HALLAM LAND MANAGEMENT (ID 05212) Doncaster Local Plan Examination Hallam Land Management (ID 05212) Matter 3 Statement – Strategic Approach Issued September 2020 1.1 This Hearing Statement is prepared on behalf of our client Hallam Land Management (ID 05212). Our client seeks to respond to Questions 3.2, 3.3, 3.4 and 3.5 only. M3. Strategic Approach Q3.2 Is the broad spatial distribution of development proposed in policies 2 and 3 justified? In particular the aims to accommodate: b) the ranges for the number of new homes in and around each of the individual Main Towns and Service Towns and Villages. Q3.3 Is the broad spatial distribution of development proposed by the employment and housing allocations in policies 4 and 6 justified having regard to the aims set out in policies 2 and 3? Are any main modifications required to ensure that the Plan is unambiguous and internally consistent in this respect? 1.2 Questions 3.2(b) and 3.3. are answered jointly below. 1.3 Policy 3 sets out how the housing requirement for the Doncaster Local Plan (DLP) will be distributed. This includes a requirement of 575 – 1,085 new homes in Dunscroft, Dunsville, Hatfield & Stainforth. 1.4 As set out in our response to Matter 2 we do not consider setting the housing requirement as a range to be consistent with national planning policy and this should be revised to set the figure. Further to this, a figure of a minimum of 1,085 dwellings across the plan period (as opposed to the range currently set out) should be set for Dunscroft, Dunsville, Hatfield & Stainforth. 1.5 We have concerns regarding delivery of housing across the plan period particularly given that delivery within the Dunscroft, Dunsville, Hatfield and Stainforth Main Town Settlement relies heavily on the DN7 Unity Site (site ref. 418). We have previously expressed concerns regarding the delivery of the DN7 Initiative to Doncaster Council, noting that this is a highly complex project that faces many challenges including a working colliery and spoil heap, existing landfill, a new railway station and live railway, Local Wildlife Sites (and other biodiversity value), flood risk, a network of drainage ditches, patchwork of arable fields and hedgerows and multiple ownerships. 1.6 Despite these issues, the site remains identified as having a 5-year supply capacity of 245 units on the basis that “works on the new Junction 5 M18 link road are now underway and… it is Pg 1/4 Lichfields.uk anticipated that the initial 2 phases of housing are due imminently”1. Doubt remains however regarding when this project will deliver housing and how much for the following reasons: • The development has already been delayed significantly; • Whilst the original outline planning permission (ref. 15/01300/OUTA) was minded to grant in 2016, a decision notice was not issued until April 2017 given issues in agreement of the S106 due to the multitude of land owners involved. • Since the granting of the original outline planning permission, a second outline planning permission has been approved on the site (ref. 18/00101/OUTM); this did not seek to increase the number of residential units or commercial floorspace approved but includes additional land to the outline planning permission. It is unclear why this additional land is needed to achieve the same amount of development. 1.7 Whilst the Council have stated that submission of Reserved Matters applications for housing at the Unity site is due imminently, but there is no sign of an application on Public Access. 1.8 Further to the above, it is acknowledged in a number of other sources that given the size, infrastructure requirements and complexity of this site, delivery is likely to be a lengthy process. Sources include: • Paragraph 52 of the Inspector’s report of Appeal Decision APP/F4410/W/16/3158500 (Land off Westminster Drive, Dunsville, Doncaster – see accompanying documentation to this Statement) which states that: “this is a strategic extension which relies on the delivery of key infrastructure… It is a complex site in multiple ownership and will take some time for development to commence on site” • Paragraph 2.11 of the Planning Statement attached to planning application 18/00101/OUTM for the Unity development confirms: “it is accepted that Unity will come forward over a number of years. A development of this scale will take up to 20+ years to complete and there will inevitably be changes to the masterplan during this period. The Unity planning consent allows a 25 year timeframe in which to submit reserved matters applications and this longevity is a fundamental requirement.” (our emphasis) • Condition 1 of Decision Notice 18/00101/OUTM (second outline application at Unity) which allows applications for approval of Reserved Matters on the site to be submitted as late as April 2042. 1.9 Cognisant of the above, there is clearly acknowledgement from the Council, applicant and PINS that delivery of this site is complex and will require extensive time to come forward. Whilst it is positive to see that progress is being made at this site concerns remain given that, notwithstanding our position on the housing requirement (set out in our response to Matter 2), whilst 3,945 units are identified as having planning permission within the Dunscroft, Dunsville, Hatfield and Stainforth Main Town settlement, 3,100 of these are within the Unity development site. Even when considering the discounted supply figure of 1,860 units set out at paragraph 16.83 (making provision for Unity units delivered after the plan period), 1,015 of these units (around 55% of the total supply in this settlement) are allocated within the Unity development site; the remainder of the sites allocated are to be delivered in the short term. With this in mind 1 Doncaster 5-Year Deliverable Housing Land Supply Statement (April 2019-March 2024) Pg 2/4 Lichfields.uk and the likelihood of further delay in its delivery during the Plan period, the Council should allocate additional housing sites within the Dunscroft, Dunsville, Hatfield and Stainforth Main Town settlement to ensure that sufficient levels of delivery are achieved in the medium term should the delivery of the Unity site be delayed. 1.10 Our client’s site north of Woodhouse Lane, Hatfield (site ref. 1038) is entirely within Flood Zone 1. Whilst within the ‘Countryside’ for the purposes of Policy 2, it is adjacent to the proposed Hatfield settlement boundary, abuts emerging residential allocation 970 (which has outline planning permission and a live Reserved Matters application for residential development) and is well related to the existing built form. Hatfield is identified within the Dunscroft, Dunsville, Hatfield and Stainforth Main Town (a Tier 2 settlement with only the Main Urban Area of Doncaster above it). The Settlement profile confirms that this settlement ranks as one of the best performing settlements in the borough against the Settlement Audit criteria – being the best provided for area in the borough outside the Main Urban Area for primary schools (Local Plan Publication Version paragraph 16.73). Hatfield is identified as having its own centre (with relatively low vacancy rates), a library and Hatfield Outdoor Activity Centre. The settlement has its own train station situated between Hatfield and Stainforth and is well served by buses. Hatfield is therefore a highly sustainable location for new residential development. Development of this site would not cause significant adverse harm to the settlement’s character, setting or appearance. It is also consistent with the requirements of emerging Policy 2 (part 5) (insofar as we consider the requirements of this policy to be consistent with the NPPF – see also our response to Matter 5 reference criteria 5e) in that: • It is consistent with the role and service function of the settlement of Dunscroft, Dunsville, Hatfield and Stainforth; • The site is well related to the existing built form of the settlement and would represent a logical extension to the built-up area and is of a scale and nature that is in keeping with the core shape, form and size of the settlement; • It will not cause significant adverse harm to the settlements character, setting or appearance or the intrinsic character of the surrounding countryside; and • It would accord with other relevant policies in the local plan. 1.11 The draft allocations therefore need to be reviewed to ensure the proposed distribution of housing can be achieved and suitable and sustainable sites such as site 1038. Q3.4 Is the suggested change to policy 2 set out in the Council’s response to PQ14 necessary to make the Plan sound? 1.12 The proposed changes do provide some further clarity on the Strategic part of the text and the decision-making part of the text. However, our client maintains its concerns regarding the settlement limits. 1.13 The development limits outlined in the DLP present a notion of controlling the location of development, which is a restrictive approach that is at odds with the NPPF. The NPPF directs that Local Plans should “provide a positive vision for the future of each area…” (NPPF paragraph 15). If development limits are proposed, their role should be to help direct development needed to the right places; providing sufficient flexibility to accommodate development needs not currently anticipated (NPPF paragraph 81). 1.14 By including development limits to control development, the DLP conflicts with the NPPF (paragraph 16) which requires that Local Plans are “prepared positively, in a way that is Pg 3/4 Lichfields.uk aspirational but deliverable…”. Whilst the NPPF expects Local Plans to identify land where development would be inappropriate and does not explicitly preclude the inclusion of settlement boundaries or development limits, it does not specify that Local Plans define settlement boundaries and does not instruct Local Plans to preclude development at the edge of a settlement.