From: Barton Wilmore on behalf of Barratt and David Wilson ...... · About Barratt and David Wilson...

From: Barton Wilmore on behalf of Barratt and David Wilson Homes - Westwood Road Bawtry Sent: 30 September 2019 14:48 To: Local Plan Subject: FW: Doncaster LP Publication Draft 2019 Rev 1 Importance: High

I have attached an assessment of the Sustainability Appraisal within the Doncaster Local Plan Publication Version. Please read this in conjunction with the attached representations sent last week.

Chris Binns

14 King Street, Leeds, LS1 2HL

From: Barton Wilmore on behalf of Barratt and David Wilson Homes - Westwood Road Bawtry Sent: 26 September 2019 16:43 To: Local Plan Subject: Doncaster LP Publication Draft 2019 Rev 1 Importance: High

Further to my email below I have updated our representations to include an appendix 1.

Please replace our reps with those attached to this email.

I would be grateful if you could confirm receipt of the amended representations.

Chris Binns

Planner 14 King Street, Leeds, LS1 2HL

From: Barton Wilmore on behalf of Barratt and David Wilson Homes - Westwood Road Bawtry Sent: 26 September 2019 12:53 To: Local Plan Subject: Doncaster LP Publication Draft 2019 Importance: High

Please find attached our representations on the Doncaster LP Publication Draft 2019. These representations have been prepared by Barton Willmore on behalf of Barratt and David Wilson Homes

(Yorkshire East).

I would be grateful if you could confirm receipt of the attached representations.

Chris Binns Planner

14 King Street, Leeds, LS1 2HL

Representations to the Doncaster Council Publication Draft

Prepared on behalf of Barratt and David Wilson Homes (Yorkshire East)

September 2019

Representations to the Doncaster Council Publication Draft

Prepared on behalf of Barratt and David Wilson Homes (Yorkshire East)

Status: Draft Final

Issue/Rev: 01 01

Date: September 2019 September 2019

Prepared by: CB CB

Checked by: CA CA

Authorised by: SN SN

Barton Willmore LLP 14 King Street

Leeds

LS1 2HL

Tel: Ref: 18640/A5/REPS/CB

Email: Date: September 2019

COPYRIGHT

The contents of this document must not be copied or reproduced in whole or in part without the

written consent of Barton Willmore LLP.

All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks.

Contents Page

1.0 Introduction 1

2.0 Draft Policies 2

3.0 Proposed Site 11

4.0 Summary and Conclusions 14

Figures

3.1 Extent of South 6 Green Belt Parcel

Appendices

Appendix 1 - Landscape Rebuttal to the Green Belt Review 2016 (Golby and Luck, Landscape Architects)

Introduction

18640/A5/LPREPS/CB 1 September 2019

1.0 INTRODUCTION

1.1 These representations have been prepared by Barton Willmore on behalf of Barratt and

David Wilson Homes (Yorkshire East) (hereafter referred to as the ‘Client’).

1.2 Our Client has a keen interest in the future development of Doncaster and is grateful for this

opportunity to engage in the forward planning process. Our Client is keen to ensure that the

emerging Local Plan is sound and will bring forward the Authority’s housing and employment

needs. Our Client is pleased to have the opportunity to positively engage with Doncaster

Council (hereafter referred to as the ‘Council’) to help it achieve a robust Local Plan.

About Barratt and David Wilson Homes

1.3 Barratt and David Wilson Homes is Britain’s best-known house builder and has built over

300,000 new homes around the country, including 17,579 homes last year. Our Client is

leading in the field of low carbon design, urban regeneration, social housing and innovation.

1.4 Barratt and David Wilson Homes is one of the largest residential developers i n the UK,

helping to meet housing demands in a range of towns, cities and rural areas. Our Client

builds a variety of housing from first-time buyers apartments to family houses, plus many for

social rent and shared ownership.

1.5 Our Client currently has interests in the following sites within Bawtry:

• 141 – Westwood Road, Bawtry (allocated for housing);

• 146 – Tickhill Road, Bawtry (promoted for housing allocation, but dismissed).

Draft Policies


2.0 DRAFT POLICIES

Strategic Approach

Policy 1 – Presumption in favour of sustainable development

2.1 Our Client welcomes the provision of a policy which sets out that development proposals will

be considered in the context of the presumption in favour of sustainable development.

However, as highlighted through previous consultation stages, the wording of the policy has

too much repetition and parts b) and c) are unnecessary and should be deleted. Part a) of

the policy quite rightly states that when considering development proposals the Council will

take a positive approach which reflects the presumption in favour o f sustainable

development contained within the National Planning Policy Framework. That should be

sufficient for the policy.

2.2 However, part b) and c) then set out the presumption in favour of sustainable development,

but this does not accurately align the wording within the Framework. There is no reference

to the presumption being subject to material considerations where proposals accord with

policies in the plan.

2.3 Our Client recommends that the policy is revised and that parts b) and c) should be

removed.

Policy 2 – Spatial Strategy and Settlement Hierarchy

2.4 The Council outline their proposed settlement hierarchy and level of distribution within the

policy. It is noted that at least 50% of the baseline housing growth figure (8,775 homes)

will be located within the ‘Main Urban Area ’ of Doncaster, with 40% being delivered in the

‘Main Towns’ of Dunscroft, Dunsville, Hatfield & Stainforth, Thorne & Moorends, Conisbrough

& Denaby, Mexborough, Armthorpe, Rossington, and Adwick & Woodlands. The remaining

10% of the housing requirement, which equates 877 over the entire plan period (just 44

dwellings per year) would be delivered across the ‘Service Towns and Villages’.

2.5 As per our previous representations our Client objects to the distribution of housing

through the settlement hierarchy; it is too heavily focused on both the Main Urban Area and

the Main Towns, with 90% of the Council’s housing to be delivered in these areas.

2.6 In addition, our Client objects to the baseline housing growth figure (8,775 houses) being

used when distributing housing. This figure ignores the planned economic growth over the

plan period, which would result in an additional 327 homes per year. This would result in an

additional 33 dwellings per year across settlements like Bawtry.

Draft Policies


2.7 There are considered to be deliverability issues in Doncaster and some of the Main Towns

and this is reflected by the fact that the Council have consistently failed to demonstrate a 5

year housing land supply, as demonstrated by planning appeal decisions. The proposed

settlement hierarchy and distribution is very similar to the existing approach set out in the

adopted Core Strategy, and it has to be questioned why the Council are taking such a similar

approach, when it has led to issues previously and is perpetuating failure.

2.8 We have genuine concerns that by carrying the same approach through to the new Local

Plan will again increase the risk of the Council not being able to deliver the required level of

housing, as well as being unable to demonstrate a 5 year housing land supply. This will

inevitably leave the Council susceptible to planning applications for windfall development. A

sound approach would be to reduce the reliance in areas which have previously had

deliverability issues.

2.9 Whilst it is accepted that the most sustainable settlements should generally accommodate

higher levels of growth, the current distribution is unacceptable. Our Client suggests that

growth should be more evenly distributed across the Authority, with higher levels of growth

in the Service Towns and Villages. The Council have a duty to ensure that they deliver the

level of housing set out within the Plan and it is important that housing is directed towards

areas where it can be delivered and where people want to live.

2.10 Preventing towns and villages from growing is not acceptable. The provision of additional

housing assists in ensuring the services and facilities in such places can remain in business

through increasing investment. In several instances villages have aging populations and the

provision of new housing can assist in providing opportunities for younger generations to get

on the housing ladder in locations they want to live. This in turn helps to provide mixed

communities, an element of sustainability which is often overlooked.

2.11 The proposed distribution is unsound as it fails to meet the tests outlined in paragraph 35 of

the Revised National Planning Policy Framework. The approach is not effective or positively

planned and should be revised to spread the distribution more evenly within the settlement

hierarchy.

2.12 Our Client objects to the Council’s proposals in respect to the development of non-allocated

sites within settlement boundaries in the Main Urban Areas, Main Towns, Service Towns and

Villages and defined villages. As per previous Draft Policies, Policy 2 continues to state that

development of non-allocated sites within development limits will be supported in

appropriate locations, which are defined as sites that would “retain the core shape and form

of the settlement; not significantly harm the settlement’s character and appearance; and not

Draft Policies


significantly harm the character and appearance of the surrounding countryside or the rural

setting of the settlement”.

2.13 The Revised National Planning Policy Framework has a clear presumption in favour of

development that falls within development limits and it is unacceptable and unreasonable to

add a negatively worded policy which seeks to restrict development in such areas. The

qualifying criteria for an ‘appropriate location’ are al l matters that should be covered by

separate policies, as such, this element of the policy should be deleted as it is unsound.

2.14 Policy 2 states that in exceptional circumstances, and subject to the demonstration of clear

local community support, residential development in appropriate locations may also be

supported in the Countryside on land adjacent to the development limit of a Defined Village.

Our Client objects to this approach based on the fact that all planning applications should

be considered against adopted planning policy and material planning considerations, not

influenced or based on community support.

Policy 3 – Level and Distribution of Growth

2.15 Our Client has serious concerns regarding the Council’s methodology which has been used to

calculate the housing target of 920 dwellings per annum over the plan period 2015 – 2035.

2.16 The Council set out within the Housing Need Assessment that they have a programme in

place which includes a team of dedicated officers focussed on tackling empty homes and

preventing homes becoming empty. They aim to bring these homes back into use and as a

result of this the housing requirement should be reduced to reflect this. We would question

the validity of this approach and given the uncertainty which surrounds the compulsory

purchase of property, this shouldn’t lead to the reduction in the housing requirement.

2.17 Policy 3 explains that, using the Government’s Standard Housing Methodology as a starting

point, national projections identify a housing need in the Borough for 585 homes per year

(baseline growth) over the plan period (8,775 homes). In addition, to meet planned

economic growth over the plan period, an addit ional 327 homes per year (economic growth)

is identified. This gives a total objectively assessed housing need (OAHN) of 912 new homes

(net) per year for the Borough once economic growth is taken into account.

2.18 Table 3 at paragraph 4.39 of the Publication Local Plan, sets out the Settlement Hierarchy

and Distribution of Proposed Housing. Paragraph 4.40 explains that Local need (baseline)

housing growth (approximately 8,775 homes) is distributed pro-rata to all settlements with a

‘service function’ to meet locally the housing growth needs of the existing population. The

balance of the local need figure (that which relates to villages without a service function) is

632. That figure has then been added to the economic-led housing growth element for

Draft Policies


distribution to higher order settlements in the Borough rather than spread pro-rata. Our

Client’s concern is that those villages that don’t have 4 or more of the 12 key services will

lose out on any form of housing allocation and as a result they will stagnate over the plan

period.

2.19 For example the balance of the number of dwellings that would otherwise have been

allocated to these villages that don’t have a service function is proposed to be added to the

economic-led housing allocation i.e. the main urban areas and 7 main towns. Our Client

objects to this approach as it may require Green Belt release in settlements such as Bawtry.

This figure should be distributed evenly across all levels of the settlement hierarchy. In

Bawtry for example this would result in an allocation of 215 houses as opposed to the 110

listed in Policy 3.

2.20 Our Client objects to this approach which further limits the housing allocation to smaller

settlements.

2.21 Our Client has serious concerns and objects to the way in which the five year housing land

supply has been calculated in that it ignores the need to meet planned economic growth

over the plan period as identified through the Housing Needs Assessment; there is nothing in

planning policy that advocates that approach.

2.22 In summary, Policy 3 is unsound and does not meet the tests of soundness set out in

paragraph 35 of the Revised Framework. The policy is not justified, effective or positively

planned and should be revised.

Policy 6 – Housing Allocations

2.23 Our Client supports the proposed allocation of their land interests on Westwood Lane,

Bawtry (site reference: 141), as this is a suitable and deliverable housing site that plays

little Green Belt function.

2.24 However, our Client objects to the dismissal of their site (reference: 146) as a proposed

housing allocation. More detailed information is provided in Section 3 of these

representations.

Meeting the Need for New Homes

Policy 8 – Delivering the necessary range of housing

2.25 Policy 8 sets out a number of aims and aspirations that the Council have in respect of

housing developments. Our Client is one of the largest housebuilders in the country and is

well placed to comment on the suitability and practicality of the policy.

Draft Policies


2.26 Part b) of the policy provides guidance on the level of affordable housing that will be

required, with developments of 15 homes or more having to provide 23% affordable housing

in the Borough’s high value housing market areas or a lower requirement of 15% elsewhere

in the Borough. The higher/lower value areas should be defined using a map within the

policy for clarity.

2.27 The figure of 23% affordable housing in the Borough’s high value housing market areas

creates issues when calculating the requirement; we propose the figure is rounded down to

20% to simplify calculations and ensure that sites are viable.

2.28 Part d) of the policy relates to provision of housing for older people. As per our previous

representations, our Client seeks clarification as to whether the Council are seeking to

impose this policy on all residential developments or if it is merely aspirational.

2.29 The policy states that new developments should include the provision of homes which are

adaptable, accessible, and suitable for people with a wide range of needs in lin e with Policy

46. Part d) states that it must be demonstrated how ‘the provision of housing types suitable

for older people…especially bungalows, extra care facilities and supported living

accommodation’ can be increased. Policy 46 sets out the minimum space standards, building

regulations requirements and states that at least 65% of all new homes on housing

developments of over 0.5 hectare or 10 or more units should meet these regulations.

2.30 Policy 46 goes on to state that ‘in all cases, the above standards should be met ’ and that

‘exemptions to these requirements will only be considered where the applicant can robustly

demonstrate, with appropriate evidence, that adhering to the standards is not feasible due

to physical constraints, or it is demonstrated that it is not viable to do so’.

2.31 The provision of bungalows, extra care facilities and supported living accommodation will

significantly impact upon the viability of developments and in turn may impact upon the

deliverability of sites. Our Client objects to this policy and recommends that that

percentage of new homes required to meet these standards is significantly reduced.

2.32 Part f) of the policy seeks to encourage custom build and self-build homes on housing

allocations. As per our previous representations our Client objects to this element of the

policy as they have genuine concerns as the provision of such units on major housing

schemes would simply not work in practice. Large developments can have anywhere between

1 to 3 developers on site and the potential involvement of an additional private individuals

could have repercussions on a number of issues such as the timing of delivery, cashflow and

equalisation, as well as potential legal agreements. In addition, the way in which Section

106 contributions and CIL are calculated would be complicated and it is unclear who’s

responsibility this would be in terms of making the relevant payments. Self-build plots are

Draft Policies


usually on small plots of land that do not require any, or very limited, contributions a nd it is

unclear if they would have to contribute to the obligations associated with the wider site.

There is also likely to be uncertainty around conditions and who would be responsible for

discharging them. For example, if a developer obtained outline planning permission for the

whole site, would they be responsible for discharging conditions specific to the self-build

plot?

2.33 In addition to the above, we would question what evidence the Council have to demonstrate

that there is a demand for self-build plots within major housing developments. Without any

evidence to underpin this requirement, it is our Clients opinion that the policy is unsound as

it is not justified or effective and therefore fails to meet the tests of soundness at paragraph

35 of the Revised Framework.

Transport, Access & Infrastructure

Policy 14 – Promoting sustainable transport within new developments

2.34 At the previous stage of representations, we commented on part b) of the policy which

related to planning obligations being sought as part of development proposals for future

transport projects. We objected to that requirement on the grounds that it would fail the

tests for when an obligation can be sought and was unreasonable. We welcome the fact that

requirement has now been omitted.

2.35 Part b) of the policy now states that ‘proposals that require new projects will be required to

make a proportionate financial contribution ’. In principle, we accept this approach however

we believe further detail should be provided as to how this will be calculated and we reserve

our position to comment further should more detailed information be provided.

Policy 19 – Development affecting public rights of way

2.36 Our Client always strives to provide high quality pedestrian routes within their developments

and they welcome a policy which seeks to protect public rights of way where possible.

However, part d) of the policy states ‘developers will be expected toto consider any

unrecorded public paths that cross development sites and treat them in the same way as a

definitive public rights of way’. This is wholly unacceptable, unsound and should be deleted

from the policy. Unrecorded paths that run through sites have no legal protection and to

state that they should be retained and treated in the same manner as a public right of way,

which does have legal protection, is completely unreasonable.

2.37 This approach is not advocated within the Revised Framework and as such this proposal is

not in accordance with national guidance and should be deleted.

Draft Policies


Green and Blue Infrastructure / Natural Environment

Policy 27 – Green and Blue Infrastructure

2.38 The policy requires development proposals to provide a green infrastructure masterplan, in

order to demonstrate how proposals will retain and/or enhance, as well as create new green

infrastructure. As highlighted through the previous consultation window, our Client agrees

that a policy should be included within the plan regarding green infrastructure, however they

object to the contents of the policy as currently worded.

2.39 The requirement for a specific document should be dealt with via the Council’s local

validation checklist, rather then within a planning policy. As such, the requirement for the

green infrastructure plan should be removed from the policy.

2.40 In addition to the above, our Client questions the need to a green infrastructure plan and

what ultimately it will achieve. Most developments will include a landscape masterplan and a

biodiversity management plan and it is contended that such documents will provide the

Council with sufficient comfort that green infrastructure will be addressed through proposed

developments. To request that this information is then drawn together into another separate

document is unnecessary and overly onerous. The policy is not justified, effective or in

accordance with national planning guidance and as such is unsound, failing to meet the tests

of paragraph 35 of the Framework.

Policy 28 – Protecting Open Space Policy Areas and Non-Designated Open Space

2.41 Our Client would question the Council’s negatively worded approach to the development of

non-designated open space in part b) of the policy. This issue was raised at the previous

consultation stage but our comments still stand: Effectively any parcel of land which is not

protected in the Local Plan as open space would therefore be classed as non-designated

open space. Clearly this is not the intention of the Revised Framework, to sterilise all open

space, and as such we object to this element of the policy.

Design & Built Environment

Policy 42 – Character and Local Distinctiveness

2.42 Part b) of the policy states ‘Where an applicant wishes to utilise standardised, or ‘off the

shelf’ designs which have been used previously, unless these designs are rigorously justified

under the requirements of part E of this policy, the designs must be adapted to complement

or re-interpret local character, or make them more distinctive by developing an appropriate

locally inspired new identity and appearance for the development ’

Draft Policies


2.43 Whilst the wording of part b) has changed slightly the restrictive still results in a negative

presumption towards the use of major housebuilders standard house types. This is unfair

and is not based on any evidence which justif ies its inclusion within the policy; for these

reasons our Client objects to this part of the policy.

2.44 It is however accepted that in some cases revisions may be required to the detailing of

certain house types, however, the policy enables the Council free reign to request revisions

to house types.

2.45 Our Client will also identify the most appropriately designed houses for each location to

ensure that the character and appearance of the area is maintained and not adversely

affected. Part b) of the policy is not effective, justified, positively p lanned or in accordance

with national planning policy and is therefore unsound and should be deleted.

Policy 43 – Good Urban Design & Policy 45 – Residential Design

2.46 Our Client is generally supportive of policies 43 and 45, which seek to ensure that high

quality designs and development is brought forward.

2.47 However, the policies should include a caveat which states that the provisions within the

policy are subject to viability.

Policy 46 – Housing Design Standards

2.48 As currently drafted our Client objects to part a) of Policy 46, which states “in order to

ensure homes are large enough for the intended number of inhabitants, all new housing

should meet the Nationally Described Space Standard as a minimum ”.

2.49 It does not appear that the Council have provided any justification as to why there is a need

for the Nationally Described Space Standards to be introduced into the borough, and without

this information, they can not seek to impose the standards. The Planning Practice Guidance

is clear (ID 56-020), that “where a need for internal space standards is identified, local

planning authorities should provide justification for requiring internal space policies” . As

part of this process, the Council need to demonstrate the need for larger units, that the

introduction of the policy would not impact adversely upon viability, and that a transitional

period may be required.

2.50 It does not appear that the Council have considered any of these factors and as such, our

Client has concerns regarding the introduction of this policy as there does not appear to be

any evidence which underpins the request. The policy should therefore be deleted as it is

unsound and does not meet the tests of paragraph 35 of the Framework.

Draft Policies


Policy 49 – Landscaping of New Development

2.51 Our Client is generally supportive of this policy, it is in their interests to make their

developments as visually attractive as possible. However, we would advise that the Policy is

revised to add a caveat that the proposals within the policy are subject to viability.

Health and Wellbeing

Policy 51 - Health

2.52 Part f) of the policy states that “the developer will demonstrate they have undertaken, and

responded to the findings of, a Health Impact Assessment (HIA) ”.

2.53 The requirement for a HIA should be dealt with via the Council’s local validation check list

and not through a specific planning policy. Our Client therefore objects to the policy on the

basis that it is not effective or consistent with the Framework, and we would advise that it is

deleted.

2.54 Our understanding is that the information that forms part of the HIA is often matters which

are beyond the control of the applicant and relate to the choices of individuals who occupy

developments.

2.55 Our Client is supportive of a strategic policy which seeks to improve the health and

wellbeing of Doncaster residents, however, the policy, as written is unsound. It takes a

broad brush approach and there appears to be no evidence which suggests that a HIA would

be required for all schemes over 100 houses (as per the Screening Tool).

Climate Change, Minerals, Resources & Energy

Policy 61 – Protecting and Enhancing Doncaster’s Soil and Water Resources

2.56 Part a) of the policy states that:

“proposals on non-allocated sites that involve the loss of the best and most versatile agricultural land (grades 1, 2 and 3a) will only be

supported where:

• there is an overriding need for the proposal;

• there are no other suitable alternative locations on lower quality

agricultural land (or non-agricultural land) available; or

• the land can be reinstated back to its previous state (where possible)”.

2.57 Our Client objects to this policy as currently drafted as it does not align with national

planning policy and is therefore unsound. The Revised NPPF at footnote 53 is clear that it is

only where significant areas of best and most versati le agricultural land will be lost, that

areas of poorer quality should be sought as an alternative. It is our understanding that

planning appeals have found that significant development in this context is circa 20

hectares.

Proposed Sites

18640/A5/LPREPS/CA 11 September 2019

3.0 PROPOSED SITES

3.1 In addition to publishing the Publication Draft document the Council have also published

their proposed housing allocations for consultation. As a major housebuilder within the

borough, our Client has a keen interest in the proposed allocations.

3.2 It is noted that our Clients land interest at Tickhill Road, Bawtry (site reference: 146) has

been rejected as a proposed housing allocation on the following grounds - “rejected housing

site – this site is currently designated as Green Belt. The Phase 3 Green Belt Review

concludes that the site has a Moderately Weak Case for inclusion in further site selection

work”.

3.3 It is important to note that the brief explanation does not dismiss this site on the basis of it

having any physical constraints such as access or flood risk issues, it is dismissed on purely

on the perceived harm to the Green Belt.

3.4 As per our previous comments and having reviewed the Green Belt Review that has been

undertaken in 2016 by Arup on behalf of the Council, our Client has significant concerns

regarding the way in which the assessment has been undertaken. Indeed, our Client

commissioned a landscape rebuttal, prepared by Golby + Luck Landscape Architects, in

response to the findings of the DMBC Green Belt Review. This rebuttal is attached at

appendix 1.

3.5 In addition to this rebuttal, at the previous consultation stage we raised fact that there

appear to be flaws in the methodology and this in turn has lead to a negative assessment of

our Client’s land, which had the assessment be undertaken in a different way, would not

have occurred.

3.6 The Green Belt Review splits the Green Belt within the borough into 64 parcels, which are

then assessed against the five purposes of the Green Belt. Whilst it is not disputed that an

assessment against the five Green Belt purposes should be undertaken, it is the fact that

only 64 parcels of Green Belt have been assessed, and in the case of site ref: 146, dismissed

because it falls within a much wider parcel.

3.7 This is not a fair and reasonable way to undertake a Green Belt review and each site put

forward should be assessed on its individual merits, not as part of a wider parcel of land,

which may well score more poorly. The map extract below shows the extent of ‘South 6’,

which is the parcel of land which site 146 falls within. The parcel is expansive with large

areas of woodlands and plantations, however, that is very different context when considered

our Clients site in isolation. To put this in context, Our Clients site area totals 15 ha whilst

the Green Belt review has assessed an area that totals over 1,500 ha. Our Clients land

Proposed Sites


equates to just 1% of this of land immediately adjacent to the settlement boundary of

Bawtry and 4.55 km from New Rossington to the North West. The site is highlighted in

yellow in figure 3.1 below.

Figure 3.1 – Extent of South 6 Green Belt Parcel

3.8 An example of how this approach is flawed, is that under each question, an assessment is

made, with reference to the various different areas within the parcel i.e. adjacent to New

Rossington, the central area, and adjacent to Bawtry, but then an overall score is given,

despite the fact that each of the areas mentioned above play greatly differing roles within

the Green Belt.

3.9 It is clear from figure 3.1 above that our Clients site will not impact upon New Rossington or

the central area and, when considering the prevention of merging or coalescence of

neighbouring towns, the Green Belt Review specifically states that the Green Belt at this

location (South 6) represents a ‘Less Essential Gap’ of a sufficient scale that development is

unlikely to cause merging. Futhermore, under the question ‘Green Belt General Area has a

role in supporting the views into and out of the historic core’ and an overa ll score of 3 is

given, which means the following – ‘views to the historic core of the settlement from the

Proposed Sites


Green Belt or our from the historic core the settlement towards the Green Belt are dispersed

and enclosed with moderate views to key historic elements within the core or out towards a

surround. There are some medium scale detractors or nearby built form which have

moderate impact on views to and from the Green Belt’.

3.10 However, the specific assessment relating to land around Bawtry states “views towards the

historic core of Bawtry are relatively limited by a copse of woodland just beyond the western

development extent of Bawtry. Views from the north west towards Bawtry are again limited

by the outdoor storage area. Views from the historic core of Bawtr y are limited by the

modern built form on the settlement’s periphery”. This does not align with scoring the site 3

on this test, and it demonstrates that the site has been scored unfairly due to it being

included within a larger parcel.

3.11 Our Client objects to the methodology used within the Green Belt Review and we point out

that ultimately, if the site was considered in isolation it would have been demonstrated that

the land does not play an important Green Belt role and would represent a rounding-off of

the settlement. The site is not constrained, a fact which does not appear to be disputed by

the Council, and subject to the provision of a strong landscaping belt along the western and

northern boundaries of the site, would represent a suitable site for a housing allocation.

Green Belt release in this location would allow additional housing in Bawtry at an acceptable

scale and in an appropriate location.

3.12 An indicative masterplan has been prepared by JRP Architects and it shows how a scheme

can be brought forward for 240 units, which only utilises approximately 50% of the overall

site, thus reducing the potential impact of the development. This is considered to be a

suitable and deliverable housing site, which is being promoted by a housebuilder with a track

record for delivery, and this site could be delivered within the first five years of the plan,

which could deliver a significant level of much needed affordable housing within this area.

We would advise that the Council undertake a specific Green Belt Assessment of this site in

isolation.

3.13 With regards to our Clients other site in Bawtry, which is located off Westwood Road (site

ref: 141), they fully support the proposed housing allocation. The site is not constrained

and has defensible boundaries on three sides, and it plays a limited role in the Green Belt

and therefore should be removed and allocated for housing.

Summary and Conclusions


4.0 SUMMARY AND CONCLUSIONS

4.1 These representations have been prepared on behalf of our Client, Barratt and David Wi lson

Homes (Yorkshire East), who are an interested stakeholder in the borough, with land

interests in Bawtry.

4.2 Whilst our Client welcomes the Council’s proposals to prepare a new Local Plan, they have a

number of concerns regarding the content of the publication document. A number of these

issues relate to the soundness of the Plan and there are concerns that the tests of paragraph

35 of the Revised National Planning Policy Framework will not be met as currently written.

Our Client’s comments on Development Management policies are provided with the intention

of helping to speed up the decision-making process, and to remove any unnecessary

complications. This is to help to ensure the speedy delivery of much needed housing within

the borough.

4.3 The principal concerns in terms of the policies as drafted within the publication version of

the Plan are the proposed housing figure which the Council have identified as their housing

requirement for the plan period. The evidence base which underpins this figure is

considered to be flawed and there is an overreliance on the reintroduction of empty homes

as well as a disproportionate distribution of housing to the top tiers of the settlement

hierarchy. For example, the surplus of housing that is diverted away from villages without a

sufficient service function should be distributed evenly across all six tiers of the settlement

hierarchy, not just the top two.

4.4 The general Council’s approach to the distribution of housing through the borough is

concerning, as they are seeking to deliver 90% of all housing in the main urban area and the

main towns, with just 10% of housing in the service towns and v illages. There are

deliverability issues within the area, which has been demonstrated by the fact the Council

have been unable to demonstrate a five-year housing land supply and despite this , the

Council are carrying forward the same approach to distribut ion as is within the adopted Core

Strategy. This is unacceptable, and the Council have to propose housing in areas where is

can be delivered. Our Client strongly objects to the distribution as currently proposed, and

a more even spread through the district should be brought forward.

4.5 Our Client supports Green Belt release in order to meet the housing requirement Our Client

supports Green belt release in order to meet housing requirements and objects to the

exclusion of their land interests at Tickhil l Road, Bawtry (site ref: 146). The sole reason it

has been dismissed is because it scores poorly as part of the Green Belt Review. We have

demonstrated within these representations that the Green Belt Review is flawed and the site



has been unfairly assessed based on the fact it forms part of a wider Green Belt Parcel that

was assessed, rather than being assessed on an individual basis.

4.6 However, our Client does support the proposed allocation of their other site in Bawtry, site

reference 141.

4.7 We welcome the opportunity to outline these in further written representations and also in

verbal representations at the Examination in Public in the near future.



Appendix 1

Landscape Rebuttal to the Green Belt Review 2016

(Golby and Luck, Landscape Architects)

Land North of Tickhill Road, Bawtry

Landscape Rebuttal to the Green Belt Review 2016 – Site 146

Client: Barratt York

Date: 24 October 2018

Ref: GL1044

l a n d s c a p e a r c h i t e c t s

golby luck+

T e l :

W e b : w w w . g o l b y a n d l u c k . c o . u k

E m a i l :

R eg i s te r ed O f f i ce : 20 7 L e i ce s te r Road , I bs t oc k , Le ic e s t e r sh i re , LE 67 6 HP

G ol by and Luc k L L P (P a r t ne r s h i p No. O C38 23 74 ) Re g i s t e r ed i n E ng l a nd an d Wal es

Land North of Tickhill Road, Bawtry – Landscape Rebuttal to the Green Belt Review 2016 – Site 146


REF: GL1044 1 DATE: 24th OCTOBER 2018

1 INTRODUCTION

1.1 The following landscape rebuttal has been prepared by Golby + Luck Landscape

Architects on behalf of Barratt York in response to the findings of the Doncaster

Metropolitan Borough Council Green Belt Review – February 2016 (the Green Belt Review).

This rebuttal should be read in conjunction with the submissions made by Barratt York to

the Doncaster Local Plan Informal Consultation: Draft Policies & Proposed Sites September

2018.

1.2 This rebuttal considers the findings of this report alongside the Doncaster Metropolitan

Borough Council Landscape Character and Capacity Assessment of Doncaster Borough

– March 2007 (the Character Assessment). It is accepted that Green Belt is purely a

functional policy and is distinct from the issues central to the assessment of landscape

character but, there are common threads running between them. This rebuttal highlights

the inconsistency between the Character Assessment and Green Belt Review. In addition,

there are areas in the detailed Stage 3 assessment for this site within the Green Belt Review

that are not accepted and have been highlighted and reassessed through this rebuttal.

1.3 This rebuttal considers the landscape setting of the site, its attributes and its function as

Green Belt land when tested against the five purposes of the Green Belt set out under

paragraph 134 of the National Planning Policy Framework 2018 (NPPF).




2 THE SITE

2.1 The site is located at the immediate western edge of Bawtry extending between Tickhill

Road to the south and Martin Lane to the north. The site sits within an existing arable field

sloping towards the settlement falling from approximately 30m above ordnance datum

(AOD) at its western boundary to approximately 20m AOD at its eastern boundary with the

settlement.

2.2 The site does not contain any notable landscape feature beyond its boundary hedgerows

to the north and south and existing farmed land use. The site is not covered by any

landscape designation that would suggest an increased value or sensitivity to change and

is not covered by any statutory or non-statutory designation that would prohibit its use for

residential development. Does not contain or adjoin any designated heritage assets and

is remote from the Bawtry Conservation Area separated from it by intervening modern

settlement.

2.3 The site does not contain or adjoin any ecological or wildlife designations and does not

contain any BAP priority habitats. The existing arable land use would suggest that the site

is of limited ecological value.

2.4 In landscape terms, the site is located within the Bawtry to Finningley Sandland Heaths and

Farmland landscape character area that has been assessed within the Character

Assessment as having a moderate capacity to accommodate development.

2.5 The character assessment sets out guidance for housing development within this LCA that

states:

Locate in dips in the landform Layout to fit with either with the contours of the landform or the straight edges

of surrounding features

Locate adjacent to existing large settlements Use existing woodland for screening

Add additional screening in the form of new woodland/trees clumps and

hedgerows using species characteristic of the LCA.




Scale of development to fit the scale of local landscape elements such as fields

or woodlands.

Replace missing trees and hedgerows to help screen and soften the

development.

Locate away from existing public rights of way to prevent enclosure and loss of

existing views.

Avoid merging settlements as this would disproportionately increases visual

impacts and affect wildlife corridors.

2.6 The proposed site and its development for residential purposes can comply with all bar

one of these landscape prescriptions. However, it should be noted that whilst no

woodland exists around the site to assist in the assimilation of development the scheme

can reinstate the historic pattern of hedgerows within the wider field and secure an

enhanced landscaped edge to the settlement.

2.7 The Character Assessment continues by making a more detailed assessment of selected

settlements to again better inform and guide future development ensuring that this

assessment cover both the macro and micro scales.

2.8 In summary, in landscape terms there is no evidence to suggest that this site should not be

considered for housing development. The Character Assessment has identified

development potential in this broad location and the site and scheme can secure the

published landscape mitigation measures.




3 THE GREEN BELT FUNCTION OF THE SITE

3.1 The Green Belt Review is set out in three stages that in a similar way to the Character

Assessment move from the macro scale looking at broad areas of land to the micro scale

looking at specific sites.

3.2 Within this review the site has been considered within the Stage 3 assessment and is

identified as site 146 – Tickhill Road, Bawtry.

3.3 The review correctly considers the performance of the Green Belt against the five functions

identified within the NPPF but does not weight this scoring on the basis that the

fundamental aim of the Green Belt is the prevention of urban sprawl, an aim that has been

central to Green Belt policy since its inception. This is the first identified purpose of the

Green Belt and whilst being read as one of the five proposes should be seen as its

overarching function.

Purpose 1 – to check the unrestricted sprawl of large built-up areas

3.4 The Green Belt review considers this function and accepts that in the location of the site

and Bawtry the designation does not provide the purpose of checking the unrestricted

sprawl of large built-up areas. This function is scored as 1 and assessment that is accepted

(Score 1).

3.5 The Green Belt Review also considers the boundaries of the site noting the permanence

and strength of Tickhill Lane to the south, Martin Lane but the potential weakness of the

existing field boundary to the west. With regard to the western boundary this should also

be considered in combination with the landform falling towards the settlement and the

further degree of separation this secures with the surrounding countryside to reinforce the

permanence of this boundary. Whilst the hedgerow boundary may be susceptible to

change drawing question to its permanence that same cannot be said of the topography

of the site.

3.6 The site has the potential to reinstate the historic pattern of hedgerow boundaries lost to

agricultural intensification. These measures alongside the implementation of a robust

structural landscaping scheme will secure a strong and enduring western boundary to the

site. The figure below illustrates the setting of the settlement in 1854 with the site boundary

identified and the potential level of hedgerow reinstatement at the western boundary of

the site.




Purpose 2 – to prevent neighbouring towns merging into one another

3.7 In the Green Belt Review this purpose is considered in two stages, first the relationship

between Bawtry and surrounding settlements, and second the role of the Green Belt in

resting ribbon development.

3.8 In terms of separation, we do not accept the score of 3 as this would suggest that the

development of the site would result in a less than satisfactory gap between settlements.

This is contrary to the findings of the assessment that accepts limited development in this

location may be possible. The site extends across land falling towards Bawtry with no

perception of the wider settlements of Harworth and Bircotes to the west. The juxtaposition

between the settlements, landform and the nature of the intervening highway (A631)

mean that development can be accommodated with the site whilst having a limited, if

any, effect on settlement separation (Score 1).

3.9 In terms of ribbon development, we do not accept the score of 5. The extension of the

settlement as proposed would result in a block of development extending the settlement

to the west. This scale and pattern of development will not be unlike the block of modern

development that already defined the pattern and character of the wider settlement




beyond its historic core. The extension of the development frontage alongside Tickhill

Road and Martin Lane would not read as extensive ribbon development unrelated to the

existing settlement edge would not materially impact on the perceived separation of

Bawtry and Harworth/Bircotes. More specifically, in relation to Tickhill Road the extension

would be read in conjunction with the contained wooded setting on the southern side of

the highway further reducing any perception that development is breeching the

boundary of the settlement and extending into open countryside (Score 2).

Purpose 3 – to assist in safeguarding the countryside from encroachment.

3.10 This purpose is considered both in terms of sensitivity and magnitude of change (i.e. the

scale of change through development). We again do not accept this finding. More

specifically this finding does not reflect the findings of the Character Assessment that

concluded this landscape as having a moderate capacity to accommodate change in

the form of residential development. Therefore, this purpose can at best be considered

as moderately safeguarding the countryside from the proposed change. In the summary

text the review states that the site contains features that are of a moderate-high sensitivity

to encroachment. There is no landscape evidence that supports this statement and it

appears in direct conflict with the findings of the Character Assessment.

3.11 This rebuttal has already demonstrated that the site and proposed development can

secure the mitigation prescriptions set out in the Character Assessment further

safeguarding the wider landscape from encroachment. It is accepted that development

will transform open arable land to residential development and this will result in a material

change in character but in the absence of all new development coming forward in

brownfield or previously developed land this is an unavoidable consequence (Score 3).

Purpose 4 – to preserve the setting and special character of historic towns

3.12 The Green Belt Review is very unclear in its assessment findings when considering this

purpose. Put simply, the site does not play a role in protecting the setting of any historic

towns surrounding Bawtry. In terms of Bawtry, the site is separated from the settlement

Conservation Area by extensive modern housing development. The site does not contain

or adjoin any heritage assets and therefore any relationship can only be through visual

connection. When considering visual connection, the Green Belt Review confirms there

are none (Score 1).

Purpose 5 – to assist in urban regeneration, by encouraging the recycling of derelict and

other urban land.




3.13 The Green Belt Review scores the site as 1 in the detailed text but 4 in the summary text?

It is taken that this score should be 4 as the site is not derelict or other urban land and it

development would not therefore encourage the reuse of such land. However, this has

to be balanced against the fact that a large proportion the Local Authrotities residential

housing need will be met through the development of greenfield sites (Score 4).

3.14 In overall terms, the aggregate Green Belt function score of the site should be 2 that in

accordance with the Green Belt Review methodology is representative of land with a

relatively weak Green Belt function.

Greenhill Road, Swannington – Landscape Review

Client: David Wilson Homes East Midlands

REF: GL0003 i DATE: NOVEMBER 2013

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T e l : W e b : w w w . g o l b y a n d l u c k . c o . u k

E m a i l :

Reg i s t e re d Of f ice : 2 07 Le ice ste r Ro ad, I b s to ck , Le ice st e r sh i r e , LE 67 6 HP

G ol by an d Luck L LP (P a r tne r sh ip N o . OC38 237 4 ) Reg i s te re d in Eng l an d an d Wal e s

Assessment of the Sustainability Appraisal of Doncaster Local Plan Publication Version

(Published August 2019)

The Council have commissioned Wood Environment & Infrastructure Solutions UK limited (‘Wood’) to

undertake a Sustainability Appraisal (SA), and this includes an assessment of al l sites that have been

put forward for consideration as potential housing allocations. The SA sets out a series of sustainability

objectives, which have a number of sub objectives along with a bullet point summary of how the

objectives will be achieved.

A qualitative scoring system has been adopted which is set out in Table 2 of the SA and copied below

for ease of reference:

The scoring system used has four possible responses with:

• (+) Green being positive i.e. likely to assist with sustainable development,

• (-) red being a negative or incompatible i.e. likely to compromise sustainable development,

• (0) white/blank being neutral i.e. likely to involve both compatible and incompatible effects; and

• (?) Unlikely to be related or Uncertain i.e. effects cannot be judged at this stage.

Our representations to the Local Plan should be read in conjunction with this assessment of the SA,

however, our Client has fundamental concerns with the Council’s approach to housing delivery over the

Plan Period.

Firstly, the Council have backdated the Plan to 2015 to enable historical completions to contribute to

the housing requirement, thus meaning fewer sites have to be allocated. Whilst we don’t dispute that

completions can contribute to the housing requirement, this should only be from 2018 onwards, when

the Council progressed with the Local Plan review. As such, our Clients view is that there should be a

substantial increase in housing allocations over and above those which are proposed, a nd our Clients

land interest in Bawtry (specifically site ref: 146 – Tickhill Road, Bawtry) represents the most suitable

site in terms of a future housing allocation.

Notwithstanding our Clients position above, if the Council proceed with the plan as currently drafted,

and only propose to allocate five sites in Bawtry (site ref: 950, 966, 982, and 499) in addition to our

Clients site ref: 141.

Tables H1 and H2 of the Publication Local Plan (below) split those sites into two categories, those with

planning permission and those without.

Our Client has interests in site ref: 141 on Westwood Road but our view remains that our Clients site

ref: 146 scores more favourably than site 499, Land off North Avenue and should be allocated.

In order to make a robust comparison, we have added a simple numerical scoring system as follows:

(+) Green = 2

(neutral) = 1 i.e. likely to involve both compatible and incompatible effects; and

(-) red = 0

(?) Unlikely to be related or Uncertain i.e. effects cannot be judged at this stage.

Based on these numerical scores we have compared site ref: 499 Land off North Avenue, Bawtry against

our Clients’ site ref: 146 Tickhill Road, Bawtry.

As it stands the Council claim that site ref: 146 – Tickhill Road, Bawtry has a cumulative score of 35 and

that site ref: 499 – Land off North Avenue, Bawtry has a cumulative score of 41.

Having reviewed the Council’s assessment of our Client ’s site (at Appendix N), we have concluded that a

number of the assessments are incorrect, and our Clients’ site has been downgraded based on

inaccurate information.

The inaccuracies are as follows:

Objective 3A and Sub Objectives i), ii) and iii) relate to the promotion of the use of public

transport.

The commentary notes that the site lies within 1200m of a train station and between 400m – 800m of a

high frequency bus stop. The site is also within recognised cycle distances of a cycle network and loca l

services.

Based on nationally recognised guidance the site is actually within walking or cycling distance of local

schools, shops, employment opportunities and local amenities in Bawtry, all within 2km walking distance

and 5km cycling distance of the site. These measures are drawn from the Institution of Highways and

Transportation (IHT) document ‘Guidelines for Providing for Journeys on Foot’ (1998) which details the

preferred maximum walking distance of 2km. The IHT and Department for Transport (DfT) document

‘Cycle Friendly Infrastructure: Guidelines for Planning and Design’ (1996) provides a guide on suggested

cycle speeds associated with cyclists of varying confidence and ability. Using a speed of 10mph (16kph)

a catchment of 5km would be availab le within approximately 20 minutes’ cycle time.

The Council have identified our site as Red (0) but given that the site falls within recognised walking

and cycling distance of a train station and bus stop that this site should have been assessed as Green

(2)

Sub Objective 3B i) Will the site be accessible to an existing centre?

Given the accepted distances highlighted above, relating to journeys on foot and by bicycle, the site is

well located to an existing centre and shopping parade. We propose that the scoring of neutral (1) is

assessed as green (2).

Sub Objective 3B ii) Will the site be accessible to a primary school?

The Council state that the site lies within 400m - 800m of a primary school which is within widely

accepted walking distances. The Council have scored a neutral (1); we propose the site is assessed as

green (2).

Sub Objective 3B iii) Will the site be accessible to a secondary school?

The Council comment that the site lies over 2km away from a secondary school, but it is worth pointing

out that the site is within 800m of a bus stop. In addition, children of secondary school age are capable

and more likely to travel to and from school by bus. We propose the negative Red (0) score is assessed

as a neutral (1) score.

Sub Objective 3B iv) Will the site be accessible to a GP?

The Council comment that the site lies within 800m of a GP surgery and is given a Green (2) score. We

support this score but question why the accessibility of a GP surgery attracts a higher score than the

accessibility of an existing centre or a primary school. We reiterate that the respective scored for access

to those facilities should be assessed as Green (2).

In summary, it is clear that the neutral and negative scores on this site in relation to accessibility

should have been assessed as green (2) rather than amber (1) and red (0). The Council’s assessment of

the site is a flawed assessment as the site is located adjacent to the village boundary, 500m from the

primary school and 600m from the GP Surgery with good public transport links.

5D i) related to availability and specifically asks “Has the site been identified as an opportunity to

address housing market failure?”.

The Council have given the score of neutral (1) and their reasons for doing so is that the site is not a

formerly cleared housing site. The site is a green field agricultural site, adjacent to the settlement limits

and is available for development as demonstrated within our previous representations. This objective

should have been assessed as a Green (2) as opposed to a neutral (1).

8A iii) Will the site avoid known areas of landfill sites? And; iv) Will the site avoid known areas of

unstable land?

The Council have confirmed that the site not located within an area identified as containing a closed

landfill site. Therefore, the site will avoid known areas of landfill and therefore fully complies with the

objective. The site is an agricultural field that has not had any buildings or alternative uses and the

Council’s neutral (1) rating is unfounded, the rating should be Green (2) as it wholly complies with that

element of the objective.

8B relates to infrastructure.

Sub-objective i) asks “Will the site have an impact on the Strategic Road Network?”

The Council comment that the impact upon the Strategic Road Network (SRN) is expected to be

mitigated but other, committed, schemes. As such the Council are claiming that there is no impact upon

the SRN. In light of this the score should be assessed as Green (2) rather than neutral (1).

Sub-objective iii) Will any additional demand for primary school places be likely from the site?

The council note that the site is located within the catchment of a primary school with additional places

needed. The latest Ofsted report1 for the Bawtry Mayflower Primary School states that the school is

currently under capacity with a surplus of spaces for new children to join. Given this evidence we

propose that the negative red (0) score be assessed as a Green (2) score.

Sub-objective iv) Will any additional demand for secondary school places be likely from the site?

The council note that the site is located within the catchment of a primary school with additional places

needed. The gov.uk website2 quotes the latest data and states that the total number of pupils

attending the school is 831. The latest Ofsted report3 states that the capacity of the school is 834.

Given that the school is currently slightly under capacity and that planning contributions would form

part of any application on this scale we propose that the negative red (0) score be assessed as a Green

(2) score.

Objective 9 relates to improvement in the health and well -being of the borough ’s population.

Sub Objective 9A i) asks “Does the site have access to formal and informal open spaces?”

The Council’s response is that the site is within the catchment of either a formal or informal open

space. However, the Council have failed to acknowledge that a development of this size will no doubt

include public open space with the development proposal and/or pay a commuted sum for the provision

1 https://reports.ofsted.gov.uk/provider/21/106737

2 https://www.compare-school-performance.service.gov.uk/school/137141/serlby-park-

academy/absence-and-pupil-population

3 https://reports.ofsted.gov.uk/provider/28/137141

https://reports.ofsted.gov.uk/provider/21/106737

https://www.compare-school-performance.service.gov.uk/school/137141/serlby-park-academy/absence-and-pupil-population

https://www.compare-school-performance.service.gov.uk/school/137141/serlby-park-academy/absence-and-pupil-population

https://reports.ofsted.gov.uk/provider/28/137141

of such opportunities through associated legal agreements. We suggest the site is assessed as Green

(2) rather than neutral (1).

Objective 12 seeks to protect, increase and enhance the natural environment, including the landscape,

its underlying geology and wildlife habitat.

Sub Objective 12 A i) asks, Will the site affect biodiversity?

The site is an agricultural field but the Council’s assertion that development of the site would negatively

affect biodiversity is unfounded. As part of a comprehensive submission the proposed scheme could in

fact result in a net gain in terms of biodiversity. The Council have scored this element as a negative red

(0). We believe the site should be assessed as a neutral (1), potentially moving up to a Green (2) with

suitable mitigation.

Similarly, sub objective 12 B i) relating to the impact upon Landscape, states that the site located in a

broad area assessed as having 'moderate' landscape capacity . The council have scored the impact as a

neutral (1) however, with a comprehensive Landscape Visual Impact Assessment potential impacts could

be mitigated and further enhanced. As such we believe the scoring should be Green (2).

Objective 13 seeks to protect, conserve and enhance the historic and cultural heritage.

The Councils comments relating to the impact upon heritage assets and archaeological features are

essentially that there are no heritage assets that would be impact upon, and no known archaeological

objection to the proposed allocation of the site .

So, bearing in mind, the development will not affect a conservation area, a listed building or it s setting,

non-designated heritage assets, registered historic park or gardens, registered battlefields or a

scheduled ancient monument. However, the Council consider that these objectives are assessed as

neutral (1). We propose that, given there is no known impact, this objective should be assessed as

Green (2).

Objective 14 seeks to Protect and enhance soil, air and water quality (watercourses and ground water)

Sub-Objectives B and C relate to water and air quality respectively. The council state that the site is

located 25m or further from an identified surface water body and located outside of an AQMA or

National Exceedance Area. Given that there appears to be no immediate impact, and that any

application would include a suite of mitigation measures we proposed that these elements are assessed

as Green (2), as opposed to neutral (1).

Taking the numerous inaccuracies outlined above into account, we set out below how the site should be

assessed, had the approach been fair and consistent.

Site ref: 146 – Tickhill Road, Bawtry = 51 Scoring considerably higher than the allocated land off

North Avenue.

As noted from the above commentary, the Council’s assessment is inaccurate and has led our Clients

land interest being substantially downgraded, when in fact it scores higher than the other proposed

allocations within the settlements of Bawtry.

From: Barton Wilmore on behalf of Barratt and David Wilson ...... · About Barratt and David Wilson...

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