From: Spawforths on behalf of Metroland 30 …...1. Introduction 1.1. Spawforths have been...

From: Spawforths on behalf of Metroland Sent: 30 September 2019 17:04 To: Local Plan Subject: Doncaster Local Plan Representations Importance: High

Please find attached representations to the Doncaster Local Plan on behalf of Metroland, in respect

of their interests in Doncaster.

The representation covers the following matters:

General Comments

Policy 6 - Housing Allocations,

o Site 115: Alverley Lane, Balby; MUA

Policy 8 - Delivering the Necessary Range of Housing.

Policy 14 - Promoting Sustainable Transport in New Developments

Policy 19 - Development Affecting Public Rights of Way

Policy 20 - Access, Design and Layout of public rights of Way

Policy 27 - Green Infrastructure

Policy 29 - Open Space in New Developments.

Policy 42 - Character and Local Distinctiveness

Policy 43 - Good Urban Design

Policy 46 - Housing Design Standards

Policy 66 - Developer Contributions

Policy 67 - Development viability

Housing Site 115; Alverley Lane, Balby; MUA

We trust that you will confirm that these representations are duly made.

We welcome the opportunity for further engagement and to continue the dialogue with the

Council in respect of these issues as the Local Plan progresses.

Please do not hesitate to contact us to discuss any issues raised in this representation further.

HANNAH LANGLER

Principal: Chartered Town Planner

BSc (Hons), Dip CRP, MRTPI

Junction 41 Business Court, East Ardsley, Leeds, WF3 2AB

Development Plan Representation

Doncaster Local Plan: 2015-

2035: Publication Version (June

2019) On behalf of Metroland (Alverley Lane, Balby)

September 2019

Development Plan Representation – Doncaster Local Plan 2015-2035 Publication Version September 2019

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1. Introduction 1.1. Spawforths have been instructed by Metroland to submit representations to the Doncaster

Local Plan 2015-2035 Publication Version and for their site at Alverley Lane, Balby (Site 115).

1.2. Metroland welcomes the opportunity to contribute to the Doncaster Local Plan and are keen

to further the role of Doncaster within the Sheffield City Region, South Yorkshire and the

Yorkshire and Humber Region as a whole.

1.3. Metroland have a significant land interest in the area which can positively contribute towards

the economic and housing growth agenda.

1.4. Metroland would like to make comments on the following policies in the Doncaster Local

Plan 2015-2035 Publication Draft:

• General Comments

• Policy 6 - Housing Allocations,

o Site 115: Alverley Lane, Balby; MUA

• Policy 8 - Delivering the Necessary Range of Housing.

• Policy 14 - Promoting Sustainable Transport in New Developments

• Policy 19 - Development Affecting Public Rights of Way

• Policy 20 - Access, Design and Layout of public rights of Way

• Policy 27 - Green Infrastructure

• Policy 29 - Open Space in New Developments.

• Policy 42 - Character and Local Distinctiveness

• Policy 43 - Good Urban Design

• Policy 46 - Housing Design Standards

• Policy 66 - Developer Contributions

• Policy 67 - Development viability

• Housing Site 115; Alverley Lane, Balby; MUA

1.5. In each case, observations are set out below with reference to the provisions of the

Framework and amendments are suggested to ensure that the Local Plan is made sound.


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1.6. Metroland welcome the opportunity for further engagement and the opportunity to appear

at the Examination in Public.

1.7. We trust that you will confirm that these representations are duly made and will give due

consideration to these comments.

1.8. Please do not hesitate to contact us to discuss any issues raised in this Representation further.


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2. National Planning Policy Context and Tests of Soundness

2.1. The Government's core objectives as established through the 2018 National Planning Policy

Framework (the 2019 Framework) are sustainable development and growth. Paragraph 11 of

the Framework stresses the need for Local Plans to meet the objectively assessed needs of an

area. The 2019 Framework sets out to boost significantly the supply of homes and that a

sufficient amount and variety of land can come forward where it is needed. In terms of building

a strong and competitive economy the 2019 Framework states that planning should help

create the conditions in which businesses can invest, expand and adapt. The key focus

throughout the 2019 Framework is to create the conditions for sustainable economic growth

and deliver a wide choice of high quality homes.

2.2. In relation to Local Plan formulation, paragraphs 15 to 37 of the Framework states that Local

Plans are the key to delivering sustainable development which reflects the vision and

aspirations of the local community. The Framework indicates that Local Plans must be

consistent with the Framework and should set out the opportunities for development and

provide clear policies on what will and will not be permitted and where.

2.3. In relation to the examination of Local Plans, paragraph 35 of the Framework sets out the

tests of soundness and establishes that:

2.4. The Local Plan and spatial development strategies are examined to assess whether they have

been prepared in accordance with legal and procedural requirements, and whether they are

sounds. Plans are ‘sound’ if they are:

Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s

objectively assessed needs; and is informed by agreements with other authorities, so that

unmet need from neighbouring areas is accommodated where it is practical to do so and is

consistent with achieving sustainable development

Justified – an appropriate strategy, taking into account the reasonable alternatives, and

based on proportionate evidence;


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Effective – deliverable over the plan period, and based on effective joint working on cross-

boundary strategic matters that have been dealt with rather than deferred, as evidenced by

the statement of common ground; and

Consistent with national policy – enabling the delivery of sustainable development in

accordance with the policies in the Framework.

2.5. This document therefore considers the content of the Doncaster Local Plan – Publication

Version (2015-2035) on behalf of Metroland in light of this planning policy context.


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3. General Comments 3.1. Metroland is concerned that the Doncaster Local Plan – Publication Plan is deficient in its

content and the evidence base does not reflect national guidance.

Test of Soundness

3.2. Metroland considers that the Doncaster Local Plan – Publication Version 2015-2035 is

unsound.

Which test of soundness are comments about?

X Positively Prepared X Effective

X Justified X Consistency with National Policy

Justification

3.3. Metroland is concerned that the Local Plan does not reflect the Framework (2019). Metroland

is concerned that there is a lack of up to date, available, and robust evidence base to

accompany the Plan, particularly in respect of an up to date Housing Needs Assessment, whilst

a 2019 update is referred to in the Plan, it is not yet publically available, the Viability Evidence

(May 2019), which requires further testing to support its conclusion, and further evidence is

required to justify key policies.

3.4. Metroland consider that the Policies in the Local Plan are not justified and does not provide

an appropriate strategy. The Plan in its present form could fail to deliver sustainable

development in accordance with the policies in the Framework and is not consistent with

national policy.

3.5. In these circumstances, Metroland do not consider the Doncaster Local Plan, in

its current form, to be sound.


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3.6. However, Metroland consider that the plan can be made sound subject to proposed changes

as set out within the following sections of these representations. Metroland will continue to

work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change

3.7. To overcome the objection and address soundness matters, the Council should:

• Review and make available supporting evidence for the plan as indicated in these

representations;

• Review and provide additional testing in the Whole Plan Viability Report; and

• Respond to the evidence and provide increased flexibility in the Plan, refer to specific

proposed changes under each policy.


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4. Policy 6: Housing Allocations (Strategic Policy)

4.1. Metroland is supportive of Policy 6 and its allocation of the Alverley Lane, Balby; MUA site

(Site 115).

Test of Soundness

4.2. Metroland considers that the Doncaster Local Plan – Publication Version 2015-2035 is sound.




Justification

4.3. Metroland supports the allocation of their site at Alverley Lane, Balby; MUA and its

identification as a proposed housing site. Technical studies are ongoing but initial assessments

demonstrate the site’s deliverability.

4.4. Metroland considers the proposed housing allocation is available, suitable and achievable and

is therefore in accordance with the Framework a deliverable site able to come forward in the

short term.

4.5. The deliverability and benefits of the Alverley Lane, Balby; MUA are set out in Section 18 and

summarised below.

4.6. The proposal is an appropriate site to provide for the housing needs of Doncaster in the short

term. The allocation of the site would confirm its potential to help continue the provision of

a balanced housing supply in the Borough in sustainable locations. The site can deliver a full

range and mix of housing and a sustainable community. Development of the site would deliver

housing and affordable housing. Doncaster needs to have a robust housing trajectory and the


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site at Alverley Lane, Balby would assist with this delivery in the short term. The site is

situated within a prime location suitable for residential development and as such would

facilitate the development of land in a more effective and efficient manner. Development of

the site would not harm or undermine the areas wider policy objectives, but seeks to reinforce

the need to develop sites within sustainable locations as a priority.

4.7. Metroland would reiterate that Doncaster have recognised that some greenbelt land will need

to be released in order to meet its housing needs. As indicated in the Advocacy previously

submitted the land at Alverley Lane, Balby does not perform any of the five green belt

functions, as set out in the Framework (paragraph 134), and its release from the greenbelt can

be justified.

4.8. The submitted Advocacy document also summarised the technical work that had been

undertaken. This concludes that a safe and suitable access can be made and confirms the

highways networks ability to accommodate the proposed development. With regards to

flooding and drainage the site is in Flood Zone 1 and is not in an area at risk from flooding.

The drainage work identified a drainage strategy for the site. It confirmed attenuation was

required on site and that the proposed location was suitable. The ecological survey confirmed

that there are no ecological constraints and that the site is of low ecological value.

Development of the site offers the opportunity to enhance the ecological value through new

planting. Further there are no known infrastructure capacity issues that would preclude the

development of this site.

4.9. The proposed allocation policy should therefore be flexible to reflect this evidence base and

ensure delivery of the scheme. The site is available, suitable and achievable and therefore

deliverable in accordance with the Framework.

4.10. Metroland supports the allocation of Site 115 consider that the Policy 6 is Sound in this

regard.

Proposed Change

No Change


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5. Policy 8: Delivering the Necessary Range of Housing (Strategic Policy)

5.1. Policy 8 seeks to ensure the right range, type, size and tenure of homes are delivered within

Doncaster. Metroland is concerned with some aspects of this policy, and the robustness of

the whole plan viability. Metroland therefore consider that the Policy 8 is unsound.

Test of Soundness


unsound.




Justification

5.3. Metroland is concerned with a number of approaches and criteria established within Policy 8.

Housing Mix

5.4. Metroland is supportive of the principle of providing a broad mix of housing. However the

Local Plan should not dictate housing mix across the borough. The local Plan should achieve

this housing mix through identifying the level of provision and the broad distribution of new

housing.

5.5. Importantly there does not appear to be an up to date Strategic Housing Market Assessment

with the Housing Needs Survey being dated 2015 with an update in 2016. The Economic

Forecasts and Housing Needs Assessment does not consider housing mix. The Housing needs

survey summary 2019 (ARC4) only appears to deal with the total affordable need and size of

affordable dwellings, in terms of number of bedrooms. Therefore there is a lack of evidence


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base for this policy approach. It is acknowledged that Appendix 4 summarises the findings of

the housing need survey 2019, however the full study is not publically available. Metroland

reserve the right to comment further when this becomes available.

5.6. Although SHMA and Appendix 4 of the Plan, derived from the Housing Need Study 2019,

considers the broad issues of housing mix, the Local Plan should not seek to control the

housing mix, since it would mean that the market would be unable to adjust to changes in the

market. Policy 8 seeks to specifically address the housing mix on sites. This aspect of the policy

is onerous and prescriptive, particularly as it is seeking to control the size of units, mix and

tenure. The policy should be amended to encourage or reflect, rather than require.

5.7. It is unclear from the Whole Plan Viability Study how the identified mix has been taken into

account. An average size of dwelling of 92.90 has been assumed for the purposes of the testing.

This appears to be based on a general assumption of 30% 2 bed dwellings 40 % 3 bed dwellings,

and 30 % 4 bed dwellings. This does not align with the mix sought through the Local Plan,

detailed in appendix 4 and derived from the housing needs study 2019.

5.8. Metroland recommend that a flexible approach is taken regarding housing mix, which

recognises that the need and demand will vary from area to area and site to site, to ensure

that the scheme is viable, and provides an appropriate mix for the location. There is a real

need to create a housing market in Doncaster that will attract investors to Doncaster and

provide an element of aspiration to ensure working people and families are retained within

the area. The evidence presented in the plan is time limited, and only identifies current deficits.

Metroland has been unable to review the full findings of the Housing Needs Study 2019, and

reserves the right for further comment in this regard. However, Metroland considers that the

mix required by policy 8 has not been appropriately tested in terms of viability and considers

Policy 8 Part A to be unsound. The policy should be amended to encourage to reflect

the identified mix rather than require it.

Affordable housing

5.9. Metroland is supportive of the need for affordable housing. The Framework is however clear

that affordable housing policies must not only take account of need but also viability.

Paragraph 34 of the Framework (2019) established the importance of viability to ensure that

development identified in the Plan should not be subject to such a scale of obligations and

policy burden that their ability to be delivered might be threatened.


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5.10. The updated viability (2019), builds upon the earlier assessment and updates it in line with the

emerging policies and the revised Framework. The assessment continues to identify three

market value areas (low, medium and high) within Doncaster.

5.11. Tables 3-14 of the 2016 Viability Report show the issues of viability for a number of sites. It

shows that the schemes in the low value areas were not able to support any level of affordable

housing, whilst a number of schemes in the medium value areas would also struggle to provide

the 15 percent required by this policy.

5.12. The 2016 Viability report previously concluded that sites located within high value areas are

comfortably viable with the Councils proposed affordable housing provision of 25%, together

with draft S106 policies. However for sites within medium to low value areas it was noted

that the viability pressure was greater, and a reduced requirement should be adopted. It is

noted that the value areas have changed within the update. Areas previously identified as lower

value areas have now been identified as medium to high in some cases.

5.13. The 2019 Whole Plan Viability Study assesses the impact of the Plan requirements.

Appendices 3 to 10 of the 2019 Whole Plan Viability Study demonstrate viability issues for a

number of site typologies, including all typologies in low value areas. Typologies in low value

areas were unviable when tested against the base assumptions. The study concluded that in

high and medium value areas site typologies were comfortably viable. However, there are

some circumstances were there are viability pressures in medium value areas, significantly the

additional policy costs and sensitivities were tested against the study’s base assumptions which

notably included 15% affordable housing and not 23% sought by Policy 8.

5.14. Metroland are concerned that there is little evidence to support an affordable housing target

of 15% in low value areas. Metroland consider that further viability evidence is required to

support the target of 23% in combination with the policy requirements of the plan, including,

mix, housing design standards, and density. Further there is limited justification in the Plan or

associated evidence for a target of 23% affordable housing. The explanatory text states that

the current need for affordable housing represents 23% of the Local Plan requirement for

housing. Paragraph 6.9 states that this does not take into account current completions or

viability.

5.15. Metroland is concerned that with all the policy requirements the Local Plan details this could

undermine the provision of affordable housing through the need for a viability assessment of


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schemes on a regular basis. The viability assessment shows that a significant proportion of

sites will not be able to achieve affordable housing due to viability matters. The Government

is keen to avoid such a situation where viability assessments are being submitted regularly to

vary planning policy obligations. The Council must be aware of the impact that viability

assessments and subsequent negotiation of obligations can have on the delivery of

development. This could impact on the delivery of the housing target. Instead, the Council

should ensure this policy is appropriately tested to ensure the sites identified and allocated

are deliverable.

5.16. The Council should be mindful that it is unrealistic to negotiate every site on a one by one

basis because the base-line aspiration of a policy or combination of policies is set too high as

this will jeopardise future housing delivery. Therefore, site by site negotiations on these sites

should occur occasionally rather than routinely.

Adaptable and Accessible Homes

5.17. Part D of the policy states that new development should aim to include the provision of homes

which are adaptable, accessible and suitable for people with a wide range of needs. Metroland

supports the adaptation of the existing stock and encouraging the provision of adaptable,

accessible homes. However, as explained in response to Policy 46 Metroland object and does

not consider it appropriate to require all developments to include this provision.

Custom and Self Build Homes

5.18. Metroland understands the need and supports the delivery of Self-Build and Custom Build

housing. Metroland understands the idea of increasing the self-build and custom build sector

for its potential contribution to the overall housing supply.

5.19. Metroland consider that further evidence should be provided in respect of the level of demand

in Doncaster for self and custom build and the nature of demand, including, whether those

wanting to self-build would actually consider building within a larger housing development. As

it stands paragraph 6.3 of the Plan provides very little explanation or evidence to support the

policy.

5.20. Metroland consider that the requirements in Policy 8 are not justified and do not provide

an appropriate strategy. Metroland consider that Policy 8 along with other policy requirements

within the Plan could threaten the deliverability of the Plan. The Plan in its present form could


14

fail to deliver sustainable development in accordance with the policies in the Framework and

is not consistent with national policy.

5.21. In these circumstances, we do not consider the Doncaster Local Plan, in its

current form, to be sound.

5.22. However, Metroland consider that with increased flexibility in Part A, revised affordable

housing targets, and increased flexibility in the approach on custom and self build alongside

robust evidence supporting the requirements the Local Plan can be found sound. Metroland

will continue to work with the Council to develop appropriate modifications to the Local Plan.

Proposed Change


• Policy 8 Part A should be amended to so that developers are encouraged to reflect

the identified mix on schemes rather than require it;

• Revise the approach to affordable housing to ensure that the evidence base and

viability is robust and credible; and

• Include a flexible approach on custom build and self build homes and ensure that the

evidence base is robust and credible.


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6. Policy 14 – Promoting Sustainable Transport in New Developments

6.1. Metroland are concerned with aspects of Policy 14, Metroland consider that Policy 14 is

unsound.

Test of Soundness


unsound.




Justification

6.3. Metroland is supportive of the principles of Policy 14, However Metroland are concerned

with aspects of the policy.

6.4. Metroland are concerned with part A-4 which seeks to ensure that appropriate levels of

parking provision are made in accordance with the standards contained within Appendix 6.

6.5. Appendix 6 notes, that for residential development, parking provision will be considered on a

case by case basis. Metroland considers that Policy 14 part A 4 should be revised to ensure

that the policy is flexible in relation to residential development, and ensure that the policy is

consistent with the text within Appendix 6.

6.6. Further, Metroland are concerned with Part B of the policy which requires post development

monitoring of traffic and mitigation measures in the event that traffic levels agreed through

the original permission are later exceeded.


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6.7. Metroland consider that this is onerous and increases uncertainty for developers in relation

to the cost of the development. It is unclear how this requirement will be enforced.

6.8. Policy 14, in its current form, is not justified and does not provide an appropriate strategy

and is not consistent with national policy.



6.10. However, we consider that with increased flexibility in part A 4 in line with the text within

Appendix 6, and removal of the requirement for post development monitoring and mitigation

under part B the Plan can be found sound. Metroland will continue to work with the Council

to develop appropriate modifications to the Local Plan.

Proposed Change


• Provide greater flexibility residential development in Policy 14 Part A 4 and improve

consistency with Appendix 6.

• Remove the part B requirement for post development monitoring of traffic and

mitigation.


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7. Policy 19: Development affecting Public Rights of Way

7.1. Metroland is concerned with aspects of Policy 19.

Test of Soundness


unsound.




Justification

7.3. Metroland is concerned with part D of the policy which states that “unrecorded routes or

desire lines that cross development sites” will be treated in the same way as definitive public

rights of way.

7.4. Metroland considers that such an approach on non-definitive footpaths is onerous and

restrictive and could hinder the delivery of schemes. The effect of such a restrictive approach

coupled with requirements for on-site open space, national space standards, requirements on

mix and other policy standards, there could be implications for potential housing schemes and

their delivery and the ability to achieve the housing requirement.

7.5. Metroland consider that the Policy as it stands is not justified and does not provide an

appropriate strategy. In these circumstances, we do not consider the Doncaster

Local Plan, in its current form, to be sound.


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7.6. Metroland consider that the policy with increased flexibility or removal of part D of Policy 19

it can be made sound. Metroland will continue to work with the Council to develop

appropriate wording.

Proposed Change


• Incorporate flexibility or remove part D of the policy.


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8. Policy 20: Access, design and layout of public rights of way

8.1. Metroland is concerned with aspects of Policy 20 and therefore consider that the Policy 20 is

unsound.

Test of Soundness


unsound.




Justification

8.3. Metroland is concerned with parts B and C of the policy which specifies the routes and

dimensions of public rights of way.

8.4. Metroland considers that such an approach is onerous and restrictive and could hinder the

delivery of schemes. The requirements for public rights of way to avoid estate roads and

where the path is enclosed to be of 3 to 5 metres is over engineered and beyond what is

required.

8.5. The effect of such a restrictive approach coupled with requirements for on-site open space,

national space standards, requirements on mix and other policy standards, there could be

implications for potential housing schemes and their delivery and the ability to achieve the

housing requirement.

8.6. Metroland consider that the policy in its present form is not justified and consider

that the Plan is unsound.


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8.7. Metroland consider that the Plan with greater flexibility or the removal of the restrictive

elements of Policy 20 the Plan can be made sound. Metroland will continue to work with the

Council to develop appropriate wording.

Proposed Change


• Incorporate flexibility or remove the restrictive elements in parts B and C of the

policy


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9. Policy 27: Green Infrastructure 9.1. Metroland is concerned with some aspects of Part A of Policy 27, that require a green

infrastructure masterplan on schemes that provide 30 family dwellings or more. Metroland

consider that this is unnecessarily onerous for schemes at this scale and consider that the

Policy 27 is unsound.

Test of Soundness


unsound.




Justification

9.3. Metroland is concerned with part A of the policy which requires a green infrastructure

masterplan for schemes of over 30 family dwellings. Whilst Metroland understands the aims

and objectives of the policy, Metroland consider that the requirement for a Green

Infrastructure Masterplan on schemes of this scale is unnecessarily onerous. The requirement

to provide a masterplan will add to cost and impact on timescales for delivery, potentially

adding up to a year to the planning process. .

9.4. Flexibility therefore needs to be incorporated into Policy 27 so that the policy encourages

rather than requires the provision of a masterplan for schemes over 30 family dwellings or

the threshold should be significantly increased.

9.5. The requirement is not justified, it is unnecessarily onerous and does not provide an

appropriate strategy. The Plan is its present form could fail to deliver sustainable development


22

in accordance with the policies in the Framework and is not consistent with national

policy.



9.7. However, we consider that with increased flexibility in Part A of the Policy the Local Plan can

be found sound. Metroland will continue to work with the Council to develop appropriate

modifications to the Local Plan.

Proposed Change


• Amend Policy 27 to include flexibility and “encourage” rather than “require” a green

infrastructure masterplan or review the threshold that the policy applies.


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10. Policy 29: Open Space Provision in New Developments

10.1. Metroland is concerned that the level of new greenspace sought on sites will hinder the ability

to deliver new housing efficiently and effectively, therefore consider that the Policy 29 is

unsound.

Test of Soundness


unsound.




Justification

10.3. Metroland welcome the revision to the requirement in Part A of the policy which previously

required 56sqm of open space per family dwelling. The requirement has been slightly reduced

and now seeks between 10 and 15% of the site to be open space on schemes over 20 dwellings.

The explanatory text indicates that 15% is required where there is an existing deficiency in

open space. Metroland still consider that coupled with national space standards, requirements

on mix and other policy standards, there could be implications for potential housing schemes

and their delivery and the ability to achieve the housing requirement.

10.4. Part B of the policy requires that where sites are adjacent or close to a large open spaces as

an alternative to on site open space, a commuted sum of 10 – 15% of the residential land value

of the site should be provided. This is excessive, the commuted sum should be derived through

consideration of specific local deficiencies in open space provision. The level of commuted

sum could undermine the deliverability of the Plan and is not consistent with the principles of


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the Framework (paragraph 34). Nor is it consistent with the tests for planning obligations (

paragraph 56 of the Framework), which seek to ensure that planning obligations are necessary

to make the development acceptable, directly related to the development and fairly and

reasonably related in scale and kind to the development.

10.5. Policy 29 states that greenspace is required on site and that schemes will only be supported

where the required open space is provided. However, this is inconsistent with Policy 66 and

67 which states that contributions will be sought and that viability assessments will be

considered on a site specific approach stating that “the Council will take a pragmatic and

flexible approach to planning obligations”.

10.6. Flexibility therefore needs to be incorporated into Policy 29, in particular part A and B which

reflects Policy 66 and 67. The Local Plan at present is internally inconsistent and could

undermine the delivery of housing.

10.7. The Plan is its present form is not justified and is not consistent with national policy. It

is considered that the Plan could fail to deliver sustainable development in accordance with

the policies in the Framework.



10.9. However, we consider that with increased flexibility in line with policy 66 and 67 the Local

Plan can be found sound. Metroland will continue to work with the Council to develop

appropriate modifications to the Local Plan.

Proposed Change


• Amend Policy 29 Parts A and B, and the associated explanatory text, specifically

paragraphs 10.22 and 10.25, to include flexibility and encourage rather than require;

and

• Reduce the level of commuted sum required so that it is consistent with the

requirements of the Framework.


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11. Policy 42: Character and Local Distinctiveness

11.1. Metroland is concerned with aspects of Policy 42 therefore consider that the Policy 42

unsound.

Test of Soundness


unsound.




Justification

11.3. Metroland support the principles of Policy 42, however are concerned with aspects which

require the adaptation of standard house types to complement or reinterpret the local

character.

11.4. This could impact on viability and therefore the deliverability of schemes. It is not clear how

the whole plan viability has taken into account the requirement for high quality design.

Metroland consider this requirement will inevitably lead to increases in professional fees and

build costs, associated with use of high quality materials. Metroland consider additional

sensitivity testing is required to consider the impacts this policy.

11.5. The requirement is not justified and does not provide an appropriate strategy. The Plan is

its present form could fail to deliver sustainable development in accordance with the policies

in the Framework and is not consistent with national policy.


26



11.7. However, we consider that with increased flexibility and review of the viability evidence the

Local Plan can be found sound. The Metroland will continue to work with the Council to

develop appropriate modifications to the Local Plan.

Proposed Change


• Test the impact of the policy on viability, and revise the policy to reflect the findings.


27

12. Policy 43: Good Urban Design 12.1. Metroland is concerned with aspects of Policy 42 therefore consider that the Policy 43

unsound.

Test of Soundness


unsound.




Justification

12.3. Metroland support the principles of Policy 43, however are concerned with aspects of the

policy which expects the use of established design tools. For major applications of over

0.5hectares or 10 or more residential units this, is stated “this should include making use of pre-

application engagement with the Council and affected community, and utilising design review”.

12.4. There are some internal inconsistencies within the policy and explanatory text. The

explanatory text in paragraph 12.10 indicates that the use design advice and design review are

encouraged. The policy should be revised to provide certainty for developers, applicants and

the community.

12.5. A requirement for design review could impact on timescales and the deliverability of schemes.

Metroland consider that the policy should be flexible and should “encourage” the use of design

review rather than “expect” or “require”, and reflect the wording within the explanatory text

to provide greater clarity.


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12.6. The requirement is not justified and does not provide an appropriate strategy. The Plan is

its present form could fail to deliver sustainable development in accordance with the policies

in the Framework and is not consistent with national policy.



12.8. However, we consider that with increased flexibility the Local Plan can be found sound. The

Metroland will continue to work with the Council to develop appropriate modifications to

the Local Plan.

Proposed Change


• Modify the policy wording to reflect the explanatory text in paragraph 12.10 to

provide greater consistency and clarity and “encourage” rather than expect the use

of design review.


29

13. Policy 46: Housing Design Standards 13.1. Metroland is concerned with Policy 46 and consider that the Policy 46 is unsound.

Test of Soundness


unsound.




Justification

13.3. Metroland is concerned that part A of this policy is seeking to implement national space

standards without the requisite justification and evidence.

13.4. This policy looks for development to meet national spaces standards as a minimum (for

residential). The enhanced standards, as introduced by Government, are intended to be

optional and can only be introduced where there is a clear need and they retain development

viability. As such they were introduced on a ‘need to have’ rather than a ‘nice to have’ basis.

13.5. PPG (ID 56-020) identifies the type of evidence required to introduce such a policy. It states

that ‘where a need for internal space standards is identified, local planning authorities should

provide justification for requiring internal space policies. Local planning authorities should take

account of the following areas.

13.6. Need – evidence should be provided on the size and type of dwellings currently being built in

the area, to ensure the impacts of adopting space standards can be properly assessed, for

example, to consider any potential impact on meeting demand for starter homes.


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13.7. Viability – the impact of adopting the space standard should be considered as part of a plan’s

viability assessment with account taken of the impact of potentially larger dwellings on land

supply. Local planning authorities will also need to consider impacts on affordability where a

space standard is to be adopted.

13.8. Timing – there may need to be a reasonable transitional period following adoption of a new

policy on space standards to enable developers to factor the cost of space standards into

future land acquisitions’.

13.9. Metroland welcomes the provision of new evidence on Housing Design Standards Policy.

Metroland consider that standards can, in some instances, have a negative impact upon

viability, increase affordability issues and reduce customer choice. In terms of choice some

developers will provide entry level two, three and four-bedroom properties which may not

meet the optional nationally described space standards but are required to ensure that those

on lower incomes can afford a property which has their required number of bedrooms. The

housebuilding industry knows its customers what type and size of housing is in demand. The

use of Nationally Described Space Standards, can therefore impact on the delivery of

affordable products, and can serve to stifle innovative design. As such Metroland consider that

NDSS should only be applied to affordable housing and not to open market.

13.10. On NDSS Metroland would encourage the Council to recognise the larger land take such

houses will require more land take. Therefore to deliver this would reduce the yield of sites

and could have potential implications on the site yields identified by the Council on identified

and allocated sites, ultimately resulting in the Council failing to meet their housing targets.

13.11. Metroland note that the viability assessment has applied an average house size which is stated

to reflect NDSS, However Metroland note that the mix tested does not reflect the Policy 8

requirement. Further the viability demonstrates that site typologies in low value areas are

unviable based on the base assumptions, and viability is worsened with addition of other

planning requirements of the Local Plan, and in some circumstances some typologies in

medium value areas were demonstrated to be unviable. The 23% affordable housing

requirement has not been tested in combination with all the requirements of Policy 46,

Metroland consider that there needs to be greater flexibility in Policy 46 with regards to the

use of NDSS.


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13.12. Metroland is also concerned that part B of this policy states that 65% of all new homes on

housing developments of 10 or more units should be built to Part M4(2) of the Building

Regulations i.e. accessible and adaptable dwellings. This is a significant increase in the

requirement expressed in the earlier draft which required 30% of all housing to meet the

standards of Building regulation requirement M4 (2).

13.13. Metroland is generally supportive of providing homes for older and disabled persons.

However, if the Council wishes to adopt the higher optional standards for accessible and

adaptable homes the Council should only do so by applying the criteria set out in the PPG.

The SHMA, Economic Forecasts and Housing Needs Assessment and subsequent Housing

Design Standards Policy Evidence paper unfortunately does not provide sufficient evidence

and does not justify the Council’s position identified in the policy. The Housing Needs

Assessment 2019, whilst referred to in the background paper and Local Plan was not available

at the time of writing. Metroland reserve the right to comment further when this is made

available.

13.14. It is important that if the Council are seeking the higher optional standards that the evidence

is forthcoming. PPG (ID 56-07) identifies the type of evidence required to introduce such a

policy, including the likely future need; the size, location, type and quality of dwellings needed;

the accessibility and adaptability of the existing stock; how the needs vary across different

housing tenures; and the overall viability.

13.15. The Written Ministerial Statement dated 25th March 2015 stated that:

13.16. The optional new national technical standards should only be required through any new Local Plan

policies if they address a clearly evidenced need, and where their impact on viability has been

considered, in accordance with the NPPG.

13.17. NPPG states that where a local planning authority adopts a policy to provide enhanced

accessibility or adaptability they should do so only by reference to requirement M4(2) and /

or M4(3) of the optional requirements in the Building Regulations and should not impose any

additional information requirements (for instance provision of furnished layouts) or seek to

determine compliance with these requirements, which is the role of the Building Control

Body. This is to ensure that all parties have the clarity and certainty of knowing which

standards they have to deal with and can factor these into their plans. For developers, this

ensures that the design and procurement complications that previously arose from a series of


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different standards in different areas are avoided. It was recognised that it was not appropriate

to apply Category 2 or 3 standards to all new homes as not all people who buy or move in to

new homes need or wish to have such provision. Category 2 and 3 standards were therefore

made “optional” with the position being that the case for requiring such standards in future

new homes should be made through the adoption of local plan policies that have properly

assessed the level of requirement for these standards in the local area, also taking into account

other relevant factors including the impact on project viability.

13.18. Metroland does not dispute the population is ageing. However, it is unclear how this ageing

population and potential future need reflects in the need for 65 percent of all new homes on

sites of 10 or more dwellings to be provided at M4(2) standards. The optional higher M4(2)

standard should only be introduced on a “need to have” rather than a “nice to have” basis.

Although there is evidence of an ageing population having regard to the PPG this does not

amount to the justification required for the Council to include the optional standard as

specified in Policy 46.

13.19. The Councils housing Design Standards Policy Evidence Paper evidences the ageing population,

indicating that the percentage of over 65’s grows from 18.7% to 25%, Not all people over 65

will require a new home or adapted home. Indeed the paper recognises this in paragraph 2.53

where it states “not all of this demand will be met through new builds, and existing stock will

play some part”. The paper notes considers the level of people with Limiting Long Term

Illnesses or Disabilities and expects just less than 40% of households will have a person with

a long term health problem or disability, the majority of people with a long term health

problem or disability are over 65 (60%). Thus there is not sufficient evidence to support a

requirement of 65% based on evidence of need.

13.20. It is important that the Council recognises the viability implications of requiring all houses to

meet these enhanced standards. The whole plan viability evidence notes that all typologies in

low value areas are unviable before the consideration of the impact of M4(2) and M4(3)

standards, It also demonstrates that the application of M4(2) and M4(3) some typologies are

unviable in medium value areas, when tested against a base assumption for affordable housing

of 15% and not 23% as sought through Policy 8, Therefore, Metroland consider that this could

result in stalled development where time is taken to debate viability issues. The Council must

be mindful that it is unrealistic to negotiate every site on a one by one basis because the base-

line aspiration of a policy or combination of policies is set too high as this will jeopardise future


33

housing delivery. Metroland would urge the Council to reduce the percentage requirements

to ensure the deliverability of any policy. The policy must not be set at such a scale that will

threaten development to be in line with the Framework and guidance established in PPG.

13.21. Metroland consider that the requirements in Policy 46 are not justified and does not provide

an appropriate strategy. The Plan is its present form could fail to deliver sustainable

development in accordance with the policies in the Framework and is not consistent with

national policy.



However, Metroland consider that with increased flexibility in Part A in relation to NDSS, and

a reduction of the target in part B to reflect evidence on need the Local Plan can be found

sound. Metroland will continue to work with the Council to develop appropriate modifications

to the Local Plan.

Proposed Change


• Remove or increase the flexibility in part A of the policy which refers to national

space standards.

• Remove or significantly reduce the requirement in part B of the policy which requires

65% of all new homes to be accessible and adaptable homes.


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14. Policy 66: Developer Contributions 14.1. Metroland is concerned with aspects of Policy 66.

Test of Soundness

14.2. Metroland considers that the Local Plan is unsound.




Justification

14.3. Metroland is supportive of the need for developer contributions. The Framework is, however,

clear that the derivation of developer contributions must not only take account of need but

also viability. Paragraph 34 of the Framework (2019) established the importance of viability

to ensure that development identified in the Plan should not be subject to such scale of

obligations and policy burden that their ability to be delivered might be threatened.

14.4. Appendices 3-10 of the Viability Report show the issues of viability for a number of sites. It

shows that the schemes in the low value areas were not able to support provision of 15%

affordable housing. In some circumstances some site typologies in the medium value areas

would also be unviable. The whole plan viability report concluded that generally schemes in

high and medium value areas were demonstrated to be viable. However, it should be noted

that this did not consider the cumulative/in combination impact of all of the policy

requirements and assessed other Plan requirements against the delivery of 15% affordable

housing and not 23% affordable housing as sought by Policy 8.


undermine the delivery of housing through the need for a viability assessment of schemes on

a regular basis. The viability assessment shows that a significant proportion of sites will not


35

be able to achieve affordable housing due to viability matters. The Government is keen to

avoid such a situation where viability assessments are being submitted regularly to vary

planning policy obligations. The Council must be aware of the impact that viability assessments

and subsequent negotiation of obligations can have on the delivery of development. This could

impact on the delivery of the housing target. Instead, the Council should ensure this policy is

well tested to ensure the sites identified and allocated are deliverable.





14.7. Metroland are concerned that the policy requirements of the Plan are not justified and are

not consistent with the Framework.



Proposed Change


• Review the viability assessment and modify policy requirements to reflect the findings

and representations contained herein.


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15. Policy 67: Development Viability 15.1. Metroland is concerned with aspects of Policy 67.

Test of Soundness

15.2. Metroland considers that the Local Plan is unsound.




Justification

15.3. Metroland is supportive of the need for developer contributions. The Framework is, however,

clear that the derivation of developer contributions must not only take account of need but

also viability. Paragraph 34 of the Framework (2018) established the importance of viability

to ensure that development identified in the Plan should not be subject to such scale of

obligations and policy burden that their ability to be delivered might be threatened.

15.4. Appendices 3-10 of the Viability Report (2019) show the issues of viability for a number of

sites. It shows that the schemes in the low value areas were not able to support 15% affordable

housing, prior to consideration of other policy requirements. In some circumstances schemes

in the medium value areas would also struggle to provide the 15 percent required by this

policy, when other policy requirements were considered. It should be noted that the Policy 8

requirement for affordable housing is 23% for high and medium value areas.


undermine the delivery of housing through the need for a viability assessment of schemes on

a regular basis. The viability assessment shows that a significant proportion of sites will not

be able to achieve affordable housing due to viability matters. The Government is keen to

avoid such a situation where viability assessments are being submitted regularly to vary

planning policy obligations. The Council must be aware of the impact that viability assessments


37

and subsequent negotiation of obligations can have on the delivery of development. This could

impact on the delivery of the housing target. Instead, the Council should ensure this policy is

well tested to ensure the sites identified and allocated are deliverable.





15.7. Furthermore, Metroland considers that there may be some circumstances where this policy

and the use of trigger points in Part B can be utilised to bring forward the delivery of homes.

However, Metroland have significant concerns around the implementation of this policy and

how frequently it will be used. The use of trigger points could add further burdens to any

developer who will need to reproduce viability assessments at a potentially regular basis, going

against Government initiatives which are looking to reduce the need for viability assessments.

Metroland considers that this policy causes unnecessary uncertainty and additional risk for

developers, and therefore the policy could become an impediment to the development

process and compromise the deliverability of large sites particularly those phased and

implemented over long time periods.

15.8. Metroland are concerned that the whole plan viability does not fully consider the in

combination impacts of the Plan requirements. It is also considered that Part B does not

provide sufficient certainty. Metroland considers that the Plan is not justified and are not

consistent with the Framework.



15.10. Metroland consider that with increased flexibility in the Plan requirements and review of the

viability assessment the Plan can be made sound. Metroland will continue to work with the

Council to develop appropriate modifications.

Proposed Change



38

• Review and update the viability assessment.

• Provide clarity on Part B or remove Part B.


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16. Housing Sites; Site 115, Alverley Lane, Balby, MUA

16.1. Metroland is supportive of Policy 6 and its allocation of the Alverley Lane, Balby, Doncaster

site (site 115). However Metroland are concerned about the justification for some of the site

specific requirements set out within Appendix 2 Development Requirements Site 115.

Metroland therefore consider that the Development Requirements are unsound.

Test of Soundness


unsound.




Justification

16.3. Metroland supports the allocation of the Alverley Lane, Balby and its identification as a

proposed housing site. An Advocacy Report and illustrative masterplan is attached

to these representations which demonstrates the site’s deliverability. An overview

of the proposals is provided in Section 17.









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16.5. The site is available, suitable and achievable and therefore deliverable in accordance with the

Framework.

16.6. Metroland are concerned that the Development Requirements established in appendix 2 of

the Local Plan are not sufficiently effective or justified. There is a requirement to for a set

back from the southern boundary. The extent of the setback is unclear and could potentially

impact on the site capacity and deliverability. It is not clear what density or net to gross ratio

has been assumed by the council when calculating the capacity of the site. However it is clear

that it is lower than the gross to net ratio and or density that form the viability assumptions

in the whole plan viability report. Thus there may be a requirement for site specific viability

testing.

16.7. Further Metroland are concerned that the sites locations is now considered to be in a Medium

to high value area. It was previously identified as being within a low value area. There is

therefore a requirement for 23% affordable housing. The adjacent area is identified within a

medium value area. The viability report considers average sales values of £2,100 per sq. m. for

medium value areas, and £2,350 per sq.m. in high value area. Metroland are concerned that

the identification of the site within a medium -high value area does not reflect the sales values

expected to be achieved at site 115.

16.8. Metroland is concerned that with all the policy requirements the local plan details, and limited

refinement of value areas that this could undermine the delivery of housing through increased

need for viability assessments, and the associated impact on delivery through extended

negotiations. The Council should review the baseline aspirations of individual policies and the

policies in combination to ensure that they are not too high and ensure that the requirements

are well tested.

16.9. Metroland consider that the requirements in their current form are not fully justified or

effective. The plan in its current form could fail to deliver sustainable development in

accordance with the policies in the framework.


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16.10. In these circumstances, Metroland do not consider the Doncaster Local Plan, in

its current form, to be sound.

16.11. However, Metroland consider that with increased clarity, and justification for the development

requirements and a review viability evidence and subsequent review of the sites capacity, the

Local Plan can be found sound. The Metroland will continue to work with the Council to

develop appropriate modifications to the Local Plan.

Proposed Change


16.13. Review the development requirements, site capacity and whole plan viability to provide

greater clarity and justification for the site requirements.


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17. Land at Alverley Lane, Balby 17.1. Metroland have previously submitted an Advocacy Report and illustrative masterplan to

support the allocation of the Land at Alverley Lane, Balby. This submission is reiterated here

to support of Housing Site 115.

Justification

17.2. Metroland supports the allocation of the Alverly Lane, Balby site. An Advocacy Report and

illustrative masterplan has been previously submitted and is re-attached to these

representations. The Advocacy Report demonstrates the site’s deliverability.

17.3. Metroland considers the proposed housing allocation is available, suitable and achievable and

therefore in accordance with the Framework. It is a deliverable site that is able to come

forward in the short term.

17.4. The deliverability and benefits of the Alverley Lane, Balby is as follows:

Overview of proposals

17.5. The site is located on the edge of an established residential area and benefits from easy access

to the full range of services and facilities located within Balby, Doncaster. The site lies adjacent

to the Edlington/Dearne Valley Railway Embankment Local Wildlife Site. The site is

approximately 6.5ha gross and could accommodate in the region of 220 new homes.


43

Deliverability

17.6. The site at Alverley Lane provides a development opportunity that is available, suitable and

achievable and therefore it is considered that the site is deliverable, in accordance with

national planning policy and guidance. It is promoted by Metroland Ltd with interest in

development from Persimmon Homes and Ongo Homes and is deliverable within the plan

period.

Availability

17.7. The land is being promoted by Metroland Ltd as landowner. The site is therefore available in

accordance with the Framework and the National Planning Practice Guidance (PPG).

17.8. The proposed development can make an efficient and attractive use of the land. The site

represents an excellent opportunity for future housing and development. This site allows

housing to be delivered within an appropriate and sustainable location within Doncaster.


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Suitability

17.9. The site is located in a highly sustainable location and has residential development to the north,

east and west. The site is within easy walking distance to Springwell Lane Local Centre with a

range of facilities provided there as well as greater facilities within Doncaster Town Centre, a

short bus ride away. There are a large number of primary and a secondary schools in the

vicinity of the site.

17.10. The site is well served by buses providing opportunities for sustainable travel to work in

Doncaster and beyond with access to Doncaster Railway Station.

17.11. The development will provide additional quality development that will benefit the Doncaster

and wider district with economic, environmental and social benefits. It is therefore considered

that the development is suitable.

Green Belt

17.12. The housing needs of Doncaster are putting severe pressure on the local authority to review

the Green Belt. To meet the housing requirement Doncaster Council recognises that some

Green Belt land will need to be released for new housing land.

17.13. Alverley Lane, Balby demonstrably fails to perform any of the five Green Belt functions set

out in the Framework and is therefore currently subject to an unjustified and out of date

Green Belt status. This therefore provides an opportunity for a logical and justified release

from the Green Belt which will not only offer a highly a sustainable site for housing delivery

to meet identified need but also enforce a defensible and more permanent Green Belt

boundary for the future beyond the Plan period.

17.14. In the Borough of Doncaster approximately 46% of the area is designated as Green Belt. This

is the western part of the Borough which forms part of the South Yorkshire Green Belt

surrounding urban areas.

17.15. The Framework considers that Green Belt boundaries can change “in exceptional

circumstances” as part of a Local Plan review. Such a circumstance exists through the

significant need to provide housing in Doncaster. To meet the housing need and economic

growth aspirations the Council has stated it will need to revise the Green Belt boundaries for

the emerging Local Plan and beyond to provide the new boundaries with some permanence.


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17.16. The site does not currently perform any of the five Green Belt functions as identified within

Paragraph 134 of the Framework:

1. To check the unrestricted sprawl of large built-up areas

17.17. Due to the Site’s specific context it does not in itself perform the objective of checking

unrestrictive sprawl. The southern boundary of the site is in the form of a continuous raised

railway line with established tree belt which is significant in mass and scale and forms an

impenetrable physical boundary to development of the urban area. It is therefore this feature

that fulfils the objective for checking unrestricted sprawl and by default removes the onus of

this function from the site itself.

2. To prevent neighbouring towns merging into one another:

17.18. There is a 2 kilometre distance between Balby and the next nearest village to the south and

as such the site is not performing as a prevention of two towns merging into one another. As

part of the recent Green Belt review the Council has stated “given the strength of the

proposed boundary” (the railway line to the south) the site has no role in preventing

neighbouring towns from merging.

3. To assist in safeguarding the countryside from encroachment:

17.19. The site is greenfield but is not considered ‘countryside’. The site is an agricultural field nestled

in between suburban housing and a railway line forming a significant physical barrier distinctly

separating the site both physically and visually from the countryside to the south. The

development of this site could not therefore be considered an encroachment into the

countryside or affect the openness of the Green Belt.

4. To preserve the setting and special character of historic towns:

17.20. Balby is not classified as a historic town nor acknowledged as having a special character or

setting typically associated with a historic town and so the site does not therefore perform

this function.

5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban

land.


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17.21. The site is located by the Council’s own definition as being in the Main Urban Area which is

intended to accommodate the majority of the Borough’s development. The site is considered

to form part of the ‘urban land’ considered in the context of the currently adopted Local Plan.

The sites inclusion in the Green Belt actually restricts the availability of suitable urban land

such as this site to deliver housing in turn putting more pressure on sites located in the

countryside. There has to be a balance between green and brown field urban land owing to

the deliverability issues often experienced on brownfield / redevelopment sites.

17.22. It is therefore concluded that the Site does not currently perform any of the five Green Belt

functions and is therefore considered a justified release to deliver much needed private and

affordable housing.

17.23. Not only is the site considered to be a justified release from the Green Belt but in doing so

will have a strengthening effect on the Green Belt boundary ensuring its permanence and

defensibility into the future beyond the plan period. The Council has recently concluded that

the existing boundary is considered to be irregular and inconsistent with the existing built

form and that if the site were to be allocated then:

17.24. “The newly formed defined boundary would be a densely vegetated dismantled railway corridor to the

south of the site and is considered to be strongly defined, recognisable and likely to be permanent.

The resultant Green Belt boundary would result in a rounding of the existing built form and concluded

as being a strong and defensible boundary”.

17.25. Alverley Lane, Balby is a site which can demonstrate failure to perform all of the five Green

Belt functions and as such is a justified release from greenbelt that will provide both an

excellent opportunity to meet housing need but also strengthen the Green Belt boundary into

the future

Achievable

17.26. A range of technical work has been undertaken and further survey work is ongoing. From

the initial assessments there are no technical issues that would prevent development or are

insurmountable. The site is therefore considered to be achievable and therefore deliverable

in accordance with national guidance. The technical assessments are summarised within the

accompanying Advocacy Report and are available and can be submitted upon request.


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17.27. The indicative masterplan shows how a mix of housing can be accommodated within the site,

alongside connectivity, landscaping and drainage features. The site has interest from

Persimmon Homes and Ongo Homes (Registered Provider).

Efficient Use of Land

17.28. Although the site is greenfield, the proposed scheme will utilise and enhance existing

infrastructure. Although the site is not previously developed it is currently under-utilised.

The site is easily accessible and the proposed main access is off Alverley Lane. The scheme is

therefore making an efficient and effective use of land and infrastructure.

Delivering a Flexible Supply of Housing

17.29. The Framework requires Local Planning Authorities to meet their full objectively assessed

housing need. Metroland considers that the site at Alverley Lane, Balby is deliverable in the

short term and will reinforce the housing supply and address the Borough’s housing needs in

the early periods of the Local Plan. The site is fully capable of being delivered in the next 5

years and there is interest from housebuilders for the site.

A Positive Response to the Key Objectives of the Framework

17.30. Framework sets out that the Governments key housing policy goal of boosting significantly

the supply of housing and proactively driving and supporting sustainable economic

development to deliver homes, business and industrial units, infrastructure and thriving local

places that the country needs. The Framework explains that the supply of new homes can

sometimes be best achieved through planning for larger scale development, such as extensions

to towns, and creating mixed and sustainable communities with good access to jobs, key

services and infrastructure. Sites should also make effective use of land and existing

infrastructure.

17.31. In relation to the Framework:

• The proposal responds positively towards national guidance.

• The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.

• The proposed site is accessible to existing local community facilities, infrastructure and services, including public transport.


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• The site has been assessed and is available, suitable and achievable for development.

Benefits

17.32. The development of the site would provide significant benefits. The site would provide

housing that would meet the needs of the Doncaster housing market. Therefore this site

provides a unique opportunity in a sustainable location and without compromising the Green

Belt function and purpose.

17.33. In accordance with the Framework this representation has shown that:

• The site is suitable for housing and can deliver circa 220 new homes.

• The proposal will deliver high quality housing.

• The proposal will deliver affordable housing.

• The proposal can provide a good mix of housing commensurate to the demand

and need in the area.

• The scheme uses land efficiently and effectively.

• The proposal is in line with planning for housing objectives.

• The site is within a sustainable location situated in close proximity to facilities

and services and also to bus stops for local bus routes.

• The proposal will deliver public open space.

• The scheme represents an opportunity to achieve gains for biodiversity through

environmental and ecological enhancement.

• The scheme will create direct and indirect job opportunities both during and

after construction.




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17.35. The proposed allocation policy should therefore be flexible to reflect this evidence base and

ensure delivery of the scheme. The site is available, suitable and achievable and therefore

deliverable in accordance with the Framework.

From: Spawforths on behalf of Metroland 30 …...1. Introduction 1.1. Spawforths have been...

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