1

Doncaster Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM Please respond by 6pm Monday 30 September 2019. The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination. Please email your completed form to us at If you can’t use email, hard copies can be sent to:

Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU. All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan

This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations)

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

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

Title Mr Mr

First Name Gareth David

Last Name Finch Diggle

Organisation (where relevant)

Peel Land and Property Management Limited Turley

Address – line 1 Peel Dome, intu Trafford Centre 1 New York Street

Address – line 2 Manchester Manchester

Address – line 3 Trafford City

Postcode M17 8PL M1 4HD

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form) What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.

• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.

• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.

• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).

Question 8 (below) – Do I need to attend the Public Examination? You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.

1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be at the request of the Inspector, based on the matters and issues she/he identifies for examination.

If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at: or

Name / Organisation Name:

Peel Land and Property Management Limited 1. To which document does your response relate? (Please tick all that apply) Doncaster Local Plan Publication Draft ☒ Policies Map ☐ Sustainability Appraisal ☐ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☐

2. To which part(s) of the document / map does your response relate? Page No.: 14-16 Paragraph:

Policy Ref.: Vision and Objectives Site Ref.:

Policies Map:

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☐ Yes ☒ 4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☒ Justified ☐

Effective ☐ Consistent with National Policy ☐

6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.

Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.

You can attach additional information but please make sure it is securely attached and clearly referenced.

See enclosed representations (Chapter 4).

7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.

(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).

See enclosed representations (Chapter 4).

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

☐ No, I do not wish to participate at the examination. I would like my representation to be dealt with by written representation.

☒ Yes, I wish to appear at the Examination.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary: In order to explain further the rationale behind the suggested changes and be given the opportunity to respond to any changes the Council propose to make and any further evidence that is presented. Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature

Date 30/09/2019 Please send your completed form, by no later than 6pm on 30th September 2019, to:

• Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU

• or email: Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan

Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:

The Council reserves the right not to publish or take into account any representations which are openly offensive or defamatory.

Doncaster Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM Please respond by 6pm Monday 30 September 2019. The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination. Please email your completed form to us at If you can’t use email, hard copies can be sent to:

Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU. All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan

This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations)

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

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

Title Mr Mr

First Name Gareth David

Last Name Finch Diggle

Organisation (where relevant)

Peel Land and Property Management Limited Turley

Address – line 1 Peel Dome, intu Trafford Centre 1 New York Street

Address – line 2 Manchester Manchester

Address – line 3 Trafford City

Postcode M17 8PL M1 4HD

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.

• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.

• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.

• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).

Question 8 (below) – Do I need to attend the Public Examination? You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.

1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be at the request of the Inspector, based on the matters and issues she/he identifies for examination.

If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at: or

Name / Organisation Name:

Peel Land and Property Management Limited 1. To which document does your response relate? (Please tick all that apply) Doncaster Local Plan Publication Draft ☒ Policies Map ☐ Sustainability Appraisal ☐ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☐

2. To which part(s) of the document / map does your response relate? Page No.: 18-45 Paragraph:

Policy Ref.: Strategic Policies 2 and 3 Site Ref.: DSA / Site Ref: 1010

Policies Map:

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☐ Yes ☒ 4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☒ Justified ☒

Effective ☒ Consistent with National Policy ☒

6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.

Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.

You can attach additional information but please make sure it is securely attached and clearly referenced.

See enclosed representations (Chapter 5 and 9).

7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.

(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).

See enclosed representations (Chapter 5 and 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 participate at the examination. I would like my representation to be dealt with by written representation.

☒ Yes, I wish to appear at the Examination.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary: In order to explain further the rationale behind the suggested changes and be given the opportunity to respond to any changes the Council propose to make and any further evidence that is presented. Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature

Date 30/09/2019 Please send your completed form, by no later than 6pm on 30th September 2019, to:

• Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU

• or email: Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan

Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:

The Council reserves the right not to publish or take into account any representations which are openly offensive or defamatory.

Doncaster Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM Please respond by 6pm Monday 30 September 2019. The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination. Please email your completed form to us at If you can’t use email, hard copies can be sent to:

Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU. All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan

This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations)

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

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

Title Mr Mr

First Name Gareth David

Last Name Finch Diggle

Organisation (where relevant)

Peel Land and Property Management Limited Turley

Address – line 1 Peel Dome, intu Trafford Centre 1 New York Street

Address – line 2 Manchester Manchester

Address – line 3 Trafford City

Postcode M17 8PL M1 4HD

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.

• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.

• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.

• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).

Question 8 (below) – Do I need to attend the Public Examination? You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.

1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be at the request of the Inspector, based on the matters and issues she/he identifies for examination.

If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at: or

Name / Organisation Name:

Peel Land and Property Management Limited 1. To which document does your response relate? (Please tick all that apply) Doncaster Local Plan Publication Draft ☒ Policies Map ☐ Sustainability Appraisal ☐ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☒

Economic Forecasts and Housing Needs Assessment (PBA, 2019)

2. To which part(s) of the document / map does your response relate? Page No.: 27-35 Paragraph:

Policy Ref.: Strategic Policies 3 – Housing Provision Site Ref.:

Policies Map:

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☐ Yes ☒ 4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☒ Justified ☒

Effective ☒ Consistent with National Policy ☒

6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.

Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.

You can attach additional information but please make sure it is securely attached and clearly referenced.

See enclosed representations (Chapter 6 and Appendix 3).

7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.

(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).

See enclosed representations (Chapter 6 and Appendix 3).

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

☐ No, I do not wish to participate at the examination. I would like my representation to be dealt with by written representation.

☒ Yes, I wish to appear at the Examination.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary: In order to explain further the rationale behind the suggested changes and be given the opportunity to respond to any changes the Council propose to make and any further evidence that is presented. Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature

Date 30/09/2019 Please send your completed form, by no later than 6pm on 30th September 2019, to:

• Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU

• or email: Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan

Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:

The Council reserves the right not to publish or take into account any representations which are openly offensive or defamatory.

Doncaster Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM Please respond by 6pm Monday 30 September 2019. The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination. Please email your completed form to us at If you can’t use email, hard copies can be sent to:

Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU. All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan

This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations)

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

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

Title Mr Mr

First Name Gareth David

Last Name Finch Diggle

Organisation (where relevant)

Peel Land and Property Management Limited Turley

Address – line 1 Peel Dome, intu Trafford Centre 1 New York Street

Address – line 2 Manchester Manchester

Address – line 3 Trafford City

Postcode M17 8PL M1 4HD

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.

• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.

• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.

• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).

Question 8 (below) – Do I need to attend the Public Examination? You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.

1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be at the request of the Inspector, based on the matters and issues she/he identifies for examination.

If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at: or

Name / Organisation Name:

Peel Land and Property Management Limited 1. To which document does your response relate? (Please tick all that apply) Doncaster Local Plan Publication Draft ☒ Policies Map ☒ Sustainability Appraisal ☐ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☒

LP Appendix 3

2. To which part(s) of the document / map does your response relate? Page No.: Chapter 5 Paragraph:

Policy Ref.: Strategic Policy 7 (Doncaster Sheffield Airport) Site Ref.: DSA (including allocations 941 E1, E2 and

E3) Policies Map:

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☐ Yes ☒ 4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☒ Justified ☒

Effective ☒ Consistent with National Policy ☐

6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.

Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.

You can attach additional information but please make sure it is securely attached and clearly referenced.

See enclosed representations (Chapter 7 and Appendix 4).

7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.

(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).

See enclosed representations (Chapter 7 and Appendix 4).

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

☐ No, I do not wish to participate at the examination. I would like my representation to be dealt with by written representation.

☒ Yes, I wish to appear at the Examination.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary: In order to explain further the rationale behind the suggested changes and be given the opportunity to respond to any changes the Council propose to make and any further evidence that is presented. Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature

Date 30/09/2019 Please send your completed form, by no later than 6pm on 30th September 2019, to:

• Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU

• or email: Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan

Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:

The Council reserves the right not to publish or take into account any representations which are openly offensive or defamatory.

Doncaster Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM Please respond by 6pm Monday 30 September 2019. The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination. Please email your completed form to us at If you can’t use email, hard copies can be sent to:

Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU. All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan

This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations)

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

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

Title Mr Mr

First Name Gareth David

Last Name Finch Diggle

Organisation (where relevant)

Peel Land and Property Management Limited Turley

Address – line 1 Peel Dome, intu Trafford Centre 1 New York Street

Address – line 2 Manchester Manchester

Address – line 3 Trafford City

Postcode M17 8PL M1 4HD

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.

• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.

• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.

• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).

Question 8 (below) – Do I need to attend the Public Examination? You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.

1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be at the request of the Inspector, based on the matters and issues she/he identifies for examination.

If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at: or

Name / Organisation Name:

Peel Land and Property Management Limited 1. To which document does your response relate? (Please tick all that apply) Doncaster Local Plan Publication Draft ☒ Policies Map ☒ Sustainability Appraisal ☐ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☒

2. To which part(s) of the document / map does your response relate? Page No.: Paragraph:

Policy Ref.: Strategic Policy 13 (Strategic Policy Network Site Ref.:

Policies Map:

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☐ Yes ☒ 4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☐ Justified ☐

Effective ☒ Consistent with National Policy ☐

6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.

Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.

You can attach additional information but please make sure it is securely attached and clearly referenced.

See enclosed representations (Chapter 8).

7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.

(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).

See enclosed representations (Chapter 8).

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

☒ No, I do not wish to participate at the examination. I would like my representation to be dealt with by written representation.

☐ Yes, I wish to appear at the Examination.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary: Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature

Date 30/09/2019 Please send your completed form, by no later than 6pm on 30th September 2019, to:

• Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU

• or email: Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan

Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:

The Council reserves the right not to publish or take into account any representations which are openly offensive or defamatory.

Doncaster Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM Please respond by 6pm Monday 30 September 2019. The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination. Please email your completed form to us at If you can’t use email, hard copies can be sent to:

Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU. All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan

This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations)

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

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

Title Mr Mr

First Name Gareth David

Last Name Finch Diggle

Organisation (where relevant)

Peel Land and Property Management Limited Turley

Address – line 1 Peel Dome, intu Trafford Centre 1 New York Street

Address – line 2 Manchester Manchester

Address – line 3 Trafford City

Postcode M17 8PL M1 4HD

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.

• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.

• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.

• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).

Question 8 (below) – Do I need to attend the Public Examination? You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.

1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be at the request of the Inspector, based on the matters and issues she/he identifies for examination.

If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at: or

Name / Organisation Name:

Peel Land and Property Management Limited 1. To which document does your response relate? (Please tick all that apply) Doncaster Local Plan Publication Draft ☒ Policies Map ☒ Sustainability Appraisal ☐ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☐

2. To which part(s) of the document / map does your response relate? Page No.: Paragraph:

Policy Ref.: Policy 26 (Development in the Countryside) Site Ref.: 1010 (Gatehouse Lane) (Omission site)

Policies Map: Development Limits/Countryside

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☐ Yes ☒ 4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☒ Justified ☐

Effective ☒ Consistent with National Policy ☐

6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.

Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.

You can attach additional information but please make sure it is securely attached and clearly referenced.

See enclosed representations (Chapter 9).

7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.

(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).

See enclosed representations (Chapter 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 participate at the examination. I would like my representation to be dealt with by written representation.

☒ Yes, I wish to appear at the Examination.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary: In order to explain further the rationale behind the suggested changes and be given the opportunity to respond to any changes the Council propose to make and any further evidence that is presented. Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature

Date 30/09/2019 Please send your completed form, by no later than 6pm on 30th September 2019, to:

• Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU

• or email: Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan

Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:

The Council reserves the right not to publish or take into account any representations which are openly offensive or defamatory.

Doncaster Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM Please respond by 6pm Monday 30 September 2019. The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination. Please email your completed form to us at If you can’t use email, hard copies can be sent to:

Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU. All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan

This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations)

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

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

Title Mr Mr

First Name Gareth David

Last Name Finch Diggle

Organisation (where relevant)

Peel Land and Property Management Limited Turley

Address – line 1 Peel Dome, intu Trafford Centre 1 New York Street

Address – line 2 Manchester Manchester

Address – line 3 Trafford City

Postcode M17 8PL M1 4HD

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.

• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.

• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.

• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).

Question 8 (below) – Do I need to attend the Public Examination? You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.

1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be at the request of the Inspector, based on the matters and issues she/he identifies for examination.

If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at: or

Name / Organisation Name:

Peel Land and Property Management Limited 1. To which document does your response relate? (Please tick all that apply) Doncaster Local Plan Publication Draft ☒ Policies Map ☐ Sustainability Appraisal ☐ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☐

2. To which part(s) of the document / map does your response relate? Page No.: 107-111 Paragraph:

Policy Ref.: Policy 30 (Ecological Network) and Policy 31 (Valuing Biodiversity and Geodiversity)

Site Ref.:

Policies Map: Mineral Resources

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☐ Yes ☒ 4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☐ Justified ☒

Effective ☐ Consistent with National Policy ☒

6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.

Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.

You can attach additional information but please make sure it is securely attached and clearly referenced.

See enclosed representations (Chapter 8).

7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.

(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).

See enclosed representations (Chapter 8).

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

☒ No, I do not wish to participate at the examination. I would like my representation to be dealt with by written representation.

☐ Yes, I wish to appear at the Examination.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary: Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature

Date 30/09/2019 Please send your completed form, by no later than 6pm on 30th September 2019, to:

• Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU

• or email: Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan

Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:

The Council reserves the right not to publish or take into account any representations which are openly offensive or defamatory.

Doncaster Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM Please respond by 6pm Monday 30 September 2019. The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination. Please email your completed form to us at If you can’t use email, hard copies can be sent to:

Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU. All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan

This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations)

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

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

Title Mr Mr

First Name Gareth David

Last Name Finch Diggle

Organisation (where relevant)

Peel Land and Property Management Limited Turley

Address – line 1 Peel Dome, intu Trafford Centre 1 New York Street

Address – line 2 Manchester Manchester

Address – line 3 Trafford City

Postcode M17 8PL M1 4HD

E-mail Address

Telephone Number

Guidance Notes (Please read before completing form)

What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.

• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.

• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.

• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).

Question 8 (below) – Do I need to attend the Public Examination? You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.

1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be at the request of the Inspector, based on the matters and issues she/he identifies for examination.

If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at: or

Name / Organisation Name:

Peel Land and Property Management Limited 1. To which document does your response relate? (Please tick all that apply) Doncaster Local Plan Publication Draft ☒ Policies Map ☒ Sustainability Appraisal ☐ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☐

2. To which part(s) of the document / map does your response relate? Page No.: 165 Paragraph:

Policy Ref.: Policy 62 (Safeguarding Minerals) Site Ref.: DSA

Policies Map: Mineral Resources

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☐ Yes ☒ 4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6) 5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)

Positively prepared ☐ Justified ☒

Effective ☐ Consistent with National Policy ☒

6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.

Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.

You can attach additional information but please make sure it is securely attached and clearly referenced.

See enclosed representations (Chapter 8).

7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.

(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).

See enclosed representations (Chapter 8).

8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)

☒ No, I do not wish to participate at the examination. I would like my representation to be dealt with by written representation.

☐ Yes, I wish to appear at the Examination.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary: Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature

Date 30/09/2019 Please send your completed form, by no later than 6pm on 30th September 2019, to:

• Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU

• or email: Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan

Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:

The Council reserves the right not to publish or take into account any representations which are openly offensive or defamatory.

Doncaster Local Plan (Regulation 19) Proposed Submission Version Doncaster Sheffield Airport

Representations on behalf of the Peel Group

September 2019

Contents

1. Introduction 1

2. The Peel Group 2

3. Doncaster Sheffield Airport 5

4. LP Vision and Objectives 11

5. Strategic Policy 2 & 3: Spatial Strategy & Settlement Hierarchy and Spatial Distribution12

6. Strategic Policy 3: Housing Provision 14

7. Strategic Policy 7: Doncaster Sheffield Airport 15

8. Other Policies 17

9. Omission Sites 19

10. Summary 21

Appendix 1: Illustrative Masterplan – The DSA Plaza

Appendix 2: Concept Master-planning Document

Appendix 3: Technical Review of Housing Evidence

Appendix 4: Proposed Modifications to Strategic Policy 7: Doncaster Sheffield Airport

Appendix 5: Gatehouse Lane Location Plan

Contact David Diggle david.diggle@turley.co.uk 30 Sep 2019

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1. Introduction

1.1 This report is prepared by Turley on behalf of our clients the Peel Group and Doncaster Sheffield Airport Limited (hereafter referred to as “Peel/DSA”). It provides representations to Doncaster Council (DC) in respect of the Proposed Publication Version Local Plan (LP) which is currently the subject of public consultation.

1.2 The Report has been prepared in general support of the LP and in particular draft policy 7 which supports the expansion of Doncaster Sheffield Airport (DSA). It does though provide suggested modifications to the wording of the draft policy (and its supporting justification) to ensure it aligns with the ambitions and objectives of Peel/DSA and its draft Airport Masterplan (DSAM). However, there are elements of the LP which are considered to be unsound as they are not justified, effective or consistent with national planning policy. As a result, Peel considers that several modifications are necessary to make the LP sound. This relates to other policies including draft spatial policy 3 relating to housing provision and the proposed policy on the open countryside. Other modifications are sought on a number of non-strategic policies. Moreover, the representations also seek to rectify deficiencies and inconsistencies in the LP, including omission sites. In this respect, land east of Gatehouse Lane is proposed within the draft DSAM for residential development and accordingly, the Regulation 18 Consultation in October 2018 identified it as a Late Housing Site (not yet assessed) with a reference number of 1010. A residential allocation has been requested, however notwithstanding it appearing as an unassessed housing site in October 2018, the LP now proposes that it remains in countryside. We comment further on this at paragraphs 5.8 and 9.1 below.

1.3 The remainder of this representation is structured as follows:

• Chapter 2: provides a summary of the Peel Group and the regional economic framework which supports the growth of DSA;

• Chapter 3: provides an overview of DSA and its vision for growth as articulated through the draft DSAM;

• Chapters 4-6: consider specific LP policies;

• Chapter 7: considers sites that are identified within the DSAM but are omitted from the LP by the absence of a positive land allocation; and

• Chapter 8: provides summary and conclusions.

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2. The Peel Group

2.1 The Peel Group is one of the leading infrastructure, real estate and investment enterprises in the UK. Peel operates a diverse network of businesses, ranging from ports to airports; land to leisure; media to hotels; wind farms to biomass, and holds a portfolio of investments in major public companies.

2.2 Peel is passionate about the growth, regeneration and prosperity of the North. It has worked with partners in the private and public sectors to drive economic growth in the North of England. Peel is excited by the Government’s plans to build a Northern Powerhouse.

2.3 It believes that it is important to plan for economic growth at local, city region, and pan-regional levels. In 2008, Peel launched “Ocean Gateway” which brings together its assets across Liverpool, Cheshire and Manchester and seeks to redefine the economic role the combined area would have for the UK. Since 2010, Peel and other partners have supported “Atlantic Gateway” – a broader economic growth and regeneration programme across this area. By combining its key assets with those of the major partners working to support the LEPs, an even more ambitious programme of economic growth has developed. In 2013, a review of the first five years of Ocean/Atlantic Gateway recorded a direct investment of £2bn, annual Gross Added Value (GVA) of £466m and over 10,000 net additional jobs.

2.4 Government priorities in creating a Northern Powerhouse include stimulating economic growth, raising productivity, and improving connectivity. Peel support these objectives and is keen to explore how their aspirations and key projects can align across the North of England to help deliver a Northern Powerhouse. Peel believes that the Northern Powerhouse has the potential to:

• improve connectivity, locally, nationally and internationally, for people and freight

• create more private sector jobs

• rebalance the economy and close the ‘North-South divide’

• improve skills, education and training

• retain talented workers in the North and attract new talent

• deliver more and better housing

• be economically self-sufficient and reduce state dependency

• drive urban regeneration

• create great places to live and work

• champion environmental quality

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2.5 Peel wishes to be a key invested partner in delivering the Northern Powerhouse. In 2015 Peel launched “Peel in the Northern Powerhouse”, a statement of commitment to partnership in helping deliver the Northern Powerhouse. It features 150 projects across the North of England which can be part of the economic and social transformation which Government seeks.

2.6 One of these 150 projects is the continued planned expansion of DSA. Indeed the Government itself clearly recognises the role the airport can play in delivering a Northern Powerhouse:

2.7 “The International gateway to Sheffield City Region for passengers and part of the logistics hub. Over £113m is currently being invested to improve its surface connectivity which will increase passenger numbers, and hence heighten its strategic significance and GVA benefits to the north.”

One North: A Proposition for an Interconnected North (HM Government, July 2014)

The Regional Economic Framework

2.8 The Sheffield City Region (SCR) Strategic Economic Plan (SEP) sets an ambitious target to increase GVA within the City Region by £3.1bn by 2025. Achieving this ambition will strengthen SCR’s contribution to the national economy and its role within the Northern Powerhouse. It targets 70,000 net additional jobs within SCR and it identifies seven long term spatial areas of growth and change where a significant proportion of growth is expected to occur.

2.9 One of the seven SCR areas of growth and change is the Doncaster Sheffield Airport corridor which is:

“Recognised as a catalyst for business development, inward investment and job creation with regard to logistics, engineering and associated aviation activities.”

2.10 It is crucial the LP fully aligns with the objectives of the SEP.

2.11 To support the SCR SEP, an Integrated Infrastructure Plan (IIP) has been published. The IIP articulates and evidences required infrastructure, spatial requirements linked to supporting the economic priority areas identified in the SEP. In essence, it seeks to provide the infrastructure necessary to create the best opportunities for economic growth, jobs and homes, to create the best attractive environments for businesses and residents. To focus investment, the IIP identifies a number of strategic spatial priorities:

1. Growth of the advanced manufacturing innovation district;

2. Provide growth and enhance the role of DSA and the surrounding area;

3. Maximise the benefits of HS2 in the Sheffield City Region; and

4. Stimulate growth and regeneration in Town and City Centres.

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2.12 DSA is expressly identified as a growth area which is currently being developed as an engineering and aero-industry centre “alongside and including” housing growth. The IIP encourages Spatial Frameworks such as the Doncaster LP to be prepared to identify strategic areas of future housing delivery aligned with the ambitions of the Growth Areas and Urban Centres – this should include strategic opportunities for housing as an integrated element of Growth Areas.

Global Innovation Corridor

2.13 DSA is working with partners in the Sheffield City Region, including the Local Enterprise Partnership, universities and advanced manufacturers, to create the Global Innovation Corridor (GIC): a destination for research, development, manufacturing, maintenance, repair and overhaul.

2.14 GIC will traverse the heart of the City Region capitalising on assets of global significance – linked by the region’s multi-modal transport connectivity to drive growth through innovation-led research, advanced manufacturing and engineering.

2.15 An expanded DSA will provide the global connectivity required to benefit the businesses within the GIC and deliver further high-quality investment to the DSA site and wider GIC. Businesses such as Rolls Royce require specialist facilities and a live airport for on-site training.

2.16 Focused around our R&D assets and skilled specialisms, the GIC will be a global magnet for people, industry and innovators, that will to grow our advanced manufacturing, wellbeing and digital clusters underpinned by great transport infrastructure.

2.17 The GIC will connect assets such as the Advanced Manufacturing Innovation District, Advanced Manufacturing Research Centre, Advanced Wellbeing Research Centre, the Sheffield Olympic Legacy Park, National College for High Speed Rail, Barnsley’s Digital Media Centre and Doncaster Sheffield Airport.

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3. Doncaster Sheffield Airport

History of the Airport

3.1 The Airport site has been in use for aviation purposes since 1915 when it was founded as Finningley Airfield. It was utilised throughout both the First and Second World Wars as an airbase and training facility; and post-war as a base for numerous RAF Corps and training units.

3.2 RAF Finningley was decommissioned in 1996. It was then converted and re-opened in 2005 as Robin Hood Airport Doncaster Sheffield when it began to operate commercially.

3.3 The Airport is now named simply ‘Doncaster Sheffield Airport’ (DSA); it has become a major economic asset to Doncaster, the Sheffield City Region (SCR) and beyond. It is recognised by TfN as one of a network of Regional Airports which are crucial in providing the North of England with International Connectivity, which in turn is of fundamental importance to Northern Powerhouse objectives.

3.4 Located in South Yorkshire, Doncaster is an important transport hub in the UK, lying close to the boundary between Yorkshire and North Nottinghamshire and at the heart of the UK’s major motorway network. DSA is directly connected to the M18 by the Great Yorkshire Way (GYW) link road providing onward connections to the A1(M), M1, M62 and wider national motorway network. In addition to the existing housing, commercial, retail and community facilities in and around the airport, DSA has the requisite ingredients to create a highly sustainable and vibrant place centred around what is now and will continue to be, Doncaster’s and the Sheffield City Region’s largest single economic asset.

The Airport Today

3.5 DSA is one of the fastest growing airports in the UK and is a major employer currently supporting over 1,000 jobs. It has witnessed a 103% growth in passenger numbers in the years 2013 - 2019, with 2019 forecast to be the busiest on record with c1.4m passengers travelling to 50 destinations. In Summer 2019, DSA experienced a net gain of 12 destinations, more than any other UK airport. May 2019 saw the commencement of a new Transatlantic route to Sanford Florida, Yorkshire’s only long-haul service; in May 2020 this long-haul connectivity will be supplemented by an additional route to Cancun, Mexico.

3.6 The airport has also developed its air cargo capability and now has an outstanding reputation for offering flexible and efficient solutions to the cargo market. 2016/17 DSA saw 10,000 tonnes of cargo handled over the year, driven by an increase in regular ad-hoc cargo services. During 2017/18, DSA secured its first scheduled cargo flights bringing in perishables from Africa. 2018/19 was another record year with 16,500 tonnes of cargo handled.

3.7 This growth has been reflective of infrastructure investment that has been delivered in and around the airport. The recent completion of GYW phase 2 has delivered a

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transformative improvement in access between the airport and the wider city region, resulting in an increased catchment of 5.53 million people.

3.8 DSA is well placed to now continue its growth and capitalise upon its vast and unique potential. It has an enviable position with unconstrained aviation capacity (for both passenger and cargo), has a catchment area larger than many other UK airports and has extensive landholdings to facilitate airport growth accompanied by supporting infrastructure, complementary land uses and a truly sustainable community. It has one of the UK’s longest runways and could facilitate, if embraced and supported, an airport equivalent to London Stanstead or even London Gatwick in their current single runway forms.

3.9 In short, DSA is primed for growth at a level which is simply unrivalled by other airports.

2018 Draft Airport Masterplan

3.10 To harness and guide this growth, Peel has produced a new draft DSA Masterplan (DSAM). The DSAM comes at a time when the airport is experiencing significant growth resulting from new passenger services, increased cargo and general aviation activity. DSAM and the wider Aero Centre Yorkshire (ACY) site within which it sits already brings a gross added value of £62 million per annum to the regional economy and supports almost 1,000 jobs. This in itself is a significant economic contribution. However through delivery of the DSAM this contribution is anticipated to grow exponentially.

3.11 The DSAM represents a significant investment (between £0.9 and £1.66BN construction value) which will provide crucial infrastructure and drive significant job creation in Doncaster and the Sheffield City Region as the airport grows and the ACY estate develops out. The vision is to deliver transformation of the regional airport into a major intercontinental gateway, alongside a significant mixed-use growth area.

3.12 This new DSAM takes account of significant further land assembly which has taken place since the previous DSA Masterplan. It sets out a vision to create an aerotropolis and sustainable community, on an enlarged scale which seeks to capitalise on the unique potential of DSA and fully reflects the high levels of ambition of the City Region Economic Plan.

3.13 The masterplan proposes:

• A passenger operation of 4.6 million passengers by 2037 with potential for up to 7.2 million to be achieved in a high growth scenario;

• A cargo operation handling 70,000 tonnes of air cargo by 2037, with potential for up to 176,500 tonnes of air cargo in a high growth scenario;

• Major terminal enhancements including doubling the size of the terminal with expanded check-in, security, departure and immigration areas – new retail facilities to enhance the customer experience;

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• 1.5 million sq ft of airside development including expanded cargo operations, general business aviation facilities, multi-purpose hangarage and a dedicated Maintenance Repair Overhaul (MRO) campus, incorporating a satellite of the University of Sheffield Advanced Manufacturing Research Centre (AMRC);

• Over 3 million sq ft landside logistics and advanced manufacturing space;

• Up to 3,000 new homes;

• New retail outlets, hotels, leisure and community facilities to be provided within a central plaza which is to be the fulcrum of the community; and

• A safeguarded route through the ACY site for a rail connection linking the East Coast Mainline with the Lincoln to Doncaster line, with a rail station close to both the passenger terminal and proposed central plaza area.

3.14 This level of intervention and growth is considerably greater than has been envisaged in the previous Masterplan and is forecast to result in 10,100 direct jobs, on-site within the DSA masterplan area including the airport itself across the LP plan period and will result in the transformation of the economic landscape of Doncaster, the City Region and provide a major contribution to the Northern Powerhouse.

3.15 Whilst the DSAM is not predicated on the new rail connection and station referenced above, in the event this direct connection to the East Coast Mainline (ECML) and new station are delivered, this would place 9 million people in the area east of the Pennines and north and east of London within 90 minutes travel time of the DSA terminal. This enhanced accessibility would further accelerate and increase economic growth and development around the airport to levels even greater than those envisaged under the Masterplan high growth scenario.

Realising the DSAM ambition

1.1 DSA and ACY is Doncaster’s and the City Region’s single biggest economic asset. To unlock the potential, realise the DSAM and capture the economic benefits and growth that will arise, there is a need for longstanding commitment from Peel coupled with an overarching local planning policy framework to create the conditions to support the vision.

1.2 Peel has invested over c.£300m in developing DSA, delivering infrastructure and capital projects. It remains fundamentally committed to DSA and its transformation agenda. In simple terms, continual investment in capital projects, infrastructure and cash injections is necessary to maintain the operation and generate the anticipated growth in commerce, passenger and cargo which in turn will continue to foster further increases in economic growth and jobs both within ACY/DSA and across the Region.

1.3 Peel is planning to inject a further £50m into DSA itself over the next ten years to fund future capital projects / infrastructure and airline route development incentivisation, with an expectation of the airport becoming self-sustaining within the next five years or so. This includes investment in the following, some of which have been, or will be, the subject of planning applications:

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• Terminal improvements and extensions (planning application approved);

• New departure gate bridges (planning application approved);

• Expansion of the aircraft apron to provide additional aircraft stands;

• Additional car parks (partly delivered under Permitted Development rights with planning applications for the remainder as envisaged in the masterplan to be submitted in October 2019); and

• Airline financial investment (incentivisation and airline specific marketing activity).

3.16 This is in addition to substantial recent investments in:

• Runway resurfacing (£6m);

• Cargo transit shed expansion to ensure ability to maintain rapid growth in cargo throughput (£1.6m including £1.2m grant contribution);

• Complete upgrade of Hold Baggage Screening x-ray equipment in order to remain compliant with European Civil Aviation Conference (ECAC) standards (£2.2m);

• Car parking expansion – premium and meet and greet infrastructure (£0.9m); and

• Airline incentivisation (£+10m)

1.4 In terms of surrounding development proposals within the wider ACY site, Peel has recently secured renewal of permission for commercial development west of the passenger terminal and main passenger car parks and is in advanced discussions with various parties for transactions which will see continuation of recent commercial development activity in these areas.

1.5 To maintain momentum and provide the opportunity for further large scale commercial development within ACY, Peel has committed to the preparation and submission of planning applications, wider master-planning and capital delivery in respect of the following:

Logistics and Advanced Manufacturing

3.17 To capitalise on DSA’s connectivity and the growth of the logistics sector, Peel submitted, in late 2018, an outline planning application1 for the development of 325,000m2 of high quality, state of the art advanced manufacturing and logistics floorspace. The outline planning application was accompanied by a full Environmental Statement (ES).

1 LPA Reference: 18/02759/OUTA

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3.18 The significant financial commitment to the logistics and advanced manufacturing application was in part precisely to demonstrate to the Council and third parties that Peel is committed to seeing delivery of the employment elements of the DSAM as early as possible.

3.19 The application is currently awaiting determination.

Central Plaza

3.20 Peel is also currently finalising a hybrid planning application to realise the vision of the central plaza to deliver up to 43,000sqm (GIA) of high quality mixed use development comprising commercial, retail and leisure floorspace, hotels and community uses as well as a small amount of residential apartments. The combination of uses seeks to deliver a range of facilities and services to create a unique place in the heart of DSA to support and bring together all elements of the DSAM, by meeting the needs of a growing living and working population, together with those of the airport community.

3.21 The draft hybrid planning application, which comprises a full suite of surveys and assessments, would seek full planning permission for highway/drainage infrastructure and strategic landscaping with outline planning permission being sought for the development floorspace and controlled via a series of parameter plans relating to development cells and land use; site re-profiling; building heights; building frontages; access and movement; green infrastructure and ecology; and drainage infrastructure.

3.22 The draft hybrid planning application is to be submitted in Autumn 2019. A copy of the illustrative masterplan is contained within Appendix 1.

Concept Masterplanning

3.23 To support the DSAM, Peel has development a ‘Concept Masterplan’ (CM) which articulates the strategic place-making principles covering areas identified in the DSAM including airport operations, employment development, the new central plaza, green infrastructure, ecology areas, open spaces and new housing areas. In addition to the respective planning applications, the CM demonstrates how the various land uses will be conceptually and physically integrated and connected and create high quality mixed use place.

3.24 The current version of the CM is included with this submission (Appendix 2 as a separate document) and it is the intention that it is to be updated and resubmitted to the Council once further detailed work on the housing element has been undertaken (see below).

Housing Masterplan

3.25 Landscape Master planners and Designers Randall Thorp have been commissioned by Peel to undertake a more detailed masterplan of the main housing element of the DSAM (comprising LP draft allocations 940 E2 and E3).

3.26 Housing is often an early catalyst to sustainable mixed use development propositions of the type encouraged by NPPF, helping to build confidence and momentum in wider

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propositions. It is therefore integral to the overall concept and attraction of the mixed use DSAM proposition. The ability to ensure early delivery of a very small proportion of the overall planned LP housing allocation will be important to unlocking the potential of DSA and ACY. The potential major employers and occupiers which are to be attracted to the ACY site, will no doubt be keen to ensure that there is a sufficient and immediate labour supply around DSA to meet some of its workforce requirements, together with quality housing provision nearby to provide potential employees with the opportunity to live close by. This will as assist in creating a community and critical mass of a working and living population which will ensure commercial viability and attractiveness of other elements of the DSAM including the proposed central plaza.

3.27 This additional housing will undoubtedly be seen as an attractive proposition for potential companies who will be considering whether to locate to DSA against a number of competitive alternative locations. Providing employment opportunities and services alongside new housing is exactly the approach which the new NPPF is directing Local Authorities to take when setting policies for major employment and housing allocations and employment.

3.28 It is also important to note that the DSAM confirms that the airport masterplan area has capacity to deliver a significant amount of housing which is over and above that which is currently envisaged in the LP. As explained further below, Peel considers that the LP should be more flexible in respect of housing delivery, in the event of DSA delivering more jobs than anticipated and/or in the event that the Borough should require further housing delivery in the absence of a five year housing land supply.

Summary

3.29 The realisation of the DSAM is not waiting upon the adoption of the LP to proceed. Since the draft DSAM was published, Peel has been advancing the delivery of substantial elements of the vision and growth of DSA itself has gone from strength to strength, with record years for passengers and cargo, addition of more new passenger routes than any other UK airport, including Yorkshire’s only long-haul route with a second already committed, together with commencement of the airport’s first scheduled freight services.

3.30 These elements are important as they demonstrate a clear financial commitment from Peel to realise the DSAM vision; to deliver economic growth; and the creation of a highly sustainable and vibrant place at DSA. Collectively, these elements also demonstrate that the DSAM is suitable and deliverable.

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4. LP Vision and Objectives

4.1 Peel supports the overall strategic Vision and Objectives of the LP and their emphasis on supporting a strong and productive economy within Doncaster and the wider region. These also refer to the need to focus on enhancing its distinctive strengths and assets to better connect Doncaster to other economies, alongside creating significant new job opportunities for local residents within a key economic hub.

4.2 Peel specifically welcomes the reference to Doncaster becoming a ‘leading centre in logistics and aviation’ and the willingness to harness the potential of the ‘growth corridor’ between the airport and Doncaster town centre. However the vision should also be specific that by 2030, the region’s international gateway airport (DSA), will have grown significantly in terms of passenger and cargo throughput and the range, extent and choice of flight destinations; the aim is for it to have developed into a genuine intercontinental gateway, with further scheduled intercontinental services beyond the already launched Trans-Atlantic destinations. Alongside an enlarged DSA will be a significant mixed-use growth area. Collectively, the Airport and the adjoining growth area are branded and identified as AeroCentre Yorkshire (ACY). In this context it is important to specifically identify that DSA/ACY is included within the growth corridor. The accompanying objectives and should be reworded to ensure consistency and clarity.

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5. Strategic Policy 2 & 3: Spatial Strategy & Settlement Hierarchy and Spatial Distribution

5.1 Peel support the emphasis within the policy to promote sustainable growth and ensuring that development helps to create strong, sustainable, cohesive and inclusive communities.

5.2 Peel also welcomes the statement that major new employment sites will be focused at Doncaster Sheffield Airport (DSA). However, this reference to DSA should also be broadened to reflect that draft Policy 7 (DSA) seeks to deliver a significant mixed use growth area at the airport (which encompasses airside and landside employment, housing, aviation, hotel, retail and other commercial uses and community uses, all within the wider ACY area) commensurate with the ambition and vision of the DSAM. For instance, the draft policy is silent in respect of the fact that DSA has significant residential development potential and seeks to deliver, in effect, a new Central Plaza facility for DSA and the surrounding community.

5.3 For clarity, consistency and completeness, draft Policy 2 (including Table 2 – network and hierarchy of town centres) and draft Policy 3 (including the growth distribution table presented in the policy) need to refer to the full proposition at DSA to reflect and be consistent with draft Policy 7 in that the mixed use growth area proposed and supported at DSA/ACY sits outside the settlement hierarchy and housing delivery but it is, nevertheless, an integral element of the Plan – in terms of development needs, economic growth and spatial distribution of growth. It should be clear that the new Central Plaza is an allocation which means that applications which accord with the allocation will not be subject to the NPPF sequential and impact tests.

5.4 In respect of housing delivery, draft Policy 2 sets out the position in the event that the Council fails to demonstrate a five year Borough housing supply. It sets out the circumstances in which proposals to develop land for housing in the Countryside around its Level 1-3 settlements2 will be considered.

5.5 While the policy seeks to ensure that sustainable housing development is delivered in appropriate locations in the event a 5 year supply is not maintained, the effect of the policy could result in a stream of unplanned, sporadically located and speculative planning applications across the majority of its settlements in less sustainable locations.

5.6 Peel considers that the policy should be modified to ensure that in the event that further housing delivery is required in the absence of a five year housing land supply, such delivery should be guided to DSA in the first instance and ahead of any sporadic incursion into the open countryside.

5.7 As the DSAM articulates, DSA is a significant, well planned, mixed-use sustainable growth opportunity and has the potential to deliver up to 3,000 dwellings across sites

2 Doncaster Main Urban Area, Main Towns, and Service Towns and Villages

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940 E2 and E3 and therefore has sufficient capacity to deliver further homes over and above the 1,200 units already identified in the LP as currently drafted.

5.8 There is also an additional site on the east side of Gate House Lane which was previously identified at Regulation 18 LP stage as a potential housing site (Site Ref 1010) which had yet to be assessed. On this Regulation 19 LP version, without explanation, this site has been retained as an isolated area of open countryside. This matter is discussed further in Chapter 8.

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6. Strategic Policy 3: Housing Provision

6.1 Peel has commissioned Turley Economics to undertake a technical review of proposed housing provision contained within the LP.

6.2 The technical report can be found in Appendix 3.

6.3 In summary, the report identifies that whilst Peel strongly supports the draft LP’s intention to deliver housing need over and above the standard method in recognition of the economic potential of the borough, it is considered that the draft policies relating to the planned provision for housing require amendment to be found sound when judged against the Framework and the associated Planning Practice Guidance. This deficiency in soundness is identified in a number of specific areas including the following:

• While the LP seeks to deliver housing need3 above the standard method4, draft policy 3 expresses the housing requirement as a range using both figures; this is not considered to be justified in the context of the Framework.

• The minimum housing requirement figure as generated by the standard method is no way representative of housing needs in the borough with evidence demonstrating that the population of Doncaster is already larger and growing to a much greater extent than it predicted. Moreover, recent and longer-term housing delivery in the borough has been around double the minimum figure generated through the standard method which must be taken into account in future plan making.

• While the Council accepts it is more appropriate to plan for a greater level of housing need, this is at risk of being undermined by retention of the standard method at the lower end of an unjustified range. Retention of it in the policy and the practical application of such a policy could markedly and unjustifiably reduce and constrain housing delivery. Such an approach is not positively prepared or consistent with national policy.

• There is evidence of still greater need for housing than that which is acknowledged by the Council at the upper end of range proposed by the draft LP. The Council’s own published evidence base confirms that an average of 1,060 dwellings per annum is likely to be needed through most of the plan period to accommodate a labour force required to support targeted housing growth of 1.0% per annum but potentially still underestimating the scale of employment growth attainable in Doncaster. Peel considers that this level if need should be explicitly recognised in the explanatory text of the policy. This emphasises the importance of policy 3 identifying a single housing requirement aligned with supporting economic growth as a minimum housing requirement for the borough and the LP should be revised accordingly.

3 920 dwellings per annum 4 550 dwellings per annum

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7. Strategic Policy 7: Doncaster Sheffield Airport

7.1 Peel strongly supports the allocation of land at DSA for the development of a new mixed use community which includes the expansion of DSA, new homes, new employment, open space and ecological networks and new central plaza.

7.2 Notwithstanding this support, Peel proposes alterations to the wording of the policy to ensure it aligns with the ambitions and objectives of the draft DSA Masterplan and the tests of soundness in accordance with the Framework.

7.3 The proposed alterations are shown in the track changes in Appendix 4; this includes amendments to the draft policy, some of its associated explanation and Appendix 3 of the LP. Where necessary further justification for the proposed alterations is provided, as follows:

• The terminology applied in some parts of the policy is inconsistent with that used in the draft DSAM and/or inconsistent with the rest of the LP; changes are proposed for consistency.

• Amendments to the method of calculating housing release (within Site Allocation 940 E3) relative to the creation of jobs within or attributable to the DSAM (either delivered and/or contracted to be delivered). This is required to ensure the policy is workable and effective in practice.

• Policy amendments to the ‘central plaza’ element to reflect the emerging proposals and the in principle acceptance for the centre to include a small element of residential apartments at upper floors to support the creation of a vibrant central place.

• The draft policy stipulates a maximum level of residential development (920 dwellings) to be delivered at Site Allocation 940 E3. To ensure consistency with other policies in the LP, we propose this be amended to a ’minimum’ figure.

If the agreed policy proposition is that housing is released to support jobs growth, there is no sound reason why there should be a cap on housing numbers should jobs growth exceed what is forecast. The policy should be amended to confirm that the housing number stipulated for the allocation is a ‘minimum’ so as to allow for more housing delivery in the event more jobs are secured than are forecast in the DSAM. It is Peel’s contention that this shouldn’t harm housing delivery elsewhere as the DSA policy is a self-fulfilling one – namely delivering the housing necessary to support the sustainable economic growth of the airport and delivery of its vision. As explained in Section 3 of these representations, sites 940 E2 and E3 have the physical capacity to deliver up to 3,000 homes.

• Deletion of the requirement to provide a Strategic Delivery Plan as the policy is unclear as to the purpose of such a document.

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• Amendments to other elements to the policy covering master-planning, Design Code and Green Infrastructure Requirements.

• Factual changes to the policy explanation.

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8. Other Policies

8.1 Peel has a number of comments on the LP’s other strategic and non-strategic policies as currently drafted. These are summarised below:

Strategic Policy 13 (Strategic Transport Network)

8.2 Peel welcome the draft policy’s commitment that proposals will be supported which improve rail transport, including a new electrified mainline rail connection and railway station at DSA/ACY, which will connect to both the East Coast Mainline and the Doncaster to Lincoln line.

8.3 The policy needs to be accompanied by explanatory text which sets out that should these rail proposals come forward within the Plan Period, there will be a need to review the relevant policies of the LP as the rail connectivity will significantly increase and change the nature of development opportunities and needs (particularly at DSA/ACY) which is currently unaccounted for in the Local Plan.

8.4 The draft policy also refers to improved access to DSA from the M18. The policy is unclear as to what are the specific proposals to improve access to DSA from the M18 given the previous completion of Great Yorkshire Way. Peel seeks further clarification on this matter.

Policy 26 (Development in the Countryside)

8.5 The draft Policy text (and Polices Map) needs to make clear that the allocated DSA sites have been removed from the Countryside. Peel request that all of the Airport Masterplan’s demise is removed from the countryside. This includes non-development areas such as the proposed rail corridor5, Hurst Wood and Marr Flatts Plantation which are physically divorced from the wider open countryside.

8.6 As described in more detail in Section 9 of these representations, Peel request that land at Gatehouse Lane is removed from the countryside.

Strategic Policy: Ecological Networks

8.7 A policy amendment is suggested below to ensure consistency with the NPPF:

“Proposals will only be supported which should deliver a net gain for biodiversity wherever possible and protect, create, maintain and enhance the borough’s ecological networks by:

A) being of an appropriate size, scale, and type in relation to their location within and impact on the ecological network;

B) maintaining, strengthening and bridging gaps in existing habitat networks;

5 To facilitate a potential rail station and associated connection of the East Coast Mainline (ECML) and Doncaster - Lincoln Line

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C) planting native species and creating new, or restoring existing, national and local priority habitats and/or species; and

D) working with strategic partnerships to deliver conservation projects at a landscape scale where appropriate.”

Strategic Policy 31 (Valuing Biodiversity and Geodiversity)

8.8 The draft policy states that proposals which may harm designated or non-designated sites or features of biodiversity interest will only be supported if (amongst other things) the proposals will deliver a 10% net gain for biodiversity.

8.9 The current NPPF requires local planning authorities to ‘pursue opportunities’ for securing measurable net gains for biodiversity. While the Spring Statement announced that the Government will be mandating net gains in the Environment Bill, detailed legislation will be required deliver 10% net gains in biodiversity. This legislation has still be developed and enacted – through the Environment Bill – and the Government has set a transition period of two years relating to biodiversity net gain requirements. This uncertainty needs to be recognised in policy and its explanation.

8.10 To be consistent with the NPPF, a policy amendment is required to provide flexibility in circumstances where a minimum 10% net gain in biodiversity cannot be achieved, or where addressing other ecological considerations (such as enhancing ecological connectivity by extending/improving movement corridors) means it is preferable not to achieve such a net gain.

Policy 62 (Providing for and Safeguarding Mineral Resources)

8.11 The draft policy and policies map appears to identify specific areas of the Borough which are existing and proposed mineral works; ‘Areas of Search’ and areas which are safeguarded. It is not clear if the policy is the definitive position of mineral workings or safeguarding across the borough as it would appear, on this basis, that the Mineral Safeguarding Area which previously existed to the west of the airport has been removed.

8.12 For completeness, Peel request clear and categoric confirmation within the LP that any Mineral Safeguarding Area which has previously been identified within the Airport Masterplan’s demise is indeed removed, as appears to be the case; the plan and polices map should make this clear. The Airport and its masterplan area is the borough’s biggest economic asset and will deliver most economic potential and growth across the borough and SCR. It should not be unnecessarily constrained in its delivery.

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9. Omission Sites

9.1 Draft LP policy 7 (DSA) does not allocate two areas of land which are part of the Airport Masterplan proposals. These parcels of land comprise the following:

• Land to the north of the Doncaster to Lincoln railway line (Site No.946)

This site is proposed under the Masterplan to deliver a community rail station, parking and residential development. Peel requests this land be removed from the open countryside and allocated for residential/mixed use development. Development Limits should be amended to accommodate this allocation. More detailed representations are being submitted by the current landowner, with whom Peel have held discussions. Allocation of Site No.946 would assist with delivery of the community rail station in the event this rail option is required (this would be the case only if the preferred rail option to connect DSA to both the ECML and Doncaster to Lincoln line did not come to fruition).

• Land at Gatehouse Lane (Site No. 1010)

This site is envisaged in the Airport Masterplan (and within the Regulation 18 consultation version) for residential development (see attached plan contained in Appendix 5). Peel requests that this land is removed from the countryside and allocated for residential development. Development Limits should be amended to accommodate this allocation.

The Site lies immediately adjacent to the east of Hayfield Green which forms part of the wider Auckley-Hayfield Green settlement and an outline planning application for the development of up to 150 dwellings is currently being prepared by Peel and is due to be submitted to the Council shortly. The site has been previously worked as a sand and gravel quarry and derelict buildings remain in a proportion of the site. It is located on the edges of Hayfield Green, with strong defensible boundaries defined by physical development to the north, east and south and presents a perfectly logical continuation of the Hayfield Green settlement. Conversely, it no longer presents a logical area of open countryside having been separated from countryside in all directions. The development will facilitate the delivery of a well-planned sustainable residential development which will provide a range of dwelling types and tenure in line with market demand, including affordable homes, within Hayfield Green. Furthermore, it offers an opportunity to provide additional public open space that is accessible to both existing and future residents and will also strengthen the character and definition of the settlement boundary in this part of Hayfield Green.

9.2 These requests are considered appropriate as we consider that a more positive approach should be taken to ensure that the LP provides for the full level of housing need that the housing assessment identifies could reasonably be associated with supporting the economic growth objectives of the Council. This would require the Plan to provide for closer to 1,060 homes per annum, or close to 15,900 homes over the plan period. Notwithstanding this, and independent of future housing at DSA as

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controlled by draft Policy 7, Peel contend that there is currently a shortfall of 300 committed homes within the immediate vicinity of DSA as a result of the reduced number of 450 homes now built out at Hurst Lane under application reference 09/02048/OUTM. The LP Housing needs assessment assumes full delivery of the 750 units consented on this site; if the committed shortfall not provided elsewhere in the vicinity, then there will be an under-delivery against the numbers assumed in the LP evidence base.

9.3 The recent resolution to grant outline planning permission (subject to S106 agreement) at the March 2019 DMBC Planning Committee of up to 140 new homes on land off Hayfield Lane (application reference 18/01748/OUTM), has meant that this shortfall has now effectively been reduced to 160 new homes. The principle of applying this shortfall on separate residential sites was fully accepted by the Council when the Hayfield Lane application was reported to and considered by the March 2019 Planning Committee. The Committee report stated:

‘…Policy CS6 of the Core Strategy recognises that the 750 dwellings approved off Hurst Lane will provide an additional source of housing to the allocations set out in Policy CS2, and any further housing growth at Hayfield Green would not be in accordance with the Core Strategy…In practice however, the reserved matters permissions for the residential development have resulted in a shortfall of 300 dwellings at the Hurst Lane site, with the density of development being much lower than anticipated. As such, the principle of 750 homes to serve the airport and its business park is applicable, and given that the 750 homes are accounted for as additional to Doncaster's housing growth allocations under Core Strategy policies CS2 and CS6, this planning application will go some way to making up this shortfall whilst not breaching the Councils wider housing delivery numbers. On this basis, given that development has already been previously been approved on the application site, and that there is headroom in the expected 750 dwellings to be delivered in this settlement as set out in the Core Strategy, it is considered that the principle of residential development is acceptable in this location.’

9.4 Therefore, although now reduced to reflect the resolution to grant outline permission 18/01748/OUTM, a committed shortfall of 160 new homes serving the DSA area still remains to be delivered at Hayfield Green in line with Policy CS6 of the adopted development plan. The allocation of Gatehouse Lane as a residential site would ensure that this shortfall is positively planned and accounted for in the draft LP. This would also ensure the risk of other third party developers speculatively to ‘claim’ this shortfall and submitting speculative planning applications on sites where are less sustainable and suitable than Gatehouse Lane.

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10. Summary

10.1 Peel welcomes the opportunity to comment on the draft policies of the Doncaster Local Plan which includes consideration for the proposed expansion of DSA and its surroundings.

10.2 Peel generally supports the Doncaster LP and in particular draft spatial policy 7 which supports the growth and expansion of DSA. However some modifications are considered necessary to be made to this policy, and a number of other policies, to make the Local Plan sound.

10.3 Peel would welcome the opportunity to discuss these representations with the Council with a view to agreeing suitable revisions.

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Appendix 1: Illustrative Masterplan – The DSA Plaza

N

General Notes

A r c h i t e c t s M a s t e r P l a n n e r s D e s i g n e r s

Hill Quays, 5 Jordan Street, Manchester, M15 4PY

f

t

e

All site dimensions shall be verified by the Contractor on siteprior to commencing any works.

Do not scale from this drawing.

Only work to written dimensions.

This drawing is the property of Fletcher-Rae (UK) Limited (t/aFletcher-Rae) and copyright is reserved by them. The drawing isnot to be copied or disclosed by or to any unauthorised personswithout the prior written consent of Fletcher-Rae (UK) Limited.

Status

Date

Drawn by

Project

Scale

Client

Drawing Description

Drawing No. Rev.

Revision

wwww.fletcher-rae.com

1:1250@A1

CF

29.03.18

Planning

13041_PL007 A

Peel Investments (North) Ltd

Indicative Masterplan

Doncaster Sheffield Airport

NB:All landscaping is indicative onlyPlease refer to landscaping strategy

Typical Upper Floors 1:1000

Apartment No.s:

E (3 Floors)1 Bed = 62 Bed = 21Total = 27 Apartments

F (3/4 Floors)1 Bed = 292 Bed = 303 Bed = 8Total = 67 Apartments

G (5 Floors)1 Bed = 152 Bed = 353 Bed = 10Total = 60 Apartments

Total = 154 Apartments

1 Bed2 Bed3 BedCore

Line of floor above

Existing Trees

A Final Issue 24.04.19 CF

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Appendix 2: Concept Master-planning Document (Separate Document)

Appendix 3: Technical Review of Housing Evidence

Appendix 3: Technical Review of the Evidence of Housing Need Informing Policy 3 and Policy 7 On behalf of The Peel Group

September 2019

Contents

1. Introduction 1

2. The Publication Version Local Plan 4

3. Requirements of National Policy 9

4. Doncaster’s Housing Needs 13

5. Housing Needs of DSA (Policy 7) 24

6. Summary and Conclusions 29

September 2019

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1. Introduction

1.1 This report has been prepared by Turley on behalf of the Peel Group and Doncaster Sheffield Airport Limited (hereafter ‘Peel/DSA’) to technically review emerging policies relating to housing provision in Doncaster, as set out in the Publication Version of the Local Plan1 (‘the draft Plan’). Reflecting Peel/DSA’s land interests in Doncaster, specific focus is placed in this review on Policy 3 (level and distribution of growth) and Policy 7 (Doncaster Sheffield Airport and Business Park).

1.2 The report has been produced in the context of an ongoing consultation by Doncaster Council (‘the Council’), which runs until 30 September 2019. It supports the overarching representations made by Peel on the draft Plan.

1.3 Peel has worked with the Council to support the preparation of the draft Plan with specific reference to Policy 7. This has included the sharing of underpinning evidence which has informed the Doncaster Sheffield Airport (DSA) Masterplan (DSAM). Peel welcomes the opportunity to continue to support the Council in the submission of a sound plan.

1.4 This report identifies a number of specific areas where it is considered that policies relating to the planned provision for housing need require amendment to be found sound when judged against the National Planning Policy Framework2 (NPPF) and the associated Planning Practice Guidance3 (PPG).

1.5 Peel strongly supports the draft Plan’s recognition in Policy 3 that housing need in Doncaster over the plan period will exceed that calculated under the standard method. This recognises the economic potential of the borough, reflecting both recent evidence of strong growth and the borough’s growth strategy and investment plans and its wider role in supporting the delivery of the Sheffield City Region (SCR) Strategic Economic Plan (SEP).

1.6 Policy 3, however, has been amended in the draft Plan to express the housing requirement as a range, with the standard method at its lower end and the Council’s calculation of the housing needed to support economic growth forming the upper end (920 homes per annum). This is not considered to be justified in the context of the NPPF and the PPG. This position is explained with reference to the Council’s own published evidence in later sections of this report. Reference to the same evidence also confirms that even the proposed upper housing requirement is unlikely to respond to the full evidenced need for housing over the plan period. The Council should give full consideration to its evidence of housing need in this regard and re-word Policy 3 to ensure it recognises the housing requirement as a ‘minimum’ level of housing to be supported and provided for over the plan period.

1.7 Whilst Peel welcomes the Council’s support for the delivery of the DSA Masterplan through Policy 7, a review of the evidence relating to the planned provision of jobs and

1 Doncaster Council (June 2019) Doncaster Local Plan 2015-2035 Publication Version 2 MHCLG (2019) National Planning Policy Framework 3 MHCLG (2019) Housing and economic needs assessment; PPG section 2a

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housing at the airport leads to the view that the policy or justification text should be more explicit in recognising that:

• The potential exists within the DSAM for a higher level of housing to be delivered at the airport, (up to 3,000 homes within sites 940 E2 and E3), where there is an acknowledged need for housing to be delivered across Doncaster in the plan period and in parallel with stronger than anticipated job growth at the airport. References to the potential level of housing delivery on sites within the DSAM should therefore be referenced as a minimum;

• The draft Plan is predicated on the basis that the provision of housing at the airport forms an integral part of the DSAM in attracting investment and supporting the vitality of other proposed uses, with specific reference to The Central Plaza area; and

• The potential for higher jobs growth associated with the DSAM is acknowledged in the Council’s evidence on housing need, recognising the masterplan’s two scenarios for growth. There should also be recognition that the potential exists for higher than current forecast job growth in the DSAM where new rail connections to the East Coast Mainline (ECML) are delivered within the Plan period.

1.8 In this context, Peel is of the view that the policy should be amended to enable a greater degree of flexibility. The overarching representations provide further clarification as to the changes sought on this basis.

Report Structure

1.9 This report is structured as follows:

• Section 2 – The Publication Version Local Plan – the Council’s proposed approach to providing for new housing in Policy 3 and the relationship with this in Policy 7, as well as the supporting justification, are summarised;

• Section 3 – Requirements of National Policy – an overview of the requirements of the NPPF and PPG when calculating local housing needs and establishing appropriate housing requirements, to inform a critique of the Council’s approach;

• Section 4 – Doncaster’s Housing Needs – the Council’s advancement of its housing requirement as a closed range within Policy 3, with the standard method forming the lower end, is challenged through a presentation of an evidenced local need for housing which exceeds both this minimum figure and the proposed upper end of the housing requirement range;

• Section 5 – Housing Needs of DSA (Policy 7) – consideration of the evidence of housing need specifically in the context of anticipated job growth in the DSAM; and

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• Section 6 – Summary and Conclusions – the analysis is drawn together and the implications for the soundness of Policy 3 and Policy 7 of the draft Plan are established.

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2. The Publication Version Local Plan

2.1 This section separately summarises Policies 3 and 7 of the draft Plan, including the justification advanced by the Council in the context of the planned provision of housing.

Policy 3 – Level and Distribution of Growth

2.2 Policy 3 of the draft Plan establishes the proposed level of housing provision for which land should be identified in Doncaster.

2.3 Rather than simply establishing a minimum requirement against which the supply of land will be judged as being sufficient to meet needs, the policy as drafted is particularly fragmented in its presentation.

2.4 It first identifies a need for 18,400 homes over the plan period from 2015 to 2035, equivalent to 920 dwellings per annum. The justifying text is clear to confirm that ‘Doncaster’s housing need is evidenced in’4:

• The Economic Forecasts and Housing Needs Assessment5 (EFHNA) produced in May 2018; and

• The Doncaster Housing Need Assessment6 produced in 2015 but partially updated in 2016.

2.5 The draft Plan indicates that these evidence-based assessments – particularly the former – have been drawn upon by the Council to uplift the minimum need implied by the standard method ‘to meet planned economic growth over the plan period’7. It states that:

“This gives a total objectively assessed housing need (OAHN) of 912 new homes (net) per year to the Borough once economic growth is taken into account”8

2.6 There is no explanation given within the draft Plan to the apparent rounding of this need to the stipulated figure of 920 homes per annum.

2.7 This annual need – which, unrounded, had been averaged over a ten year period from 2016 to 2026 within the EFHNA9 – is extrapolated by the Council over the entire plan period (2015-35) before completions in the first three years are deducted (2015-18). Table 5 of the draft Plan explains that this produces a residual requirement for 15,000 homes over 17 years, equivalent to circa 882 dwellings per annum, albeit Policy 3 only

4 Doncaster Council (June 2019) Doncaster Local Plan 2015-2035 Publication Version, paragraph 4.37 5 PBA (2018) Economic Forecasts and Housing Needs Assessment 6 Doncaster Council (August 2015) Housing Need Assessment 2015; Doncaster Council (March 2016) Housing Need Assessment 2015 Update March 2016 7 Doncaster Council (June 2019) Doncaster Local Plan 2015-2035 Publication Version, paragraph 4.38 8 Ibid 9 PBA (2018) Economic Forecasts and Housing Needs Assessment, paragraph 5.27

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seeks to provide ‘sufficient land…to deliver 15 years’ of supply of housing’10. It thus envisages a need to allocate land capable of accommodating 13,230 homes at an average rate of 882 dwellings per annum.

2.8 On an average annual basis, this residual need is evidently lower than that calculated as being needed over the full plan period. This is a result of the higher rate of delivery achieved during the first three years of the plan period. It is also lower in overall terms than would be needed over the 17 years remaining when completions are taken into account, due to the Council’s proposal to curtail its plan period and allocate land capable of meeting only 15 years’ needs. There is no clear justification for such an approach, which in looking only to 2033 would notably fail to ‘look ahead over a minimum 15 year period from adoption’ as required by the NPPF11 (emphasis added).

2.9 Separately, the policy confusingly introduces a second calculation of need, against which it proposes that the five year housing land supply (5YHLS) is judged. It does not assign an annual need figure or requirement to this, but stipulates that the latest calculation following the standard method should be used. At the current point in time, the calculation would imply a need for only 550 homes per annum in Doncaster. This is substantially lower than the full need for some 920 homes per annum recognised elsewhere in the policy.

2.10 The draft Plan makes no clear attempt to rationalise this approach, conflicting with the basic requirement for plans to be ‘justified’ if they are to be found sound12. The PPG implies that plan-makers must “argue” for a requirement set out as a range through examination13, indicating that there will be proper scrutiny of any such proposals. There is currently considered to be insufficient justification for why this approach is necessary or appropriate in Doncaster.

2.11 It is noted that the EFHNA described the option of presenting housing need as a range in this way, but this was crucially based on the speculative assumption that ‘the new NPPF and PPG remain as drafted’14 given that the report was completed before the revised NPPF and PPG were formally published in July 2018. Critically, there were important changes from the drafts, with the suggested recognition of circumstances in which ‘the local housing need figure can be reflected as a range, with the lower end of the range being as a minimum the figure calculated using the standard method’ ultimately omitted in its entirety from the revised PPG15.

2.12 In their final form, neither the NPPF nor the PPG explicitly endorse the presentation of a housing requirement as a range, but instead make clear that the housing requirement should prevail over the outcome of the standard method for the purposes of assessing 5YHLS. The PPG confirms that:

10 Ibid, p27 11 MHCLG (2019) National Planning Policy Framework, paragraph 22 12 Ibid, paragraph 35 13 PPG Reference ID 68-027-20190722 14 PBA (2018) Economic Forecasts and Housing Needs Assessment, paragraph 5.28 15 MHCLG (2018) Draft Planning Practice Guidance, p26

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“Authorities should use the standard method as the starting point when preparing the housing requirement in their plan, unless exceptional circumstances justify an alternative approach”16

2.13 It proceeds to state that:

“A 5 year land supply is a supply of specific deliverable sites sufficient to provide 5 years’ worth of housing (and appropriate buffer) against a housing requirement set out in adopted strategic policies, or against a local housing need figure, using the standard method, as appropriate in accordance with paragraph 73 of the National Planning Policy Framework”17 (emphasis added)

2.14 Importantly paragraph 73 of the NPPF confirms that a plan-making authority should assess their 5YHLS ‘against their housing requirement set out in adopted strategic policies, or against their local housing need where the strategic policies are more than five years old’18 (emphasis added).

2.15 In recognising both a need and housing requirement within the draft Plan which is higher than the standard method, it is thus considered incorrect for the Council to then propose to calculate its 5YHLS against a different figure, even where that figure is the local housing need calculated using the standard method.

2.16 This directly challenges the validity of the final sentence in Policy 3, which claims that:

“…the housing requirement is expressed as a range with the bottom of the range being the Local Housing Need figure and the top of the range being 920 dwellings per annum”

2.17 It is noted that the drafting of Policy 3 in the Publication Version of the draft Plan has changed substantially from the previous iteration consulted upon in 2018, which was considered to demonstrate greater compliance with the NPPF by seeking to provide for ‘at least 920 (net) new homes each year over the plan period’19. Whilst its calibration over a 15 year period produced a broadly comparable level of provision to that now proposed over 15 years by the Council (13,800/13,230 respectively), there was a much clearer and welcome acknowledgement of the need to remove the prospect of housing acting as a barrier to growth by describing this as the minimum level of provision required in Doncaster (‘at least’). The Publication Version now advances such a requirement as the upper end of a closed range.

2.18 The subsequent section of the report further considers the requirements of national policy in the setting of a housing requirement, where this is recognised to be a single figure, and specifically acknowledges the legitimacy of the Council identifying circumstances which require the borough to plan for a level of housing need in excess of the standard method.

16 PPG Reference ID 68-001-20190722 17 PPG Reference ID: 68-002-20190722 18 MHCLG (2019) National Planning Policy Framework, paragraph 73 19 Doncaster Council (2018) Doncaster Local Plan Informal Consultation: Draft Policies & Proposed Sites, p13

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Policy 7 – Doncaster Sheffield Airport and Business Park

2.19 The draft Plan states that one of its key proposals is ‘supporting the sustainable growth of Doncaster Sheffield Airport’20.

2.20 Policy 7 reaffirms that growth and investment at the airport will be supported to enable its development and expansion in line with a number of guiding principles. In justifying these principles, the explanatory text to the policy confirms that in supporting the growth of the airport:

“…it must also ensure this is done in a considered and balanced manner, in order that any growth is delivered in a sustainable way, and with potential negative impacts suitably mitigated”21

2.21 Direct reference is made to the development of a comprehensive airport wide masterplan, to be prepared in collaboration with the Council. Peel has produced a new DSA Masterplan (DSAM).

2.22 The DSAM comes at a time when the airport is experiencing significant growth resulting from new passenger services, increased cargo and general aviation activity. DSAM and the wider Aero Centre Yorkshire (ACY) site within which it sits already brings a gross added value of £62 million per annum to the regional economy and supports almost 1,000 jobs. This in itself is a significant economic contribution. However through delivery of the DSAM this contribution is anticipated to grow exponentially.

2.23 From the perspective of job generation alone the DSAM forecasts that it will result in 10,100 direct jobs on site within the DSA masterplan area including the airport itself across the LP plan period and will result in the transformation of the economic landscape of Doncaster, the City Region and provide a major contribution to the Northern Powerhouse. The DSAM also identifies the potential to deliver up to 3,000 new homes within sites 940 E2 and E3, alongside specific employment generating uses.

2.24 Whilst the DSM is not predicated on the new rail connection and station, in the event this direct connection to the East Coast Mainline (ECML) and new station are delivered, this would place 9 million people in the area east of the Pennines and north and east of London within 90 minutes travel time of the DSA terminal. This enhanced accessibility would further accelerate and increase economic growth and development around the airport to levels even greater than those envisaged under the Masterplan high growth scenario.

2.25 In the context of housing provision, one of the guidelines states that ‘an area of 105.5 hectares…is identified as a potential housing-led mixed urban extension’. It provides further text to define the housing element which consists of two areas:

• 11 hectares of land east of Hurst Lane…is allocated for housing to accommodate up to 280 dwellings to support initial phases of airport expansion and employment growth; and

20 Doncaster Council (June 2019) Doncaster Local Plan 2015-2035 Publication Version, Document Summary 21 Ibid, paragraph 5.15

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• An additional area of approximately 70 hectares…is proposed as an Airport Reserve Housing Site and could accommodate up to 920 houses. The release of housing on this site will be phased and strictly tied to the robustly evidenced delivery of jobs in line with the airport growth plan and as set out in Part F.

2.26 Part F confirms that ‘any release of housing in excess of the 280 dwellings allocated to support the initial phases of airport expansion and employment growth will only be permitted in line with’ specified principles and mechanisms, which seek to provide a very prescriptive relationship between the provision of job growth at the airport and housing need. This includes the application of a ratio of 0.11 houses for every job created, up to a maximum of 1,200 houses. It confirms that:

“This will be net additional jobs in addition to the number of jobs identified by the Council as existing at the airport as at 2020, plus an annualised share in lieu of the initial tranch of 280 houses”

2.27 Further stipulations are identified in the policy, which require demonstration of job growth prior to the seeking of permission to deliver beyond the threshold of 280 homes. This is reaffirmed in the requirement that the applicant must demonstrate ‘clear evidence that the additional jobs have already been delivered’.

2.28 With reference to the masterplan, it is noted that the draft Plan confirms that:

“It will need to demonstrate how the various land uses will be conceptually and physically integrated, particularly in terms of transport connectivity and the creation [of] a high quality mixed use place. It will need to clearly establish a delivery framework and phasing plan in order to meet these requirements”22 (emphasis added)

2.29 It is considered that there is a tension between the current drafting of stipulations in Policy 7 around the quantitative approach to phasing housing and jobs and the capacity of the masterplan to allow a degree of flexibility in ensuring the creation of a high-quality mixed-use place. This is considered further in section 5 of this report. Proposed changes to the policy are provided within the overarching representation document submitted by Peel/DSA.

22 Ibid, paragraph 5.18

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3. Requirements of National Policy

National Planning Policy Framework

3.1 National planning policy is a vital mechanism for growing and rebalancing the economy to ‘build a country that works for everyone’23.

3.2 The publication of the revised NPPF represents a significant change in the informing policy context for the preparation of the draft Plan. It nonetheless retains at its core the Government’s commitment to ensuring that the planning system achieves the parallel objectives of delivering the homes that are needed, supporting the ongoing development of a strong, responsive and competitive economy and making effective use of land to enhance the natural environment24.

3.3 National policy and guidance provides a clear framework for doing so. The implications for the draft Plan are summarised as follows:

• The draft Plan must include ‘strategic policies’25 to address the identified priorities for the development and use of land across Doncaster. These policies and priorities must address social, economic and environmental objectives in ‘mutually supportive ways’, mindful that they are interdependent components of achieving sustainable development26.

• In respect of social objectives, the strategic policies of the draft Plan must ‘make sufficient provision for…housing (including affordable housing)’27. This should be achieved by ensuring that a ‘sufficient amount and variety of land’ is made available28.

• The ‘minimum’ number of new homes needed across Doncaster should be identified using the Government’s ‘standard method’29, the methodology for which is set out in the national PPG.

• The standard method identifies the ‘minimum starting point’ in determining housing needs and there will be circumstances where the ‘actual housing need is higher than the standard method indicates’30. The PPG makes clear that this will ‘need to be assessed’ before the identified need is translated into a housing requirement figure in the draft Plan31.

23 Cabinet Office (2017) ‘Building a country that works for everyone: the government’s plan’ – series of departmental plans 24 MHCLG (February 2019) National Planning Policy Framework, paragraph 8 25 Ibid, paragraph 17 26 Ibid, paragraph 8 27 Ibid, paragraph 20 28 Ibid, paragraph 59 29 Ibid, paragraph 60 30 PPG Reference ID 2a-010-20190220 31 Ibid

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• The draft Plan must ‘help create the conditions in which businesses can invest, expand and adapt’, and ‘enable a rapid response to changes in economic circumstances’32. Policies should ‘set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth, having regard to Local Industrial Strategies and other local policies for economic development and regeneration’33. They should ‘seek to address potential barriers to investment, such as…housing’34.

• All policies should be underpinned by ‘relevant and up-to-date evidence’, which should focus ‘tightly on supporting and justifying the policies concerned, and take into account relevant market signals’35.

3.4 The NPPF confirms that a strategy which either fails to promote sustainable patterns of growth36 or severely restricts economic growth37 would form neither a positive, nor justified, nor effective, nor national policy consistent approach. It would therefore be unsound38.

Calculating Local Housing Need

3.5 As referenced above, paragraph 60 of the NPPF states that strategic policies on housing provision should be informed by the outcome of the standard method in determining the minimum number of homes needed.

3.6 It is important to recognise, as the Government has been clear to state, that the calculation of need through the standard method ‘does not represent a mandatory target for local authorities to plan for, but the starting point for the planning process’39. The PPG unequivocally states that the method ‘does not produce a housing requirement figure’40.

3.7 This clearly does not prohibit authorities from planning for levels of housing which exceed this ‘minimum’ benchmark, nor drawing upon existing or additional evidence on housing need. Indeed, the Government has been clear to articulate its expectation that authorities do exceed the minimum, and it has acknowledged that the output of the standard method will not in isolation deliver the 300,000 homes needed each year by the mid-2020s to avert the current housing crisis. As the method was introduced, the former Secretary of State for Housing confirmed that:

32 MHCLG (February 2019) National Planning Policy Framework, paragraphs 80 and 81d 33 Ibid, paragraph 81a 34 Ibid, paragraph 81c 35 Ibid, paragraph 31 36 Ibid, paragraphs 20 and 103 37 Ibid, paragraphs 20 and 80 38 Ibid, paragraph 35 39 MHCLG (2019) ‘Government response to the technical consultation on updates to national planning policy and guidance – A summary of consultation responses and the Government’s view on the way forward’, February 2019, page 6 40 PPG Reference ID 2a-002-20190220

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“The standard method is intended to provide what we believe is a realistic starting point for assessing the number of homes needed for each area. …that is not a target. That is your starting point… It relies on past trends, so does not account for changing circumstances, for example new infrastructure. Where growth is expected beyond historic trends authorities are encouraged to establish higher lead figures. …All we are saying is that it is a methodology. It is a starting point for councils to use as part of their need and supply policies”41 (emphasis added)

3.8 In responding to a question which directly challenged the limitations of the methodology – with regards to a concern that there will be a ‘battle’ at Local Plan examinations in the North, when variant housing requirement figures are often justified and intended to reflect the aspirations of northern areas – the Secretary of State was clear to respond that:

“I very firmly hear that aspiration and that intent. That is something I certainly do not want to discourage at all. I would underline that the methodology is based on historic trends, which simply show more growth in the south than the north. I would underline that the standard method is a minimum, not a maximum, and there is absolutely nothing to stop local authorities planning for growth…Authorities can certainly plan for growth in their numbers and their ambition, and that is something I firmly encourage”42 (emphasis added)

3.9 The PPG translates this support for plan-makers in planning for an appropriate level of new housing provision. It is clear to state that the standard method ‘does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour’43. As referenced above, it therefore identifies that there will be circumstances where ‘actual housing need is higher than the standard method indicates’.

3.10 It identifies a non-exhaustive list of circumstances which would lead to situations where the need for housing would be expected to exceed past trends, because of:

• Growth strategies that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);

• Strategic level infrastructure improvements that are likely to drive an increase in the homes needed locally; or

• An authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground.

3.11 In the same section, the PPG also identifies further ‘situations’ which should be considered when determining the appropriateness of planning for a higher level of housing need than the standard model suggests. These are where either of the following are ‘significantly greater’ than the outcome of the standard method:

41 Housing, Communities and Local Government Committee oral evidence: MHCLG priorities for the Secretary of State, HC 1036 – Rt Hon James Brokenshire MP, Secretary of State, Ministry of Housing response to Question 32 42 Ibid - Response to Questions 35 and 36 43 PPG Reference ID 2a-010-20190220

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• Previous levels of housing delivery; or

• A previous assessment of need, such as a recently-produced SHMA.

Evaluating the Council’s Approach

3.12 The Council is correct to acknowledge within the draft Plan that the standard method produces only a ‘minimum’ level of housing need, and takes no account of the needs of the local economy.

3.13 However, the Council’s translation of its evidence of housing need into the housing requirement in Policy 3 is in direct conflict with the NPPF as:

• It proposes with insufficient justification that the housing requirement forms a range with the standard method at its lower end. The Council has failed to recognise in doing so that judging housing delivery against this level of need would markedly slow the rate of recent provision and create a situation where housing acts as a barrier to job creation and investment in Doncaster; and

• The implicit proposition that the upper end of the range be viewed as a maximum, based on the nature of a range, fails to recognise that the Council’s own evidence base has identified that supporting the borough’s economic growth is likely to result in a higher level of housing need.

3.14 The analysis presented in the following section strongly confirms the position reached in the Council’s own evidence that the full need for housing will exceed that suggested at either end of the Council’s advanced housing requirement range. Specifically it challenges the Council’s failure to adequately justify the retention of the standard method figure as being in any way representative of future needs in Doncaster.

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4. Doncaster’s Housing Needs

4.1 The Council’s advancement of its housing requirement as a closed range within Policy 3 – with the standard method forming the lower end – is challenged in this section, through the identification of an evidenced need which substantially exceeds the lower standard method figure and indeed surpasses the upper end of the proposed range.

Flaws in the Standard Method for Doncaster

4.2 The precise outcome of the standard method is highly sensitive to the assumptions made within its input demographic baseline. Where this figure is uncritically retained at the lower end of a range, as proposed by the Council, inaccuracies in these assumptions bring a fundamental risk that housing needs are underestimated and therefore not met.

4.3 The baseline is currently drawn from the 2014-based household projections, which show ‘the number of households there would be in England if a set of assumptions based on previous demographic trends in population – births, deaths and migration – and household formation were to be realised in practice’44.

4.4 As such, the precise figure generated through the method is intrinsically linked to the 2014-based sub-national population projections (SNPP) which estimate how births, deaths and migration might affect the population of local authorities, such as Doncaster. They take account of official population estimates up to and including 2014, and make assumptions on future changes based on trends recorded in the preceding five year period45 (2009-14).

4.5 The ONS continues to estimate the population of every local authority each year, with the latest such estimates relating to mid-2018. This allows comparison with the population growth suggested in the initial four years of the 2014-based SNPP, to test the reliability and suitability of their assumptions at a high level46.

4.6 The 2014-based SNPP anticipated that the population of Doncaster would increase by circa 1,700 persons between 2014 and 2018, representing population growth of 0.6%. However, subsequently released ONS estimates show that the population has actually grown at over three times this rate (2.0%), meaning that the population of Doncaster is thought to be around 1.5% larger in 2018 than was assumed under the official projections used in the standard method.

44 ONS (October 2018) What our household projections really show 45 ONS (May 2016) Methodology used to produce the 2014-based subnational population projections for England 46 It is recognised that the ONS revised the population for the base year of the 2014-based SNPP, and the preceding years since 2011, albeit this had a relatively minor impact in Doncaster and slightly increased the population estimate for 2014 by 0.07%

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Figure 4.1: Comparing Projected and Estimated Population (2014-18)

Source: ONS

4.7 Much of this discrepancy has been caused by migration, both internationally and within the UK. In terms of the latter, the 2014-based SNPP assumed that there would be a net outflow of some 2,800 people to other parts of the UK over this four year period, yet Doncaster has actually proved to be much more effective at attracting and retaining people such that there was a much smaller net outflow of only 180 people; some 94% smaller than anticipated. This is symbolic of an improving and encouraging trend, illustrated in the chart below.

300,000

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2014 2015 2016 2017 2018

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Figure 4.2: Net Inflow to Doncaster from Rest of UK (2001-18)

Source: ONS

4.8 This confirms that the standard method for Doncaster is predicated upon a demographic baseline which makes regressive assumptions about the factors likely to change the population of the borough, which are unreliable.

4.9 Furthermore, when the baseline is calculated over ten years from 2019 – as currently required by the PPG47 – it does not recognise that the starting population is already much larger than the underlying projections have assumed. This is a key consideration, given that the 2014-based household projections estimate the households that will be formed both by new and existing residents. As shown in the following chart, it is already the case that the population of Doncaster is almost as large as it was assumed under the 2014-based projections to be in 2029 when calculating the baseline for the standard method.

47 PPG Reference ID 2a-004-20190220

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Figure 4.3: Benchmarking Population Assumed in Standard Method Baseline

Source: ONS

4.10 The standard method is intended to produce only a ‘minimum’ figure, which should allow for the limitations of its demographic baseline – as well as other factors – to be taken into account when considering the likely level of housing need. However, the Council’s proposal to uncritically retain the standard method figure as a lower housing requirement figure removes the opportunity to correct such flaws. There is clear evidence that this approach risks significantly underestimating the factors likely to change the population of Doncaster in future, and providing insufficient housing as a result. This conflicts with a basic requirement of the NPPF48.

Taking Account of Past Delivery

4.11 The draft Plan relays the Government’s clear aim of significantly boosting housing supply49. It is this ambition, and a clear appreciation of the scale of the national housing crisis, which led to the recent ‘radical’ reforms that culminated in the publication of the revised NPPF and introduction of a new standard method for assessing housing needs. This sought to ensure that local authorities could not ‘duck potentially difficult decisions’ by advancing an alternative methodology50.

4.12 The PPG recognises that there will occasionally be situations where past delivery is ‘significantly greater’ than the minimum figures generated through its formula, and

48 ‘Ensuring that a sufficient number…of homes can be provided to meet the needs of present and future generations’ is key to the social objectives of sustainable development (paragraph 8a); and strategic policies must ‘make sufficient provision for…housing’ (paragraph 20) 49 Doncaster Council (June 2019) Doncaster Local Plan 2015-2035 Publication Version, paragraph 6.3 50 DCLG (2017) Fixing our Broken Housing Market – the housing white paper, paragraph 14

310,542

306,438BASELINE2019-29

310,769

270,000

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2001

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Population estimates 2014-based SNPP

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confirms that this must be taken into account when considering whether it is appropriate to plan for a higher level of need51.

4.13 Such an unintended situation has evidently arisen in Doncaster. The standard method currently implies that a minimum of 550 dwellings per annum are needed, yet more than twice as many homes have often been delivered in the borough in recent years.

4.14 The draft Plan notes that 3,400 net additional homes have been completed since 2015, and this is broken down to individual years – and presented for the period back to 2011 – in the Council’s latest published Residential Land Availability Report52. This monitoring is understood to draw upon statistics published by the Valuation Office Agency, and can therefore be brought further up-to-date through reference to recently released 2019 data53.

4.15 As shown in the following chart, the standard method figure for Doncaster has been exceeded in each of the past six years, and more than doubled in three of the last four years. An average of 1,106 homes have been completed annually over the past five years, which is more than double the standard method figure and also higher than the upper housing requirement proposed in the draft Plan (920dpa).

Figure 4.4: Standard Method Relative to Past Delivery in Doncaster

Source: Doncaster Council, 2018; VOA, 2019

4.16 The recent boosting of housing supply appears to have helped Doncaster to become more effective at retaining people who have historically tended to move elsewhere, when completions are considered in the context of the improving internal migration trends summarised at Figure 4.2.

51 PPG Reference ID 2a-010-20190220 52 Doncaster Council (2018) Residential Land Availability Report 2017/18 53 VOA (September 2019) Council Tax: stock of properties, 2019

457

316

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792

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3 1,34

0

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4.17 Furthermore, while the Council’s monitoring goes back only to 2011, statistics published by MHCLG54 reaffirm that it has been relatively common for Doncaster to deliver in the order of 1,050 homes per annum, with this representing the median annual rate of delivery seen since 2001.

4.18 In the context of the PPG, it is therefore clear that it would be considered more appropriate to plan for a higher level of need than the minimum outcome of the standard method in the local circumstances of Doncaster.

4.19 The Council is ostensibly doing so through its evidencing of a need for 920 dwellings per annum, but this risks being undermined by the uncritical retention of the standard method at the lower end of a range. This could contribute to a marked reduction of the recent and indeed long-term rate of delivery in Doncaster, in conflict with the Government’s clear aim of significantly boosting housing supply to address a national housing crisis. This would not be justified and is not consistent with national policy, and as such is considered to be unsound.

Supporting Future Job Growth

4.20 Peel’s response to the Council’s informal consultation last year welcomed the publication of the Economic Forecasts and Housing Needs Assessment (EFHNA), which provided an up-to-date and integrated assessment of likely economic growth and associated housing needs. It provides important evidence on the housing needed to support the local economy, mindful that the standard method makes no attempt to predict how changing economic circumstances may affect housing needs55. In the context of the NPPF, such an assessment is therefore essential to avoid a scenario in which housing acts as a barrier to investment56.

4.21 In general terms, it is considered that the EFHNA deploys a reasonable and appropriate methodology to both establish a suitable scale of economic growth in Doncaster and in turn understand the implications for housing need. While it presents two scenarios, the draft Plan rightly attributes the greatest weight to the higher scenario – described as “policy-led” in the EFHNA – in which job growth aligns with the ‘attainable’ target that is emerging across the Sheffield City Region (SCR) by averaging 1.0% per annum57. The EFHNA indicated that this target will underpin the emerging refresh of the Strategic Economic Plan (SEP), which will be a ‘single overarching strategy’ that will set out ‘the wider socio-economic aspirations and inclusive priorities over the medium to long term’ and inform the parallel production of a Local Industrial Strategy58 (LIS). The NPPF notably confirms that planning policies must have regard to the LIS59, which is scheduled for publication in December 2019 and will therefore be available prior to the examination of the draft Plan.

54 MHCLG (2018) Table 122 Net additional dwellings by local authority district, England 2001-02 to 2017-18 55 PPG Reference ID 2a-010-20190220 56 MHCLG (2019) National Planning Policy Framework, paragraphs 80-81 57 Metro Dynamics (2017) Target Metrics Sheffield City Region; cited in PBA (2018) Economic Forecasts and Housing Needs Assessment, p16 58 Sheffield City Region Mayoral Combined Authority (29 August 2019) Report to Housing Board: Strategic Economic Plan and Local Industrial Strategy 59 MHCLG (2019) National Planning Policy Framework, paragraph 81a

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4.22 It is important to reflect on the committed programme of investment already set out by the SCR, in advance of the publication of the refresh of the SEP and the LIS. The SCR published an Integrated Infrastructure Plan (IIP). The IIP articulates and evidences required infrastructure, spatial requirements linked to supporting the economic priority areas identified in the SEP. In essence, it seeks to provide the infrastructure necessary to create the best opportunities for economic growth, jobs and homes, to create the best attractive environments for businesses and residents. To focus investment, the IIP identifies a number of strategic spatial priorities, a number of which will evidently have a positive impact on the borough:

• Growth of the advanced manufacturing innovation district;

• Provide growth and enhance the role of DSA and the surrounding area;

• Maximise the benefits of HS2 in the Sheffield City Region; and

• Stimulate growth and regeneration in Town and City Centres.

4.23 DSA is also working with partners in the SCR to create the Global Innovation Corridor (GIC). The GIC will extend across the City Region linking and capitalising on assets of global significance, including but not limited to the Advanced Manufacturing District, Advanced Manufacturing Research Centre, the Sheffield Olympic Legacy Park, National College for High Speed Rail, Barnsley’s Digital Media Centre and DSA. The DSA will, through its planned growth, provide a global connection required to benefit businesses across the GIC and deliver further additionality and investment.

4.24 The draft Plan discounts the lower “business-as-usual” scenario presented in the EFHNA, in which job growth of 0.6% per annum could occur in Doncaster, given the ‘very low’ employment land requirement that it implies and the Council’s clear desire – in accordance with the NPPF – to ‘boost productivity and provide the conditions for existing and new sectors to grow’60. The draft Plan expresses an intention to ‘retain an ambitious growth target’ and considers there to be ‘sufficient previous evidence’ of investment and land development to justify the allocation of employment land which supports 1.0% employment growth each year. The Council therefore continues to express confidence that this growth strategy is deliverable.

4.25 Whilst it is agreed that this represents a more reasonable level of job growth than the “business-as-usual” scenario in the context of Doncaster’s economic strengths and prospects for further growth, employment growth could conceivably be still higher. This position is based on:

• The concession within the EFHNA that Doncaster has historically seen employment levels increase by an average of 1.0% per annum, between 1997 and 2015 – a period that notably included a once-in-a-generation recession. Continuing this rate of growth could conceivably be viewed as “business as usual” for the borough, rather than necessarily being an aspirational level of growth. This situation could be due to the setting of the target at SCR level, which obscures the greater or more modest contributions required of individual

60 Doncaster Council (June 2019) Doncaster Local Plan 2015-2035 Publication Version, paragraph 4.26

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authorities for the wider SCR to achieve this outcome. A greater contribution could be reasonably expected of Doncaster, given that the borough currently has the second largest employment base of the nine SCR authorities61;

• The suggestion within the EFHNA that the vast majority of the uplift from the baseline forecast is attributable to just two areas of economic intervention, namely DSA and the iPort logistics park62. In reality, these projects are likely to have a catalytic and compound effect on other parts of the economy, encouraging additional investment and boosting employment growth as a result;

• The identified scale of job growth forecast within the DSAM, which indicates that there will be at least 1,744 direct jobs generated through the growth of the airports operation by 2031 (i.e. close to the end of the plan period), this being a component of the overall 10,100 direct jobs forecast to be created. As considered in section 5, it is understood that this growth has not been fully captured in the policy-led forecast;

• The acknowledgement within the EFHNA that, in seeking to validate the policy-led scenario as a reasonable level of growth for Doncaster, comparison is made only with the lower of the two scenarios presented within the DSA masterplan; namely the “core growth” scenario as opposed to “high growth”. The latter suggests a level of potential job growth which is almost double the former. Whilst it is considered broadly reasonable to take such an approach in the context of the information available at this time, it must be acknowledged that there is a reasonable prospect that substantially higher employment growth could be achieved through the successful growth of DSA. This potential is referenced in section 2 of this report and in more detail within the overarching representations made by Peel. This has an important bearing in ensuring that plans are ‘flexible enough to accommodate needs not anticipated in the plan…and to enable a rapid response to changes in economic circumstances’63. Again this a point returned to in the consideration of Policy 7 of the draft Plan in section 5 of this report; and

• The caveat within the EFHNA, when concluding on the reasonableness of the policy-led scenario, that there will possibly be ‘considerable demand for strategic warehousing over and above the scenario’, but that the quantification of ‘such strategic demand would require a regional or sub-regional study’64.

4.26 Within this context, Peel continues to support the conclusion reached in the EFHNA that the Council should take a positive approach to allocating employment land to support upper forecasts of job growth, as follows:

61 Sheffield City Region (June 2019) SEP & LIS Evidence 62 PBA (2018) Economic Forecasts and Housing Needs Assessment, paragraph 2.50. This suggests that the two projects potentially have the capacity to accommodate 10,000 of the 12,800 additional jobs assumed under the policy-led scenario, relative to “business-as-usual” 63 MHCLG (2019) National Planning Policy Framework, paragraph 81d 64 PBA (2018) Economic Forecasts and Housing Needs Assessment, paragraph 2.52

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“In the interest of maximising economic growth, it may be right to allocate enough land over the plan period to match the job-led scenario…The new plan may even provide land above the job-led scenario, if it aims to attract regional / national demand for strategic warehousing; and to ensure it is ready [and] able to meet unexpected occupier requirements, so that no opportunities for economic growth are missed. Over-allocating land in this way may be a reasonable choice for an ambitious authority such as Doncaster”65

4.27 This acknowledgement of the need for flexibility must also extend to the provision of land to accommodate new homes, as the alternative would risk housing becoming a barrier to business investment and thus undermining the economic ambitions of the Council and the wider SCR. Such a position would conflict with paragraph 81 of the NPPF.

4.28 The EFHNA estimates the housing needed in Doncaster to accommodate the resident labour force that is required to support the “policy-led” scenario. From a technical perspective, its modelling can be viewed as largely up-to-date, having drawn upon the assumptions applied in the official 2014-based projections. While the EFHNA emphasised that ‘all the numbers’ were subject to change following the release of the 2016-based projections, the Government has subsequently advised against the use of these projections for the purposes of assessing housing needs and continues to endorse the 2014-based projections through the PPG66. This removes any ambiguity around the absolute scale of housing need concluded in the EFHNA.

4.29 It confirms that an average of 1,073 dwellings per annum would be needed between 2015 and 2032 to support the “policy-led” scenario and grow employment levels by an average of 1.0% each year. This average falls to 912 dwellings per annum when calculated over the period from 2016 to 2026.

4.30 While neither period aligns with the stated horizon of the draft Plan (2015-35), there is clearly a much greater alignment with the former, which captures 17 years from the base date of the 20 year plan period. The latter covers a selective ten year period therein, omitting later years after 2026 without clear justification and demonstrably skewing the average as a result. The EFHNA notably explains that:

“In the job-led scenario job numbers grow faster every year than the baseline…Consequently, the longer the forecast period the greater is the difference between the scenario and the baseline, whether in terms of jobs, population or household numbers”67

4.31 This is an important consideration given the Council’s interpretation of the modelling presented in the EFHNA. The draft Plan makes no reference to the average annual need for 1,073 homes that has been evidenced throughout much of the plan period. It instead refers only to the annual need for 912 homes that can be expected on average in half of the plan period, but demonstrably underestimates the full scale of need over a timescale that is more aligned to the plan period.

65 Ibid, paragraph 3.21 66 PPG Reference ID 2a-005-20190220 67 PBA (2018) Economic Forecasts and Housing Needs Assessment, paragraph 4.30

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4.32 This is compounded by the simple extrapolation of the lower average over a twenty year period, which is unnecessary and misleading given that a position on housing needs within much of this timeframe was already available to the Council. It is compounded further still by the discounting of housing completions to date, with the scale of any perceived overprovision naturally moderated when considered in the context of a higher annual need for 1,073 homes on average68.

4.33 The Council’s confused approach leaves a requirement for 882 dwellings per annum; little more than 80% of the housing provision needed annually on average to support job growth over much of the plan period. As such, the plan should acknowledge that there is a risk that housing delivery in line with the proposed upper end of the housing requirement in Policy 3 will not be sufficient to grow the labour force and support the economic ambition.

4.34 This is an unnecessary risk that can be easily avoided. In establishing the housing requirement in Policy 3 the Council should acknowledge the evidenced annual need for 1,073 homes on average over the period from 2015 to 2032 within the explanatory text. This is equivalent to a total need for 18,241 homes, and can logically take account of the 3,400 homes completed during the first three years of this defined period. This produces a residual need for 14,841 homes to be met over 14 years, which equates to 1,060 dwellings per annum. This can be reasonably extended by one year to cover the 15 year period that the Council wishes to allocate land for, and would thus require sites capable of accommodating 15,901 homes – some 20% more than claimed in the draft Plan (13,230). This shortfall only increases when the draft Plan is amended to look ahead 15 years ‘from adoption’ as required by the NPPF69.

4.35 The provision of 13,230 homes cannot therefore be reasonably viewed as sufficient to meet an upper estimate of housing needs, or perceived as a maximum, because the Council’s own evidence shows that a greater need is likely to arise within the timescales of the draft Plan as Doncaster’s economy grows. In turn, the Council’s evidence as to the anticipated changing economic circumstances over the plan period provide an equally compelling argument as to why there is no justification for Policy 3 referencing the standard method’s calculated need as this would manifestly serve to constrain the borough from realising its economic potential.

Summary and Implications

4.36 The analysis in this section demonstrates that the minimum figure generated for Doncaster by the standard method is in no way representative of housing needs in the borough. The assumptions applied in its demographic baseline are regressive and unreliable, with the population of Doncaster already larger and growing to a much greater extent than it predicted. Furthermore, recent and indeed longer-term housing delivery in the borough has been around double the minimum figure generated through the method, which the PPG confirms must be taken into account when considering whether it is appropriate to plan for a higher level of need.

68 The draft Plan confirms that 3,400 homes have been completed between 2015 and 2018. This is 24% higher than the average need calculated over ten years from 2016 but only 6% higher than the average need calculated over much of the actual plan period (2015-32) 69 MHCLG (2019) National Planning Policy Framework, paragraph 22

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4.37 The Council is ostensibly doing so through its acknowledgement of a greater need for as many as 920 dwellings per annum to support its view of the future economic circumstances of the borough, but this risks being undermined by the uncritical retention of the standard method figure – currently 550 dwellings per annum – as the lower end of an unjustified range. This could markedly and unjustifiably reduce housing delivery, and removes the opportunity to correct flaws in the method that risk significantly underestimating housing needs in Doncaster. Such an approach is not positively prepared or consistent with national policy, and therefore is not sound.

4.38 Furthermore, the Council’s published evidence confirms that there is a risk that the proposed upper end of the range, 920 homes per annum, does not represent the full need for housing where the forecast changes to economic circumstances and the borough’s growth plans are taken into consideration. Its published evidence base confirms that an average of 1,073 dwellings per annum will be needed throughout most of the plan period (2015-32) to accommodate the labour force required to support targeted job growth of 1.0% per annum, thereby aligning with the emerging Local Industrial Strategy – as required by the NPPF – but potentially still underestimating the scale of employment growth attainable in Doncaster.

4.39 The draft Plan makes no reference to this level of need in Policy 3 or the explanatory text, and instead refers only to the annual need for 912 homes that is calculated over a misrepresentative ten year period (2016-26) within its evidence base. This takes no account of the implications of continued employment growth in the latter years of the actual plan period, and overstates the impact of delivery to date in meeting long-term housing needs. Its confused approach leads to a proposed requirement for 882 dwellings per annum, which would provide little more than 80% of the homes needed annually throughout much of the plan period to support targeted job growth. This creates a risk that the required growth in the labour force will not be supported by housing delivery.

4.40 Such a risk can be avoided by recognising the more appropriately calculated need for housing within its evidence base and referencing this within the explanatory text. This would require reference to an evidenced need for in the order of 15,900 homes over 15 years from 2018 – some 20% more than claimed over the same period within the draft Plan (13,230). The shortfall only increases where emerging policies are amended to look ahead over the 15 years from adoption required by the NPPF. This would form an important context for a re-wording of Policy 3 which recognises a single housing requirement aligned with supporting economic growth as a minimum.

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5. Housing Needs of DSA (Policy 7)

5.1 As set out earlier in this report Peel has worked with the Council to develop the wording of Policy 7 and specifically the mechanism to ensure that the growth of the airport achieves a sustainable balance between job generation and new housing delivery. Providing employment opportunities and services alongside new housing is exactly the approach which the new NPPF is directing local authorities to take when setting policies for major employment and housing allocations and employment.

5.2 As outlined earlier in the report Peel is concerned, however, that in the context of an evidenced need for housing across the borough to support its wider economic potential and the importance of ensuring that housing is available as an important component of attracting investment at the airport that the policy should be amended to recognise a greater degree of flexibility.

5.3 It is important to recognise that Peel’s investment in delivering the DSAM is not awaiting the adoption of the Local Plan to proceed, with elements of the masterplan already subject to the submission of planning applications with others planned prior to the anticipated adoption of the masterplan. This will ensure that DSA continues to play an increasingly significant role in the creation of direct and indirect employment opportunities within the borough.

5.4 As outlined earlier in this report, the Council’s estimate of a need for 920 dwellings per annum, though potentially under-estimating the full calculated need over the proposed plan period, originates from the EFHNA. This estimates the housing needed to grow employment levels in Doncaster by an average of 1.0% per annum, over much of the plan period (1,073dpa; 2015-32) or a selective ten year period therein (912dpa;2016-26).

5.5 The labour force capacity that would implicitly become available to support individual sectors, where housing delivery aligned with this need, can be estimated through reference to the breakdown presented at its Table 2.5, which is illustrated below.

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Figure 5.1: Sectoral Employment Growth Anticipated in EFHNA (2015-32)

Source: PBA; Experian

5.6 The above chart shows that the EFHNA estimates the housing needed to support a relatively pronounced growth in the land transport, storage and post sector, while simultaneously providing labour to support other growth sectors including wholesale and health.

5.7 In the context of DSA, it notably does not appear to envisage a need for housing being generated by growth of the air transport sector, which is generically categorised with water transport but relates exclusively to air travel in the case of Doncaster. Only 100 additional jobs are anticipated in this sector over the period to 2032.

5.8 The EFHNA does note that much of the operation of DSA is ‘surprisingly’ classified to land transport, rather than air transport70. It is agreed that this category, as defined by

70 PBA (2018) Economic Forecasts and Housing Needs Assessment, paragraph 2.43

-1,000 1,000 3,000 5,000 7,000

Public administration and defenceAgriculture, forestry and fishing

Extraction and miningMedia activities

TelecomsInsurance and pensions

UtilitiesRetail

Air and water transportComputing and information services

Other private servicesReal estate

FinanceManufacturing

Construction of buildingsRecreation

Professional servicesCivil engineering

Specialised construction activitiesEducation

Accommodation and food servicesResidential care and social work

Administrative and supportive service activitiesHealth

WholesaleLand transport, storage and post

Change (2015-32)

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Experian through reference to the Standard Industrial Classification (SIC), includes activities that relate to air transportation71. However, in Doncaster, it is notable that such activities currently account for only a small proportion of jobs in this category, which is largely orientated towards warehousing, road freight and land transportation such that these activities collectively account for almost three quarters (74%) of all jobs in the broad sector defined in the EFHNA72.

Figure 5.2: Further Breakdown of Jobs in Land Transport, Storage & Post (2017)

Source: Business Register and Employment Survey, 2017

5.9 In the context of Figure 5.1, this existing profile should temper any presumption that the implicit capacity to support the creation of around 6,700 new jobs in the “land transport, storage and post” sector – by providing the housing needed to support 1.0% job growth overall throughout the plan period – will necessarily or exclusively support an expanded DSA. This limited supply of additional labour will also be drawn upon by established and growing businesses, and other development projects in the borough such as iPort.

71 Experian’s data guide confirms that its “land transport, storage and post” category includes “warehousing and support activities for transportation” (SIC 52), which itself includes a category titled “service activities incidental to air transportation” (SIC 5223). Documentation published by the ONS confirms that this category includes the operation of terminal facilities, airport and air-traffic-control activities, and ground service activities 72 ONS (2017) Business Register and Employment Survey

2%

Warehousing and storage Freight transport by road

Service activities incidental to land transportation Freight rail transport

Postal activities under universal service obligation Urban and suburban passenger land transport

Other postal and courier activities Passenger rail transport, interurban

Service activities incidental to air transportation Other transportation support activities

Taxi operation Other passenger land transport n.e.c.

Cargo handling Removal services

Service activities incidental to water transportation Transport via pipeline

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5.10 This is a key consideration and one which is recognised within the EFHNA. It notes that even under the baseline scenario for DSA if all of the jobs identified were created alongside those forecast at iPort and were additional to the baseline forecast, ‘these two large projects would deliver the bulk of the 12,800 additional jobs that are shown our job-led scenario, over and above the baseline forecast’73.

5.11 Whilst the EFHNA proceeds to conclude that where there will be an element of jobs included within the baseline and there is uncertainty around actual delivery it considers that its scenario looks consistent with evidence of job generation from the major projects. It must be noted, as the EFHNA itself does, that the DSAM confirms that job growth would almost double under a “high growth” scenario, which is not unrealistic given the current trajectory of growth; DSA is expected to have its busiest ever year in 2019, having recently increased its seat capacity by 25% year-on-year74.

5.12 Equally, as referenced in section 2 whilst the DSAM is not predicated on potential investment in a potential rail connection to the East Coast Mainline (ECML), if delivered this would place 9 million people in the area east of the Pennines and north and east of London within 90 minutes travel time of the DSA terminal. This enhanced accessibility would further accelerate and increase economic growth and development around the airport to levels even greater than those envisaged under the Masterplan high growth scenario.

5.13 This continues to affirm that the modelled scenario of housing need associated with forecast job growth within the EFHNA – and, as a result, the proposed housing requirement – is extremely unlikely to fully capture the full need for labour which will be generated through the delivery of the DSAM. In accordance with the NPPF, it is considered that a proactive approach should therefore continue to be taken through the policy to ensure that the housing needed to support this investment and expansion can be provided75. It should also be ‘sufficiently flexible to adapt to rapid change’ in labour demand, particularly where this had not been anticipated in the plan76.

5.14 Within this context, the draft Plan’s recognition of a separate and distinct need for housing arising from the delivery of the DSA masterplan and specifically the successful delivery of additional employment opportunities is justified and strongly supported.

5.15 Recognising, however, that the full need for housing associated with the evidence in the EFHNA is calculated as being potentially higher than the proposed housing requirement and that there is a real potential for the delivery of the DSAM to generate higher levels of job growth than recognised in the Council’s modelling of need that Policy 7 must provide a greater level of flexibility to enable the proactive delivery of housing at DSA alongside the creation of new jobs, rather than simply following after jobs have ‘already been delivered’77.

73 PBA (2018) Economic Forecasts and Housing Needs Assessment, paragraph 2.50 74 http://flydsa.co.uk/2019/01/10/doncaster-sheffield-airport-expecting-its-busiest-year-ever/ 75 MHCLG (2019) National Planning Policy Framework, paragraphs 80 and 81a 76 Ibid, paragraphs 11a and 81d 77 Ibid, p49

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5.16 Where the implied capacity for new housing to be provided within the DSAM are not recognised as a ‘minimum’ level the current wording of Policy 7 could lead to situations where jobs are created and filled by people that do not have the option of living in housing close to DSA and therefore meet their needs elsewhere, creating less sustainable commuting patterns and conflicting with the overarching vision for this location. Rigidly constraining the granting of permission after jobs have been delivered to an unnecessarily finite limit is unnecessarily restrictive, and enabling a more flexible wording in the policy would be more effective at sustainably delivering the housing needed to accommodate a growing labour force at DSA within a high-quality, mixed-use location.

5.17 In turn it is important to recognise when considering the relationship between job growth and housing need at DSA housing should be viewed not only as an integral part of supporting the attraction of business investment but also an integral part of supporting the vitality of other proposed uses within the masterplan area. This includes, for example, mix of uses proposed within the Central Plaza area. The provision of housing alongside the delivery of social infrastructure here, including retail, will be important in ensuring its vitality therefore representing another important consideration alongside a simple formulaic balancing of jobs and homes provision and phasing. The continued development of aspects of the DSAM will need to take account of such considerations thereby requiring a degree of further flexibility in the policy.

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6. Summary and Conclusions

6.1 This report has been prepared by Turley on behalf of Peel to technically review emerging policies relating to housing provision in Doncaster, as set out in the Publication Version of the Local Plan. The report is produced in the context of an ongoing consultation which runs until 30 September 2019.

6.2 Peel/DSA has worked with the Council to support the preparation of the draft Plan, specifically Policy 7. This has included the sharing of the evidence that has informed the emerging masterplan for Doncaster Sheffield Airport (DSA).

6.3 Peel welcomes the opportunity to continue to support the Council in the submission of a sound plan, but currently has a number of specific concerns where it considers that policies relating to the planned provision for housing need require amendment to be found sound in the context of the NPPF and PPG.

6.4 The Council has correctly acknowledged in Policy 3 that the standard method produces only a ‘minimum’ level of housing need, but is proposing to uncritically retain this figure as the lower end of a housing requirement expressed as a range. The draft Plan makes no attempt to justify this approach, which is not endorsed or encouraged by revised national policy that has now been published in its final form. National policy instead makes clear that the housing requirement should prevail over the outcome of the standard method for the purposes of assessing housing supply, and emphasises that the method produces only a minimum starting point and not a housing requirement.

6.5 The minimum figure generated for Doncaster by the standard method is in no way representative of housing needs in the borough. The assumptions applied in its demographic baseline are regressive and unreliable, with the population of Doncaster already larger and growing to a much greater extent than it had predicted. Recent and indeed longer-term housing delivery in the borough has also been around double that implied by the method, which the PPG confirms must be taken into account when considering whether it is appropriate to plan for a higher level of need. A failure to do so by uncritically retaining this minimum figure as a lower housing requirement could markedly and unjustifiably reduce housing delivery, and removes the opportunity to correct flaws in the method that risk significantly underestimating housing needs in Doncaster.

6.6 The draft Plan rightly identifies evidence of a substantially greater need for housing to support growth in the local economy, but appears to understate the full scale of this need over the plan period. There is acknowledgement of a need for as many as 920 dwellings per annum, implied as the upper end of a closed range rather than the minimum need suggested in the previous consultation (‘at least’). While this appears to have been drawn from the Economic Forecasts and Housing Needs Study (EFHNA), the study actually confirms that an average of 1,073 dwellings per annum are likely to be needed throughout most of the plan period to accommodate the labour force required to support targeted job growth of 1.0% per annum. The draft Plan makes no reference to this level of need, and instead refers only to an annual need that is calculated over a

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misrepresentative ten year period which does not fully account for the long-term implications of continued job growth and overstates the impact of delivery to date in meeting long-term housing needs.

6.7 The outcome of this is the presentation of a proposed requirement for up to 882 dwellings per annum, which would provide little more than 80% of the homes needed annually throughout most the plan period to support targeted job growth. This creates an unnecessary risk that the required growth in the labour force will not be supported by housing delivery, which can be avoided by acknowledging in the explanatory text to the policy that the evidence identifies a need to provide at least 1,060 homes per annum or 15,900 homes over 15 years from 2018 – some 20% more than claimed over the same period within the draft Plan (13,230). This shortfall only increases where emerging policies are amended to look ahead over the 15 years from adoption required by the NPPF. This would form an important context for a re-wording of Policy 3 which recognises a single housing requirement aligned with supporting economic growth as a minimum.

6.8 The potential for higher jobs growth associated with the DSAM is acknowledged in the Council’s evidence on housing need, recognising the masterplan’s two scenarios for growth. Policy 7 should recognise the potential for higher job growth in its presentation of the implied capacity for new housing as a ‘minimum’. The EFHNA shows the labour force capacity that would implicitly become available to support individual sectors where the housing required to support targeted growth in the economy is provided. This indicates that there will be only a limited supply of additional labour that can be drawn upon by businesses in the “land transport, storage and post” sector, which is dominated by logistics rather than land-based activities relating to air transportation. As such, there is some doubt as to whether the EFHNA fully captures the demand for labour which could potentially be realised through the delivery of the DSAM. Equally there should be recognition that the potential exists for higher than current forecast job growth in the DSAM where new rail connections to the East Coast Mainline (ECML) are delivered within the Plan period. The draft Plan’s recognition that provision of housing and jobs at the airport be considered collectively and separately from that set out in Policy 3 is therefore supported. However, in recognition of the Council’s evidence calculating that a higher need across the borough to realise its economic potential and the capacity of the airport to deliver up to 3,000 homes it is considered that references to the potential level of housing delivery on sites within the DSAM under Policy 7 should therefore be referenced as a minimum.

Turley 1 New York Street Manchester M1 4HD T

Appendix 4: Proposed Modifications to Strategic Policy 7: Doncaster Sheffield Airport

Policy 7: Doncaster Sheffield Airport

Growth and investment at Doncaster Sheffield Airport (in areas defined on the Policies map), will be supported to enable its development and expansion in line with the following principles:

A) Aviation uses and infrastructure required for the safe operation and growth of the operational passenger and freight airport uses at the airport, as defined on the Policies Map, will be supported. In this area the following new or enhanced infrastructure will be supported:

1. an expanded passenger terminal; 2. additional taxiways, aprons and aircraft stands; 3. new air cargo transit sheds; 4. new aircraft ‘Maintenance, Repair and Overhaul’ (MRO) campus and advanced

manufacturing research centre; 5. airside related retail and catering facilities; 6. public and staff car parking; 7. public transport facilities and enhanced services in accordance with an adopted

airport travel plan; 8. training centres for airlines and related services; and 9. other facilities for general aviation and associated infrastructure.

B) Aviation related development will be permitted within the airport area (as shown on the

Policies Map).

C) Employment (B1 b/c, B2 and B8) uses will be supported on land allocated at the Airport (Sites 734, 748 & 941) subject to the requirements of Policy 4.

D) Further employment development will be supported for:

1. engineering and manufacturing for aerospace and automotive purposes; 2. supporting activities relating to the operation of the airport or ancillary to

employment areas; and 3. offices where they are aviation related or meet the sequential test requirements of

Policy 23.

E) An area of 105.5* hectares (as shown on the Policies map and which includes existing woodlands) is identified as a potential housing-led mixed use urban extension on land to the south-west of Hayfield Green and to the west of Doncaster Sheffield Airport, as per parts a i – iii below:

i. 10* hectares of land east of Poplars Farm and south of the Airport Access Road (as

shown on the Policies Map as Site 940 E1) is allocated to accommodate a central area of retail, food and drink, hotel and other commercial and community uses to serve the needs of existing and future residents, employment areas and users/staff

of the airport, and a small element of residential development on upper floors (up to 150 dwellingsapartments) to support the creation of a sense of place;

ii. 11* hectares of land east of Hurst Lane (as shown on the Policies Map) is allocated for housing to accommodate up to 280 dwellings to support initial phases of airport expansion and employment growth;

iii. An additional area of approximately 70* hectares (as shown on the Policies Map) is

proposed as an Airport Reserve Housing Site allocated for housing and could accommodate a minimum ofup to 920 houses. The release of housing here is conditional, being will be phased and strictly tied to the robustly evidenced delivery of jobs in line with the draft airport masterplan and as set out in part F below.

F) Any release of additional housing in excess addition toof the 280 dwellings immediately

allocated to support the initial next phases of airport expansion and employment growth will only be permitted in line with the following principles and mechanisms:

i. The number of jobs created to trigger the release of housing will be on the ratio of

0.11 houses for every job created., up to a maximum of 1,200 houses. This will be net additional jobs in addition to the number of jobs identified by the Council as existing at the airport as at 2020, plus an annualised share in lieu of the initial tranche of 280 houses, as below.

ii.i. An initial tranche of 280 houses will be permitted on land specified in the Policies Map (Site 940 E2) in lieu of 2,5451 FTE jobs in addition to the existing jobs provided at the airport and within the Airport Masterplan areaat the airport. The delivery of the 2,545 jobs to account for theis initial housing allocation will be annualised out across the 15 years remaining in the plan period (2020 – 2035, or on average, a rate of 170 jobs expected per annum – this is called the annualised share). For further housing to be released (at Site 940 E3), the applicant must clearly demonstrate that at the point of any associated planning application, the current number level of jobs secured at the airport and within the Airport Masterplan area and/or within the Doncaster Borough which are specifically and clearly related to the airport since 31st March 2018, is in excess of the annualised share. as at April 2020 has been maintained, and on average, 170 net additional jobs have been created and sustained in addition to this, at the point of application. If this can be demonstrated, then any jobs delivered above the annualised share this figure will trigger a release of housing on the ratio of 0.11 houses per extra job above that owned in lieu.

iii.ii. Evidence of the number of additional jobs delivered (releasing a minimum of up to a

maximum total of 920 houses in addition to the initial 280 houses – a maximum of 1200 houses overall), must be submitted alongside any planning application for residential development within the Airport Reserve Housing Site. conditionally

1 280 houses = 2,545 jobs using a ratio of 0.11:1

allocated areaSite 940 E3. This evidence will be reviewed by an independent report commissioned by the council and paid for by the applicant. For further housing to be supported, the evidence will need to clearly demonstrate and quantify the provision of new net additional full time equivalent jobs delivered on within the Airport site, and/or across the wider area covered by the draft aAirport mMasterplan and/or via jobs specifically and clearly related to Doncaster Sheffield Airport within the borough, over and above the agreed number of jobs existing at the airport as at 2020 plus the annualised share to account for the initial tranche of 280 dwellings, with clear evidence that the additional jobs have already been delivered and/or are contracted to be delivered. To be clear, jobs are net, and therefore based on a running total factoring in gains and losses.

G) Development supporting aviation heritage and training will be located at land north of Hurst Lane (as shown on the Policies Map).

H) Access to the Airport must be shown to be compatible with the Airport’s Surface Access

Strategy to enable easy access through a range of travel modes from the borough, city region and the wider region. Any additional car parking to meet the users of the airport and businesses should be provided on-site linked to increasing use of public transport. There will be a presumption against provision of airport car parking in off-site locations outside the area of the draft aAirport mMasterplan as this would undermine the Airport Surface Access Strategy. .

I) In relation to transport infrastructure, the following new or enhanced infrastructure related to the airport will be supported:

1. a new electrified main line rail connection and railway station at Doncaster Sheffield Airport, connecting the airport onto the East Coast Main Line and to the Doncaster to Lincoln line, part of the route for which is allowed for by both the Airport Masterplan and the allocations under this policy. 2. improved access to the M18 junction 4 from the airport site.

J) Development proposals must be informed by a comprehensive framework document to guide how the components of the Airport Masterplan and the associated allocations under this policy will be inter-connected and integrated in terms of pedestrian, vehicular and ecological connectivity. In addition, a framework masterplan and design code for the housing areas south of the Airport Access Road / Great Yorkshire Way must be prepared in advance of any development on this land. The framework connectivity document and residential masterplan and design code must be prepared in collaboration with the Council, landowners, airport operator, with the wider engagement of stakeholders and the local community. Development proposals must satisfy the requirements of all other relevant policies of the Development Plan and respect the following specific development guidelines:

1. Within the Public Safety Zones adjacent to the airport runway, as identified on the Policies Map, there is a general presumption against new development, unless the proposal accords with guidance in DfT circular 1/2010 or any successor guidance.

2. Within the following safeguarding areas (as shown on the Policies Map) planning applications are required to be the subject of consultation with the airport:

the established official safeguarding plan for the airport; 13 km radius bird strike hazard area for development proposals likely to attract birds; and a 30 km radius circle of critical airspace centred on the airport (which covers the whole of

the Borough) that needs to be safeguarded against harmful effects of wind farms. Within such areas, the height and location/design of development that creates a bird hazard and location of wind farms may be restricted. Development that could affect the operational integrity or safety of traffic services of the airport or its surveillance systems will not be permitted. 3. A Strategic Delivery Plan will be required to enable a full assessment of the transport implications and identification of timely future interventions required to support and facilitate delivery of the masterplan.

K) Development at the airport site will be informed by a Green Infrastructure (GI) Strategy which protects

the component assets and where possible enhances the GI network through planned interventions (e.g. habitat creation and restoration) and appropriate land management. The GI Strategy will be developed in conjunction with the Local Authority and other relevant stakeholders, within the framework connectivity document referenced within J above. The GI Strategy will seek to avoid the fragmentation and isolation of existing ecological assets, particularly established woodlands and grasslands, and where possible allow and enable species movement through and around the site. Development proposals at the site must demonstrate how theyseek to deliver a net gain for biodiversity and enhance the ecological network in accordance with the Green Infrastructure Strategy, although this will need to be balanced with the potentially conflicting aim of maintaining and enhancing species movement corridor connectivity.

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Appendix 3: Doncaster Sheffield Airport and Business Park

Policy 7 proposes the release of housing linked to delivery of jobs at the airport (or airport masterplan area, or closely related to airport functions). This appendix clarifies how this is calculated.

Two sites are allocated for housing development on land adjacent to the airport. Site 940 E2 is allocated for the development of 280 houses while Site 940 E3 on land adjacent to the airport. A Reserve Housing Site is earmarked allocated for further housing for a minimum of 920 houses for up to a maximum 920 houses subject to provision of robust evidence of jobs delivery over and above an annualised share. In total, on land adjacent to this meaning a total of a minimum of 1,200 homes

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could be brought forward overall at the airporton these two sites (Both sites are shown on the Polices Map).

The release of housing on Site 940 E3 is conditional, being the Reserve Housing Site will be strictly controlled and linked to the proven delivery of jobs at the airport and (/or within the Airport Mmasterplan area, and/or via jobs specifically and clearly related to Doncaster Sheffield Airport within the borough closely related to airport functions) over and above the annualised share..

In the following example, it is assumed that the airport currently employs approximately 1,000 people.

The ratio of jobs: houses (i.e. the number of houses allowed per job created) for calculation purposes is 1:0.11. For clarification, 500 jobs, 1,000 jobs or 2,000 jobs would result in 55, 110 and 220 houses respectively (jobs number x 0.11). The delivery of approximately 9 jobs would therefore result in 1 house.

To support the economic expansion of the airport, 280 of the minimum 1,200 houses will be allocated ‘up-front’ (Site 940 E2) in lieu of delivery of jobs. However, the Council will expect the jobs related to this initial tranche to be delivered. Therefore, before any of the remaining 920 houses are permitted, it must be evidenced that the annualised share a number of the jobs equivalent to the 280 houses has actually been delivered.

Using the ratio of 1:0.11, 2,545 jobs is the equivalent of 280 houses;

The Local Plan will be adopted in 2020 with a plan period to 2035, which is 15 years. The 2,545 jobs equivalent to the upfront 280 houses will be split between the 15 years. 2,545/15 = 170 (rounded) – this is called the annualised share;

Before any further release of land (within site 940 E3) is to be permitted for housing development beyond the 280 upfront houses, the applicant must demonstrate, at the time of an application for planning permission, that the levelnumber of airport related jobs secured at the airport, and/or within the Airport Masterplan area and/or within the Doncaster Borough which are specifically and clearly related to the airport, since 31st March 2018 must beis in excess of the annualised share (i.e. above an additional 170 jobs per annum (based on the number of years since 2018 at the point of application) have been delivered or are contracted to be delivered). (a) the level of airport related jobs existing at the time of Plan adoption has been maintained; and (b) an additional 170 net jobs per annum (based on the number of years since 2020 at the point of application) have been delivered.

Should the applicant be able to robustly evidence that this has been achieved, then a calculation can be made to determined how manyuch housinges can be permitted. Any net full time equivalent (FTE) jobs delivered above this figurethe annualised share at that point in time will allow housing to be permitted at a rate of 0.11 houses per additional job.

Units Permissible = ( [no. of jobs secured/created at the airport since 31st March 2018 at point of

application ] – [number of existing jobs at airport at LP adoption] – [170 x no. of years since LP

adopted31st March 2018]) x 0.11

For example, should an applicant wish to apply for housing on Site 940 E3 the Airport Reserve Housing Site in 2030, the amount permissible would be calculated as follows:

[TABLE].

Using this example, should an applicant wish to apply for housing in 203028, they must show that the number of jobs created at the airport, and/or within the Airport Masterplan area and/or within the Doncaster Borough which are specifically and clearly related to the airport is at the airport is over 21,700, or in other words, since 31st March Local Plan adoption in 20202018, 11,700 new jobs have been delivered in addition to the agreed number of existing jobs at Local Plan adoption. For any jobs created since 31st March 2018 over and above 21,700 jobs, houses would be permitted at a rate of 0.11 houses per additional job.

Using the table above, the figures below are presented to illustrate how the calculation would work:

In 203028, the applicant robustly proves that since 31st March 2018, the number of jobs created at the airport, and/or within the Airport Masterplan area and/or within the Doncaster Borough which are specifically and clearly related to the airport is directly responsible for the employment of 8,000 people at the airport (or airport masterplan area, or via closely related airport functions) since 31st March 2018..

1,000 jobs (actual number to be confirmed at Local Plan adoption) must be deducted as they already existed at Plan adoption in 2020 (8,000 – 1,000 = 7,000).

10 years’ (202018-203028) worth of jobs related to the split of the upfront housing allocation must also be subtracted to account for houses already delivered up front (170x10 = 1,700; 87,000 – 1,700 = 65,300 jobs)

This 65,300 net additional jobs must then be translated into houses using the ratio of 1 job: 0.11 houses.

In this scenario 65983 houses would therefore be permitted. This is in addition to the 280 which were permitted up front.

The overall site would therefore, at this point, be capable of delivering 973863 houses out of a maximum of 1,200 (69583 + 280).

The remaining 22337 (1,200-973863) houses could only come forward were an applicant to be demonstrate delivery of any further net additional jobs beyond those delivered assumed as above, and using the calculation above.

There are some very important caveats to this policy:

The maximum number of up-front houses permitted in the initial tranche is 280. The 2,545 jobs that otherwise result in 280 houses (using the ration of 1:0.11) must be

delivered in lieu of this. This is termed the annualised share and must be taken into account when an application for additional housing on site 940 E3 comes forward.

The maximum number of houses that may come forward dependent on the delivery of jobs is 920 – in addition to the maximum 280, unless it is demonstrated that the number of jobs created since 31st March 2018 has exceeded 10,900, in which case additional housing on site 940 E3 will only permitted at the same ratio of 0.11 houses per additional job. This means that there will be a maximum of 1,200 houses permitted subject to the proven delivery of jobs, but that this can be exceeded where the jobs growth exceeds DSAM expectations and forecasts. Should the number of jobs exceed the related equivalent number of houses (10,910 jobs (1,200/0.11), no further housing will be permitted related to the additional jobs.

Jobs figures are net. They factor in gains and losses over time. They must be robustly evidenced and shown as actually delivered before housing release related to this can be considered.

The final list of types of directly related jobs that is acceptable to count towards this calculation will be agreed following discussions between the Council and the airport. However:

- Jobs must be within Doncaster Borough

- Jobs must be Full Time Equivalent (FTE)

- Jobs must be directly related to the airport (or provided within the area of the aAirport mMasterplan area,, or elsewhere within the Borough but closely related to airports functions). For example, new FTE jobs at an offsite Doncaster based supplier of specialist air related goods or services directly procured by Doncaster Sheffield Airport.

The Council considers that this strikes the right balance between supporting the airport and its economic aspirations, which are also important to the Borough and the City Region, and capturing the benefits for Doncaster. Additional housing acts as both support for the Airport’s development and an incentive to deliver jobs to boost the local economy.

The initial tranche is designed to help the Airport begin to release its economic ambitions and potential. However, the jobs related to this must be delivered. This is the only time that housing will come before a contracted commitment to deliver jobs in this location. For subsequent applications, jobs delivery and/or a contractual commitment to delivery of such jobs must be clearly demonstrated before housing is released. This means the impetus onus is with the airport operator/landowner if it wishes to enable housing development, to deliver its economic ambitions, which are also important for the Borough.

Explanation 5.9. National policy10 recognises the importance of Airports and their potential to contribute to economic growth at both national and regional level. The UK’s air links make it one of the best connected countries in the world, and the government is keen to continue this. The growth and importance of airports outside London is acknowledged and encouraged. However, national guidance also recognises the potential for airports to have both positive and negative impacts, with airport expansion to be “judged on their individual merits, taking careful account of all relevant considerations, particularly economic and environmental impacts”. National Policy Statement on Airports1 recognise the significant contribution that the aviation sector provides to economic growth across the country. The National Infrastructure Delivery Plan also recognises that smaller airports are vital for local economies and they open up opportunities for global connections2. The Airports National Policy Statement also recognises that international connectivity attracts businesses to cluster around airports, and they help to improve the productivity of the wider UK economy3. National planning policy requires planning policies to provide for the infrastructure and wider development required to support the operation, expansion and contribution to the wider economy of large scale transport infrastructure such as airports4 5.10. The primary function and purpose of the airport is as a passenger and freight terminal with General and Business Aviation, allied to the accommodation of other aviation uses which require an on-airport location such as (in the case of DSA) Maintenance Repair and Overhaul (MRO), oil-spill response, and the National Police Air Service. As such, of fundamental importance is the maintenance and improvement of this airport function itself. Development of “airside” land inside the airport boundary is supported for aviation development and aviation infrastructure. Other functions solely related to the functionality of the airport include airside operations and public safety. Airside Operations 5.11. Certain development within airport boundaries benefit from permitted development11. Development of land within the airport boundary which requiresing planning permission and is related to the airport function is supported for the types listed on land within the airport boundary (see Figure 5). Public Safety 5.12. Doncaster Sheffield Airport is protected through the process of aerodrome safeguarding12. Within this area, as defined on the Policies Map, the airport must be consulted on planning applications. Safeguarding areas are maintained to allow the airport to operate safely. 5.13. It is important that development at the airport does not have an impact on the continuity of safe operations. These include: the maintenance of airspace through which aircraft fly; protecting the integrity of radar and other electronic aids from interference; protecting visual aids, such as runway lighting; and avoiding any increase in the risk of bird strike. 5.14. Land uses or tall structures which would prejudice air safety will not be permitted within the ‘safeguarding area’. Additionally, a Public Safety Zone is designated at each end of the runway, within which development ins restricted in order to control the number of people on the ground at risk of death or injury in the event of an aircraft accident on take–off or landing (see Figure 5). It includes a general presumption against new or replacement development or change of use of existing buildings within Public Safety Zones. No new residential development is permitted within these zones. Airport Masterplan 5.15. The Council is keen to support the growth of Doncaster Sheffield Airport. However, it must also ensure this is done in a considered and balanced manner, in order that any growth is delivered in a sustainable way, and with potential negative impacts suitably mitigated. 1 Airports National Policy Statement: new runway capacity and infrastructure at airports in the South East of England’. Department for Transport.; June 2018. 2 National Infrastructure Delivery Plan 2026 – 2021. National Infrastructure Commission. 2016. Paragraph 5.11. 3 ‘Airports National Policy Statement: new runway capacity and infrastructure at airports in the South East of England’. Department for Transport.; June 2018, page 5. 4 National Planning Policy Framework. Ministry of Housing, Communities and Local Government. July 2018. Paragraph 104e).

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5.16. In order to achieve this, the Council, through this policy, is supportive of the multi-use growth of the airport, in line with the development of a comprehensive airport wide masterplan, which was prepared in consultation with the Council and then subject to extensive public and stakeholder consultation for a 10 week period between March and May 2018, resulting in around 1,600 responses. The land allocations proposed under Policy 5 reflect the zonings within the airport wide Masterplan.will be prepared in collaboration between the Council, landowners, airport operator, with wider engagement of stakeholders and the local community.13

10 2013 Aviation Policy Framework 11 General Permitted Development Order, 2015, Part 8, Classes F - M 12 Town and Country Planning (safeguarded aerodromes, technical sites and military explosive areas) direction 2002

13 To be clear, this is separate to the airports ‘Masterplan 2018 – 2037 Draft consultation report’, which was published by the airport owners and not subject to wider stakeholder involvement in its development.

5.17. The masterplan will ensure aproposes a holistic approach to development at the airport, and the comprehensive development framework document referenced within Policy 7(J) will guide how the components of the Airport Masterplan and the associated allocations under this policy will be inter-connected and integrated in terms of pedestrian, vehicular and ecological connectivity to ensure that the various elements are brought together in a carefully considered and well thought out manner, as opposed to a piecemeal approach which could result in a poorly integrated, disconnected series of developments. This is particularly important given the release mechanism for housing and the aspirations for a central plaza which will serve the needs of local residents, the growing working population and passing airport passengers. 5.18. The airport masterplan will consist ofis an overall growth plan, and the measures to be outlined within the comprehensive development framework document will ensure it is implemented as a well-considered place-making vision and strategy covering areas identified for airport operations, employment development, the new local centrecentral plaza, transport infrastructure, green infrastructure, ecology areas, open space and new housing areas. It will need toThe development framework will demonstrate how the various land uses will be conceptually and physically integrated, particularly in terms of transport connectivity and the creation a high quality mixed use place. It will need to clearly establish a delivery framework and as far as possible a phasing plan in order to meet these requirements. 5.19. Of particular importance are theFuture planning applications will need to consider the following issues. Archaeology 5.20. As part of satisfying other development policies within the Local Plan the impact on the heritage assets in the vicinity of the airport will need to be assessed including the impact on any archaeology that may be present. A study of aerial photography and other archival sources has shown that there are likely to be archaeological remains present on the allocated airport sites south and west of the runway, of up to regional or higher significance. A detailed archaeological evaluation of these sites will be required to determine the extent, nature, date, and condition of any archaeological remains present, and to establish their significance which will then inform the layout and design of future proposals. Design 5.21. The overriding intention of the development proposed framework document will be to ensure the airport masterplan is delivered so as to provide a a well-designed and integrated and carefully thought out schemeset of component schemes, however there are specific design requirements which must be taken into account. 5.22. Overall the scheme should achieve high quality development with distinctive design for all new buildings and spaces, reflective of the area’s significance as an international gateway to Doncaster, the Sheffield City Region, and beyond. This is especially important for the Plaza and all development adjacent to the Great Yorkshire Way. 5.23. A comprehensively connected scheme should be created for both the movement of people as well as ecological movements. This includes connectivity through the individual developments and integration with existing local networks. 5.24. It must be ensured that the development in accordance with the masterplan and the design code for the housing areas is designed, phased and delivered to ensure that there is adequate opportunity for employment, living and community interaction, including recreation, nature and open space throughout the course of the development. Environmental Management 5.25. The development approved masterplanframework document must include as a major element, a Green Infrastructure Strategy. The Green Infrastructure strategy should clearly set out how the important ecological and landscape features are identified in relation to biodiversity, landscape character and green space provision. 5.26. The ecological section of the Green Infrastructure Strategy shall identify how biodiversity will be protected and enhanced to where possible deliver a biodiversity net gain. The application of the mitigation hierarchy will provide a means by which development impacts on biodiversity of developments within the policy allocations (habitats, species and ecological networks) will be accounted for, and avoided, mitigated, or, as a final resort, for, mitigated in an appropriate and proportionate manner through specific planning interventions and planning applications and, if possible a net gain in biodiversity compensated, in line with the GI Strategy and within the context of the airport masterplan. Off-site biodiversity enhancement utilising the DEFRA biodiversity Metric, in

line with Policy 30, will be required where a biodiversity net gain cannot be secured as part of a development proposal, utilising the DEFRA biodiversity metric. 5.27. The direct, indirect and cumulative environmental impacts associated with the airport’s development and operation need to be understood and addressed, including those to human health (such as noise and air quality), biodiversity and wider environmental degradation. In particular, Thorne and Hatfield Moors are internationally important, rain-fed, wetland nature reserves and are inherently susceptible to degradation associated with pollution and poor air and water quality. Detailed consideration, including through a Habitat Regulation Assessment, will need to be given to the air quality impacts of future increases in flights and any other activity. The land take of the airport and its associated development will result in the significant loss of habitats, including priority habitats, impacts on priority species, and the functioning and connectivity of ecological networks. Proposals will need to account for their impacts, follow the mitigation hierarchy and deliver strategic biodiversity compensation in-line with an agreed airport Green Infrastructure Strategy that delivers the Lawton principles of ‘bigger, better, more and joined’ habitats14. Employment 5.28. The allocated employment sites will provide opportunities for businesses who wish to take advantage of being close to an airport. These will include aviation related-uses, aerospace businesses, logistics, advanced manufacturing (including businesses specialising in engineering and manufacturing for aerospace and automotive purposes) and offices that seek proximity to an aAirport and the international connectivity that this supports. Like the Airports National Policy Statement, the February 2017 Independent International Connectivity Commission Report exemplifies the economic benefits of clustering a broad range of uses around Airports, stating “Airports have the potential to position themselves as linchpins for a wider economic hubs, supporting the attraction of Foreign Direct Investment. This may be through focusing on activities related to the core business, such as logistics or aircraft maintenance, or may be through more general business park activities, allowing companies to benefit from locating immediately adjacent to an airport. These clusters can add significant economic value locally. Income from such developments can help airports enhance their facilities and services to assist in delivering core growth in connectivity. This is typically acknowledged locally through the planning system, for example by granting approval for the use of land adjacent to airports for a broad range of economic uses, to ensure that the benefits can be realised.” It is envisaged that companies such as those specialising in engineering and manufacturing for aerospace and automotive purposes will be attracted to the available land thus providing higher skilled jobs. The airport offers an opportunity for aviation related and other office uses (as envisaged by the Airports National Policy Statement and the International Connectivity Commission Report) to locate there and this policy will in principle permit offices at the airport as long as they are needed to support aviation services or they can meet the sequential tests and impact assessments as set out in Policy 23. Regard should also be had to Policy 4 which requires the developer/applicant to enter into a local labour agreement which will help to develop the skills of the Borough’s workforce. 5.29. The masterplan development framework documentmust will also take account of employment development and, as with housing, it should set out the design expectations, principles and parameters which new applications will need to follow. Regard will need to be givenhave regard to issues such as public access including pedestrian links and cycle routes. There may also be a need for a lorry park in line with Policy 16. Housing 5.30. In relation to the housing, thethe masterplan will include a comprehensive design code referenced at 7(J) which will clearly set out the design expectations, principles and parameters which new applications for housing will conform to. This is important to co-ordinate a large phased housing scheme which may be delivered by a number of developers. The design code must be produced and agreed by the Council prior to any application for housing south of the airport access road / Great Yorkshire Way. In developing tThe framework masterplan and design code for this particular area, the applicants must adhere to other relevant Local Plan policies and Supplementary Planning Documents. As a gateway site to the region, it is important that the design of buildings and landscaping are of high quality. The housing will also be subject to wider Local Plan policies which will be important to ensure that a proportionate amount will be delivered as affordable housing given some airport related jobs will be lower paid. 5.31. Further information on the release mechanism for housing on land to the south of the Airport Access Road is available in Appendix 3.

Comment [GF1]: Premature given the metric has only reached a consultation stage and is subject to objections

Comment [DD2]: DSA developments will meet their own parking needs.

14 The Lawton Review, DEFRA, 2010

Retail and Commercial 5.32. To supportIn the delivery of expanding the airport growth and expansion,a and nd nearby residential and commercial employment development at the scale envisaged, the provision of a central plaza area to provide new services and community facilities will be supported. This area should accommodate appropriately small scaled retail, related services and leisure uses (as including those defined in the Use Classes A1 to A35, D1 and D2) whereby they will be permitted in order to serve the needs primarily of existing and future residents, and employees in the area and visitors including airport passengers. Offices as envisaged by the Airports National Policy Statement and International Connectivity Commission Report will also be acceptable (subject to other policies in the plan including sequential test requirements). Other suitable uses such as hotels (Use Class C1) will help meet the demand for accommodation arising from development by the expanding the airport and from the increasing number of businesses around the Airport Masterplan area. Within any such development there should be opportunities to link the area to the wider network to ensure good public transport links and a safe and secure walking and cycling routes are integrated where it would not lead to unto provide full opportunities for sustainable trip generals generation for users and help develop a thriving community. Transport 5.33. Ensuring sustainable multi-modal access is a fundamental element of successful growth at the airport. Preparation of the masterplan must consider transport requirements in relation to an up to date Airport Surface Access Strategy (ASAS). The ASAS should be regularly reviewed and looks to develop, implement and promote sustainable surface access to the airport to facilitate long term growth and to maximise the opportunities for inclusive transport access. 5.31. Surface access to the site must consider both the impact of vehicle trips on the highway network and ensure opportunities for access by sustainable modes. Prioritisation of multi-modal access must be compliant with the NPPF, considering the needs of pedestrians and cyclists and public transport accessibility. The developments delivered under the Airport Masterplan and in accordance with the allocations under Policy 7 masterplan should ensure opportunities for sustainable transport are maximised and provide safe and secure access by all modes. Car parking requirements in respect of the Airport itself should be line with an up to date ASAS and all developments should accord with the relevant standards set out in Appendix 6, considering the need for a balanced approach to ensure effective demand management and be justified by need as agreed by the Local Authority. 5.34. The masterplan must include a full assessment of the transport implications and identification of timely, future interventions required to support and facilitate delivery of the development. Significant impacts arising from the proposed development on the transport network may require mitigation measures. Access improvements are required from the airport to the M18 to ensure network capacity to support growth aspirations. 5.35. Doncaster Council is currently working with Doncaster Sheffield Airport, Sheffield City Region, Department for Transport, Network Rail and Transport for the North to further plans for a new station at Doncaster Sheffield Airport connected to both the East Coast Mainline and Doncaster to Lincoln line. The introduction of a new station, and associated improvements to the rail lines, will support the growth and investment at the airport and areas beyond. The station will provide transformational connectivity to the airport, not only by expanding the travel catchment for air passengers, but also by introducing a new sustainable mode of travel to access the airport, with the potential to significantly reduce car usage. Other 5.36. It is likely that land will be required to be safeguarded for a primary school in this location, and the impact of development on schools will need to be monitored and managed accordingly.

Appendix 5: Gatehouse Lane Location Plan

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36

MP 0.5

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2

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Where are new homes in Auckley-Hayfield Green being proposed through the emerging Doncaster Local Plan?

How many new homes are being proposed?

The emerging Doncaster Local Plan, and its supporting evidence base, has identified Auckley-Hayfield Green as one of 10 Service Towns/Villages in the borough. The Homes & Settlements consultation (March 2016) proposed a housing allocation to the settlement of 105 new homes over the plan period to 2032. The latest, and most up-to-date evidence base, now proposes a slightly higher target for Auckley-Hayfield Green of 125 new homes during this same timeframe.

What are the main physical and policy constraints to growth at the Village of Auckley-Hayfield Green?

Flood Risk – National policy states areas at risk of flooding should be avoided where possible. According to the Council’s Strategic Flood Risk Assessment (November 2015) the majority of Auckley-Hayfield Green, and surrounding land, is not within an area of high (Flood Risk Zone 3) or medium (Flood Risk Zone 2) flood risk with the exception of an eastern part of Auckley where some land is medium flood risk. However, the maps do not take account of the presence of flood defences and how they may reduce flood risk to the Village. Other sources of flood risk, such as surface water flooding, must also be considered.

Countryside – The settlement is entirely surrounded by a local Countryside policy designation as identified on the map via the yellow shading. Please note, these are the current Countryside boundaries as per the Unitary Development Plan and will need to be reviewed as part of the Doncaster Local Plan. Doncaster Sheffield Airport is located adjacent to Hayfield Green to the south-east of the village.

How many planning permissions already exist that will contribute towards the Villages’ housing need?

Some sites have already been built/approved for housing at the settlement as at the base date of the Local Plan (1st April 2015) and will contribute towards Auckley-Hayfield Green’s housing requirement of 125 new homes therefore. The largest of these sites (i.e. sites which could provide at least 5+ new homes) are identified as green outline sites on the map and summarised below in Table 1; these sites are proposed to be allocated. National policy states that planning permissions are assumed to be deliverable sites unless clear evidence to the contrary.

There are also some smaller sites which have been built over the first 2 years of the plan period (1st April 2015- 31st March 2017) which are also being included in the overall numbers for Auckley-Hayfield Green (but not shown on the map/summary table as they are too small to allocate). In summary, 420 of the 125 new homes have already been built or have planning permission already granted as at 1st April 2017.

How much more housing needs to be identified at Auckley-Hayfield Green?

Given the supply of new housing from completions on small sites and existing permissions 5+ units (420 new homes), compared with Auckley-Hayfield Green’s housing growth requirement, there is no need to find further sites as the target has already been well exceeded. However, some additional sites are being proposed by landowners/developers as set out below. Also, Doncaster Sheffield Airport is located to the east of Hayfield Green and the emerging local plan is proposing to support additional housing around the airport but conditional to the creation of further jobs and economic growth at the airport first (also see below).

What sites have been put forward to provide additional housing by landowners/developers and which are being proposed to be supported/rejected through the local plan?

There are a further 11 sites at Auckley-Hayfield Green that have been considered through the site selection methodology process and shown on the map. A very brief summary of each, including why the site is either being proposed (identified on the map via an orange outline) or rejected (shown with a red outline) as a new housing site in the emerging local plan is provided in Table 2.

Are there any other sites being proposed for housing at the village?

At the time of writing, a further 3 sites have been promoted to the Council for consideration as housing sites, but were submitted too late to be included in the site selection methodology work so far. However, these have been shown on the map (grey outline) and comments on them are welcomed.

Where can I find more information about the site selection process?

This document provides a very brief summary of the evidence base that has informed the decisions on whether sites should be supported or rejected. Further information and detail therefore can be seen through the Site Selection Methodology & Results Report published alongside this consultation and available to view via: www.doncaster.gov.uk/localplan

I want to let the Council know now what I think about these proposals. How can I do this?

This engagement stage runs until Friday 26th October 2018. You can provide your comments and feedback to us via completing the Local Plan Draft Policies & Proposed Sites response form available to download via the following web-link: www.doncaster.gov.uk/localplan The response form provides all the relevant information for how you can return your comments to us or how you should contact us if you have any queries in respect to this stage, or any aspect of the emerging Doncaster Local Plan.

Table 1: Completions & Existing Planning Permissions for new homes at Auckley-Hayfield Green Completions on small sites (1st April 2015- 31st March 2017 on sites of less than 5 units)

Number of new homes 7

Site Ref: Site Name/Address: 615 Land at Hayfield Lane, Auckley 14 837 Hurst Lane, Hayfield Lane 375 877 Club Impact, Finningley Estate, Hayfield Lane. Auckley 24

Total new homes identified 420

Table 2: Proposed & Rejected Housing Sites Site Ref:

Site Name/ Address:

Potential Number of new homes

Proposed to be supported or rejected through the emerging local plan?

007 Land adjacent 21 Main Street, Auckley

25 Rejected Housing Site – the site would lead to inappropriate development in an area at high risk of flooding (FRZ3) – site fails the flood risk sequential test therefore.

049 Bell Butts, Bell Butts Lane, Auckley

36 Rejected Housing Site - Given sufficient deliverable permissions (420 units) have already been identified that are already well over three-times in excess of the settlement’s identified local need requirement of 125 dwellings it is not considered that any allocations on land currently designated as Countryside Policy Area are necessary, nor can they be justified. Further to this, the settlement’s housing target was delivered and fully met through completions in just year 1 of the plan period.

174 Land off Main Street, Auckley

80 Rejected Housing Site – the site would lead to inappropriate development in an area at medium risk of flooding (FRZ2) – site fails the flood risk sequential test therefore.

201 Poors Land, Hurst Lane, Auckley

48 Rejected Housing Site - Given sufficient deliverable permissions (420 units) have already been identified that are already well over three-times in excess of the settlement’s identified local need requirement of 125 dwellings it is not considered that any allocations on land currently designated as Countryside Policy Area are necessary, nor can they be justified. Further to this, the settlement’s housing target was delivered and fully met through completions in just year 1 of the plan period.

223 RHADS Site 2A, Land at Hayfield Lane, Auckley

117 Proposed Housing Site - 6 hectare site which could potentially accommodate 136 units. This is greenfield land having previously been part of the RAF Finningley Airfield, and lies on a former RAF sports ground, which contains disused tennis courts. Site has a railway line to the north, and housing on all other sides. Immediately to the south east is a business park. The site performs strongly thought the Sustainability Appraisal with mainly positive and neutral effects. Negative effects in respect to access to a train station and local centre can be mitigated through a Travel Assessment and Transport Plan and it is noted the site has positive effects for access to core bus network and existing cycling network. Negative effects in respect to school capacity (both primary and secondary) could be mitigated through a developer contribution towards increasing capacity in the local area. There is a signed Section 106 Agreement in place that requires the front part of the site to be delivered as Public Open Space which was agreed as part of planning permission relating to the original Airport development. The top-north-western part of ther site is also understood to be required (car parking use) as part of a potential station at the Airport which is still being proposed in addition to the East Coast Mainline Station further to the south of this site. In conclusion, allocating the site, but capacity reduced to 117 units due to existing S106 Agreement in place to provide public open space on part of the site. Although the settlement has far exceeded its plan period requirement already, this is an urban site that performs well through the Sustainability Appraisal and provides an additional supply of

housing therefore in line with national policy to significantly boost supply. 299 Orchard

Farm, Hurst Lane

276 Rejected Housing Site - Given sufficient deliverable permissions (420 units) have already been identified that are already well over three-times in excess of the settlement’s identified local need requirement of 125 dwellings it is not considered that any allocations on land currently designated as Countryside Policy Area are necessary, nor can they be justified. Further to this, the settlement’s housing target was delivered and fully met through completions in just year 1 of the plan period.

330 Land off Bell Butts Lane, Auckley

28 Rejected Housing Site - Given sufficient deliverable permissions (420 units) have already been identified that are already well over three-times in excess of the settlement’s identified local need requirement of 125 dwellings it is not considered that any allocations on land currently designated as Countryside Policy Area are necessary, nor can they be justified. Further to this, the settlement’s housing target was delivered and fully met through completions in just year 1 of the plan period.

422 Auckley 1, East of The Hollows, Auckley

30 Rejected Housing Site - Given sufficient deliverable permissions (420 units) have already been identified that are already well over three-times in excess of the settlement’s identified local need requirement of 125 dwellings it is not considered that any allocations on land currently designated as Countryside Policy Area are necessary, nor can they be justified. Further to this, the settlement’s housing target was delivered and fully met through completions in just year 1 of the plan period.

446 Blaxton Quarry Phase 2, Mosham Road, Auckley

357 Rejected Housing Site - Given sufficient deliverable permissions (420 units) have already been identified that are already well over three-times in excess of the settlement’s identified local need requirement of 125 dwellings it is not considered that any allocations on land currently designated as Countryside Policy Area are necessary, nor can they be justified. Further to this, the settlement’s housing target was delivered and fully met through completions in just year 1 of the plan period.

464 Willow Farm, Branton

122 Rejected Housing Site – the site would lead to inappropriate development in an area at high risk of flooding (FRZ3) – site fails the flood risk sequential test therefore.

832 Land at Auckley

63 Rejected Housing Site - Given sufficient deliverable permissions (420 units) have already been identified that are already well over three-times in excess of the settlement’s identified local need requirement of 125 dwellings it is not considered that any allocations on land currently designated as Countryside Policy Area are necessary, nor can they be justified. Further to this, the settlement’s housing target was delivered and fully met through completions in just year 1 of the plan period.

Table 3: Proposed Housing Site Allocation Summary

Total potential of additional new homes

(Table 2)

3,792

Total new homes proposed to be

supported (Table 2)

117

Total new homes proposed to be

rejected (Table 2)

3,675

How does this compare to the

settlement’s housing requirement?

Requirement = 125 new homes Completions & Existing Planning Permissions = 420 new homes (Table 1) Proposed Housing Allocations = 117 new homes (Table 2) Total Housing Identified = 537 new homes (+412 homes compared to the target)

Doncaster Sheffield Airport – Additional Housing Allocation & Conditional Housing Support Subject to Job Creation & Economic Growth at the Airport

The emerging Local Plan (Policy 7: Doncaster Sheffield Airport) identifies the importance of Doncaster Sheffield Airport (DSA) to Doncaster’s economy, as well as the wider region (e.g. Sheffield City Region (SCR) Strategic Economic Plan & Integrated Infrastructure Plan). There are ambitious growth aspirations for both passenger numbers and cargo/freight handling which have recently been subject to consultation by the Airport operators through a draft Airport Masterplan (2018-2037) in spring 2018. The SCR Infrastructure Plan, via the associated Investment Fund, has helped to fund critical infrastructure, such as the Great Yorkshire Way. It further identifies the DSA Corridor as one of the top two strategic priority growth areas in the City Region, being developed as an engineering and aero-industry centre, alongside and including housing growth. In addition to road improvements, the need to further improve rail connections to the Airport is recognised as part of the Government’s ‘Northern Powerhouse’ initiative. The council is supportive of growth of the Airport and a successful airport brings economic benefits for the borough and the city region. It opens both up to enhanced business and employment opportunities, and increases opportunities for international investment, as well as easy access to international markets for local businesses. A successful airport makes the borough a more attractive place for both people and business to locate, and also provides convenient tourism opportunities for the boroughs residents, as well as catering for inbound visitors. Should the goals of the masterplan be realised, there can be little doubt that the airport will be transformed by 2037. The council are proposing an additional and conditional allocation of up to a maximum of 1,200 houses on land at the airport (identified on the plan above via the grey hatched area and by site reference 940: Site 1, Land East of Poplars Farm, Hurst Lane). The release of housing on this site will be strictly related to the clearly demonstrated delivery of jobs at the airport. This is with the exception of an initial tranche of land within this area which is being proposed to provide 280 new homes upfront (as identified on the plan above via the orange hatching), but the future jobs delivery mechanism requires that jobs are provided in time in lieu of these initial 280 houses, and before any further housing tranches are released. Further detail and justification is set out in the draft Local Plan Policy 7 and supporting settlement background paper. It should be noted that the proposed allocation of 280 dwellings (or any of the further 920 houses [280 + 920 = 1,200] on the conditional allocation) are not contributing towards the settlement strategy or borough’s housing requirement. Any delivery of housing on the site will be additional and boost the overall supply of housing within the borough. As such, any housing delivery from the site are not included in the summary table above. The Sustainability Appraisal identifies potential significant negative effects in relation to biodiversity, surface water pollution and archaeology for the site which will need to be mitigated. However, it is noted that this is a very large site with areas of ancient woodland (Finningley Big Wood) and local wildlife sites (Hurst Wood) which will not be developed and the development will need to provide appropriate off setting and buffering to such areas. Further investigations are likely to be required due to the presence of known archaeology remains of national or regional significance where there has been little disturbance and likely survival of heritage assets is considered to be moderate or good. Again, the size of the site provides scope and some flexibility for a sensitive layout of development to account of any archaeological constraints.

940 Site 1, Land East of Poplars Farm, Hurst Lane

Up to 1,200 Proposed Conditional Housing Site - site reference 940 is only supported for housing (up to 920 new homes) subject to the delivery of jobs at the Airport, and as per the mechanisms set out in draft Local Plan Policy 7. This is with the exception of an initial tranche of 280 dwellings which are being supported now as an additional allocation (so not contributing towards the settlement strategy/borough housing requirement) and provided upfront with future jobs required in lieu of this allocation before further tranches of the 920 dwellings will be supported.

Turley Office 1 New York Street Manchester M1 4HD T