From: The Joint Rural Parishes Sent: 30 September 2019 17:53 To: Local Plan Subject: Local Plan: comments (Representation) form

I enclose the following:

Local Plan Comments Form, The Joint Rural Parishes (JRP) Submission, which says Draft,

but is final, and the JRP's response to the consultation Dec 2018, which is an addendum to the

September 2019 submission.

Pamela Moorhouse

Secretary to JRP

Please respond by 6pm Monday 30September 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. Pleaseemail 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 andPart B– Your Comments (referred to as representations)

PartA Please complete in full. Please see the Privacy Statement at end of form.

1. Personal Details 2. Agent’s Details (if applicable)

Title Mrs

First Name Pamela

Last Name Moorhouse

Organisation (where relevant)

Joint Rural Parishes Group

Address – line 1 30 Pickburn Lane

Address – line 2 Pickburn

Address – line 3 Doncaster

Postcode DN5 7XF

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

Doncaster

Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION)FORM

WhatcanImake commentson? You can comment (make representations)on any part of the Doncaster Local Plan PublicationVersion and its supportingdocuments. These include: Sustainability Appraisal, Habitat RegulationsAssessment, 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 ). DoIhave tousethe responseform? Yes please.This is because further changes to the plan arefor 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 attachadditionalevidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additionalevidence 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.Additionalresponse forms are available online at www.doncaster.gov.uk/localplan Can I submit representationson behalf of a group or neighbourhood? Yesyou can.Where there are groups who share a common view on how they wish to see the plan modified,it wouldbe

helpful for that group to send a single formthat represents that view. In such cases the group should indicate howmany people it is representing including a list of their names and addresses, and how the representation was agreed e.g.via a parish council/actiongroup meeting,signing a petition,etc. Itshould stillbe submittedon this standard form with the informationattached. Question3(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 ConsultationStatements and the Duty to Cooperate Statement, which can be foundat:www.doncaster.gov.uk/localplan Questions4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fitfor purpose’ and ‘showing good judgement’. The Inspector will explore and investigatethe plan against the NationalPlanning 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).

Question8 (below) – Do I need to attendthe Public Examination? You can present your representationat a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than writtenevidence. The Inspector will use his/her own discretionto decide who should participateat the Public Examination.All examinationhearings 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:

Joint Rural Parishes Group

1. To which document does your response relate?(Please tickall that apply)

Doncaster Local Plan Publication Draft / Policies Map ☐

Sustainability Appraisal ☐ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): Green Belt Topic Paper

☐/ Other Document(s)?If so, which one(s): ☐/

HELAA Interactive maps Green Belt ‘Vision and Values 2015 Vision, Aims and Objectives NPPF March 2019 Settlement Background Paper Local Plan evidence base Green Belt Stage 3 site summaries Sec 106 Annual Monitoring Report Doncaster Infrastructure Strategy and Annex Settlement Audit

2. To which part(s) of the document / map does your response relate?

Page No.: Paragraph:

Policy Ref.: 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 Question6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tickall that apply)

Positively prepared ☐ Justified ☐/

Effective ☐ Consistent with National Policy ☐

6. Please give reasons for your answers to Questions 3, 4and 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.

Please see the submission (attached). Also enclosed as an addendum is our December 2018 response, which elaborates on Chapter 4, ‘call for sites’.

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 Question6 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).

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 participateat the examination.I would like my representationto be dealt withby writtenrepresentation.

☐ Yes, I wish to appear at the Examination.

If you have selected No,your representation(s)will stillbe considered by the independent Planning Inspector by way of writtenrepresentations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:

Please note: the Inspector will determine the most appropriate way to hear those who wanted to participateat the hearing session. Your Signature

Date 30/09/2019

Please send your completed form,by no later than 6pm on 30thSeptember 2019,to:

Planning Policy & EnvironmentTeam, 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.

Doncaster Local Plan

- Response by The Joint Rural Parishes

September 2019

1

Background.

The Joint Rural Parishes (JRP), which represents the rural communities to the west of

Doncaster, held a number of meetings to formulate a joint response to the Doncaster Local

Plan 2015-2035, which is being examined by the Inspector on its soundness and legal

compliance. This submission should be considered a general overview which reflects the

majority opinion and key concerns of the the following communities: Barnburgh and

Harlington, Brodsworth incl. Green Lane, Cadeby, Clayton and Frickley, Hickleton, High

Melton, Hooton Pagnell, Skelbrooke and Hampole, Marr and Pickburn.

In addition Parishes may also submit responses on issues that are more specific to their

individual community.

Consideration has been given to the Local Plan in its entirety, including the Appendices,

HELAA, Settlement Background Paper, Settlement Audit, Local Plan Evidence Base,

Doncaster Infrastructure Strategy, Green Belt Topic Paper, Green Belt Stage 3 Site

Summaries, Vision, Aims and Objectives 2015, Section 106 Monitoring Report, Interactive

Maps and NPPF March 2019.

The JRP has agreed that the Local Plan has been positively prepared, effective and

consistent with national policy, though it has reservations about its effectiveness, which will

be explained more fully in the text.

OVERVIEW Chapters 1,2,3 The JRP agrees with the evidence base and vision for the future. Chapter 4. Policy 2. The JRP agrees in principle with the ‘Spatial Strategy and Settlement Heirarchy’. However, the figures for housing need, which include the evidence from Economic Forecasts and Housing Needs Assessment1 , the Government’s Standard Housing methodology, together with DMBC’s planned economic growth figure may be inflated. Clearly plans will need reviewing regularly to ensure supply and demand is balanced. Settlement Hierarchy: (1) explains the settlement hierarchy for Main Urban Area, Main Towns, Service Towns and Villages and Defined Villages in its proposals for new development. However, there are anomalies where clarifications are required. For example,

1 PeterBrett Associates (May 2018)

Doncaster Local Plan

- Response by The Joint Rural Parishes

September 2019

2

In the section on Main Urban Area (MUA) and Defined Villages, Green Lane, classified by DMBC as Brodsworth, a ‘defined village’, has been placed in the MUA of Scawsby, which clearly has different criteria for development. This needs clarification. (Letter from DMBC enclosed).

Defined Villages and Countryside (4&5) The JRP agrees that, in order to make communities sustainable, some appropriate development may be required in villages and countryside and welcomes the statement of community involvement in any development. Clearly, there are challenges to ensure that these villages, identified as ‘defined’ do not stagnate. However, should DMBC continue to uphold its previous position to include the ‘call for sites’ 2014, it follows that some of the sites could be an additional supply of housing (windfalls) in the defined villages. The JRP reiterates, as in the previous response to the Local Plan in 2018, that no development, other than small scale infill should be permitted. We request that that DMBC remove these sites entirely to avoid developers coming forward with applications for development. Although a distinction has been made between ‘service villages’ and ‘defined villages’ in relation to new developments, the Local Plan states that non-residential development is justified to support a prosperous rural economy. This statement needs further clarification. For example, change of use of existing agricultural buildings should not justify larger scale industrial developments to occur in the small defined villages and hamlets. Green Belt (6) the meaning of Green Belt is explained. However,

The removal of land from Green Belt in both service villages of Barnburgh-Harlington and Sprotborough (Appendix 2, sites 777 & 929 respectively) requires further justification with regards to ‘special circumstances’ (NPPF). Otherwise, precedents will be set for reducing the amount of Green Belt land.

Chapter 6 Policy 8: Meeting the Need for New Homes The JRP welcomes the explanation of meeting future housing needs by taking account of the demography of Doncaster, most especially as it predicts a reduction in younger people and a 30% increase in the over 60’s demographic. Clearly, regular monitoring will be required in order to satisfy the needs and demands of the population. Although DMBC has engaged with service providers, the JRP believe there is insufficient evidence stated within the Plan to ensure there is provision of services for residents of new

Doncaster Local Plan

- Response by The Joint Rural Parishes

September 2019

3

housing developments: specifically, the availability of school places, GPs and dentistry for the expected and projected increase in population. Chapter 7 Transport, Access and Infrastructure Policy 13 This chapter shows a good analysis of existing and future transport needs. The challenge will be to meet targets to reduce pollution created by movement of goods and people, while at the same time enhancing employment opportunities across the Borough. The JRP welcomes the inclusion of a by-pass for the A635 for Hickleton and Marr to alleviate congestion, improve air quality and reduce accidents (the most recent being 2 fatalities in September 2019). The challenge will be to determine and find the most suitable route for the by-pass which will serve the needs of road users whilst preserving the villages and the historic environment, particularly the Grade 1 heritage asset, Brodsworth Hall.

The need for the A1/A19 link road, whose development is stated as being towards the end of the Plan, will increase employment opportunities in the north of the Borough, as indeed will the upgrading of the A1 by Highways England. However, all these developments should not be targeted to open up further employment sites for warehousing along the strategic road network in the west of Doncaster where it would encroach, not only on Green Belt, but also on prime agricultural land. Policy 14: Strategy for Promoting Sustainable Modes of Transport The JRP notes that policy 14 details the strategy for Promoting Sustainable Transport in New Developments. It hopes that the Planning Authority will be robust in its requirements for new developments. Evidence suggests otherwise. For example, the housing development, off Longlands Lane, on the former Brodsworth colliery site, has a housing allocation of 342. [Ch 16, Table H1(B)] The first phase is completed. There is little evidence that sustainable modes of transport have been considered. People walk to work along this rural road, which is unlit, has no speed limit, no pavements and overhanging trees. Without clear, robust transport plans, monitoring and enforcement are ineffective. Chapter 14: Climate Change, Mineral Resources and Energy Policy 60

The policy states locations where windfarms will be permitted and identifies an area of search in the map. (fig 13, p 163). There is no mention of where permission has already been granted for windfarms. Doncaster’s Infrastructure Strategy Annex 2019 states that planning permission has been granted for a windfarm at Clayton. The Local Plan is misleading by omission, because, if indeed planning permission has been granted, then the Local Plan should say so. However, it may be that the land is safeguarded because of the

Doncaster Local Plan

- Response by The Joint Rural Parishes

September 2019

4

proposed HS2 Phase 2b route. If so, the Local Plan should state this is the case.

Chapter 15: Implementation and Monitoring

Appendix 12 – gives details of monitoring, but throughout the chapter and the appendix, there is little mention of planning enforcement. There are only 4 references which are very specific: one in the context of gypsy sites and this mentions 'sites which are immune from enforcement' (footnote to Table 6 on p64); one in Chapter 7, fig 7, which outlines the enforcement process in ‘Transport Assessment of Planning Applications’; one in the context of HMO's where it states that 'the Council will utilise all its powers available including licensing and enforcement .... to ensure that our communities are not negatively impacted by the provision of such accommodation' (policy 10, paragraph F on p60) and one in the context of extraction of minerals where it states 'that there is a requirement for routine monitoring and if necessary enforcement to ensure conditions that mitigate impacts are complied with' (minerals policy paragraph 14.33 on p166). It is not at all clear why only these 4 specific areas have been selected for enforcement action policy. In order to have an effective Local Plan there must surely be a clear and unambiguous policy for enforcement across the board to deal with all transgressions in planning - whether unauthorised developments or non-compliance with authorised developments and their conditions. To have an effective plan, the Local Plan must be monitored and controlled and this must involve policing and enforcement of developments to ensure objectives are met. The current approach by DMBC to enforcement is haphazard and lacks any clarity and consequently this leads to confusion and abuse. The opportunity should be taken now to put forward a clear and unambiguous enforcement policy as a key part of the Local Plan. Education One of the challenges described in the Local Plan, Chapter 2 (2.18) is to increase the proportion of highly-skilled workers, because Doncaster has a higher than average number in low-skilled employment. Clearly higher and further education will be a key driver, with Doncaster College as a prime mover. The JRP supports Doncaster’s ambitions to improve educational opportunities and higher skilled employment. To that end, it would support objectives to enhance the digital/media economy. However, in the Doncaster Infrastructure Strategy Annex, Education and Learning: Chapter 2, p15, 2.22 on Education, reads as though the High Melton site of Doncaster College is still operational, though it has not been used for any educational purposes over 2 years and as such, buildings are becoming derelict. Ch 8 6.14, gives details of a £4.1 million development grant for film and TV studios and other facilities including an hotel.

Clearly, it is misleading to give the impression that this has been approved by DMBC, when the site is not yet sold, and any planning permission would need to take into account whether the planned buildings would be greater than the original footprint, which could

Doncaster Local Plan

- Response by The Joint Rural Parishes

September 2019

5

therefore, encroach on Green Belt. This £4.1m development is nowhere near or close to being confirmed.

Summary While much of the Local Plan appears to meet most of the requirements of ‘soundness’, in so far as the JRP can judge on the evidence provided, it can only be effective if there are robust monitoring and enforcement measures.

The Joint Rural Parishes Group was formed in 2015. Rhonda Job, Chairperson Pamela Moorhouse Secretary Cynthia Ransome (Cllr) Nick Balliger Joanne Thompson Jean Dickinson Beryl Smith Tracey Care Kath Johnson Frank Mann P Calladine John Poole

1

A NEW LOCAL PLAN FOR DONCASTER

The Joint Rural Parishes Response to the Proposed Local Plan for Doncaster 2018

1. BACKGROUND

The Joint Rural Parishes (JRP), which represents the rural communities to the west of Doncaster,

(Barnburgh, Harlington, High Melton, Adwick on Dearne, Cadeby, Hickleton, Marr, Brodsworth,

Pickburn, Green Lane, Hooton Pagnell, Clayton, Frickley, Moorhouse, Hampole, Skelbrooke and

Sprotbrough) have held meetings & worked together to formulate a joint response to the latest

phase of consultation regarding the draft proposals which are being considered by DMBC as part of

The Local Plan for Doncaster. This submission should be considered a general overview which

reflects the majority opinion and key concerns of these communities. In addition Parishes may also

submit responses on issues that are more specific to their individual community.

Detailed consideration has been given to the proposed draft policies to determine planning

applications and the proposed Sites for new housing, employment and other uses. In addition, we

have reviewed the Homes and Settlements proposal, the Green Belt Review proposals and

Sustainability Appraisal - along with the published feedback from the previous Consultations.

Reference has also been made to the revised Vision, Aims and Objectives and Issues & Options, the

two main documents on which the previous consultation was based.

The Consultation Process

Doncaster Council are preparing a new Local Plan to shape how Doncaster develops: how we want it

to look and feel; and the policies and proposals needed to guide development to the right places

whilst protecting and improving the environment and people’s quality of life.

The Local Plan is used to decide planning applications and guide investment in the Borough. It

delivers the new homes, businesses, jobs and infrastructure needed over the next 15 years. It will

replace the 1988 Unitary Development Plan and 2012 Core Strategy.

The JRP agreed that its response could be better conveyed through a written submission as not all

rural communities have the facility to reply electronically. It was also felt that the online

Consultation Response Form format was unsuitable to accommodate our full contribution. The JRP

congratulate the Council on their in-depth analysis and evidence based reports used to shape and

create a 15 year Local Plan for Doncaster. We further acknowledge the work and effort of DMBC

staff in collating these reports and would like to specifically recognise and thank those in the

Planning Department for all their hard work. We appreciate the timing scheduling of the

consultation process as it has avoided national holiday periods. However, due to the vast number of

reports that have only recently been made available, together with the very short consultation

period, is one of great concern. The Council are seeking views from its electorate and local Parish

Councils on important issues, which are likely to shape Doncaster and impact its residents for the

next 15 years. However, it is a near impossible task for the vast majority of residents and

communities due to the sheer volume and length of documents which must be reviewed.

The Local Plan proposals are therefore less likely to receive the attention they deserve given that the

Council has chosen to release all of the reports at the same time instead of making them publicly

available in a more timely and manageable manner over the course of the last two years.

2

2. SPECIFIC COMMENTS ON MAIN CONSULTATION DOCUMENTS

2.1 Infill

The JRP broadly agreed with the outline contained within the previous 2016 Draft Proposals

and were encouraged by the “Infill” policy for the rural 'Defined' villages. We were further

pleased by DMBC’s recognition that most of the land within the long-established

development boundaries was designated as Residential Policy Area. We continued to

support this initiative, whilst it was not detrimental to our existing rural communities or

identity. The rural communities represented by the JRP are unanimous in their view that

development in the small villages and hamlets must be proportionate, sympathetic and in

keeping with their character. Infill, as previously described by our then allocated Local Plan

Officer, would deliver small but manageable housing growth in rural settings, ‘…usually

between 1-5 units … change of use, conversions or replacement of existing buildings. So, it is

really small scale piecemeal changes within the settlements rather than any major new

development or urban extensions. The settlement boundaries are defined by the extent of the

green belt that surrounds them …. The Green Belt designation constrains the extent to which

they can accommodate new development, as it is difficult to develop in the green belt unless

there are very special circumstances…. These boundaries are unlikely to change as part of the

Green Belt Review, so the existing settlement boundaries (formed by the Green Belt) and

areas washed over by the Green Belt are likely to remain the same in the Local Plan as

currently set out on the UDP map.’

DMBC now propose significant changes to the Settlement Hierarchy with 28 previously

‘Defined Villages’ now classified as ‘Smaller Greenbelt’ or ‘Washed over Greenbelt Villages’

with no’ Identified Development Limits’.

There was much confusion over this terminology as well as concern and uncertainty around

the implications of this re-categorisation for the majority of our rural communities; as such

we sought written clarification on these points from a Senior Planning Officer from the

Planning Policy and Environment Team.

It is now our understanding that those villages which DMBC propose to re-categorise as

‘washed over greenbelt’ and when there is no longer a defined village boundary, infill will be

defined within the policies. It is currently defined in Draft Policy 2 ‘Infilling means the filling

of a small gap which fronts onto a highway and has a width less than 20 metres between

existing buildings’. However, this relates specifically to settlements in the countryside (non-

Green Belt).

It is noted on Page 5 of the draft policies that in the Green Belt, national policy applies.

(Paragraph 145e) of the National Planning Policy Framework (NPPF) notes that ‘limited infill

in villages’ is an exception to inappropriate development in Green Belt.

NPPF (Para 145g) also notes with regard to infill in the Green Belt: ‘A local planning authority

should regard the construction of new buildings as inappropriate in the Green Belt.

Exceptions to this are: g) Limited infilling or the partial or complete redevelopment of

previously developed land, whether redundant or in continuing use (excluding temporary

buildings), which would:- not have a greater impact on the openness of the Green Belt than

the existing development; or – not cause substantial harm to the openness of the Green Belt,

where the development would re-use previously developed land and contribute to meeting

an identified affordable housing need within the area of the local planning authority’

3

The JRP fully support the re-categorising of the 28 villages to ‘washed over green belt’ status

provided the Council only permit Infill development in the small villages and hamlets in line

with the stated policy and with the assurance that any application for such development

which must be proportionate, sympathetic and in keeping with their character.

It is further noted that the proposed settlement strategy does not direct housing to the

smaller ‘washed over Green Belt’ villages and DMBC have stated that they do not propose to

allocate sites in these settlements within the draft Local Plan, irrespective of the Green Belt

status. We would therefore urge DMBC to remove any and all proposed development sites

identified and included within the previous ‘Call-for-sites’ for these villages as these should

now be considered inappropriate and unsupported by both the JRP and DMBC.

Barnburgh & Harlington and Sprotbrough Village have been categorised as Defined Villages

whereby ‘Small boundary changes will be subject to further greenbelt analysis’. In addition,

The Proposed Local Plan Housing Distribution suggests an allocation of 95 new dwellings in

Sprotbrough Village and 60 new dwellings in Barnburgh & Harlington over the 15 year plan

period; a combined total of approximately 1% of the overall new dwellings required over the

15 year period.

Page 70 3.5.58 of …. states: “The role of the Defined villages is that some growth will be

supported in ’appropriate locations’ within the defined ‘Development Limits’.

‘Appropriate in this context means a location which does not conflict, when taken as a whole,

with national policy or policies in this Local Plan. In addition, to qualify as an ‘appropriate

location’, the site, if developed, would:

Retain the core shape and form of the settlement

Not significantly harm the settlement’s character and appearance and

Not significantly harm the character and appearance of the surrounding countryside

or the rural setting of the settlement.

The JRP acknowledge that DMBC has undertaken a detailed review of all Settlements and an

assessment of local services available - including those which are currently available in

Sprotbrough Village and Barnburgh/Harlington. The Local Plan asserts that some services

exist in these rural villages however, it neither considers nor assesses service availability or

accessibility.

As such, we do not agree with the proposed development sites and scale of development

identified within the Proposed Local Plan for these two Defined Villages. Sprotbrough Parish

and Sprotbrough Village, encouraged by DMBC, have worked tirelessly for three years to

thoroughly review the future housing needs of its Parish. Through continuous and ongoing

consultation with its residents, an in-depth assessment of its services as well as robustly

assessing potential impacts on services, they have created an endorsed Draft Neighbourhood

Plan ready for delivery. The Local Plan development proposals are contrary to the already

identified housing needs. We fully concur with Sprotbrough Parish that additional housing

development proposed within the Local Plan will mean irreparable loss of Greenbelt land

and the detrimental and irreversible effect on already well documented congested road and

bus transport routes. Furthermore, it will have a detrimental impact on already over

burdened existing services which are unable to absorb further population increases including

oversubscribed school places and GP surgeries – Ridgewood School is already full to capacity.

4

Particular consideration must also be given to the impact of new dwellings proposed on land

that floods at Barnburgh/Harlington. Services here are also stretched to breaking point with

schools and GP’s at capacity – resulting in the very recent threat of closure of the GP surgery.

Unacceptable levels of congestion continue to plague and impede vehicle movement on

these and surrounding ‘B’ routes. This will be further compounded by the addition of a

proposed 445 – 1000 new houses in Mexborough, huge development plans along the Dearne

Valley Parkway which Barnsley Council propose to deliver through their own Local Plan – all

of which will result in increased vehicle traffic on routes through and around the village.

We strongly object to the inclusion of these new developments within the local plan, as

they cannot be considered reasonable or sustainable.

2.2 Housing Stock

As stated in previous consultation feedback, we maintain that before making a commitment

to significant investment in developing new housing stock to meet future demand, the JRP

request that DMBC ascertain the current vacant housing stock – the latest statistics

published were correct as of October 2014, where DMBC declared 4,281 houses as vacant.

The National Policy Framework (paragraph 51) places an obligation on local authorities “to

bring back into residential use empty houses and buildings and where appropriate acquire

properties under compulsory purchase powers” and as such, we believe this should be

included and considered within the Local Plan to ensure that a full utilisation of vacant or

disused housing stock is seen as a priority - especially as it potentially represents up to 31%

of the total projected new homes required for the next 15 years. In addition, the JRP are still

firmly of the view that the authority should bring back into use all of its vacant buildings as

per the NPPF – “the authority should normally approve planning applications for change to

residential use”. It is our strong belief that there is little point in building new homes,

potentially taking land out of Green Belt, when there is such a large number of vacant

properties already available - an approach which fully aligns to and delivers

affordable/starter homes and sustainability and green policies/obligations.

The JRP note that in the draft Homes and Settlements proposal, the current total households

for the Borough totals 130,165 and the draft still proposes an additional 13,800 new homes

over the next 15 years.

DMBC propose 920 new dwellings per year, 585 to accommodate population rise within the

borough and an additional 335 allocated for economic growth across the borough. DMBC

project that 15,640 new dwellings will be required to meet demand over a 17 year period

between 2015 – 2032.

In previous consultations we raised concerns over the targeted increase and the number of

projected new dwellings within the draft Local Plan. We understand the rationale and the

basis on which this target has been established, however, our concerns still remain the same

since this still constitutes an increase of +10% on the total available housing stock across the

borough, a borough which has one of the worst performing housing markets in the UK.

For several years, Doncaster has suffered from an oversupplied property market and a

reducing volume of Homebuyers in a financial position to purchase.

5

With one of the highest rates of deprived areas, welfare dependency, and the lowest

average wages across the Region, it is difficult to balance this current performance with the

need for further housing stock for its Residents. Our concerns remain that a 10% increase in

homes could be seen as overly ambitious and should the projected economic growth not be

met, this would result in a “glut” of new homes, de-valuing all existing properties within the

Borough and as a result, creating a negative equity effect which would only have a

detrimental impact on Doncaster’s future economy and prosperity.

The JRP were pleased to read that we aspire to have a “greener” Doncaster and that DMBC

propose to ensure 10% of land will be set aside by developers for “green spaces”.

2.3. Employment

‘Overall, Doncaster is in the top 20% most deprived Local Authorities nationally, with 60% of

the population classed as living in areas that have worse than the English average

depravation. This impacts on housing because relatively low incomes reduce demand for

higher house sales and rental values which are therefore also relatively low’.

The JRP fully endorse the Council’s aspirations to attract new employers and businesses,

improve training and facilitate access to higher education in order to increase the number of

skilled job opportunities within its Borough. By providing skilled job availability, we agree

that better salaried positions will help to improve our resident’s standard of living and begin

to bridge improvement of our wage gap within the Region. We are mindful that increasing

skilled jobs and encouraging residents to them, is critical to the Local Plan delivery. Without

the availability of these new jobs, the average wage will not improve and there will be fewer

in a financial position to purchase their own home. It is imperative that real focus is

maintained towards creating this skilled workforce and that skilled employment

opportunities materialise. It is vital that DMBC do not fall back into traditional habits and

predicate minimum wage opportunities. We acknowledge these types of jobs would be

simpler and easier to deliver however, if we indeed are to make substantial changes and to

better improve the lives of our residents, DMBC must not be persuaded to accept or

facilitate further low wage employment opportunities.

The delivery of the proposed Local Plan is dependent on two key factors: increasing and

securing skilled jobs and increasing the number of new houses. One is co-dependant on the

other to deliver success.

2.4 Employment Land

Doncaster has an employment land requirement of 407 ha over the plan period 2015 -2032.

This figure has been derived using a methodology set out in the Employment Land Needs

Assessment(ELNA 2015), which has been applied to projected jobs figures provided in the

Economic Forecasts and Housing Need Assessment (May 2018).

This is made up of two components:

A baseline (business as usual) projection of 14,300 jobs which require land

allocations totalling 103ha, and

An aspirational economic uplift to a total of 27,100 jobs which requires 407ha of

additional land allocations (this includes the baseline).

6

The ELNA tested a range of scenarios for ways in which the potential land requirement could

be met. The one picked as the ‘preliminary land requirement’, this scenario looked at the

actual amount of land that was developed and for what use in Doncaster between 2000 and

2015 (350ha) .The annual rate by use was calculated and those figures projected forward to

provide a land requirement up to 2032 of 490ha, which was subsequently reduced to the

final total of 474ha to take account of a forecast of a lower take up of office space in future.

Previous Local Plan documents stated that DMBC, along with the Sheffield City Region,

predicted economic growth would result in the creation of an additional 20,000 new jobs

within Doncaster over the next 15 years. The JRP note that this target has now been

increased to 27,100 over the 15 year period - a further 35% increase in new jobs over the

previous target.

Within the Draft Local Plan, DMBC project that this will necessitate an additional 338 new

homes per annum to service these new employment positions, delivered by new businesses

attracted to Doncaster. The JRP note, this target of 338 new homes per annum has remained

unchanged even though DMBC are predicting a further 35% rise in demand through

economic growth. The draft proposals appear to base economic growth on new jobs and

subsequently, new homes to accommodate this growth trend. Since economic growth is

driven by these two factors, the JRP consider the new targets to be inconsistent and would

like clearer, evidence based understanding which supports these new calculations.

We agree with DMBC’s suggested milestone reviews to assess delivery against targets for

both new job and new homes. As these targets underpin the Local Plan and as such will be

the driving force to deliver the Local Plan, it is therefore imperative that an annual net new

job creation review is carried out.

2.5. Economic Growth

Doncaster, a key stakeholder within the Sheffield City Region (SCR, have both made future

Economic Growth projections. The JRP contest whether the targets that have been set are

indeed achievable or deliverable. It is our view that there is insufficient allowance made

within the Local Plan to take into consideration the impact of ‘non- delivery’ or ‘reduced

delivery’ of major Regional/National transport infrastructure projects the affect this might

have on the delivery of stated targets and objectives. Major impacts that could impede

target delivery include: European business expansion and investment programmes as a

result of Brexit: economic impacts directly related to the delivery of a High Speed Rail

scheme on our current local/ regional/national rail services or the potential for HS2 to by-

pass South Yorkshire: and the uncertainty surrounding non- inclusion of Doncaster and the

SCR in Transport for the North’s (TfN) improved Trans-Pennine cross-country connectivity

rail scheme. Non-delivery or downgraded delivery of the Northern Powerhouse’s Conditional

Outputs will mean that the entire North’s projected Productivity targets (including its

additional £92 billion GVA and 850,000 new jobs) cannot be met. Since uncertainty around

delivery of these schemes is still likely to remain for some considerable time, we would

advocate that the Local Plan’s targets be amended to reflect such risk.

Since the new target proposes a further 7,100 uplift in new job creation against a

background of economic uncertainty, we strongly recommend a ‘best’ case, ‘average’ and

‘worst case’ target delivery scenario are included within the Local Plan.

7

2.6 Development Land Allocation

‘The Location of new employment land has been informed by consultation at Issues and

Options stage. Consultation feedback was that employment provision did not necessarily

need to be close to major residential areas and could be provided in locations less suitable for

new homes (such as close to the motorway network) as long as these opportunities are

accessible’

In principle we are supportive of DMBC’s strategies as set out in its Issues and Options

(objectives 1, 2, 8, and 11) provided that existing redundant and brownfield sites are

prioritised over Greenbelt locations. We further contest that job creation does not

constitute ‘very special circumstances’. To meet its new employment targets, the JRP

strongly object to any assumption or inclusions within the Local Plan that suggests that it

does or that it will.

We concur with DMBC’s assertions that development along the A1(M) should continue to be

avoided as they state: it is unclear what land-take the road will require – capacity

improvements are likely to include both widening of the road and junction re-alignments-

and that it is unlikely that extra traffic on the A1(M) will be supported by Highways England.

Responses to the Issues and Options consultation also did not support development along the

A1 (M) corridor.

We maintain that it would be illogical to consider developing any sites along the A1 (M)

corridor since Highways England propose to widen this road. Any new developments could

only impact choice or preference, further disrupting the delivery of a new scheme. As such,

we recognise DMBC’s respect of previous consultation feedback and fully support its

decision to exclude this corridor from its proposed Local Plan for development purposes.

2.7 Services

In previous consultation responses the JRP raised concerns regarding the provision of

services, and access to these services, for the current population circa 300,000 and the

mounting pressure that will be applied to provide these services to incorporate a projected

9% increase. Cautious projections suggest 13,800 new homes will increase the population by

an additional 27,600 new residents.

We appreciate that a more detailed Settlement Review has been conducted along with

services identified within each settlement area. We further note and agree with the decision

that targeted development for new dwellings has been directed to areas where services are

more prevalent and more readily available. However, we remain unconvinced that the Local

Plan has assessed or has made robust plans for, how it will adequately address the impact

on such services. The Local Plan must ensure that the needs of the projected increase in

population can be met by all current major providers and all other essential services e.g.

schools, GP’s, Dentists, Public transport capacity and duration and Hospitals. It is our opinion

that these services are critical to sustainability and should be further scrutinised. Without

confidently outlining how this is to be delivered, any proposed Local Plan cannot be

considered “robust” if we are unable to ensure that our services meet current and future

needs.

8

2.8 Social/Affordable Housing

The JRP believe a more targeted approach is needed to identify the future needs of the

borough. Firstly, we need to establish the current number of available social/ affordable

houses. Secondly, to confirm the number of empty houses (currently estimated to be over

4,000) and the number of residents on the waiting list for social housing (currently thought

to be approximately 800). As previously suggested, it may also be prudent to include in this

analysis, the number of residents who have “bid” on houses and who have as yet failed to

secure housing. This could assist in determining the number of those who are still likely to

need housing in the future, thus determining the Boroughs “future needs”. The JRP would

like to see a clearer breakdown of the 338 predicted new homes required by the planned

economic growth which “comprises; houses for sale and rent on the open market and

affordable housing for those who cannot afford to buy or rent on the open market”. This

“baseline growth” accounts for 37% of the new homes target but there is no specific number

accredited to Affordable or Social housing. This must be clarified to ensure that both

developers and DMBC are aware of this target in order to meet the future needs of the

Borough.

2.9 Elderly/Aging Population

The majority of the “Homes and Settlement” Draft Proposal appears to concentrate on

“how” the number of new homes required was determined along with “where and what

quantity” DMBC propose to disperse this number throughout the Borough to meet varied

demographic needs. However, The JRP believes that DMBC have omitted to include our

elderly population within this proposal.

In the Local Plan Reports DMBC state: ‘Like many parts of the country, Doncaster’s

population is aging, with the 2015 Housing Needs Assessment predicting that the number of

older people is set to increase by 36% between 2015 and 2032, whilst younger age groups

are predicted to slightly decrease. This brings social and economic challenges for the

borough.’

We further believe that this significant demographic has been overlooked as there is no

mention, let alone any detailed numbers included within the Draft Proposal. Currently the

over 65 population accounts for 25% [75,600] of our 302,400 population but by 2032 this is

expected to rise to 36% [108,864+). The JRP consider this may to be a significant oversight by

DMBC.

The JRP would like to refer DMBC to the NPPF (paragraph 50) which states that: ‘the

authority should plan for a mix of housing based on current and future demographic trends …

and the needs of different groups in the community such as … older people and people with

disabilities …’ With a rapidly growing elderly population, and the Strategic Housing Market

assessment (SHMA) highlighting a shortfall of 3,704 units of specialist housing for older

people in Doncaster (using national guidance), the JRP would expect new homes to reflect

this with “Lifetime Homes Standards” and a proportion of bungalows along with the addition

of Residential Care Homes, Sheltered Housing supported by assisted living needs and

services provision. In light of the growing number [33,000] of our aging population, The JRP

suggests that 10% of new homes should be built to a fully wheelchair accessible standard.

The JRP further believe that DMBC has an opportunity to deliver a much needed Retirement

Village within the Local Plan.

9

We fundamentally believe that a strategy designed around housing ‘stepping stones’ could

provide new housing options and alternative solutions for our ever increasing elderly/infirm

population. This would balance future social and economic challenges for the borough.

Without a visible plan to tackle the future needs of this demographic, the borough will be

creating a scenario where limited housing provision is available to meet its growing demand,

combined with an ever growing financial liability on already stretched budgets in order to

deliver the expected increase for care and in-home service provision.

If implemented, confident in a range of available alternative housing propositions, an elderly

population could chose suitable accommodation and plan to meet their future needs. Such

developments would potentially release existing housing stock across the borough and in

particular, rural communities, enabling residential areas where property demand is high but

availability is limited to become accessible to a wide and diverse range of new residents.

DMBC has based its target for new dwellings on the future needs of families and younger

people. However, since the report states: ‘…younger age groups are predicted to slightly

decrease…’ the subsequent number of new houses apportioned to this age group appears

skewed. We believe the future housing needs of the borough should be revised to better

reflect the future changes in demographic age profiles.

In view of the issues outlined above, the JRP believe that in its present format, the proposed

Draft Local Plan, does not appear to be sufficiently robust and therefore is not “Fit for

Purpose” as it does not meet the identified “Future Needs” of the Borough in this regard.

2.10 A1 expansion

The JRP fully support DMBC’s position that any development within proximity to the A1

should be put “on hold” until Highways England has assessed where the expansion of the A1

is to be located, in the same way that no homes should be considered around Mineral

Extraction locations so as not to restrict potential extraction.

The A1 itself and all roads to the west of the A1 such as the A638 and the A635 are already

severely congested and the JRP believe sensible intervention is urgently needed.

The JRP fully supports the M18 corridor along with the redevelopment of brown field sites

(e.g. Wheatley Hall Road and Kirk Sandall) as well as filling vacant sites on more recent

developments (e.g. Redhouse Interchange).

2.11 Transport Links and Infrastructure

The JRP understand how vital transport links are and how they can contribute to the

prosperity of the Borough and it is in this context submit our views and concerns.

i) The JRP note the feedback from the previous consultation, in that 77% of the responses

“….supported the expansion of the A1/A1 (M) to a) improve connectivity and b) relieve

congestion. However...many people are of the opinion that the impact on the Green Belt

should be kept to a minimum and that improvements should not necessarily be a precursor

to further development in the A1 corridor”.

10

The JRP are unanimously in agreement with this view and support DMBC in their assessment

that development along the A1(M) corridor is inappropriate,…’there are congestion

problems along the A1(M) which currently limit the delivery of new large scale strategic

employment sites…’ a decision supported by Highways England on the grounds of ‘capacity

and safety concerns’.

ii) The JRP support the proposed widening of the existing A1/A1 (M) but is completely

opposed to the creation of a new build A1/A1 (M). However, where the A1/A1 (M) currently

runs (from the northern boundary of the Borough to Marr) there is only a narrow band of

Green Belt Land separating a number of rural villages and farms from this road. We

acknowledge that some Green Belt land will potentially need to be utilised to enable road

widening but this must be kept to a minimum. The JRP would not support the expansion of

the A1/A1 (M) to the west or the creation of a “new” A1/A1 (M) on Green Belt land which as

a result would create Green Belt land isolated within an old and new A1/A1 (M).

The JRP still firmly believes there is no requirement or public demand for a link road

between the A19 and A1 (M) and therefore does not support it. The JRP further noted from

previous consultation feedback that this proposed initiative had by far the lowest support

‘and attracted a number of negative comments’. Highways England Route Strategy 2015

states: ‘….one of the priority issues is the capacity and safety concerns on the A1 between

junctions 34 (Blyth) and Holmfield Interchange (M62)’. And they further state: ‘… and there is

a lack of capacity to support growth…’ We support DMBC in their interpretation of Highways

England when they state ‘…it is unlikely that extra traffic on the A1 (M) will be supported by

Highways England….’

The proposed A19 link road to the A1 (M) will mean generating extra traffic onto this already

congested stretch of the A1 (M). In light of overwhelming evidence against this proposal the

JRP cannot understand why this link road remains in the Local Plan and we reaffirm our

objection to this link road on these grounds.

There is more than sufficient access to the east of the Borough and beyond via the A1 to the

M62 or M18 or via the existing A19 and as such the JRP will expect this scheme to be

omitted from the Full Local Plan Draft.

iii) The JRP concurs with DMBC’s appraisal of the M18 that it has capacity for further growth.

Along with 77% of respondents on previous consultation feedback, the JRP are also in

support of development along this transport corridor and acknowledge that it is ‘of strategic

importance for freight and logistics as it is a vital link to a number of strategic road network

sections in SY as well as to the Humber ports….’ there are significant levels of growth which

are focused along the M18 corridor and that it will need to be adapt to additional traffic

flows created by corridor developments and increases in tonnage through the Humber

ports…’. Development here has the ability to grow in line with demand and we note

‘Together with demand information which shows that large end users wish to be located

along the M18 and congestion & access issues along the A1 (M), there is currently no

exceptional circumstance justification for Greenbelt land to be allocated for employment use,

and no Greenbelt sites will be proposed for allocation.’. The JRP recognises the strategic

importance of employment development along the M18 and that in doing so, it will not

consume any Greenbelt land, a policy which we fully support and endorse.

11

iv) The JRP support the dualling of the A630 Westmoor Link Road to improve access to

Wheatley Hall Road / Kirk Sandall and potentially release the vast acreage of land and large

number of underdeveloped brown field sites in this location for development. The JRP would

like to see this scheme included in the Full Local Plan Draft Proposal

v) The JRP support the Hatfield Link road scheme to connect Hatfield/Stainforth to Junction

5 of the M18/Junction 1 of the M180 and unlocking 200ha of development land. The JRP

would like to see this scheme included in the Full Local Plan Draft Proposal.

vi) The JRP remain encouraged by previous consultation feedback, in that ‘Clearly the A635

Bypass is the favoured scheme and has received a significant number of comments in

support’. Supported by 66% of respondents, it received by far the strongest support for road

schemes and similar to that of the A1 (M). With strong declared support and endorsement

from Doncaster’s electorate, the JRP expect to see this Bypass incorporated within the Full

Local Plan Draft Proposal.

As Doncaster grows, there will be an increasing imperative to address the congested trunk

roads in the West of the Borough. We firmly believe the much needed A635 by-pass must be

a priority for delivery within the Local Plan. Previously, the JRP believed The Local Plan

demonstrated a preference for concentrating the majority of its trunk road development

proposals towards the east. The JRP consider this may now be corrected with the inclusion of

this by-pass within the Local Plan. It is critical to improving accessibility and connectivity to

neighbouring towns and boroughs in the Sheffield City Regional Council, as well as Wakefield,

which are all only accessible via the west. We still maintain that improved transport links to

these boroughs and towns will lead to greater development opportunities.

Within their Local Plan reports, DMBC further acknowledge that Sheffield City Region has

cited the A635 as one of the ‘top 20 highways forecast to experience delays and could limit

economic growth’. With such a poor endorsement, it is imperative that a rapid solution be

implemented to address these issues. Doncaster cannot afford to lose the potential for

economic growth if it is to meet its ambitious growth targets, as detailed within the draft

Local Plan.

Doncaster's ambitious growth plans, together with Barnsley’s development proposals and a

congested A1, will only serve to exacerbate this situation. DMBC must prioritise and invest in

the existing road/transport infrastructure before it proposes to invest in new link roads if it

is to meet its expected housing growth needs. As a result, the A635 bypass is now a “need to

have” in the full Local Plan Draft Proposal.

vii) We strongly oppose the current High Speed Phase 2b proposed rail route through

Doncaster and South Yorkshire as well as a proposed rail junction at Clayton or a Parkway

Station.

2.12 Planning Policy

We believe there needs to be a change in Planning Policy. It is essential that DMBC carry out

full due diligence at proposed Development sites. They must instigate and invest in Traffic

surveys in order to assess the individual and cumulative effects of any proposed

development.

12

We believe it reasonable to expect prior independent surveys be carried out by DMBC and

not by any proposed developers before any proposed sites can even be considered as

potentially appropriate or suitable for development. It is vital that cumulative impacts from

proposed developments are measured at the outset to establish what the compounding

impact will have on neighbouring villages & communities and on already congested trunk

/local transport routes. This must be done ahead of sites being designated as appropriate or

they cannot to be considered truly sustainable.

It is our very strong view that DMBC must not allow individual site assessment to be

undertaken and/or funded by developers, since all reports will be presumed as biased and

prejudicial in their favour. Current Planning Policy dictates that individual developers finance

impact assessment reports only specifically relating to their own proposed development

plans. The Planning Committee can then only base their decision on an individual ‘case by

case’ basis.

With many sites being proposed for development within the local plan, we have both a duty

and an opportunity to address accumulative effects, thus preventing us from creating new

problems or adding to problematic road congestion or increasing particulates leading to

poor or worsening Air Quality. Awareness of the cumulative impacts means that we can stop

these types of issues happening before they arise. This would be in keeping with DMBC’s

Carbon Emissions and Green Policies.

When DMBC have completed the Local Plan, a list of all potential development sites will be

created. It is our very firm view that such development sites are all independently assessed

by DMBC but pre- financed by the developer. This would provide not only an independent

assessment of each site but would highlight any accumulative effect of delivering multiple

developments within areas. Developers must then work together to fund any remedial,

preventative or mitigation measures resulting from their multiple developments.

We believe this proposal is a reasonable and rational solution. If implemented, it gives the

opportunity to address or prevent cumulative negative impacts created by DMBC’s extensive

development plans within communities. We recommend this policy is reviewed and

considered for implementation.

2.13 Renewable Energy

The JRP’s position is unchanged and we support the aims of Doncaster becoming a low

carbon Borough. Once again however, we have major concerns on the omission in the Local

Plan of how the Council will achieve this. The JRP would strongly object to utilising the Green

Belt and scarring the landscape with more wind turbines and solar farms. The JRP would give

its full support to an approach which prioritises the installation of solar panels on large roofs

e.g. suitable industrial, commercial and agricultural buildings, followed by a managed roll

out of residential roof installations, with priority given to all new housing. To further assist

the Council in facilitating its green policies, we would encourage DMBC planning policy to

insist that all developers and new developments must demonstrate how they will support

and deliver the councils green ambitions.

13

2.14 Fracking

The JRP unanimously support DMBC’s policy and its objection to permit fracking within the

Authorities boundaries.

2.15 Green Belt

The JRP note that there has been an overwhelming and very strong response in all the

previous consultation feedback in support of retaining and protecting our Green Belt. Over

75% of the respondents supported “The Borough’s overall housing and employment needs

should be met outside the Green Belt as far as possible so as to help protect the Green Belt”.

The JRP unanimously support this view and expect the Full Local Plan Draft to reflect the

strong views shown by its electorate.

Furthermore, Doncaster has much land to the east available for development as well as

numerous brown field sites ripe for regeneration. The JRP noted that throughout previous

feedback documents there were a significant number of responders who supported the use

of Brown Field sites in preference to Green Belt for employment and development. It is

crucial that the Green Belt bands between Doncaster, Wakefield, Barnsley and Rotherham

are not eroded.

The JRP would like a clearer understanding of the process which DMBC are to use to assess

which potential allocations may be taken out of Green Belt, based on The Green Belt Review

which assessed and scored the performance of each of the 62 parcels of Doncaster’s Green

Belt against the 5 purposes of the Green Belt. The Draft Proposal stated ‘Any land proposed

to be taken out of the Green Belt will be informed by the conclusions of the Green Belt

Review’. Having consulted and reviewed these vast documents, the JRP are still unclear

which Green Belt sites, if any, are to be proposed for Housing or Employment development

and which may be under consideration for being taken out of Greenbelt. The JRP

recommend further clarity is given on this matter.

The JRP remain aggrieved and strongly opposed to any proposal whereby DMBC would

consider taking land out of Green Belt to be ‘Safeguarded’. There is little need to take land

out of Green Belt at all but there is absolutely no justification for removing more than the

minimum required, only for this ‘excess’ precious Green Belt land to be later re-categorised

as ‘protected from development for the life of the plan’ and therefore not used in any

purposeful way – this cannot be deemed as ‘exceptional circumstances’. We strongly object

to any land being categorised as ‘Safeguarded’.

The JRP remain dismayed by the content of point 49 within the Draft Homes and Settlement

proposal which states; ‘Within the Green Belt and Countryside Policy Area proposals for

general housing will not normally be appropriate. Nevertheless there are a number of

circumstances where specialist forms of residential development …. rural exceptions for

affordable housing … can be appropriate subject to the relevant policies that will be set out

in the Local Plan’. The JRP maintain the view that affordable housing is not only needed but

must be integral to the Local Plan. However, we do not believe that Rural Communities can

deliver the supporting services that will be needed e.g. public transport, health and

Employment support and are crucial to sustainable communities.

14

To the West of the Borough the majority of the proposed re-categorised Defined Villages to

‘Smaller Greenbelt’ or ‘washed over Greenbelt’ are Rural Conservation Villages and as such

the ‘Rural exceptions’ in the draft proposal is a direct contradiction to ‘…subject to the

relevant policies of the Local Plan (design policies, Conservation Area policies etc)’. As such,

the JRP remain firm in our belief that affordable housing needs will only be realistically met

within urban locations. We would again reiterate that the rural communities represented by

the JRP maintain their view that development in small villages and hamlets must be

proportionate, sympathetic and in keeping with their character to maintain our rural

identities.

The JRP were encouraged by the statement made by our Local Plan Officer- ‘…by proposing

to make villages part of the Greenbelt, we are in essence making it more difficult to develop

within them, as land in the Greenbelt is subject to a higher level of protection. … we believe

that this proposed policy may help preserve the character of villages within the borough by

directing growth to larger and more sustainable settlements…’. The JRP support and

welcome these new proposed planning policies, where growth is directed to larger and more

sustainable settlements and which also provides greater protection for rural communities

and identities.

As per the Draft Proposals ‘Constraints and other considerations’, “Land will be taken out of

the Green Belt in exceptional circumstances; this will include; … where Green Belt sites are

demonstrably more sustainable than other options”. The JRP remain seriously concerned

that the Local Plan is already heavily weighted by the opinions of Developers/Landowners

and the above statement can only be to the advantage of developers whose preference will

always be to build on clean, virgin land where profit margins are greatest and will try to

demonstrate in every instance that Green Belt Land is “more sustainable”.

For transparency, the JRP continue to insist that any potential Green Belt land that may be

under consideration for allocation is identified solely by DMBC with no input from

Developers/ Landowners. Once assessment has been confirmed, it is only then that

Developers/ Landowners should have a say in whether they wish to bid for the sites or not.

As stated previously, potential sites at risk of being taken out of Greenbelt need to be clearly

listed, identified and communicated to ensure meaningful feedback can be given.

As per our previous submissions, the original Call for Sites consultation process delivered a

Local Plan led by Landowner and Developer needs and demands. We have seen no evidence

from the new current documents to suggest that this bias has changed and we would stress

once again that it should be the role of the DMBC along with its electorate to formulate a

Local Plan which identifies the growth and regeneration needs of the Borough and in doing

so, choose the optimum sites for development and direct the type of development required.

We do not believe that Landowners and Developers should be leading the Local Plan by

deciding where and what they want to build but that needs should be driven by the strategic

decisions of the Council to deliver their Housing and Employment vision.

In addition, the JRP remain perplexed as to the reason and timing for a Green Belt review

given that Sheffield City Region has made it clear that ‘exceptional circumstances have to

exist to justify a Green Belt review in order to meet objectively assessed housing and

employment needs’.

15

Doncaster Council had not yet assessed nor identified objectively its vacant housing and its

Employment land Availability in Doncaster Report (March 2015) states (Table 4 – Remaining

Supply by year 2005 -2015) that …’the remaining supply of Employment Land is 550

hectares’.

Since only 16 hectares were utilised in 2015, and this was the greatest usage over an 8 year

period, DMBC has therefore not identified any true need for Green Belt usage to deliver the

Local Plan. The fact that the Green Belt Review was instigated prior to the initial Issues and

Options consultation and no strategic Option had been adopted, we still ask why a review

was necessary at this stage and what the exceptional circumstances were to justify it? The

need for a review would surely have depended on the feedback from the consultation and

on which Local Plan Option or mix of Options would be finally adopted. Commissioning a

Green Belt Review at that stage (prior to the consultation Feedback) in the process still

appears premature, deceptive and completely unfounded.

2.16 Mineral Extraction

The JRP still maintain that it is vital to assess the value of minerals before any development

takes place and the impact on environment, landscape and local settlements is fully

understood and adequate consultation takes place. The JRP’s opinion appears to mirror the

50% majority feedback of respondents from previous consultations. The JRP still endorse

that no homes be developed near potential Mineral sites which may hamper or prevent

extraction. We maintain this is a sensible approach.

3. SUMMARY

We fully support DMBC’s recommendations that focus new development within main towns that are

best placed to accommodate new housing to areas which can sustain employment growth. This

approach represents more sustainable development by ensuring access to existing services, facilities

and public transport. Whilst more dispersed development could well help to support and secure the

future of smaller towns and Defined villages, any growth within these locations must be in keeping

with the character and proportionate to the current size of the settlement.

We fully support considerations to protect rural character through change of designation for some

rural villages, now proposed to be recognised as ‘Smaller Greenbelt’ and ‘Smaller washed over

Greenbelt’. We see this as a positive approach with limited small scale infill schemes only being

appropriate in villages in such circumstances. Protection of Green Belt is vital, and brown field land

must take preference where developments are proposed. Also, as Doncaster grows, there will be an

increasing imperative to address the congested trunk roads in the West of the Borough. We firmly

believe that the much needed A635 by-pass must be a priority for delivery within the Local Plan, not

just an aspiration.

A review of Services has been carried out. However, an assessment of Service capacity, accessibility

and availability has not. Overall we firmly believe that additional analysis is needed to assess the

availability of such services at proposed development sites.

We believe Planning Policy needs to change. It is essential that DMBC carry out full due diligence at

proposed Development sites. They must instigate and invest in Traffic surveys in order to assess

individual and accumulative effects of proposed development.

16

We believe it reasonable to expect prior independent surveys be carried out by DMBC and not by

any proposed developers before any proposed sites can even be considered as potentially

appropriate or suitable for development We strongly advocate that the proposed new homes

allocation be revised. It must include and address the future housing needs of our growing elderly

population. This needs to be numerically specified as well as setting a projected target number

increase for Affordable and Social new housing.

We applaud DMBC on its Visions, Aims and Objectives and we fully support its Values however,

scepticism remains around its skilled employment target and its delivery. We believe influence from

numerous other and external factors will depend on whether these targets can be met. We remain

supportive of initiatives which improve health, quality of life and environmental impacts such as Air

Quality by reducing particulates and congestion on roads for the benefit of all Doncaster residents.

We strongly oppose the current HS2 route, its junction at Clayton, the Northern Loop, its station

location and any proposed Parkway station.

Finally, the Majority Feedback from the Consultations should be included within the full Draft Local

Plan Proposal.

The JRP would welcome involvement in all stages of future consultations and will continue to play a

proactive role in the development of the Local Plan for the benefit of Doncaster and its residents.

Signed: Date:

Chairperson - Joint Rural Parishes