COMMENTS (REPRESENTATION) FORM...1.2 In compiling this representation Pegasus Group have applied the...
Transcript of COMMENTS (REPRESENTATION) FORM...1.2 In compiling this representation Pegasus Group have applied the...
Doncaster
Local Plan
Publication Draft 2019
Ref: (For Official Use Only)
COMMENTS (REPRESENTATION) FORM
Please respond by 6pm Monday 30 September 2019. The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination. Please email your completed form to us at If you can’t use email, hard copies can be sent to:
Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU. All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan
This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations)
Part A Please complete in full. Please see the Privacy Statement at end of form.
1. Personal Details 2. Agent’s Details (if applicable)
Title Mr Mr
First Name L Matthew
Last Name Saywell Good
Organisation (where relevant)
The Gascoine Group Pegasus Group
Address – line 1 The Pavilion
Address – line 2 Green Lane
Address – line 3 Garforth
Postcode LS25 2AF
E-mail Address
Telephone Number
Guidance Notes (Please read before completing form) What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be
helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:
• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.
• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.
• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.
• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).
Question 8 (below) – Do I need to attend the Public Examination? You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.
1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making
Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be
at the request of the Inspector, based on the matters and issues she/he identifies for examination.
If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at:
or
Name / Organisation Name:
Pegasus Group
1. To which document does your response relate? (Please tick all that apply)
Doncaster Local Plan Publication Draft ☒ Policies Map ☐
Sustainability Appraisal ☒ Habitats Regulations Assessment ☐
Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☒ Green Belt Phase 3 Report
2. To which part(s) of the document / map does your response relate?
Page No.: Paragraph:
Policy Ref.: Policy 2, 3 & Bawtry Housing Allocations
Site Ref.:
Policies Map:
3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☒ Yes ☐
4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)
Positively prepared ☒ Justified ☒
Effective ☒ Consistent with National Policy ☒
6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.
Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.
You can attach additional information but please make sure it is securely attached and clearly referenced.
This comment form should be read in conjunction with the associated report.
7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.
(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).
See associated report.
8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)
☐ No, I do not wish to participate at the examination. I would like my representation to be dealt with by written representation.
☒ Yes, I wish to appear at the Examination.
If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:
To provide a full explanation of our points and address issues raised by the Council, Inspector or other
participants.
Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature
Date 30/09/2019
Please send your completed form, by no later than 6pm on 30th September 2019, to:
• Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU
• or email: Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan
Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:
The Council reserves the right not to publish or take into account any representations which are openly offensive
or defamatory.
Pavilion Court, Green Lane, Garforth, Leeds, LS25 2AF Page | 1
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004.MG/P17-1594.002
30th September 2019
Local Plan Team
Civic Office
Waterdale
Doncaster
South Yorkshire
DN1 3BU
Dear Sir/Madam,
Re: Publication Draft Doncaster Local Plan: Consultation
Representation on behalf of The Gascoine Group
Please find enclosed a representation prepared by Pegasus Group on behalf of The Gascoine
Group in relation to Land of West Bawtry Hall, Bawtry. The representation considers the
content within the Publication Draft of the Doncaster Local Plan.
The representation should be read in conjunction with the accompanying representation
produced by Pegasus Group to the draft policies and proposed site informal consultation in
September 2018 and promotional document which are enclosed.
Electronic versions of the above have also been submitted to [email protected].
I would be grateful if you could confirm receipt of these submissions.
Yours faithfully,
Matthew Good
Director
Email:
cc. Luke Saywell (The Gascoine Group)
Toby Cockcroft (Croft Residential)
Page | 2
DONCASTER LOCAL PLAN
PUBLICATION DRAFT CONSULTATION (AUGUST – SEPTEMBER 2019)
LAND OF WEST BAWTRY HALL, BAWTRY FOR THE GASCOINE GROUP
1.0 Introduction
1.1 This representation is prepared by Pegasus Group on behalf of The Gascoine Group
in relation to Land of West Bawtry Hall, Bawtry. The representation considers the
content within the Publication Draft of the Doncaster Local Plan.
1.2 In compiling this representation Pegasus Group have applied the four elements of
soundness referred to in the National Planning Policy Framework, which are;
positively prepared, justified, effective and consistent with national policy.
1.3 This representation should be read in conjunction with the accompanying
representation produced by Pegasus Group to the draft policies and proposed site
informal consultation in September 2018. That document promotes the site and
illustrates why is should be allocated for residential development. The purpose of this
submission is to focus on the matters within the Publication Draft only, mainly the
overall requirement and distribution of housing.
2.0 Our Vision for the Future
2.1 The Local Plan sets a clear and ambitious vision for the future of the borough. The
Local Plan is informed by the ‘Team Doncaster’ strategy ‘Doncaster Growing
Together’. This strategy has an over-arching vision for Doncaster to be a “thriving
place to learn, work, live and care”. The Local Plan (para. 3.4) clearly sets out that
the vision is informed by the ambitions of the City Region, its Strategic Economic
Plan as well the Northern Powerhouse. The vision is also supported by several clear
outcomes, including;
• be a more important economic hub with a stronger, more balanced and
productive economy;
• become a University City and ensured residents have the education and skills
businesses need;
• meet our communities housing needs and aspirations focusing growth in the
main urban area, main towns, service towns and larger villages providing a
diverse range of homes, services and improved links in between;
• enhance the vitality of our existing town centres and the wider Borough
making a more attractive, healthier, safer and more active place to live, visit
and work; and
• ensure the sustainability of villages and rural economy through appropriate
development.
2.2 Our client is supportive of this vision and the identified outcomes.
2.3 The Local Plan and its policies must provide a positive framework for the future of
the Borough; in a way that is aspirational but deliverable. The economic aspirations
of the Borough are clear in their intent to expand existing and attract new
Page | 3
business; become an important economic hub, a University City and a leading
centre in logistics, aviation, rail and civil engineering.
2.4 The economic aspirations of the Borough must be matched by a clear commitment
to deliver the area’s future housing needs as a minimum. Objective 9 of the Local
Plan seeks to; “ensure housing provision meets the housing need and aspirations
by increasing the provision of new homes for all to meet current and future needs
and create mixed and balanced communities.”
2.5 Unfortunately, the proposed policies and strategy within the Local Plan do not meet
this challenge. This clearly has implications for the soundness of the plan. Our
client’s concerns are discussed in greater detail against the relevant policies below.
3.0 Policy 2: Spatial Strategy and Settlement Hierarchy
3.1 This policy is considered unsound as it is not justified or effective.
3.2 The policy seeks to distribute the majority of new development to the most
sustainable locations, these being the Main Urban Area of Doncaster, the 7 Main
Towns and the 10 Service Towns and Villages. This general principal is considered
appropriate and is supported. It is, however, important that this is sustainable and
deliverable.
3.3 Bawtry is identified as in the ‘Service Towns and Villages’ category. The Local Plan
identifies that this level of settlement will “…provide a good range of services meeting
their own needs and the local area. To maintain and enhance their role as service
towns and villages which provide housing, employment, retail, and key services and
facilities for the local area, these settlements will be a focus for accommodating an
appropriate level of growth to meet their local needs, as well as renewing and
regenerating any run-down neighbourhoods.”
3.4 The identification of Bawtry within the Service Town and Village tier is supported. It
is a high performing settlement and provides many primary services. It is well
served by a district centre containing local services and amenities, including a
primary school and health care provision. It also has excellent public transport
connections to higher level centres such as Doncaster, Worksop, Retford and
Gainsborough through regular bus services. Bawtry is, therefore, considered a
sustainable settlement suitable for new growth.
3.6 In terms of new homes the policy seeks to deliver at least 50% within the ‘Main
Urban Area’ of Doncaster and 40% within the 7 ‘Main Towns’ with just 10% allocated
to the ‘Service Towns and Villages’. The derivation of this split is discussed within the
‘Sustainability Appraisal of the Doncaster Local Plan 2015-2035: Publication Version’
(SA) and ‘Settlement Background Paper’. The key criteria used is a ‘proportional’ split
based upon population and the ‘economic element’ of the housing requirement uplift
being split between the Main Urban Area and Main Towns (Settlement Background
Paper para 3.1.6 and 3.1.7). None of the economic uplift element is distributed to
lower tier settlements.
Page | 4
3.7 The distribution takes no account of other factors such as affordable housing need,
deliverability or development opportunities. The Council’s viability evidence ‘Whole
Plan Viability Testing – Update, May 2019’ (2019 Viability Report) identifies the
challenges of delivering within many areas of the borough. The 2019 Viability Report
identifies three ‘value zones’ across Doncaster, these being High, Medium and Low.
The low value zones are generally concentrated in and around the Main Urban Area
and Main Towns.
3.8 The 2019 Viability Report highlights that; “…viability pressure was at its highest for
schemes in low value areas. These schemes were shown to be unviable if a 20% (or
higher) affordable housing provision was applied. However, some schemes did
return a viable outcome if the affordable housing provision was reduced to 15%,
although typically this also required a reduction in the other S106 policy
contributions.” (our emphasis, para. 7.5).
3.9 It is notable that Policy 8 of the Local Plan reduces affordable housing to 15% in the
low value areas. However, based upon the output from the 2019 Viability Report it is
likely that many schemes within these areas will remain unviable even with the
reduced level of affordable housing. This threatens the deliverability of the plan and
the ability to meet the affordable housing needs of the area.
3.10 The Council’s background paper ‘Housing Need Study / Affordable Housing Need’
identifies a need for 209 affordable dwellings per annum. This represents almost 23%
of the districts overall housing need. The reduction to 15% within areas of low value,
combined with the concentration of development within these areas will ensure that
the affordable housing needs of the area are unlikely to be met.
3.11 To ensure that the plan is deliverable and that it provides the greatest opportunity
to deliver much needed affordable housing it is recommended that an increased
percentage of housing be allocated to lower tier settlements. Given their inherent
sustainability the majority of this re-distribution should be within the Service Towns
and Villages, such as Bawtry.
4.0 Policy 3: Level and Distribution of Growth
4.1 The policy is not sound as it is not positively prepared, justified, consistent with
national policy or effective.
Housing Requirement
4.2 Policy 3 of the Publication Draft of the Local Plan sets a target for at least 920 (net)
new homes each year over the plan period 2015-2035 (18,400 homes in total) with
sufficient land allocated to deliver the housing requirement.
4.3 This proposed level of housing growth remains unchanged since the draft policies
consultation in 2018. Therefore, Pegasus continue to question whether this approach
Page | 5
to meeting the needs for new homes demonstrates that the Plan is positively
prepared and justified. The reasons for this remain as the previous representation:
a) The Borough has a clear economic growth agenda – this is evidence in the draft
Local Plan’s Vision and Objectives.
Doncaster forms a key part of Sheffield City Region and target metrics produced
independently for SCR LEP1 identify the need for jobs growth of 1.0% p.a. if the
City Region is to improve its performance relative to the UK. Given that Doncaster
has seen employment increase either at or above the levels experienced by SCR
since 1998, and in line with its positive growth aspirations, it does not seem
unreasonable to expect the Borough to align with the City Region target and for
jobs growth in the District to average 1.0% in the long-term.
Long-term economic aspirations should be properly planned for within this land
use plan, to facilitate these aspirations becoming a reality. The impact of this
would be to increase housing requirements from the current OAN of 920dpa to
1,073dpa – an additional 153 homes per annum.
b) Affordability ratios in Doncaster have changed little over the past decade (4.81 –
Source: 2018 Affordability Ratio Data), suggesting that the housing ladder
remains out of reach for a substantial part of the local population. Build rates will
therefore need to be high in the long-term to address this issue. Housing
completion data for the Borough from 2004/5 and 2017/18 shows that it is
capable of delivering in excess of 1,000 units per annum.
c) The Office for National Statistics (ONS) published variant household projections
in December 2018. These considered a range of variant projections to assist users
in examining future growth scenarios. At this stage a variant which includes
higher household formation rates for younger adults (those aged 25 to 44 years)
has not been provided. The ONS is currently considering how to robustly evidence
this variant. This variant will be critical as evidence suggests that such households
were unable to form as freely as previous generations (due to high house prices,
less access to finance etc.). An increase in housing numbers in Doncaster will
help ensure that supply is able to meet demand – especially from younger adult
who move into the area.
4.4 The PPG states the Government will be supportive of authorities who wish to plan for
growth. In addition, the PPG identifies other factors which need to be considered
when determining the housing requirement. These include growth strategies,
planned infrastructure, previous levels of delivery and recent assessments of need
such as Strategic Housing Market Assessments (SHMA) where this suggests a higher
need (PPG ID 2a-010). These are all important considerations in the context of
Doncaster.
1 Source: Target Metrics Sheffield City Region: Metro Dynamics, June 2017
Page | 6
4.5 Table 4.1, below, identifies net completions over the 14-year period from 2004/5 to
2017/18. During this period delivery rates have averaged 1,013 net additional
dwellings. Since the start of the plan period (2015) average delivery rates have
been higher at 1,140 net additional dwellings. Setting the housing requirement
nearly 100 dwellings per annum (dpa) lower than average levels of delivery over
the previous 14 years and 220dpa lower than the plan period average, would be
contrary to the ethos of the NPPF and the Government’s continued desire to boost
significantly the supply and delivery of housing.
Table 4.1: Housing delivery in Doncaster (2004 to 2018)2
Year Dwellings completed (Net)
2004/5 1,426
2005/6 1,380
2006/7 1,285
2007/8 1,414
2008/9 1,709
2009/10 506
2010/11 817
2011/12 457
2012/13 316
2013/14 654
2014/15 792
2015/16 1,162
2016/17 1,049
2017/18 1,208
Average 2004/5 to 2017/18 1,013
Average 2015/16 to 2017/18 1,140
Average 2009/10 to 2013/14 550
Source: MHCLG Live Table 122
2 The figures for the years 2011/12 to 2017/18 are provisional and subject to revisions pending the release of future census dwelling stock data. Figure highlighted red are imputed.
Page | 7
4.6 To assist in the determination of the appropriate housing requirement, three
alternatives have been considered through the SA. These are;
• Option 1: 920dpa and 481ha employment land;
• Option 2: 585dpa and 103ha employment land; and
• Option 3: 753dpa and 242ha employment land.
4.7 The SA identifies Option 1 as the preferred option as it will “..meet local need but
also enable employment-led growth in accordance with the Sheffield City Regional
Plan, whilst providing a degree of flexibility…” (SA, para. 5.3.5). From the options
considered it is agreed that this is the most appropriate. However, the Council has
failed to consider an option which promotes a higher housing requirement than
920dpa. Given previous rates of delivery, identified in table 4.1 above, it is considered
a figure in excess of 1,000dpa should have been considered as a reasonable
alternative.
4.8 Following setting the housing target for the Local Plan Period, draft Policy 3
progresses to state:
…For the purposes of calculating 5-year housing land supply, the requirement
will be based on the Local Housing Need figure, as derived from the Standard
Methodology, which will be reviewed and revised throughout the plan period
in line with the latest household projections and affordability ratio. As such,
the housing requirement is expressed as a range with the bottom of the range
being the Local Housing Need figure and the top of the range being 920
dwellings per annum;
4.9 Pegasus have concerns regarding the Council’s proposed approach to calculating 5-
year supply and the overall wording of Policy 3 in this regard.
4.10 Frist, Policy 3 sets a target for at least 920 (net) new homes each year over the plan
period, but then when discussing the ‘range of housing need’ states that the top
range of local housing need figure is 920dpa. Clearly, these two statements are
contradictory to each other.
4.11 Second, we contend that the approach of Policy 3 in applying a lower housing need
figure for the purposes of calculating 5-year housing supply is contrary to the
approach of Policy 3 in setting a minimum requirement. We would question how, in
the context of the need to significantly boost housing supply, seeking to meet a figure
significantly below the minimum housing target and previous levels of delivery could
be considered to be a pro-active or positive approach.
Bawtry Housing Distribution
4.12 Bawtry is identified as being one of Doncaster’s Service Towns and will contribute to
the overall 10% split of total housing development alongside Askern; Auckley-
Hayfield Green; Barnburgh-Harlington; Barnby Dun; Carcroft and Skellow; Edlington;
Page | 8
Finningley; Sportborough; and Tickhill. I refer to our objections to Policy 2 with
regards the percentage split identified.
4.13 In the Case of Bawtry itself, the Publication Draft identifies a requirement for growth
of 110 dwellings across the plan period. However, the Council propose to allocate
only 90 dwellings in the settlement, split between sites with and without planning
permission. This means that there is a 20-dwelling shortfall between the number of
units allocated and the settlement target growth. Paragraph 16.194 of the Local Plan
discusses this matter stating:
“As at 1st April 2018, there are permissions for 54 dwellings on sites large
enough to allocate through the Local Plan (5+ units remaining). An additional
two relatively small allocations are made through the plan; one being a
greenfield urban site and the other a greenfield extension on land formerly
designated as Green Belt. These two sites have a combined capacity of 36
new homes and bring the settlement’s housing allocation up to 90 dwellings
for the plan period, which is 20 units short of its requirement. Any additional
allocations would require large urban extensions on land currently designated
as Green Belt where it is not considered exceptional 240 [go to Contents]
circumstances exist to remove further sites for such a small shortfall in the
context of additional sources of housing supply in the town. For example, at
April 2018 there are permissioned small sites (1-4 units) that total 14 new
homes and there will be additional windfall development within the town
throughout the plan period so confidence that the town’s requirement of 105
new homes will have been met.”
4.14 As stated within Paragraph 16.194, the Council believe that meeting the 20-dwelling
shortfall in Bawtry would require large urban extensions not appropriate for such a
shortfall in the supply. Pegasus question the scale of the shortfall within Bawtry due
to our comments relating to the housing requirement and distribution. Furthermore,
the site at Land West of Bawtry Hall could accommodate some of this growth without
large scale changes to the Green Belt.
4.15 Paragraph 16.194 suggestion to overcome the shortfall is that the remainder of the
need can be met through windfall development in the settlement across the plan
period. This statement is however contrary to the subtext of Policy 6: Housing
Allocations (Strategic Policy), which at policy 4.83 states:
“The allocated supply has not been reduced to make allowance for windfalls
and so all windfalls will be additional land supply to meet the plan period
requirement.”
4.16 Despite this statement, it is clear that the Council have reduced the allocated supply
to make allowance for windfalls in Bawtry. We believe this approach is flawed and
additional allocations should be made to meet the required shortfall rather than
relying upon windfall development.
Page | 9
4.17 Pegasus are concerned with any reduction or limitation on the housing target for a
settlement purely on the basis that it is in a Green Belt location. The housing target
for a settlement should be focused on the need to ensure the settlement can grow in
a sustainable manner to support the local community and its population. Housing
allocations, and Green Belt release, should then be made according to meeting that
need.
5.0 The Proposed Allocated Sites in Bawtry
5.1 The following table reviews those sites allocated in Bawtry. We reserve the right to
comment further on the suitability or otherwise of sites proposed, however our initial
research indicates that 18 - 20 units can be discounted from Bawtry’s supply. This
provides further justification for the allocation of the site Land West of Bawtry Hall.
Table 5.1: Review of Bawtry Sites
Ref. Address Pegasus Initial Comments
950 Station Hotel, 93
Station Road, Bawtry
- Original planning permission on the
site, application ref. 14/01733/FULM,
was granted in 2016. Condition 1
requires the permission to be
commenced by 20th October 2019.
- No evidence available to suggest that
conditions have been discharged and
the development will commence in
time.
966 Bawtry Hall, South
Parade, Bawtry
- Planning permission ref. 16/00733/FUL
expired on 7th June 2019. As confirmed
by the consultation document, the
development has not commenced.
- No further applications have been
submitted to the Council and the
intention to development the site is in
doubt.
- It is recommended to remove the
allocation.
982 Land and Buildings on
the West Side of Top
Street, Bawtry
- Retirement housing. Accommodation is
restricted to persons over 60 years of
age.
141 Westwood Road,
Bawtry
- Green Belt site. Exceptional
circumstances considered to exist to
justify removal from Green Belt
- Council allocate the site for 20
dwellings, however the site layout
submitted as part of planning
application 16/01672/OUTM
(withdrawn) illustrates a capacity of 14.
- It is recommended to remove 6
dwellings from the allocation.
Page | 10
499 Land off North Avenue,
Bawtry
- Allocated for 16 units in the 0-5 year
period. Given the size, shape and
orientation of the site, Pegasus believe
the site could realistically deliver 10 -
12 units.
- This is a proposed allocation only and
no evidence is provided to show that
the site will come forward in the 5 year
period expected by the Council.
- It is recommended to remove 4 -6
units from the allocation.
Page | 11
APPENDIX 1: INFORMAL CONSULTATION: DRAFT POLICIES &
PROPOSED SITES
Page | 12
APPENDIX 2: BAWTRY HALL PROMOTIONAL DOCUMENT
OCT 2018 | MM | P17-1594.001
DONCASTER LOCAL PLAN INFORMAL CONSULTATION: DRAFT POLICIES & PROPOSED SITES (SEPT 2018)
REPRESENTATION FOR THE GASCOINE GROUP
Land West of Bawtry Hall, Bawtry
Pegasus Group
Pavilion Court | Green Lane | Garforth | Leeds | LS25 2AF
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© Copyright Pegasus Planning Group Limited. The contents of this document must not be copied or reproduced in whole or in
part without the written consent of Pegasus Planning Group Limited.
The Gascoine Group
Doncaster Local Plan Representation - Bawtry
Oct 2018 | P17-1594.001 1
1. INTRODUCTION
1.1 This representation is prepared by Pegasus Group on behalf of the Gascoine Group
in response to the ‘Informal Consultation’ on the Draft Policies and Proposed Sites
for the Doncaster Local Plan.
1.2 The comments in this representation relate to the Draft Policies, and in particular
meeting the need for new homes in Bawtry. This representation also considers the
approach to growth for Bawtry and the Proposed Sites at this location. This
representation is accompanied by a Promotional Document, provided as Appendix
A.
1.3 The representation considers the questions of soundness referred to in the National
Planning Policy Framework, which are; positively prepared, justified, effective and
consistent with national policy, and in respect of the relevant legal tests.
The Site
1.4 The site being promoted on behalf of the Gascoine Group is approximately 5.3ha
of land located to the west of Bawtry Hall which sits on the southern edge of the
settlement of Bawtry.
Site Location Plan
The Gascoine Group
Doncaster Local Plan Representation - Bawtry
Oct 2018 | P17-1594.001 2
2. STATUTORY CONTEXT: SOUNDNESS AND THE LEGAL TESTS
2.1 The Doncaster Local Plan has been issued at informal draft stage for public
comment prior to being issued in Publication Draft.
2.2 Section 19(2) of the Planning & Compulsory Purchase Act 2004 provides that:
“(2) In preparing a development plan document or any other local development
document the local planning authority must have regard to –
(a) National policies and advice contained in guidance issued by the Secretary of
State….”
Section 20(5) then states:
“The purpose of an independent examination us to determine in respect of the
development plan document-
(a) Whether it satisfies the requirements of sections 19 and 24(1), regulations
under section 17(7) and any regulations under section 36 relating to the
preparation of development plan documents;
(b) Whether it is sound; and
(c) Whether the local planning authority complied with any duty imposed on the
authority by section 33 A in relation to its preparation”.
2.3 The NPPF outlines the Government’s policy in respect of plan making. The
transitional arrangements in the NPPF (2018) apply, and for Doncaster Local Plan
mean that the policies in the newly adopted Framework are applicable. NPPF
paragraph 35 provides the considerations which should be taken into account in
the process of examination of an emerging development plan. This states:
Plans are “sound” if they are:
• Positively prepared – the plan should be prepared based on 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 needs
from neighbouring areas is accommodated where it is practical to do so and
consistent with achieving sustainable development;
• Justified – an appropriate strategy, taking into account the reasonable
alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint
working on cross-boundary strategic matters that have been dealt with
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Doncaster Local Plan Representation - Bawtry
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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.
2.4 Regulation 8 (2) of the Town and Country Planning (Local Planning) Regulations
2012 require that “a local Plan or Supplementary Planning Document must contain
reasoned justification of the policies contained within it”.
2.5 Regulation 8 (4) of the Town and Country Planning (Local Planning) Regulations
2012 continues that the policies contained within a local plan must be consistent
with the adopted development plan.
The Gascoine Group
Doncaster Local Plan Representation - Bawtry
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3 LOCAL PLAN VISION & OBJECTIVES
3.1 The vision for Doncaster in the draft Local Plan identifies that the Borough has
ambitious plans for the future.
3.2 The high-level vison set out in the draft Local Plan is welcomed, which aims for
Doncaster to be "a thriving place to learn, work, live and care” and support the
three objectives of the Local Plan, for Doncaster to have:
• A strong economy supporting progressive, healthy, safe and vibrant
communities.
• Full potential in employment, education and care.
• Prosperity and pride in Doncaster.
3.3 It should be the case that the Council set objectives for the Plan that provide a
positive framework for the future of the Borough; in a way that is aspirational but
deliverable. The economic aspirations of the Borough are clear in their intent to
expand existing and attract new business; become an important economic hub, a
University City and a leading centre in logistics, aviation, rail and civil engineering.
It is important that the economic aspirations of the Borough are matched by
ambition to meet and exceed, rather than just meet, the area’s housing needs
(Objective 9). Consideration of the synergies of housing and employment growth
are discussed further in Chapter 4.
3.4 ; in a way that is aspirational but deliverable.
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Doncaster Local Plan Representation - Bawtry
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4. LOCAL PLAN DRAFT POLICIES & PROPOSED SITES
4.1 This chapter discusses the Draft Policies of the Local Plan relating to delivery of a
sufficient supply of homes, and also the Site Selection Results in relation to the
settlement of Bawtry.
Strategic Approach – Meeting the Need for New Homes
4.2 Policy 3 of the draft Local Plan sets a target for at least 920 (net) new homes each
year over the plan period 2015-2032 (15,640 homes in total) with sufficient land
allocated to deliver at least 15 years’ supply. We would question whether this
approach to meeting the need for new homes demonstrates that the Plan is
positively prepared and justified for the following reasons:
a) The Borough has a clear economic growth agenda – this is evidence in the draft
Local Plan’s Vision and Objectives.
Doncaster forms a key part of Sheffield City Region and target metrics produced
independently for SCR LEP1 identify the need for jobs growth of 1.0% p.a. if the
City Region is to improve its performance relative to the UK. Given that
Doncaster has seen employment increase either at or above the levels
experienced by SCR since 1998, and in line with its positive growth aspirations,
it does not seem unreasonable to expect the Borough to align with the City
Region target and for jobs growth in the District to average 1.0% in the long-
term.
Long-term economic aspirations should be properly planned for within this land
use plan, to facilitate these aspirations becoming a reality. The impact of this
would be to increase housing requirements from the current OAN of 920dpa to
1,073dpa – an additional 153 homes per annum.
b) Affordability ratios in Doncaster have changed little over the past decade (5.21
– Source: 2017 Affordability Ratio Data), suggesting that the housing ladder
remains out of reach for a substantial part of the local population. Build rates
will therefore need to be high in the long-term to address this issue. Housing
1 Source: Target Metrics Sheffield City Region: Metro Dynamics, June 2017
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completion data for the Borough for 2015-16 and 2016/17 shows that it is
capable of delivering in excess of 1,000 units per annum.
c) The Office for National Statistics has confirmed that they will be producing
variant projections, which are due to be published in early December 2018.
These variant projections will include higher formation rates for younger adults
(those aged 25 to 44 years), as evidence suggests that such households were
unable to form as freely as previous generations (due to high house prices, less
access to finance etc.). An increase in housing numbers in Doncaster will help
ensure that supply is able to meet demand – especially from younger adult who
move into the area.
4.3 The Plan should provide a sufficient range of allocated land to provide enough active
sites to allow delivery to be maintained at the required levels throughout the Plan
period. The draft Plan does not presently account for such a supply buffer that
would deal with under-delivery from sites and provide sufficient flexibility for
unforeseen circumstances.
4.4 In order to be considered properly positively prepared, the Plan must demonstrate
that housing need is being met as a minimum not a limit. The Plan must be
aspirational but deliverable to be positively prepared (NPPF, paragraph 16). The
Local Plan target of 920 (net) new homes per annum is insufficient to realise job-
led housing need in the Borough. In order to be found sound, the Local Plan should
be targeting higher growth.
Hierarchy for Future Growth – Growth for Bawtry
Bawtry: Sustainable Location for Growth
4.5 The draft Local Plan at Policy 2 establishes a network and hierarchy of settlements
within the Borough. Setting out an overall strategy for the pattern of housing,
employment, retail and other commercial development within a Plan area is
considered to be a sound approach in accordance with paragraph 20 of the NPPF.
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4.6 Policy 2 identifies Bawtry as a Service Town / Village. The policy defines such
settlements as having a good range of services meeting their own needs and the
local area.
4.7 Within the Service Towns and Villages tier, Bawtry is a high performing settlement
and provides a large number of primary services. It is well served by a district
centre containing local services and amenities, including a primary school and
health care provision.
4.8 As a result, Bawtry is considered to be a sustainable settlement suitable for new
growth in the Borough.
Bawtry: Level of Growth
4.9 Draft Local Plan Policy 2 specifies that “to maintain and enhance their role as service
towns and larger villages which provide housing, employment, retail, and key
services and facilities for the local area, these settlements will be a focus for
accommodating an appropriate level of growth with priority given to renewing and
regenerating run-down neighbourhoods”.
4.10 The target for new homes in Bawtry is 110 units over the Plan period.
4.11 Earlier in this representation we provided commentary on the strategic approach
to meeting housing need at Borough-level. Economic evidence justifies a higher
housing requirement for Doncaster and the Borough should be positively preparing
its Plan to achieve this. In a scenario where the housing requirement were to
increase, such growth should be focussed in accordance with the Borough’s
strategic policies, appropriate to the size of individual settlements.
4.12 The Site Selection results for Bawtry identify that the residual housing target for
the settlement is at least 36 new units. This assumes an identified supply from
completion on small sites and existing permissions of 5+ units of 78 units (as of
April 2017). The Council consider these units to be specific, deliverable supply for
years one to five of the plan period.
4.13 When using residual housing targets based on identified sites within Plans, it is
necessary to ensure that these sites are deliverable by the terms of new definition
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Doncaster Local Plan Representation - Bawtry
Oct 2018 | P17-1594.001 8
in the revised NPPF (NPPF Glossary, page 66). Where such sites are not capable of
being defined as deliverable they cannot be justified in the draft Local Plan as
forming current supply. We reserve the right to comment further on this in
subsequent consultations on the Plan.
4.14 We have concerns that 78 homes (or 71% of Bawtry’s housing requirement) over
the plan period have already been provided from existing planning permissions, or
would only contribute to very short term supply.
4.15 We oppose the position that only 36 units are required to be allocated as part of
the Local Plan. This relatively modest number of new units which in our view would
result in an unsustainable programme of growth and housing delivery in Bawtry
over the full period of the Local Plan. This provision of housing in the initial years
of the plan (from base date to pre-adoption) would also be contrary to the aims of
the Housing Delivery Test which seeks to maintain a percentage measurement of
the number of net homes delivered against the number of homes required over a
rolling three year period.
4.16 The Proposed Housing Site Allocation outcome for Bawtry is that there are two
suitable sites for growth – Site 499 and Site 141. It has rejected 1,063 units on 7
sites.
4.17 Further discussion of Green Belt Exceptional Circumstances and the Green Belt
Review of sites at Bawtry is provided in the following paragraphs.
Green Belt
Exceptional Circumstances for Green Belt Review
4.18 The Local Plan Evidence Base ‘Green Belt Phase 3 Report Summary’ identifies that
there are known constraints on the supply of land at those settlements which form
strategic settlements in the draft Local Plan Policy 2 – a Strategic Policy. In doing
so, and in respect of NPPF paragraph 137, the Authority confirm that exceptional
circumstances exist to justify changes to Green Belt boundaries in this Local Plan,
and this approach is being taken at Service Town / Village in the Borough. However,
at the Service Town / Village of Bawtry, no Housing Sites are identified in the Green
Belt to meet the settlement’s strategy need. This is not consistent with the
development plan’s strategy for meeting identified requirements for sustainable
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Doncaster Local Plan Representation - Bawtry
Oct 2018 | P17-1594.001 9
development through re-defining its Green Belt boundary elsewhere in the Plan,
contrary to NPPF paragraph 139.
4.19 Given the need for additional housing in Bawtry identified within this
representation, we support that it is necessary and justified to review the Green
Belt boundary at the settlement of Bawtry.
Bawtry: Green Belt Review
4.20 The Local Plan Evidence Base ‘Green Belt Phase 3 Report Summary’ confirms the
methodology for the assessments of Sites through the Green Belt Review. Each site
has been assessed in two ways: for the strength of the boundary, and against the
site’s contribution to the five purposes of the Green Belt (NPPF, para 134). The site
is then given an overall score through a ‘Strength of Case’ Matrix on the “strength
of case for continuing in the site selection process”. This could be strong,
moderately strong, moderate, moderately weak or weak case.
4.21 The site forming Site 996 – Land West of Bawtry Hall – has not yet been assessed
by the Local Planning Authority, though the site has been put before them since
24th August 2017. The site does however form part of Green Belt General Area –
Bawtry 2, as identified within Stage 1 of the Green Belt Review.
4.22 Firstly, it is shown below that the Green Belt General Area (Bawtry 2) forms a
detached parcel of land which is separate from the wider West and South Yorkshire
Green Belt. We believe that this devalues the need for this parcel of land to be
retained as Green Belt.
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4.23 In respect of the purposes of the Green Belt, we believe that Site 996 strongly
performs against local interpretation of the Green Belt purposes.
Purpose 1: to check the unrestricted sprawl of large built-up areas
4.24 Bawtry is identified within the plan process as a small urban area / service village.
As a result, the land West of Bawtry Hall does not have the purpose of checking
the unrestricted sprawl of a large built-up area and there is no conflict with Purpose
1 in this regard. This is agreed by the LPA in their assessment of the Green Belt
General Area.
Purpose 2: to prevent neighbouring towns merging into one another
4.25 The site is situated within the southern part of Bawtry, not beyond the extents of
the existing settlement. It is over 1.7km from the sites edge to any other
settlement, including the densely wooded area located on the southern edge of the
Green Belt General Area. As a result of the scale of the gap, it is considered that
the proposal to remove the site from the Green Belt would not conflict with purpose
2. This is agreed by the LPA in their assessment of the General Area who concludes
that the “General Area is not contiguous to or in close proximity to any of the
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Doncaster Local Plan Representation - Bawtry
Oct 2018 | P17-1594.001 11
settlements within Tables 8 and 9 and makes no discernable contribution to
separation”.
4.26 It is noted that the LPA Green Belt assessment adds in a secondary aspect to their
assessment of Purpose 2 “Role of the Proposed Green Belt Site in resisting ribbon
development which would otherwise have resulted in the reduction of perceived
separation between settlements.” This aspect is not dictated by national policy, and
in this case, it is considered that the potential release of this site from the Green
Belt would not have a perceptible impact upon the separation between Bawtry and
other settlements.
Purpose 3: to assist in safeguarding the countryside from encroachment
4.27 The site represents an appropriate extension to the settlement of Bawtry set within
the extents of existing development. As is noted in its place in the Settlement
Hierarchy, Bawtry is a sustainable settlement which is able to provide a notable
proportion of the district’s growth over the plan period. Given the other constraints
to the settlement, particularly the areas of Flood Risk Zones to the east of the
settlement, opportunities for growth, such as this site, should be accepted where
it can be demonstrated that they are deliverable.
4.28 It is accepted that the development would represent some encroachment into the
Green Belt, however this is confined by the constraints of the site and it is well
within the extents of existing development. It also does not extend beyond the
edges of the settlement. Balanced with this and the need for housing land, it is
considered that the encroachment into the countryside is, in this case, acceptable.
Purpose 4: to preserve the setting and special character of historic towns
4.29 The Site is not located within the Bawtry Conservation Area, although is located
within close proximity to the Conversation Area and also Bawtry Hall, Grade II*
Listed.
4.30 The Site Promotion document that accompanies this representation provides a
detailed heritage analysis of the site. The document concludes that the site, which
forms only part of Green Belt General Area, can be developed such that it would
not impact upon the setting or special character of Bawtry.
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Purpose 5: to assist in urban regeneration, by encouraging the recycling of derelict
and other urban land
4.31 Whether or not the proposed development here takes place there will have no
significant effect on the recycling of other urban land across the district. The
development of the site for this purpose has no effect in this respect and as a result
it can reasonably be concluded that the site serves no obvious Green Belt function
in relation to the interests of urban regeneration for Doncaster. This is confirmed
by the LPA in the assessment of the Green Belt General Area.
4.32 In summary, given the isolated nature of this parcel land in relation to the wider
Green Belt and the conclusions of the Green Belt review, we believe that the site
does not make an important contribution to the open character of the village or to
the wider openness of the Green Belt. The LPA primary concern relates to purpose
4 of the Green Belt tests, relating to the historic setting and special character of
the town. On this basis, we believe that it Paragraph 140 of the NPPF is relevant.
This states:
140. If it is necessary to restrict development in a village primarily because of
the important contribution which the open character of the village makes to
the openness of the Green Belt, the village should be included in the Green
Belt. If, however, the character of the village needs to be protected for other
reasons, other means should be used, such as conservation area or normal
development management policies, and the village should be excluded from
the Green Belt.
4.33 As a result of the Green Belt Assessment it is our position that this site should not
be ruled out for removal from the Green Belt and is suitable for further
consideration through the site selection process.
Land West of Bawtry Hall, Bawtry (Site 996): Development Opportunity
4.34 This representation is accompanied by a Site Promotion document which explains
why Site 996 represents a suitable location for new homes in accordance with the
strategic draft policy targeting growth to the settlement of Bawtry. It also illustrates
how development could be achieved on the site in a well-designed manner,
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Oct 2018 | P17-1594.001 13
responding to site conditions and local characteristics, including heritage setting
considerations.
4.35 The site is capable of delivering a range of type and tenure housing suitable for
different groups in the community.
4.36 The provision of new homes in this settlement will not only make an important
contribution to meeting the housing requirement for the Borough, as a minimum,
but will also have local and Borough-wide economic benefits in terms of
construction impact and household expenditure once constructed.
4.37 We consider that Site 996 is a suitable site at Bawtry for housing growth to
contribute to the Borough’s growth and boost housing land supply.
4.38 We confirm that Site 996 is available now, that the promotion of the site is
supported by willing landowners, and that development on the site could be
delivered in a timely manner to contribute to the Borough’s supply.
4.39 We reserve the right to comment further on proposed sites in Bawtry in subsequent
consultations on the draft Plan.
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APPENDIX A
PROMOTIONAL DOCUMENT
LAND WEST OF BAWTRY HALL, BAWTRYPromotional document on behalf of The Gascoine Group
Promotional Document | Land West of Bawtry Hall, Bawtry
Prepared by Pegasus Group 3
Contents
Pegasus GroupPavilion CourtGreen LaneGarforthLeedsLS25 2AF
www.pegasuspg.co.uk |
Prepared on behalf of The Gascoine GroupJuly 2017Project Code: P17-1594Contact: Chris Hunter / Chris CalvertChecked by: CH / CC
COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Ltd. Front cover: Aerial photo of the site
Crown copyright. All rights reserved, Licence number 100042093
Site Analysis 14
Settlement Character 11
Proposed Design & Summary 21
Planning Context 6
Site Location 5
Introduction 4
NOTE: This document is designed to be viewed as A4 landscape double sided (booklet)
Heritage Analysis 8
4 Prepared by Pegasus Group
Introduction
BAWTRY
This document has been produced on behalf of the Gascoine Group by Pegasus Group to promote land to the West of Bawtry Hall, Bawtry through the emerging Local Plan ‘Call for Sites’ process.
Doncaster Metropolitan Borough Council are currently preparing a new Local Plan to guide development in the Borough. The purpose of this document is to support discussions around the new Local Plan and to demonstrate how the site could be delivered to provide new housing in a sustainable location in Bawtry.
Promotional Document | Land West of Bawtry Hall, Bawtry
Prepared by Pegasus Group 5
Site Location
Prepared by Pegasus Group 5
The site is a 5.3 hectare (13.1 acres) parcel of land at land west of Bawtry Hall at the southern edge of Bawtry, only 200m from the main shopping street within the settlement. The site lies within the administrative boundary of Doncaster Metropolitan District Council.
The A631 is located approximately 250m to the north of the site and the A638, just 100m to the east. Both routes provide excellent access to the surrounding area, including Doncaster Airport situated 6km to the north.
The site consists of a relatively large area of mature woodland which includes a number of local walking routes . Also within the site is a clearing to the south of Richmond Lane which includes a variety of rough grassland species and scrub vegetation.
Between the site and the A638 is Bawtry Hall and its associated gardens (locally registered park and garden). These gardens consist of formal planting which is maintained to compliment the Grade II* listed property which provides office uses as well as offering to host functions such as weddings and conferences.
6 Prepared by Pegasus Group
Planning Context
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PLANNING POLICY
The adopted development plan comprises saved policies from the UDP (1998) and the more recent Core Strategy (2012). Doncaster Council are presently progressing a new Local Plan for the Borough, but this emerging draft document is not sufficiently progressed to be given weight in the decision-making process.
The new Local Plan will set out the spatial priorities for the District and set out how land should be used in the future to achieve the Borough’s economic, environmental and social goals. The Local Plan will supersede the Core Strategy and will set out detailed development management policies to guide new development in the borough.
The Doncaster Local Plan must be prepared in accordance with the Duty to Cooperate, legal and procedural requirements and must be sound; i.e. it must be:
• Positively prepared – the plan should be pre-pared based on a strategy which seeks to meet objectively assessment development and infrastructure requirements, including unmet requirements from neighbouring authorities
where it is reasonable to do so and consistent with achieving sustainable development;
• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
• Effective – the plans should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework
In March and April 2016, Doncaster Metropolitan Borough Council consulted on two documents: Homes and Settlements paper and the Sustainability Appraisal Growth Options.
The Homes and Settlements paper set out the proposed number of new homes planned for (both open market and affordable housing) and their proposed distribution across Doncaster’s towns and villages. The Council proposed to plan for 920 new homes per year 2015-2032 (15,640 new homes in total). This reflects the identified need for both open market and affordable housing and would meet the future needs of the existing population and the needs that will arise from planned jobs growth.
Public consultation on Draft Sites Allocations and Local Plan policies is the next stage of the Local Plan. This consultation stage of the Local Plan was planned for July 2017, however this has been delayed.
Given the need to ensure that the Local Plan is prepared on a strategy to positively meet the objectively assessed housing need, the Council is now consulting on an updated Pool of Sites, as well as through a future review of the Housing & Economic Land Availability Assessment (HELAA).
In response to this consultation land to the west of Bawtry Hall, is being promoted as a suitable and deliverable housing site for allocation in the emerging Local Plan.
HELAA Economic Development Map (DMBC)
Promotional Document | Land West of Bawtry Hall, Bawtry
Prepared by Pegasus Group 7
Planning Context
The graphics opposite show the current pool of sites submitted as part of the emerging Local Plan ‘Call for Sites’ and HELAA process.The Doncaster Local Plan Housing & Economic Land Availability Assessment (December 2016) identifies the sources of sites which will be examined and the factors which each site will be assessed against, which are:
• physical limitations or problems such as access, infrastructure, ground conditions, flood risk, hazardous risks, pollution or contamination;
• potential impacts including the effect upon landscapes including landscape features, nature and heritage conservation;
• appropriateness and likely market attractiveness for the type of development proposed;
• contribution to regeneration priority areas; • environmental /amenity impacts experienced
by would be occupiers and neighbouring areas.
The site passes the requirement for examination and performs well against the factors for assessment. This document addresses each of these issues and demonstrates the site’s suitability for residential development.
HELAA Housing Map (DMBC)
KEY
SITELOCATION
8 Prepared by Pegasus Group
Heritage Analysis
Designations PlanPrepared by Pegasus Group 8
HERITAGE
This section addresses the heritage resource located within and in the proximity of the proposed site.
The site lies within close proximity to a number of Listed Buildings, including the grade II* Bawtry House to the northeast, grade II War Memorial to the southeast, and the grade II Listed Buildings of Nos. 2 - 12 South Parade to the east. The proposed site lies directly south of the Bawtry Conservation Area and west of the locally registered park and garden of the grounds of Bawtry Hall.
The proposed site lies within the wider parkland of Bawtry Hall. The grounds were extensive and included a menagerie, pleasure ground, ponds, boathouses, groves and plantations. The separation between the parkland and formal gardens occurred in the early 20th-century when Major. G.H Peake remodelled the gardens and created brick walls to separate and create the formal area to the south and east of the hall, which is the area covered by the local designation.
Promotional Document | Land West of Bawtry Hall, Bawtry
Prepared by Pegasus Group 9Prepared by Pegasus Group 9
Heritage Analysis
Bawtry Hall was acquired by the MoD in 1939 and is now in private ownership. This 20th-century ownership has not affected the locally designated park and garden area but the wider parkland has been significantly changed by the encroachment of modern housing developments into the parkland, removing historic elements and changing the relationship between parkland and the hall. This can be seen on the Ordnance Survey maps of the 20th century.
The proposed site does not currently lie within the boundary of the Conservation Area, however it is identified as an area of open space which positively contributes to the special interest of the Conservation Area.
The original Conservation Area appraisal of 2007 identified potential amendments to the boundary. One of the boundary amendments was an extension to include the entirety of the Bawtry Hall grounds and former parkland within the Conservation Area. This was proposed to add additional protection to the landscape which forms the context and setting for the hall. The boundary amendments have
not yet been formally adopted by Doncaster MBC, however the 2015 review documents states that the “recommendation has influenced planning decisions in the area”. The proposed site forms part of the setting of the Bawtry Conservation Area and the setting of the grade II* Bawtry Hall and it contributes to the significance of these assets. The contribution made has been reduced by the development of modern housing directly to the west and north of the proposed development which has eroded the historic legibility of the parkland.
The core of the legible historic layout of the gardens of Bawtry Hall, and that area identified as a locally significant park and garden would not be affected by the proposed development. An area of the parkland would experience change due to the development but the wider surrounding parkland has been significantly eroded by the introduction of modern housing, reducing major elements of the former landscape, such as Menagerie Wood.
10 Prepared by Pegasus Group
View north from within Bawtry Hall Locally Registered Park and Garden View south across pond from Bawtry Hall Locally Registered Park and Garden
Promotional Document | Land West of Bawtry Hall, Bawtry
Prepared by Pegasus Group 11
URBAN GRAIN
The site is located within an area characterised by the surrounding woodland, Residential development within the southern part of Bawtry are characterised by the mature woodland blocks and previous housing developments have responded to the existing landscape framework to develop green, sheltered and attractive places to live.
The plan (right) illustrates that the housing development to the west of the site boundary appears as a linear form which runs along the mature woodland located within the site. It is therefore understood that any development at this site should respect the existing woodland and ensure that its retention should be a priority in order to respect the evolution of the settlement. This approach will ensure that careful consideration has been applied to the existing local vernacular and residential character of Bawtry.
Existing Urban Grain
Settlement Character
6
1
2
3
5
4
7
8
9
A
B
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Settlement Character
Richmond Lane
Market Place
Leeming CourtMadison Drive Linton Close
Cheyne Walk
Cock Hill Lane
Pemberton Grove
Church Street
This section provides an overview of the settlement character and local vernacular.
The dwellings differentiate throughout the area but most of the dwellings are two storeys high and are set back from the road, creating a landscaped positive street scene. Mature trees are also a frequent characteristic within this part of Bawtry.
2 3
4
7 8 9
5 6
1
A
B A631 TICKHILL ROAD
Dwellings on this street are a mix of large detached and semi-detached homes.
The streetscene to the north of the site along Tickhill Road is relatively inactive due to the presence of red brick walls, single sided mature rows of trees and houses being set back beyond wide grass verges.
These dwellings are of a lower density with higher density housing situated to the rear.
A638, GREAT NORTH ROAD
Rural in character to the south of Bawtry and including red brick walling, gappy hedgerows and mature deciduous trees. Red brick, three storey dwellings fronting onto the road when arriving at Bawtry with further red brick and white/cream rendered buildings within Bawtree.
The dwellings to the eastern side of the A638 front directly onto the road with parking courts situated to the rear.
Promotional Document | Land West of Bawtry Hall, Bawtry
Prepared by Pegasus Group 13
Settlement Character
14 Prepared by Pegasus Group
Site Analysis
The site lies within an opening, north of Fish Pond Wood in the southern part of Bawtry and consists of rough grassland and scrub vegetation.
The presence of the mature woodland vegetation which creates a horseshoe shape around the opening, provides substantial screen when considering views from the west, south and east.
It is acknowledged that views will be available from within the woodland which is accessible via a network of footpaths. However, these views would likely be heavily filtered by intervening vegetation and would not detract from the nature of these walking routes.
When considering potential visual receptors for this site, it is considered that the majority would be located to the north of the site and would include a relatively small number of visual receptors.
Assessment of this site and it’s visual influence will likely summarise that the site visually contained due to the presence of the surrounding mature woodland with potential views from Bawtry Hall, Residential properties to the north of the site and
View from north of the site looking towards property at eastern end of Richmond Lane
View south towards woodland near Richmond Lane
View from north of the site looking east towards Bawtry Hall
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Promotional Document | Land West of Bawtry Hall, Bawtry
Prepared by Pegasus Group 15
Site Analysis
Landscape Framework Plan
from the open space to the north of the site. Visual influence is unlikely to extend further than approximately 100m from the proposed site boundary.
Visual Receptors:
• properties at northern boundary at Richmond Lane;
• glimpsed views from properties at Pemberton Grove;
• Upper storey windows of Bawtry Hall;• Areas of open space to the south of Pemberton
Grove;• potential views from sections of the footpath
network within Fish Pond Wood.
As discussed previously, it is assessed at this early stage that proposed residential development at this site would result in a relatively small area of visual influence. Views of the site beyond 100m of are not anticipated to be available. Beyond this distance, any available views are unlikely to result in a notable level visual effect.
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Site Analysis
The site falls within National Character Area 39- Humberside Levels. Within the Doncaster Landscape Character Assessment and Capacity Study (2006/2007), the site falls within an Urban area with LCA H1 - Bawtry to Finningley Sandland Heaths & Farmland located to the north of the settlement.Some of the key characteristics for H1 are listed as follows:• Large scale coniferous forestry plantations
and smaller scattered mixed deciduous and coniferous woodlands.
• Road and rail transport corridor.• Long distance views to lower ground, many
wooded skylines, other enclosed views due to landform and woodlands.
The site is not wholly typical of this landscape character type due to its enclosed position within Fish Pond Wood at the southern edge of Bawtry. As part of a comprehensive assessment of the landscape impact, Bassetlaw Landscape Character Assessment (May 2009) would also be reviewed. This is due to the site being closely situated to the boundary of the Idle Lowlands character type.
Sensitivities Plan
Promotional Document | Land West of Bawtry Hall, Bawtry
Prepared by Pegasus Group 17
Site Analysis
Sustainability Plan
The site is suitably located to encourage sustainable travel choices. It is within walking or cycling distance of the main high street within Bawtry.
A variety of retail, leisure and convenience services are situated within the 500m radius from the site boundary.
The site is also located near to local bus stops which provide a number of various routes including 21, 25, 27, 29, 98, 99, 200, 319, 688 and the Doncaster Shopper (DS)
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Site Analysis
Opportunities & Constraints
OPPORTUNITIES• Creation of a semi-enclosed residential
development to the south of Bawtry;• Strengthen local green infrastructure and
provide an attractive area of open space for informal recreational use;
• Creation of new woodland extensions and habitat creation and enhancement;
• Retention of existing mature woodland to provide instant maturity to the setting of future development;
• Potential links to the existing footpath network through Fish Pond Wood.
CONSTRAINTS• Views from the properties to the north of the
site including those at Richmond Lane and Pemberton Grove, and the office uses at Bawtry Hall;
• Protection and integration of existing vegetation;
• Protection and integration of the areas of woodland adjacent to the site at the western and southern site boundaries.
• Acknowledgement of flood risk and ecology.
Promotional Document | Land West of Bawtry Hall, Bawtry
Prepared by Pegasus Group 19
Site Analysis
View from local footpath within the proposed site
LANDSCAPE INTEGRATION
The following measures would be incorporated to ensure that development is successfully and sensitively integrated into the landscape:
• A robust new woodland extension would be created to the north eastern corner of the site reflecting the existing vegetation along Bawtry Hall gardens to contain the proposed development and protect views from the north east.
• Existing woodland trees would be retained within the development to provide instant maturity to the proposed housing;
• Opportunities would be considered to create new areas of publicly accessible open space within a strong landscape offset/buffer, which would be incorporated around the sensitive boundaries to assimilate and integrate the development into the landscape and to provide an enhanced streetscene;
• New development would reflect the local vernacular style and would be of a high quality design and locally characteristic materials, appropriate for its location within Bawtry;
• Additional corridors of planting would be incorporated along proposed vehicular routes.
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Design Concept
Concept Plan20 Prepared by Pegasus Group
CONCEPT PLAN
The initial site analysis exercise has enabled the development of a concept scheme. This illustrates appropriate development parcels within the north eastern part of the site that will be surrounded by areas of open space, existing mature woodland and proposed woodland extensions.
MASTERPLAN
The masterplan overleaf identifies different character areas within the site. There is one site access point from Richmond Lane. The network of proposed roads are designed to suit the developable area of the site to create streetscenes with natural surveillance.
The proposal can incorporate 2-3 bed semi-detached and 4-5 bed detached units producing character areas from low density, high quality executive dwellings to medium density family homes. There are focal buildings designed as vista points along the streetscene.
A proposed woodland buffer on the eastern boundary is designed to strengthen the visual separation of the proposed development and existing views from Bawtry Hall. As well as benefiting from the proposed green perimeter, the site also incorporates green corridors.
Promotional Document | Land West of Bawtry Hall, Bawtry
Prepared by Pegasus Group 21
Proposed Design
Illustrative Masterplan
SUMMARY
This document has demonstrated that the site is well suited to residential development and can respond to the recommendations made by the Council’s initial sustainability assessment. The approach taken through the derivation of the concept masterplan has accounted for all known environmental constraints and is considered to have satisfactorily addressed them through sensitive design. It has been demonstrated that the site offers a highly deliverable, yet appropriate response to its location and surroundings and would make a significant contribution toward the delivery of the Districts future housing requirements. Overall the site is considered to be appropriate for allocation for residential development within Doncaster’s emerging Local Plan.
Pegasus GroupPavilion CourtGreen LaneGarforthLeedsLS25 2AF
www.pegasuspg.co.uk |
Prepared on behalf of The Gascoine GroupJuly 2017Project Code: P17-1594Contact: Chris Hunter / Chris CalvertChecked by: CH / CC
COPYRIGHT The contents of this document must not be copied or reproducedin whole or in part without the written consent of Pegasus Planning Group LtdFront cover: Aerial photo of the site
Crown copyright. All rights reserved, Licence number 100042093
www.pegasuspg.co.uk