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. 2 Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019 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. 3 Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019 2. National Planning Policy Context and Tests of Soundness 2.1. The Government's core objectives as established through the 2018 National Planning Policy Framework (the 2019 Framework) are sustainable development and growth. Paragraph 11 of the Framework stresses the need for Local Plans to meet the objectively assessed needs of an area. The 2019 Framework sets out to boost significantly the supply of homes and that a sufficient amount and variety of land can come forward where it is needed. In terms of building a strong and competitive economy the 2019 Framework states that planning should help create the conditions in which businesses can invest, expand and adapt. The key focus throughout the 2019 Framework is to create the conditions for sustainable economic growth and deliver a wide choice of high quality homes. 2.2. In relation to Local Plan formulation, paragraphs 15 to 37 of the Framework states that Local Plans are the key to delivering sustainable development which reflects the vision and aspirations of the local community. The Framework indicates that Local Plans must be consistent with the Framework and should set out the opportunities for development and provide clear policies on what will and will not be permitted and where. 2.3. In relation to the examination of Local Plans, paragraph 35 of the Framework sets out the tests of soundness and establishes that: 2.4. The Local Plan and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sounds. Plans are ‘sound’ if they are: Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; 4 Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019 Effective – deliverable over the plan period, and based on effective joint working on cross- boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework. 2.5. This document therefore considers the content of the Doncaster Local Plan – Publication Version (2015-2035) on behalf of Metroland in light of this planning policy context. 5 Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019 3. General Comments 3.1. 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. 6 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. 7 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