Emma Winter Contact: Mel Roberts Tel: Carter Jonas E-Mail: First Floor 9 Bond Court Website Leeds Our Ref: 19/01224/PREAPP LS1 2JZ Date: 19th September 2019 Dear Emma, I refer to your pre-application enquiry for proposed employment space (B1(c), B2 and B8) with ancillary offices on land at Bradholme Farm, Thorne and can advise you as follows: Principle Doncaster UDP The application site lies within the Countryside Policy Area as defined by the Doncaster Unitary Development Plan. This application is a departure from the UDP. Although an Inspector recently found that UDP policies ENV2 and ENV4 were out of date (in Edenthorpe), this was one decision and these are saved policies and are given moderate weight. Core Strategy (adopted 2012) The Doncaster Core Strategy Policy CS2: Growth and Regeneration Strategy states that “Employment opportunities will be located ……..to support the Settlement Hierarchy, attract a range of businesses (including higher skilled jobs) and ensure good sustainable transport links to the settlement network exist or can be provided.” The relevant locations are: M18/M18 corridor at junctions close to Armthorpe, Stainforth/Hatfield and/or Thorne and the Strategic Rail Freight Interchange at Rossington (290 ha) for distribution warehousing; Robin Hood Airport and its business parks for businesses related to the airport; and In accordance with the Settlement Hierarchy, including replacing current sites which are unsuitable for modern business needs (190 ha) for light industry and manufacturing The policy explanatory text states that employment allocations “will support the settlement hierarchy but must also take account of deliverability issues (i.e. the needs of business) and Doncaster’s Economic Strategy; employment sites cannot always be located next to the communities they serve.” There is a need for Doncaster to concentrate on using its assets within or adjacent to the Main Urban Area, Principal Towns and Potential Growth Towns where infrastructure can be brought forward; transport connectivity will be a priority to ensure there is access to jobs for all communities. Doncaster Metropolitan Borough Council, Civic Office, Waterdale, Doncaster, DN1 3BU Core Strategy Policy 3: Countryside states that countryside will be protected and enhanced and lists 3 principles A) ……; B) the countryside in the east of the borough will continue to be protected through a Countryside Protection Policy Area; C) proposals that are outside development allocations will only be supported where they would …. 4 criteria are listed. Core Strategy Policy 5: Employment Strategy states that Doncaster’s economy will be supported in accordance with a number of principles (listed in the policy) which will enable improved levels of economic output and increase access to opportunities. The principles include: A) Sufficient employment land will be allocated to take into account: i. The identified potential for the creation of 36,000 jobs ….. ii. Doncaster’s wider aspirations for economic growth … iii. Historic take-up rates of employment land, and iv. The need for a range of sites to provide flexibility. The amount of new employment sites is set out in the Growth and Regeneration Strategy (Policy CS2). In releasing new land for strategic warehousing, priority will be given to the proposed Strategic Rail Freight Interchange at Rossington. The Core Strategy does not allocate sites and the Sites and Policies document, which would have done so, was withdrawn. Local Plan (Currently at Publication Stage) The Local Plan, which is currently in preparation, will become the statutory development plan once adopted. In September – October 2018, the Council consulted on the Draft Policies and Proposed Sites. This version included the proposed site (Bradholme, site ref 160) as a potential employment allocation. As a result of the consultation process, where a large number of people/organisations (including Thorne and Moorends Town Council) objected, the Publication version of the Local Plan no longer includes Bradholme as an employment allocation. At this time, the Local Plan is given limited weight. This weight will however increase as the process moves forward. In conclusion, this site is a departure from the UDP and Core Strategy and is not supported through the emerging Local Plan. Transportation A Transport Assessment and Travel Plan are required in accordance with current guidance. The submitted Preliminary Feasibility Study – Transport, refers to a mixed-use employment (2,000,000 sqft) and residential development (600 dwellings). The Masterplan drawing 15372-004 does not show any residential development and it is assumed reference to residential is a mistake. It should be noted that the SYSTM+ traffic model has now been replaced with the Sheffield City Region Transport Model (SCRTM1). Traffic counts are to be undertaken to establish baseline transport data and to properly assess the impact of this development. Once the trip generation and distribution exercise has been undertaken, any junction with an impact of 30 or more (2-way) vehicles in the peak hours is to be capacity assessed. Committed developments are to be taken into account. The most recent 5 years collision data is to be reviewed. Any future year assessment to be +10 years. Lorry parking facilities to be provided on site to prevent HGVs parking/waiting on local roads. Cycle parking to be provided at a ratio of 1:10 car parking spaces (Employment) A Routing Agreement will be required to control the movement of HGV traffic. The applicant should discuss and agree the scope of the Transport Assessment with the Councils’ Transportation Unit prior to undertaking the assessment in order to avoid any abortive or unnecessary work. The Travel Plan should include monitoring and a bond as per DMBC requirements (see below). Travel Plan Should a full planning application be submitted, Doncaster Council’s Active Travel Auditor will visit site and audit its accessibility by sustainable modes and produce a list of requirements to encourage active travel. Targets The DMBC requirement is for a 10% reduction in single occupancy car journeys to be demonstrated over a 5-year period. Travel Plan Monitoring The DMBC requirement for monitoring (as per section 3 of the Returnable Transport Mitigation Bond Guidance) is annual counts at each vehicular entrance point of the site, undertaken in a neutral month by an independent consultant for a period of 5 years. The parameters of any monitoring need to be agreed with DMBC prior to being undertaken. Monitoring can be undertaken by DMBC at a cost of £5,000 per entrance/exit point and this will be secured by the Section 106 agreement. Travel Plan Bond A Bond is required to mitigate any traffic in the event that targets are not met. The purpose of the Bond is to ensure that the targets within the Travel Plan towards sustainable travel can be met, and if not met, the Council would step in with sustainable measures using the Bond. The Council needs to be assured that the Travel Plan is effective and has reasonable targets that can be met. The formula for calculating the bond is as follows:- No. of dwellings/No. of employees x the current cost of a 28 day SY Connect+ ticket (currently £111.40) x 1.1 Full Travel Plans are to be submitted within 3 months of full occupation for each individual unit. A Developer Contribution to Unity Link (Hatfield Link Road) may be required. Core Strategy Policy CS9 – Providing Travel Choice details the requirements for contributions towards major highway schemes which the Council is progressing for implementation through the Sheffield City Region Investment Fund and ‘proposals will be supported which improve the efficiency of, and key connections to, the internal road, strategic road and motorway networks’. The Council has assessed the cumulative impact of all development sites (AECOM Report) and developed a methodology for determining the level of funding that is required from each site which impact upon the following SCRIF projects A630 West Moor Link Improvement Scheme A1-A19 Link Road Hatfield Link Road Waterfront Access The methodology calculates 1. the total traffic flow and the percentage that is attributable to the cumulative developments 2. the total cost attributable to the cumulative developments 3. the traffic flow from the individual development site and hence the percentage of the total flow 4. the financial contribution based on the percentage (3) and total cost to developers (2) Highways Access to the development is taken from High Levels Bank and Tudworth Road, both of which are subject to a national speed limit. Reference is made in the preliminary feasibility study to the highway accesses and the need to use DMRB design standards to which we concur. Options are discussed in respect of the form of junction, however should an application be forthcoming, there will be a need to provide all relevant geometric design information as well as operational assessment through the Transport Assessment process. The proposed access arrangement shall be subject to a Road Safety Audit in accordance with DMRB Volume 5 Section 2 Part 2 Road Safety audit (GG119). Full swept path analysis of the access junctions are required using an articulated vehicle with a single axle at the rear of the trailer, of length 16.5 metres. Please provide plans showing these turning movements. Whilst it is acknowledged that servicing and delivery will be dealt with as part of a future application, we would expect this to be designed in accordance with the design recommendations and operational considerations contained within the FTA document “Designing for Deliveries”. Pedestrian, cycling and public transport accessibility is key for this site and appropriate provision shall be made for all non-motorised users. It should be noted that within the Councils’ parking standards, it states that “Individual assessment of the lorry parking facilities to be provided where necessary, including those sites where the overnight parking of vehicles can be anticipated”.