd as landowner. The site is therefore available in accordance with the Framework and the National Planning Practice Guidance (PPG).

17.8. The proposed development can make an efficient and attractive use of the land. The site represents an excellent opportunity for future housing and development. This site allows housing to be delivered within an appropriate and sustainable location within Doncaster.

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Suitability

17.9. The site is located in a highly sustainable location and has residential development to the north, east and west. The site is within easy walking distance to Springwell Lane Local Centre with a range of facilities provided there as well as greater facilities within Doncaster Town Centre, a short bus ride away. There are a large number of primary and a secondary schools in the vicinity of the site.

17.10. The site is well served by buses providing opportunities for sustainable travel to work in Doncaster and beyond with access to Doncaster Railway Station.

17.11. The development will provide additional quality development that will benefit the Doncaster and wider district with economic, environmental and social benefits. It is therefore considered that the development is suitable.

Green Belt

17.12. 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.

17.13. Alverley Lane, Balby demonstrably fails to perform any of the five Green Belt functions set out in the Framework and is therefore currently subject to an unjustified and out of date Green Belt status. This therefore provides an opportunity for a logical and justified release from the Green Belt which will not only offer a highly a sustainable site for housing delivery to meet identified need but also enforce a defensible and more permanent Green Belt boundary for the future beyond the Plan period.

17.14. In the Borough of Doncaster approximately 46% of the area is designated as Green Belt. This is the western part of the Borough which forms part of the South Yorkshire Green Belt surrounding urban areas.

17.15. The Framework considers that Green Belt boundaries can change “in exceptional circumstances” as part of a Local Plan review. Such a circumstance exists through the significant need to provide housing in Doncaster. To meet the housing need and economic growth aspirations the Council has stated it will need to revise the Green Belt boundaries for the emerging Local Plan and beyond to provide the new boundaries with some permanence.

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17.16. The site does not currently perform any of the five Green Belt functions as identified within Paragraph 134 of the Framework:

1. To check the unrestricted sprawl of large built-up areas

17.17. Due to the Site’s specific context it does not in itself perform the objective of checking unrestrictive sprawl. The southern boundary of the site is in the form of a continuous raised railway line with established tree belt which is significant in mass and scale and forms an impenetrable physical boundary to development of the urban area. It is therefore this feature that fulfils the objective for checking unrestricted sprawl and by default removes the onus of this function from the site itself.

2. To prevent neighbouring towns merging into one another:

17.18. There is a 2 kilometre distance between Balby and the next nearest village to the south and as such the site is not performing as a prevention of two towns merging into one another. As part of the recent Green Belt review the Council has stated “given the strength of the proposed boundary” (the railway line to the south) the site has no role in preventing neighbouring towns from merging.

3. To assist in safeguarding the countryside from encroachment:

17.19. The site is greenfield but is not considered ‘countryside’. The site is an agricultural field nestled in between suburban housing and a railway line forming a significant physical barrier distinctly separating the site both physically and visually from the countryside to the south. The development of this site could not therefore be considered an encroachment into the countryside or affect the openness of the Green Belt.

4. To preserve the setting and special character of historic towns:

17.20. Balby is not classified as a historic town nor acknowledged as having a special character or setting typically associated with a historic town and so the site does not therefore perform this function.

5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

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17.21. The site is located by the Council’s own definition as being in the Main Urban Area which is intended to accommodate the majority of the Borough’s development. The site is considered to form part of the ‘urban land’ considered in the context of the currently adopted Local Plan. The sites inclusion in the Green Belt actually restricts the availability of suitable urban land such as this site to deliver housing in turn putting more pressure on sites located in the countryside. There has to be a balance between green and brown field urban land owing to the deliverability issues often experienced on brownfield / redevelopment sites.

17.22. It is therefore concluded that the Site does not currently perform any of the five Green Belt functions and is therefore considered a justified release to deliver much needed private and affordable housing.

17.23. Not only is the site considered to be a justified release from the Green Belt but in doing so will have a strengthening effect on the Green Belt boundary ensuring its permanence and defensibility into the future beyond the plan period. The Council has recently concluded that the existing boundary is considered to be irregular and inconsistent with the existing built form and that if the site were to be allocated then:

17.24. “The newly formed defined boundary would be a densely vegetated dismantled railway corridor to the south of the site and is considered to be strongly defined, recognisable and likely to be permanent. The resultant Green Belt boundary would result in a rounding of the existing built form and concluded as being a strong and defensible boundary”.

17.25. Alverley Lane, Balby is a site which can demonstrate failure to perform all of the five Green Belt functions and as such is a justified release from greenbelt that will provide both an excellent opportunity to meet housing need but also strengthen the Green Belt boundary into the future

Achievable

17.26. A range of technical work has been undertaken and further survey work is ongoing. From the initial assessments there are no technical issues that would prevent development or are insurmountable. The site is therefore considered to be achievable and therefore deliverable in accordance with national guidance. The technical assessments are summarised within the accompanying Advocacy Report and are available and can be submitted upon request.

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17.27. The indicative masterplan shows how a mix of housing can be accommodated within the site, alongside connectivity, landscaping and drainage features. The site has interest from Persimmon Homes and Ongo Homes (Registered Provider).

Efficient Use of Land

17.28. Although the site is greenfield, the proposed scheme will utilise and enhance existing infrastructure. Although the site is not previously developed it is currently under-utilised. The site is easily accessible and the proposed main access is off Alverley Lane. The scheme is therefore making an efficient and effective use of land and infrastructure.

Delivering a Flexible Supply of Housing

17.29. The Framework requires Local Planning Authorities to meet their full objectively assessed housing need. Metroland considers that the site at Alverley Lane, Balby is deliverable in the short term and will reinforce the housing supply and address the Borough’s housing needs in the early periods of the Local Plan. The site is fully capable of being delivered in the next 5 years and there is interest from housebuilders for the site.

A Positive Response to the Key Objectives of the Framework

17.30. Framework sets out that the Governments key housing policy goal of boosting significantly the supply of housing and proactively driving and supporting sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs. The Framework explains that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as extensions to towns, and creating mixed and sustainable communities with good access to jobs, key services and infrastructure. Sites should also make effective use of land and existing infrastructure.

17.31. In relation to the Framework:

• The proposal responds positively towards national guidance.

• The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.

• The proposed site is accessible to existing local community facilities, infrastructure and services, including public transport.

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• The site has been assessed and is available, suitable and achievable for development.

Benefits

17.32. The development of the site would provide significant benefits. The site would provide housing that would meet the needs of the Doncaster housing market. Therefore this site provides a unique opportunity in a sustainable location and without compromising the Green Belt function and purpose.

17.33. In accordance with the Framework this representation has shown that:

• The site is suitable for housing and can deliver circa 220 new homes.

• The proposal will deliver high quality housing.

• The proposal will deliver affordable housing.

• The proposal can provide a good mix of housing commensurate to the demand and need in the area.

• The scheme uses land efficiently and effectively.

• The proposal is in line with planning for housing objectives.

• The site is within a sustainable location situated in close proximity to facilities and services and also to bus stops for local bus routes.

• The proposal will deliver public open space.

• The scheme represents an opportunity to achieve gains for biodiversity through environmental and ecological enhancement.

• The scheme will create direct and indirect job opportunities both during and after construction.

17.34. The proposal is an appropriate site to provide for the housing needs of Doncaster in the short term. The allocation of the site would confirm its potential to help continue the provision of

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a balanced housing supply in the Borough in sustainable locations. The site can deliver a full range and mix of housing and a sustainable community. Development of the site would deliver housing and affordable housing. Doncaster needs to have a robust housing trajectory and the site at Alverley Lane, Balby would assist with this delivery in the short term. The site is situated within a prime location suitable for residential development and as such would facilitate the development of land in a more effective and efficient manner. Development of the site would not harm or undermine the areas wider policy objectives, but seeks to reinforce the need to develop sites within sustainable locations as a priority.

17.35. The proposed allocation policy should therefore be flexible to reflect this evidence base and ensure delivery of the scheme. The site is available, suitable and achievable and therefore deliverable in accordance with the Framework.