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
18640/A5/LPREPS/CB 2 September 2019
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
18640/A5/LPREPS/CB 3 September 2019
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
18640/A5/LPREPS/CB 4 September 2019
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
18640/A5/LPREPS/CB 5 September 2019
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
18640/A5/LPREPS/CB 6 September 2019
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
18640/A5/LPREPS/CB 7 September 2019
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
18640/A5/LPREPS/CB 8 September 2019
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
18640/A5/LPREPS/CB 9 September 2019
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
18640/A5/LPREPS/CB 10 September 2019
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
18640/A5/LPREPS/CA 12 September 2019
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
18640/A5/LPREPS/CA 13 September 2019
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
18640/A5/LPREPS/CA 14 September 2019
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
Summary and Conclusions
18640/A5/LPREPS/CA 15 September 2019
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.
Summary and Conclusions
18640/A5/LPREPS/CA 16 September 2019
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
Client: Barratt York
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).
Land North of Tickhill Road, Bawtry – Landscape Rebuttal to the Green Belt Review 2016 – Site 146
Client: Barratt York
REF: GL1044 2 DATE: 24th OCTOBER 2018
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.
Land North of Tickhill Road, Bawtry – Landscape Rebuttal to the Green Belt Review 2016 – Site 146
Client: Barratt York
REF: GL1044 3 DATE: 24th OCTOBER 2018
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.
Land North of Tickhill Road, Bawtry – Landscape Rebuttal to the Green Belt Review 2016 – Site 146
Client: Barratt York
REF: GL1044 4 DATE: 24th OCTOBER 2018
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.
Land North of Tickhill Road, Bawtry – Landscape Rebuttal to the Green Belt Review 2016 – Site 146
Client: Barratt York
REF: GL1044 5 DATE: 24th OCTOBER 2018
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
Land North of Tickhill Road, Bawtry – Landscape Rebuttal to the Green Belt Review 2016 – Site 146
Client: Barratt York
REF: GL1044 6 DATE: 24th OCTOBER 2018
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.
Land North of Tickhill Road, Bawtry – Landscape Rebuttal to the Green Belt Review 2016 – Site 146
Client: Barratt York
REF: GL1044 7 DATE: 24th OCTOBER 2018
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
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 :
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
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.
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