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DONCASTER LOCAL PLAN Development Guidance and Requirements Supplementary Planning Document CONSULTATION STATEMENT July 2015

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Page 1: DONCASTER LOCAL PLAN€¦ · A report was taken to Planning Committee on the 3rd February 2015, setting out the background and issues, and outlining the intention to consolidate and

DONCASTER LOCAL PLAN

Development Guidance and Requirements

Supplementary Planning Document

CONSULTATION STATEMENT

July 2015

Page 2: DONCASTER LOCAL PLAN€¦ · A report was taken to Planning Committee on the 3rd February 2015, setting out the background and issues, and outlining the intention to consolidate and

DONCASTER LOCAL PLAN

Development Guidance and Requirements Supplementary Planning

Document (SPD)

STATEMENT OF REPRESENTATIONS PROCEDURE

The Town and Country Planning (Local Planning) (England) Regulations

2012 – Regulation 12 Public Participation

Introduction Due to the timescales associated with preparing the new Local Plan, there is an urgent need to provide additional guidance to supplement the statutory development plan. The Core Strategy (adopted May 2012) and Unitary Development Plan (adopted July 1998) provide policy requirements, but do not give sufficient detail to implement the requirements of the National Planning Policy Framework at the local level. In addition, existing guidance needs to be simplified and consolidated into fewer documents to improve ease of use, consistency and decision making. The aim of the SPD is to create guidance for applicants, agents, developers and officers, to help aid the development management process and promote high quality design. The SPD will help to protect and enhance the qualities of existing urban and rural areas for different development types e.g. residential, commercial, householder alterations and extensions. The Council currently have 11 adopted SPD’s. It is now proposed to retain 3 and simplify and consolidate the others into one SPD now adopted. Most of the guidance has been retained, but the text has been condensed and simplified to improve reading and understanding.

As an SPD, it will need to be monitored and reported on as part of the Annual Monitoring Report. Therefore, it is considered that the SPD will be a more robust and transparent approach for the future.

Adopted SPDs Date of Adoption Proposed

Bessacarr Conservation Area Development Control Guide – Interim SPD

12th July 2005

Simplify and Consolidate

Landscape Planning on Development Sites SPD

4th February 2008

Simplify and Consolidate

Planning for Trees and Hedgerows on Development Sites

4th February 2008

Simplify and Consolidate

Planning for Nature SPD 4th February 2008 Simplify and Consolidate

Sustainable Constriction SPD 4th February 2008 Simplify and Consolidate

Biodiversity Mitigation and Compensation SPD

28th July 2008

Simplify and Consolidate

Development and Floodrisk SPD 4th October 2010 Retain separately

Local Wildlife and Geological Sites SPD 15th November 2010 Simplify and Consolidate

Residential Backland and Infill

Development SPD 15

th November 2010

Retain separately

Extensions to Domestic Dwellings SPG (Supplementary Planning Guidance)

20th July 2004

Simplify and Consolidate

South Yorkshire Residential Design Guide 2011 To be adopted at same time

as new SPD.

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Process of production of the Draft SPD The SPD has been informed by detailed discussions with the Council’s Development Management Team and internal consultees such as the Built and Environment Team and Highways Team. A report was taken to Planning Committee on the 3

rd February 2015, setting out the

background and issues, and outlining the intention to consolidate and simplify the existing guidance and publish a draft Supplementary Planning Guidance as one SPD. Planning Committee endorsed the proposal to produce a Supplementary Planning Document. An Officer Decision Record (ODR) was then taken to approve the consultation procedure. Consultation then took place formally for a period of 4 weeks from 17 April to 15 May 2015.

Formal Public Consultation The formal consultation process included:

Sending a letter or e-mail with notification of the consultation process to all contacts held on the Local Plan database. This includes statutory bodies (such as Natural England and English Heritage), local groups (such as the Yorkshire Wildlife Trust and Internal Drainage Board) and other interested parties. Approximately 2800 organisations or individuals will be contacted in this way.

Making the documents available for inspection at the Doncaster Council, Civic Office, Waterdale, Doncaster, DN1 3BU during normal office hours; Monday – Friday: 8:30–17:00

Publish details on the Council’s website;

Printing an advert in the Doncaster Star; and;

Publicising the consultation on social media (@LDF_doncaster)

Response to Public Consultation The table below sets out a summary of the representations received and our response to the points raised, highlighting where changes have been made to the document..

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No. ID/Name Object/Support

Summary Officer Comments Action/Proposed Change

1 Public Health (Clare Henry)

Support with comments

Could there be acknowledgement within the guidance to the positive impact that we wish developments to have towards health and wellbeing so there is a common thread through all of the documents? (Sample of other Authorities Health SPD attached)

The new draft SPD is an amalgamation of the existing adopted SPD’s which have been around some time (tried and tested), whereas it is thought that any new material suggested to be added really does need further thought and maybe testing and we are uncertain to the viability of it. It is thought that this would be best progressed through the Local Plan as a policy, and we think the best approach is for us to work together on this throughout the Local Plan production.”

Develop specific policy and guidance in Local Plan.

2 Environment Agency

Support with comments

Para 2.4 Residential Design Requirements - Link to Flooding SPD.

Flood resilient design is mentioned in table 1, point 13. Ref to SPD added.

No suggested changes

Para 5.3 Green Wedges and 5.4 Green infrastructure requirements within major planning applications - recommend the inclusion of an additional bullet point as follows; details of new green infrastructure provision, including design, planting and details of any targeted habitat/species

Noted Amended as suggested

Section 5.4 We recommend the inclusion of an additional bullet point as follows; details of new green infrastructure provision, including design, planting and details of any targeted habitat/species.

Noted Amended as suggested

Para 6.2 The importance of Local Sites - suggest rewording of 1st para

Noted Amended as suggested

Para 6.4 Improving Ecological Networks - No reference to 5 key aims in existing Planning for Nature SPD. Suggestions made. Suggestions also made so not to mislead and make clear of NPPF.

Noted Amended as suggested

Para 6.5 Biodiversity accounting - 3rd para (pg. 67) suggest reference to need to like-for-like compensation.

Noted New paragraph added

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3 Theatres Trust Support with comments

Section 2.3, page 6 - The key design requirements for retail, commercial, mixed use listed on page 6, and for residential development in Table 1, should emphasise the need to consider the adjoining land use and ensure the design of the development addresses any potential land use conflicts.

New sentence added to 2.3 bullet points Amended as suggested

Section 2.4 Table 1, Item 1 Page 10 - For example, cultural land uses such as theatres, pubs, live music venues or concert halls do generate noise related to their use and from patrons arriving and leaving these venues, and from the loading and unloading of equipment. New development must ensure that the new residents/ users will not be disturbed by the on-going use of an existing cultural facility to the extent that Council would be required to take any action.

New sentence added to Table 1, 3rd row as this section deals with relationships to neighbours

Amended as suggested

The promotion and protection of culture is a core planning principle within the National Planning Policy Framework (NPPF). Notably paragraph 70 states that in ‘promoting healthy communities’, planning decisions should ‘plan positively for cultural buildings’ and ‘guard against the loss of cultural facilities and services.’

Noted No action required

The protection of existing business operations is also emphasised in paragraph 123 of the NPPF and Planning Practice Guidance for Noise. In line with the above comments, we would also recommend that Item 12 of Table 1, page 15 be amended to read: ‘… and each should benefit from good levels of acoustic insulation, privacy and security.

Noted text amended as suggested. Amended as suggested

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4 Tickhill Town Council

Support with comments

Support but urge DMBC to promote the use of solar roofs (not panels) on new buildings especially warehouses.

The Council does promote the use of solar roofing tiles in appropriate contexts, particularly where it would affect a heritage asset. However these sorts of PV installations tend to be more expensive, difficult to install and are less reliable than PV panels in many instances so applicants are often reluctant to use them. PV installations outside sensitive areas tend to fall under Permitted Development so the Council have little or no control over the design of the installations. Core Strategy Policy CS14 encourages renewable energy for all types of developments including warehouses.

No action required

5 Wakefield Council

Support with comments

Wakefield Council note the contents of this section with regard to tariff based financial contributions towards major highway schemes. However we do think it is important to highlight that the SPD does not make any mention of CIL Regulation 123 which restricts the pooling of section 106 agreements for specific types of infrastructure. The NPPG says the following with regard to the situation nationally from April 2015, regardless of if an authority has a CIL in place or not: ‘the regulations restrict the use of pooled contributions towards items that may be funded via the levy. At that point, no more may be collected in respect of a specific infrastructure project or a type of infrastructure through a section 106 agreement, if five or more obligations for that project or type of infrastructure have already been entered into since 6 April 2010, and it is a type of infrastructure that is capable of being funded by the levy’ (Paragraph 100, NPPG CIL Section). We would advise that Doncaster Council consider this issue further as the SPD may need to be amended to reflect the current position as laid out in CIL regulations and NPPG. It is possible that if there are other policies which require tariff based contributions in adopted Local Plans that they could also be affected.

Consider new Section on CIL/contribrutions. Discussed, will be part of Local Plan.

No Action required

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6 The Coal Authority

Support with comments

The Coal Authority notes that within the current Draft Development Guidance and Requirements SPD document, there does not appear to be a relevant section to which issues of coal mining legacy and minerals safeguarding could be easily included. However, if the document is intended to signpost developers and other stakeholders to sources of information and guidance relevant to the planning application decision making process then it may be prudent for the LPA to add a section to the guidance on ‘Environmental Issues’

The new draft SPD is an amalgamation of the existing adopted SPD’s which have been around some time (tried and tested), whereas it is thought that any new material suggested to be added really does need further thought and maybe testing and we are uncertain to the viability of it. It is thought that this would be best progressed through the Local Plan as a policy, and we think the best approach is for us to work together on this throughout the Local Plan production.”

Develop specific policy and guidance in Local Plan not in the SPD

7 Highways England

Support with comments

Suggest that rather than referring to the motorway network reference should be made to the Strategic Road Network as this covers not only the motorways but also the A1 Trunk road

Accepted - change wording Re-Wording accepted and changed

8 JRA Moorhouse c/o D Parkinson

Support Noted No action required

9 Natural England

Support with comments

Welcomes section 6 however suggest including Ramsar wetlands, even though they are no in the borough consideration should be given to impacts from outside boundaries.

Noted Amended as suggested

Welcomes Green Infrastructure Noted No action required

10 NLP Hallam Land Management

Support with comments

Background Para 1.3 - suggested additional reference to NPPF

It is not considered necessary to re-iterate aspects of the NPPF. The purpose of the SPD is to provide further supplementary guidance in relation to adopted development plan policies, which conform with the NPPF, in order to help applicants make successful applications. A conscious decision was made not to include references from the NPPF as it was felt this would add to the length of the document compromising its usability. Those submitting applications need to refer to the NPPF along with the Local Plan and the SPD. However it is acknowledged that the NPPF would benefit referencing so this has

Reference to NPPF added to introduction.

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been added to the introduction.

Residential Design Requirements Section 2.4 - Suggest inclusion of viability of schemes which should be taken into account in the formulation of design guidance (NPPF para 59)

See above point. Viability must be considered as part of the NPPF requirement and therefore it is not felt necessary to repeat this in the SPD as it is already set out clearly in that document.

No action required

Table 1 parts 3 and 11 - too onerous and do not provide flexibility conflicting with NPPF (para 56).

The SPD clearly states it is guidance in the first sentence. This paragraph has been amended to state it is just one of a number of planning considerations in relation to a site. The NPPF does state policies should avoid unnecessary prescription or detail but the SPD is not policy, it is guidance and is therefore afforded less weight in decision making. As the respondent suggests the NPPF also states SPD can be used to help applicants make successful planning applications which is the purpose of the document. When considering the role and status of the document and the weight to be afforded to it in decision making it is not considered too onerous.

Introductory paragraph amended

Table 1 Part 2 - should be flexible so not to prevent innovation where appropriate. A blanket requirement would prevent delivery of modern designed schemes and innovation. In additional, development should be required to follow design of the surrounding area. Suggested re-wording (NPPF para 58)

Innovation is actively encouraged in the wording of Core Strategy Policy CS14 to which this guidance supports. Table 1 part 2 has been amended as suggested with the inclusion of the words 'whilst allowing for innovation where appropriate'. The remaining wording is sufficiently flexible to enable innovation, and focuses upon key design principles which are generally appropriate considerations to all areas, but being more important in 'sensitive' areas.

Table 1 part 2 amended.

Table 1 - Part 2 - Suggest density of residential developments follow those established in surrounding local area. And acknowledged that densities should be of between 30-50 dph although each should be considered on its own merits.

Agree. Density has been removed from this section. Table 1 part 2 amended.

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Table 1 - Part 3 - Should avoid prescriptive requirements and should be considered on a case by case basis (NPPF para 59)

It is not considered the guidelines in part 3 of the table are prescriptive they are established and well used planning guidelines and tools which seek to ensure homeowners have a decent level of privacy, outlook and amenity. These have been included in the Backland and Infill SPD since adoption and are used on a regular basis in the determination of applications without significant issue.

No action required

Table 1 - Part 11 - Appears too onerous. Requirements should not be too prescriptive (NPPF Para 59)

Everything in the document is guidance. The guidelines contained in this section are no different. The garden sizes are included in the South Yorkshire Residential Design Guide so have been used flexibly for over 4 years without significant adverse impact on the design, viability or deliverability of housing schemes.

No action required

Table 1 - Part 13 - Suggest that the SPD acknowledge Code for Sustainable Homes standards. Also should reference Sustainable Construction requirements as in CS14.

Reference to CS14 sustainability requirements for housing has been removed from the document as the Council will not be requiring new development to meet these due to the recent housing standards review and changes to Building Regulations.

Table 1 part 13 and p.21 amended.

Section 4.3 - Acknowledge the importance of obligations but SPD should recognise that where viability is an issue, the formulae and charges will be used as a starting point for negotiation.

Noted. Sentence added to reflect viability.

Open Space - Section 7.3 - Provide justification for the proposed requirement and clarity when such requirements will be triggered.

Comment from existing UDP. Amendment added - justification is saved UDP policy RL4

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Landscape Section 8.10 - Provide justification for proposed figure of 50% soft landscape treatment.

The SPD clearly states it is guidance in the first sentence. The use of 50% of a site area as a target for soft landscape is an aspiration that was derived from the private and communal amenity space standards set out in table 1 and the South Yorkshire Residential Design Guide (p.129-131) and is clearly caveated as being subject to individual site considerations. However, it is accepted that there is no evidence base to substantiate this figure.

Text amended to make it clearer that this is an aspirational figure.

11 Auckley Parish Council

Support No comments. Noted No action required

12 Historic England

Support with comments

Guidance is welcomed. Suggested change of wording as guidance has been replaced.

Noted. Updated guidance references in SPD

13 P Pennington Support with comments

General. The principles enunciated in the Farrell Review should be adhered to as closely as possible.

Noted. The new draft SPD is an amalgamation of the existing adopted SPD’s which have been around some time (tried and tested) the new draft SPD has pulled together all of these for ease of use.

No action required

I consider that the following should be add to formal list of topics eligible for planning obligations: Flooding, Main artificial water ways, Foul water sewage, Nature reserves. You will know the project known as DN7 between Hatfield and Stainforth but it is of considerable size with doubts about the facilities and therefore the developers should contribute to the above public resources.

Consider new Section on CIL/contributions. Discussed, will be part of Local Plan.

No action required

14 DLP Planning Support with comments

Section 3.4 - Suggest amended wording to adhere with NPPF and up to date guidance.

Noted Update guidance references in SPD

Section 8.8 - Suggests requirements are flexible and suggest wording

Trees are a valuable asset and should be replaced with appropriate numbers to mitigate what is to be lost through development. It is considered that flexibility has already been built in through use of a financial contribution to replace on Council land. However, the planting of reduced numbers in favour of the use of larger nursery stock may also be an appropriate mechanism to vary planting numbers.

Text amended.

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15 J10 Planning c/o Brodsworth

Objects with comments

Para 2.16 - This runs contrary to NPPF and the GPDO; it is a wholly arbitrary restriction and no evidence base is provided to justify this policy guidance. We consider this to be unlawful and unsound.

Suggest change wording in SPD. Reason/justification is to minimise impact on GB.

Added wording to clarify LPA's position.

Para 4.3 - SCRIF have not been accurately or correctly valued so any attempt to generate a sum from development is presently unsound. Premature guidance

Para 5.3 - Suggest that this policy guidance is an attempt to subvert the due Local Plan process and totally unfounded and unsound.

No change - green wedges are identified in the Core Strategy and this guidance sets out the principles which will be used to assess planning applications within these areas.

No action required

Para 7.3 - No evidence is provided to justify rates being sought.

Amendment added - justification is saved UDP policy RL4

Clarification sought in draft SPD.

Para 7.4 - Green Space Audit is not referenced and not being out for consultation. The Audit is not clear as to what level of deficiency might be in each community and there is no rational explanation of what commuted sums might ne and how these are calculated.

There is no requirement to consult on the audit document as it is factual. It has however been through consultation as part of the LDF evidence base development in 2013 / 2014

No action required

Para 7.8 - Open Space Audit hasn't been through examination and as such unsound and premature to protect all open space.

The audit is a factual document which will be used to establish the green / open spaces which will be identified and protected on the new Local Plan Policies Maps

Text added to document to confirm status.

Conclusion - SPD is an attempt to introduce planning policy through the back door and avoid formal examination of several topics that should be part of formal statutory plan making process that is tested at examination. Section 7 should be deleted in their entirety.

Noted. Due to the timescales associated with preparing the new Local Plan, there is an urgent need to provide additional guidance to supplement the statutory development plan. The new draft SPD is an amalgamation of the existing adopted SPD’s which have been around some time (tried and tested), pulled together for ease of use.

comment noted

16 David Lock Associates

Support with comments

Applicability of Guidance - Suggest clarification that not all the document will be relevant to all applications.

Introduction has been amended as suggested to clarify applicability of guidance.

Amended as suggested.

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Clear Design Principles and Usability - Table 1 of SPD is welcomed however, text in places is considered to be superfluous. To provide a concise set of guidance and standards it is suggested that a summary is prepared that includes only that information which is applicable to development proposals, excluding the explanatory material, this would improve the usability of the document by developers. We would also suggest a review of the contextual material on the basis that if it is reproducing information from elsewhere, then then may be possibility that it could be reduced to enable a focus on the clear standards and principles.

Table 1 aims to be a summary of key design considerations from all the guidance, i.e. a quick one-stop-shop of the key requirements for developers to focus on. We have considerably reduced the amount of textual guidance from the current adopted SPD's in order to improve usability. However this has to be balanced with the need to provide a sufficient level of clarity and explanation for those who may need to better understand the various requirements in the SPD.

review text where appropriate with a view to condensing

Suggestion to have clear understanding of what is an obligatory requirement and what is guidance.

Introduction has been amended as suggested to clarify applicability of guidance. It is difficult to set out clearly what is mandatory and what is not as there will always be a balancing act between competing design objectives which will be different for each site and context and therefore often afforded different weight. The guidance aims to demonstrate what are key considerations by highlighting these as bullet points, and in the case of residential by summarising key requirements in Table1.

No action required

Table 1 - Maintaining and enhancing character and amenity - the second bullet point related to character areas should recognise that such changes in character will not be applicable in every instance and should only be pursed where it is appropriate in the context. The guidance provided in relation to section 11 of Table 1 indicates that detailing “should have integrity and should not be a pastiche of architectural styles that have no relevance to the context”. This demonstrates that different character areas should not necessary seek to facilitate a change in architectural style if this is not relevant to the area. Character areas should be used only where appropriate to respond to the context.

Agree. Amended as suggested Text amended

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Table 1 - Parking standards – the guidance for 2 bed units appears unclear and we would suggest that this is reviewed.

Amended to be more clear. Text amended. Residential parking standards also added to appendix 1

Section 2.5 - Character and amenity - Supportive of the design principles but considers it not necessarily applicable for all large developments

Amended with the words where appropriate. Text amended.

Section 4.2 - Transport Assessments and Travel Plans - Travel Plans should be reviewed against CIL.

Noted. Minor amendment to text

Section 4.3 - The requirement for cumulative developer contributions towards major highway schemes should be reviewed against the pooling restrictions on S106 contributions as imposed by the CIL Regulations in April 2015.

Noted. CIL maybe considered in Local Plan production.

Minor amendment to text.

17 Yorkshire Wildlife Trust

Support with comments

Section 5 - Yorkshire Wildlife Trust welcomes the inclusion of Green wedges in the SPD however we would like to advise that development in such areas is avoided where possible. We also recommend that the ecological value of development sites are considered when the areas of the green wedge boundaries/ ecological buffer zones are determined. We are pleased to note that the planting of native plant species of local provenance has been advised for the landscape buffer zones which will support local biodiversity however we feel that more information could be provided on how GI can support and enhance biodiversity.

Core Strategy states that "the identification of an area as being within a green wedge...would not in itself exempt it from development (although Green Belt/Countryside Protection Policy Area designation would). However.....there will be an expectation that the development must deliver an extensive buffer and an exceptionally high standard of landscaping (to prevent the complete merging of settlements and enhance the amenity and visual appearance of settlement edges), as well as improving access to the countryside etc.".

Amend the text to emphasise the ecological value of green wedges

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Section 6 - Welcomes the inclusion of biodiversity opportunity areas and ecological networks, however, recommend the adoption of our Living Landscape corridors in Local Plans and other planning guidance documents and would support the enhancement of natural habitats within these areas.

Noted. Propose not to adopt YWT living landscapes layer but to make minor edits the Biodiversity opportunity areas map to incorporate the living landscape boundaries.

Suggest that some small areas of the BOA's are amended to incorporate YWT living landscapes areas. In addition the text has been amended to note that conservation partner project areas have been incorporated into the biodiversity opportunity areas map.

18 Anglian Water Support with comments

Section 2.6 - The focus of this section is on the principles which should be followed to create a well structured layout. Consideration should also be given to ensuring that development does not adversely affect existing water and wastewater infrastructure. Suggestion of text changes.

Noted a point has been added to Table 1 section 4 covering utilities

Table 1 amended.

Section 8.5 - When incorporating new tree, woodland and hedgerow planting consideration to the location and protection (from tree routes) of existing underground infrastructure needs to be considered. Suggested LPA seek further guidance (link given)

The comment refers to section 8.5 but is more pertinent to section 8.9. Whilst the 6th Edition of Sewers for Adoption did indeed include specific distances that trees should be planted from sewers (including no tree within mature crown radius) the 7th Edition does not. Instead, paragraph B5.5 states that “where there is a risk of tree root intrusion (see Clause B2.1.13) the sewer system should be resistant to tree root ingress (e.g., by use of appropriate barriers or constructed from polyethylene with welded joints)”. Although root barriers are mentioned in section 8.9 it is considered appropriate to expand on this conflict to encourage early discussion of available options.

Text amended in section 8.9.

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Section 8.12 - Support Noted No action required

19 Paul Whiting (Broad Axe Field Action Group)

Support with comments

Doncaster urgently requires the regeneration of its Brownfield Sites and the land along The South Yorkshire Canal & the River Don. Many other towns and cities have developed sites adjacent watercourses into highly desirable developments. Doncaster seems to be lagging. There is therefore a requirement to direct and assist with information to encourage the speedy regeneration of redundant land, and to implement a robust Green Belt Policy.

Noted. The Local Plan will seek to address major regeneration projects throughout the Borough. Brownfield land will be prioritised in line with NPPF requirements. Green Belt issues will be considered in the Local Plan process. Currently, NPPF and CS due address Green Belt.

No action required

There is a need for; 1) Guidance on the regeneration of Brownfields, ‘Building More Homes on Brownfield Sites’ (Dept. of Communities & Local Communities, January 2015) ‘Local Development Orders for Housing Development on Brown Field Land; Invitation to bid’ (£50000 funding for sites of over 100units) 2) Guidance on the remediation of Brownfield sites, 3) Guidance on the Regeneration of Canal & River Side Developments, 4) Guidance on Demolition to encourage a swift regeneration of disused sites and 5) Guidance for construction in Flood Risk areas

The purpose of the SPD is to provide further guidance on the adopted Core Strategy (CS) and Unitary Development Plan (UDP) policies. The SPD is to be adopted as guidance not policy.

No action required

Seems odd for DMBC to adopt Green Wedges some of which are also Green Belt to utilise the Development Requirements and Guidance Supplementary Planning Document to set out how these may be developed.

The green wedge concept is firmly entrenched in the Core Strategy but further guidance is needed to explain how it will be implemented.

No action required

20 South Yorkshire Archaeology Service

Support with comments

Suggested changes with amendments and clarifications to wording within Section 3.

Noted Updated guidance in SPD

21 Barton Willmore c/o Barratt and David Wilson Homes

Object with comments

Welcome the acknowledgement that the existing SPDs need to be replaced, updated or withdrawn.

Noted No action required

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Para 2.3 - Clarity needed for retention of existing buildings in mixed use developments

Comments noted- the re-use of buildings is an aspiration not a requirement as acknowledged it will not always be possible hence the words 'where possible' are used.

No action required

Existing Green Infrastructure - unnecessary and onerous to the applicant.

Previous comment made with regards this. Amended text in draft document

Separation Distances - clarify of 10m with the use of obscure outlook. Separate issue for new dwellings as in Residential Backland and Infill Development SPD - where as new draft SPD is wider bearing.

Text amended as suggested in relation to 10m from existing boundary rule.

Amended text.

Creating a well structured layout - to be included in policy and not SPD. It is unclear what is meant by sustainable funding mechanism.

Addressed in section 7.6 of the SPD - Managing and maintaining open Space. Ref made to section 7.6

Amended text

Error in parking standards - 2 bed units Previous comment made with regards this. Text updated in document.

Attractive, liveable and sustainable Homes - open space requirements for flats does not account for mixed use development therefore appears onerous.

Noted that is why balconies are suggested as an alternative and the guidance in that section also makes reference to the amount of local POS provision as a consideration.

No change required

Historic Environment - Direct impact and impact upon the assets setting - important delineation

The distinction between direct impact on heritage asset and an assets setting is noted but is not a distinction made in the NPPF. It usual but not always the case that impact on setting has less effect on significance than direct alteration to a heritage asset. The NPPF in p129 on assessing impact on heritage assets and setting requires identification of heritage significance and p132 introduces the idea of proportionality as a consideration developed further in p133-135. This adequately covers the variety of impacts direct or otherwise.

No action required

Biodiversity, Geodiversity and Ecological Networks - management plans must be in relation to the context of the site and level of impact.

Previous comment made with regards this. Noted amended text and inserted new paragraph.

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Open Space - Section 7.3 - No reference to the CS or UDP saved policies. Context of sites needs to be taken into consideration.

Amendment added - justification is saved UDP policy RL4

Text updated

Section 7.8 - do not understand requirements. The requirements follow NPPF and CS (UDP RL1 and 2)

No action required

Chapter 8 - Para 8.10 - clarification for soft landscaping ration requirements

See comments above from J10 Planning. 50% soft landscaping figure includes private gardens. Therefore, 50% is not considered unreasonable aspirational.

Text amended to make it clearer that this is an aspirational figure.