Addendum to the Publication Plan Sustainability Report...plan policies including development requirements for the proposed site allocations. Proposed Amendments 1.2.5 Consultation

Doncaster Council

Sustainability Appraisal of the Local Plan

Addendum to the Publication Plan Sustainability Report

Wood Environment & Infrastructure Solutions UK Limited – March 2020

2 © Wood Environment & Infrastructure Solutions UK Limited

March 2020 Doc Ref. L38404

Report for Jonathan Clarke Principal Local Plan Delivery Officer Doncaster Council Civic Office Waterdale Doncaster DN1 3BU

Main contributors Robert Deanwood Pete Davis

Issued by ................................................................................. Robert Deanwood

Approved by ................................................................................. Pete Davis

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Document revisions No. Details Date

1 Draft Report for Comment February 2020

2 Final Report for Issue March 2020



Contents

1. Introduction 5

1.1 Overview 5 1.2 The Doncaster Local Plan 5

The Submission Local Plan 5 Proposed Amendments 6

1.3 Sustainability Appraisal 6 The Requirement for Sustainability Appraisal 6 The SA Process To-date 7

1.4 This Report 8

2. SA Approach 9

2.1 Introduction 9 2.2 Determining the Significance of the Changes 9

Assessment of secondary, cumulative and synergistic effects 10 2.3 Difficulties Encountered in Undertaking the Appraisal 10

3. Appraisal of Changes 13

3.1 Introduction 13 3.2 Screening Outcomes 13 3.3 Summary of Representations on the Appraisal of Reasonable Alternatives 14

Publication Local Plan Representations on Reasonable Alternatives 14 Appraisal of Reasonable Alternatives 16 Commentary on Policy 3: The Indicative and Proposed Distribution of Housing 18

3.4 Summary of Representations on Site Scoring and Responses (see also Appendix B) 19 3.5 Appraisal of Cumulative Effects 24

Cumulative Effects Arising from the Publication Local Plan 24 Cumulative Effects Arising from other Plans and Programmes 24

3.6 Mitigation and Enhancement 25

4. Conclusions, Monitoring and Next Steps 27

4.1 Conclusions 27 4.2 Next Steps 27 4.3 Monitoring and Implementation 27

Table 3.1 Screening of Proposed Plan Amendments and their Significance for SA (see also Appendix A) 13 Table 3.2 Summary Representations on the August 2019 SA Report Related to Reasonable Alternatives (see also Appendix B) 15 Table 3.3 Indicative and Proposed Distribution of Homes by Settlement 17 Table 3.4 Assessment of Significance of Site Scoring Challenges and Proposed Changes 20 Table 3.5 Proposed Amendments to Site SA Scores 23



Appendix A Schedule of Suggested Changes to the Publication Local Plan Appendix B Schedule of Representations on the Sustainability Appraisal and Response Appendix C Update to Appendix J of the Publication Local Plan - Appraisal of Policies Appendix D Update to Appendix I of the Publication Local Plan - Appraisal of Options for Housing and Employment

Growth (updated text in red)



1. Introduction

1.1 Overview 1.1.1 Doncaster Metropolitan Borough Council (the Council) is currently preparing a new Local Plan for

its administrative area. The new Local Plan will set out the vision, spatial principles, planning policies and site allocations that will guide development in the local authority area in the period up to 2035.

1.1.2 The Council published the Doncaster Local Plan: Publication Document (hereafter referred to as the Publication Local Plan) for public consultation between 12th August 2019 and 30th September 2019 in accordance with Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 20121. Wood Environment and Infrastructure UK Ltd (Wood) was commissioned by the Council to undertake a Sustainability Appraisal (SA) of the Local Plan in order to assess the environmental, social and economic effects of the Local Plan (and any reasonable alternatives), help to inform its development and identify opportunities to improve the contribution of the Local Plan to sustainable development. A SA Report2 presenting the findings of this assessment was published alongside the Publication Local Plan for consultation (hereafter referred to as the ‘August 2019 SA Report’).

1.1.3 Having considered the representations received, various suggested changes to the content of the Publication Local Plan have been proposed (see Appendix A which contains the Schedule of the Suggested Changes which the Council considered as being major in nature). These suggested changes, along with the responses received, are being submitting alongside the Publication Local Plan (June 2019) to the Planning Inspectorate for independent examination. Other minor typographical changes have also been identified by the Council in a separate schedule and, by their very nature (typos, grammatical changes etc) are minor and will have no implications in respect to SA.

1.1.4 This document is an Addendum to the August 2019 SA Report and has been prepared in order to take account of, and appraise, the suggested changes to the Publication Local Plan. It identifies, describes and evaluates the likely significant environmental, social and economic effects of the suggested changes to the Publication Local Pan, identifies measures to address any negative effects, aiding the plan’s contribution to sustainable development.

1.2 The Doncaster Local Plan

The Publication Local Plan 1.2.1 The Doncaster Local Plan will set out how much new development will be delivered across the

Borough in the period up to 2035 and where this growth will be located. It will also contain planning policies and site allocations.

1.2.2 The first stage in the development of the Local Plan was the publication of the Issues and Options Consultation Document that was consulted on between July and September 2015. The Issues and Options Consultation Document set out, and sought views on, the planning issues that face Doncaster over the next 15 years and options for the way they could be addressed in terms of the amount and broad location of future development across the Borough. Following consideration of

1 HM Government (2012) The Town and Country Planning (Local Planning) (England) Regulations 2012. Available from http://www.legislation.gov.uk/uksi/2012/767/pdfs/uksi_20120767_en.pdf 2 Wood (2019) Doncaster Local Plan Publication Sustainability Appraisal Report



the comments received as part of that consultation, ongoing engagement and further evidence base work, the Council selected its preferred options for the Local Plan in terms of the amount and location of growth to be delivered in the plan area up to 2035 and which formed the Draft Policies and Proposed Sites Document.

1.2.3 The Draft Policies and Proposed Sites Document was published for consultation between 13th September and 26th October 2018 and included the draft Local Plan Strategic Priorities, Vision and Spatial Principles, development requirements and Spatial Strategy, proposed site allocations and plan policies.

1.2.4 The Draft Policies and Proposed Sites Document was subsequently revised to reflect representations received during consultation, new evidence and the recommendations of its accompanying SA and in August 2019 the Publication Local Plan was published for consultation. The Publication Local Plan includes the following key parts: Local Plan Strategic Priorities, reflected in the Vision and Spatial Principles; the overarching Local Plan strategy in terms of the amount of new development to be

accommodated (development requirements) and where it will be accommodated (the Spatial Strategy);

proposed site allocations to deliver the development requirements according to the spatial strategy; and

plan policies including development requirements for the proposed site allocations.

Proposed Amendments 1.2.5 Consultation on the Publication Local Plan ended on 30th September 2019. Following consultation,

the Council has produced a Schedule of Suggested Changes comprising proposed amendments to the Publication Local Plan. The Schedule is set out in Appendix A of this report and includes clarifications to policies and textual changes to ensure consistency throughout the Local Plan as well to address some of the comments received from the Representations.

1.3 Sustainability Appraisal

The Requirement for Sustainability Appraisal 1.3.1 Under Section 19(5) of the Planning and Compulsory Purchase Act 2004, the Council is required to

carry out a SA of the Local Plan to help guide the selection and development of policies and proposals in terms of their potential social, environmental and economic effects. In undertaking this requirement, local planning authorities must also incorporate the requirements of European Union Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment, referred to as the Strategic Environmental Assessment (SEA) Directive, and its transposing regulations the Environmental Assessment of Plans and Programmes Regulations 2004 (statutory instrument 2004 No. 1633) (the SEA Regulations).

1.3.2 The SEA Directive and transposing regulations seek to provide a high level of protection of the environment by integrating environmental considerations into the process of preparing certain plans and programmes. The aim of the SEA Directive is “to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development, by ensuing that, in accordance with this Directive, an environmental assessment is carried out of certain plans and programmes which are likely to have significant effects on the environment.”



1.3.3 At paragraph 16, the National Planning Policy Framework (NPPF) (2019)3 sets out that local plans are key to delivering sustainable development and that they must be prepared with the objective of contributing to the achievement of sustainable development. In this context, paragraph 32 reiterates the requirement for SA/SEA as it relates to local plan preparation: “Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed relevant economic, social and environmental objectives (including opportunities for net gains).”

1.3.4 Planning Practice Guidance (PPG) (2019)4 also makes clear that SA plays an important role in demonstrating that a local plan reflects sustainability objectives and has considered reasonable alternatives. In this regard, SA will help to ensure that a local plan is “justified”, a key test of soundness that concerns the extent to which the plan is the most appropriate strategy, when considered against the reasonable alternatives and available and proportionate evidence5.

The SA Process To-date 1.3.5 SA has been an integral part of the preparation of the draft Local Plan with each stage of the Plan’s

development having been accompanied by a SA, as follows: Issues and Options (with a SA of Growth Options completed in July 2015 and an SA of the

Revised Growth Options completed in March 2016). Draft Policies and Proposed Sites Document, published for consultation between 13th

September and 26th October 2018. Publication Local Plan.

1.3.6 The SA of the Publication Local Plan was undertaken in August 2019. The SA Report was prepared to meet the reporting requirements of the SEA Directive and assessed the following key components of the document: Local Plan Vision and Spatial Principles; the quantum of growth to be provided over the plan period (development requirements) and

distribution of that growth (Spatial Strategy); site allocations to deliver the development requirements identified in the Publication Local Plan

(including reasonable alternatives); and Local Plan policies including development requirements for proposed site allocations contained

In the Publication Local Plan. 1.3.7 A schedule of responses received to the August 2019 SA Report is contained at Appendix B to this

Addendum. 1.3.8 To ensure that the Local Plan takes into account sustainability considerations, and to meet the

Council’s responsibilities under the SEA Directive, this report has been prepared to screen and

3 Ministry for Housing, Communities and Local Government (MHCLG) (2019) National Planning Policy Framework – available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/810197/NPPF_Feb_2019_revised.pdf 4 MHCLG (2019) Planning Practice Guidance – available from: https://www.gov.uk/government/collections/planning-practice-guidance 5 The NPPF at para 35(b) says that plans be: “Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence”



where necessary, appraise, the Council’s responses to the Representations received on the Publication Local Plan in order to update the August 2019 SA Report.

1.4 This Report 1.4.1 The following sections of this report:

describe the approach to identifying the changes that are considered significant for the purposes of the SA (Section 2);

set out the approach taken to the assessment of those changes considered to be significant (Section 2);

summarise the findings of the SA of the changes considered to be significant (Section 3); provide an appraisal of the additional reasonable alternative identified (Section 3); and detail the next steps for the SA of the Local Plan (Section 4).

1.4.2 This report should be read in conjunction with the August 2019 SA Report6.

6 Wood (August 2019) Sustainability Report of the Doncaster Publication Local Plan



2. SA Approach

2.1 Introduction 2.1.1 This section outlines the methodology used to screen the Suggested Changes to the Publication

Local Plan and determine whether they are considered significant for the purposes of the SA. It then sets out the SA Framework that has been used to appraise those changes that are considered to be significant. The SA objectives that comprise the appraisal framework, and the approach to site assessment, are consistent with the methodology adopted for the assessment of the Publication Local Plan.

2.2 Determining the Significance of the Changes 2.2.1 The changes have been reviewed to determine whether or not they are significant and the need for

any consequential changes to the previous assessment work. It should be noted that there is no detailed guidance on how to determine significance in this context. The following paragraphs set out the key principles underpinning the screening of changes in the context of the proposed changes made to the Publication Local Plan.

2.2.2 There are a number of changes which make the wording and/or intent of policies clearer. This can be through either clarifications to the wording or the provision of additional information that expands upon the existing text. These are not considered to be significant for the purposes of the assessment, unless they also introduce a new criterion or topic that has not been previously assessed.

2.2.3 The changes to reasoned justification text clarify how policies will be implemented and/or provide justification for them; such changes are not considered to be significant.

2.2.4 Where changes involve the deletion of preferred sites, such changes are not considered to be significant (so the deletion of the site has not been assessed) where these sites are now not considered to be deliverable and/or developable.

2.2.5 Where changes to a policy introduces an additional criterion, a judgement is made as to whether or not the amendment would affect the previous assessment findings and/or should be acknowledged in the assessment. In such instances, significance has been determined on a case-by-case basis and a comment made on whether or not the previous assessment has been amended and which SA objectives are affected.

2.2.6 Based on the principles outlined above, each Suggested Change has been screened in order to determine the significance of the proposed change. Appendix A presents this analysis. The final column of the table contained in this appendix indicates, for each change, whether or not it would require an amendment to the SA and why. The changes that are considered to be significant are summarised in Section 3.2 of this report, together with an indication of why they are considered to be significant. These changes have been assessed against the SA objectives and consequential revisions made to the assessment matrices contained in the August 2019 Report. The relevant appendices of the August 2019 Report are: Appendix I - Appraisal of Options for Housing and Employment Growth; Appendix J – Appraisal of Policies.



2.2.7 Changes to the policy appraisal matrices are presented in Appendix D of this Addendum. Where the score has been amended on a matrix, this is indicated using strikethrough for the previous score and underlining for the revised score.

2.2.8 Various comments have been received on the August 2019 SA Report and these are presented in the schedule of responses contained at Appendix B to this report. Some of the responses have focused on consideration of reasonable alternatives to the Publication Local Plan and these are summarised and addressed in Section 3.3 of this Addendum.

2.2.9 Various challenges to the scoring of sites were made; these challenges, and an assessment of their significance are summarised in Appendix B of this Addendum and discussed in Section 3.5 of this Addendum.

Assessment of secondary, cumulative and synergistic effects 2.2.10 The policies of the Local Plan do not sit in isolation from each other. The policies will work together

to achieve the objectives of the Plan. For this reason, it is important to understand what the combined environmental effects of the policies will be.

2.2.11 The assessment of the proposed Local Plan policies was undertaken by Local Plan chapter in order to determine the cumulative effects of each policy area. In addition, a cumulative effect appraisal was undertaken in order to clearly identify areas where policies work together. This appraisal is contained in the August 2019 SA Report and reviewed in Section 3.6 of this Addendum.

2.3 Difficulties Encountered in Undertaking the Appraisal 2.3.1 The SEA Directive requires the identification of any difficulties (such as technical deficiencies or lack

of knowledge) encountered during the appraisal process. These uncertainties and assumptions are detailed in the appraisal matrices. Those uncertainties and assumptions common across the appraisal are outlined below.

Uncertainties 2.3.2 The precise locations, sites, composition, timing and extent of actual development occurring cannot

be determined and this has on occasion affected the ability of the appraisal team to determine likely effects and/or when the effects could occur. This has been detailed in the individual policy appraisals.

2.3.3 It is uncertain whether or not the transport infrastructure and accessibility improvements that will be brought about by the Local Plan will reach all of those in need.

2.3.4 The extent to which the local plan can deliver safer communities is in part dependent on a number of socio-economic factors outwith the Local Plan and planning process.

2.3.5 The extent to which job creation is locally significant will depend on the type of jobs created (in the context of the local labour market) and the recruitment policies of prospective employers.

2.3.6 The exact scale of waste arisings associated with the Local Plan will be dependent on a number of factors including: the design of new development; waste collection and disposal regimes; and individual behaviour with regard to recycling and reuse.

Assumptions 2.3.7 The quantum and phasing of development will be as set out in the draft Local Plan (any variation

from which will affect the appraisal of effects in short, medium and long term). In some instances,



such as the likely delivery of network improvements, where phasing has not been indicated, the appraisal team has indicated an assumed timeframe.

2.3.8 The assumed levels of housing and economic development are consistent with current needs, and that present challenges in achieving sustained economic recovery have not affected assessment of need (i.e. understated housing need or population growth from inward migration to the Borough). It is assumed that the percentage of affordable housing will be delivered (we do note that there are recent changes in government policy that allow for greater discussion with developers on viability which may lower the overall % figure on any single development).

2.3.9 It is assumed that current energy mix will continue (and associated carbon emissions will be largely similarly to current), although it is noted that against carbon trajectories provided by BEIS this may lead to an overestimate of carbon emissions.

2.3.10 It is assumed that, where appropriate, development proposals would be accompanied by a Flood Risk Assessment (FRA) and that suitable flood alleviation measures would be incorporated into the design of new development where necessary to minimise flood risk.

2.3.11 It is assumed that, as part of policy implementation, there will be mitigation of adverse effects through various mechanisms such as the Infrastructure Delivery Plan, the Community Infrastructure Levy and the Considerate Constructors Scheme. Policy-specific mitigation is considered as part of the detailed appraisal of policies.

2.3.12 There remain a substantial number of uncertainties associated with the policy implications of Brexit in the medium to longer term (one potentially being the ongoing applicability of regulations with cross references to European Directives, such as the SEA regulations). It is assumed that all relevant legislation and regulations will remain in place reflecting the Government’s stated commitments7.

7 For example HM Government (2018) A Green Future: Our 25 Year Plan to Improve the Environment, available at https://www.gov.uk/government/publications/25-year-environment-plan and HM Government guidance https://www.gov.uk/government/publications/upholding-environmental-standards-if-theres-no-brexit-deal/upholding-environmental-standards-if-theres-no-brexit-deal [both accessed August 2019]





3. Appraisal of Changes

3.1 Introduction 3.1.1 As set out in Section 1.3, it is necessary to consider the sustainability effects of the Suggested

Changes to the Publication Local Plan in order to ensure that all the likely significant effects of the Local Plan have been identified, described and evaluated.

3.1.2 This section summarises the appraisal of the Suggested Changes. Section 3.2 details the outcome of the initial screening used to determine the significance of the proposed changes and considers the implications for the appraisal of the Local Plan policies contained in the August 2019 SA Report. Section 3.3 summarises comments received on reasonable alternatives and presents further appraisal. Section 3.4 presents a summary of the representations to the site appraisals and amended scoring. Section 3.5 assesses the implications of the changes for the assessment of cumulative effects and Section 3.6 outlines whether any further mitigation measures are required in addition to those identified in the August 2019 Report.

3.2 Screening Outcomes 3.2.1 There are total of 35 Suggested Changes to the Publication Local Plan. In accordance with the

approach detailed in Section 2.2, each proposed amendment has been screened in order to determine the significance within the context of the SA. Appendix A presents this analysis in full.

3.2.2 Based on the screening exercise, only one change has been identified as Significant for the purposes of the SA and this is set out in Table 3.1. The implications for the August 2019 SA Report are presented after the table.

Table 3.1 Screening of Proposed Plan Amendments and their Significance for SA (see also Appendix A)

Chapter Page No.

Section/ Policy

Number/ Ref

Para Ref

Amendment required

Reason for amendment

Minor/ Major

(DMBC classifica

tion)

Significant for the SA? (Wood

classification)

16 – Spatial Proposals

212 Policy 70 – Unity Regeneration Project

Part D & new criteria G

Part D Criteria 4 & new Part G 4. other uses, including leisure, which will be supported where they lead to the long term conservation of the grade II listed headstocks.

Representation from Historic England - The Grade II Listed Headstocks are the defining feature of this area and their future conservation together with how any future development relates to them are matters which all development in the area needs to

Major Significant - Change SA score from uncertain to positive reflecting reinforcement of the heritage aspect of the Policy. Appendix J appraised the effect of Policy 70 on heritage assets as neutral/uncertain with the following rationale:



Chapter Page No.

Section/ Policy

Number/ Ref

Para Ref

Amendment required

Reason for amendment

Minor/ Major

(DMBC classifica

tion)

Significant for the SA? (Wood

classification)

G) Development of the site should help to secure the long-term conservation of the Grade II Listed headstocks. Detailed Masterplanning should seek to maximise the potential of the headstocks as a focal point for the development and place-shaping.

consider. Policy 70 therefore needs to set out a framework to secure their future and how they will be incorporated into development proposals to maximise place-making.

“The supporting text to Policy 70 includes a requirement for development of the former colliery area to assess the impact on the setting of the former headstocks, which are a grade II listed building. Views from the south of the former colliery site are also of heritage significance. Uncertain effects are identified in terms of the effects of this policy.”

3.2.3 The enhancement of the score in respect of Objective 14 against Policy 70 will require the following

amendment to the text of the SA Report at paragraph 7.1.33: “Policies seek to improve the public realm, which will also contribute towards this objective. On the same basis a number of site specific issues have been identified and are reflected in the Local Plan, for example the supporting text to Policy 70 includes a requirement for development of the former colliery area to assess the impact on the setting of the former headstocks, which are Grade II listed buildings. Views from the south of the former colliery site are also of heritage significance. Uncertain effects are identified in terms of the effects of this policy. The site has been separately assessed as a proposed allocation (Site 418) and the detailed site appraisal provides more information.”

3.3 Summary of Representations on the Appraisal of Reasonable Alternatives

Publication Local Plan Representations on Reasonable Alternatives 3.3.1 Table 3.2 sets out the representations made on the August 2019 SA Report that relate to the

reasonable alternatives considered (the full suite of Representations on the SA Report and the Council’s response to these is set out in Appendix B).



Table 3.2 Summary Representations on the August 2019 SA Report Related to Reasonable Alternatives (see also Appendix B)

Respondent Summary Comment Response

04444, Johnson Mowat on behalf of Strategic Land Group

The actual amount of homes distributed around the borough has not been assessed in the SA, which only considers the target distribution. The options have remained unchanged since the 2015 SA. The level of distribution in the SA does not reflect the actual distribution. Of the 18 settlements in the hierarchy, only 8 are proposing to deliver a level of housing that meets the distribution that is in the SA preferred option 4. It does not assess the target distribution or the actual Local Plan allocation distribution. This is a failing of the SA.

Paragraphs 3.3.4 – 3.3.6 of this Addendum sets out the justification for the indicative and proposed distribution amongst the Borough’s settlements. The indicative range has been assessed (Appendix I) and the overall level of housing delivery remains at the same figure of 920dpa which has consistently been the subject of appraisal. Appendix J of the Publication SA appraises the proposed policies, whilst Appendices H and I appraise the strategic growth options and options for housing and employment growth respectively.

03116, DLP Planning Ltd on behalf of Mr Ian Brealey, Minerals Investments Ltd

Although Brodswoth Quarry has been previously promoted to the Council as a mixed use development, it is not considered as a "reasonable alternative" with the Sustainability Assessment. It has also been subject to a memorandum on the ODPM website setting out that the land owner and Persimmon Homes have previously undertaken consultations with the local community adjoining the site about developing the site as a Millennium Village. There is an appreciation amongst the local population that the redevelopment of the site could have positive impacts on the wider community. The Council's approach to identifying the likely significant effects has not had sufficient regard to the Local Plan evidence base (including its assessment of full objectively assessed housing need). This limits the degree to which the Local Plan's proposals can be shown to have been developed as part of an iterative process, taking account of the appraisal's findings at each stage of preparation as required by Planning Practice Guidance. The Council has not ensured that realistic alternatives are considered for key issues, and that the reasons for choosing them are documented. This is a requirement of legislation for Sustainability Appraisal. Specifically, it is a requirement that all reasonable alternatives tested are realistic and deliverable. This is not the case for the scenarios tested as part of the Council's SA, which in-turn means the SA does not provide an accurate understanding of the potential effects of the selected strategy compared to other reasonable alternatives. There is a summary of the PPG requiring all reasonable alternatives to be assessed and a court case is also mentioned Heard v Broadland [2012] EWHC 344 (Admin)

Case Law states that an alternative is not reasonable if it does not meet the objectives of the Plan, and that is up to evaluative judgement of the local authority to determine the alternatives that should be tested to meet the plan objectives (see commentary and footnote on case law in paragraph 3.3.2 below). The Council has assessed all sites that are capable of contributing towards the plan's vision and objectives and in line with the preferred spatial strategy.

Section 5 of the August 2019 SA Report presents the appraisal of the development and growth options. It includes the reasons for rejection and selection of the preferred options. Section 8 of the August 2019 SA Report presents an appraisal of the options for housing and employment sites and minerals proposals including reasons for selecting and rejecting sites.



Respondent Summary Comment Response including, see paragraphs 53 to 73, where the approach to the process of SA and alternatives are considered. In summary Ouseley J in paragraph 73 states: "the aim of the directive, which may affect which alternatives it is reasonable to select, is more obviously met by, and it is best interpreted as requiring, an equal examination of the alternatives which it is reasonable to select for examination alongside whatever, even at the outset, may be the preferred option. It is part of the purpose of this process to test whether what may start out as preferred should still end up as preferred after a fair and public analysis of what the authority regards as reasonable alternatives?" This approach has not been taken by the Council. Therefore the assessment is flawed in and does not follow the Regulations/the SEA Directive nor case law.

03116, DLP Planning Ltd on behalf of, Mr Ian Brealey, Minerals Investments Ltd

The Sustainability Appraisal fails to consider reasonable alternatives. The SA considers the impact of the following: a. The planned housing allocations to meet the need to 2033 not 2035, b. The planned provision of 889 dpa for the period 2018 to 2033 and not the higher requirement based on meeting future economic growth which would be 1,073 dpa for the period 2015-2032. The reasonable alternatives that the SA has failed to consider are as follows: a. The impact of making housing allocations to meet the need to 2035. b. The impact of making housing allocations to accommodate 1,073 dpa for the period 2015-2032 (or any higher alternative figure to support the demand for job-led growth to 2035).

Paragraph 3.3.8 of this Addendum presents a summary of the SA of the proposed spatial distribution which covers the plan period to 2035. A detailed appraisal of the likely significant effects of providing for a higher figure is presented in Appendix C of this Addendum which sets out an update to Appendix I (Appraisal of Options for Housing and Employment Growth) with an Option of a higher housing growth figure of 1,073.

Appraisal of Reasonable Alternatives 3.3.2 Comments on the August 2019 SA Report suggested that there should be additional appraisals of

reasonable alternatives8 as follows:

8 Case Law (paragraphs 40 and 41, The Queen on the Application of Rlt Built Environment Limited v The Cornwall Council v St Ives Town Council, [2016] EWHC 2817 (Admin), 2016 WL 06581737) has determined that an alternative is not reasonable if it does not meet the objectives of the Plan and that is, it is up to the evaluative judgement of the local authority to determine what should be tested to meet the plan objectives.

(iv) “Reasonable alternatives” does not include all possible alternatives: the use of the word “reasonable” clearly and necessarily imports an evaluative judgment as to which alternatives should be included. That evaluation is a matter primarily for the decision-making authority, subject to challenge only on conventional public law grounds. (v) Article 5(1) refers to “reasonable alternatives taking into account the objectives… of the plan or programme …” (emphasis added). “Reasonableness” in this context is informed by the objectives sought to be achieved. An option which does not achieve the objectives, even if it can properly be called an “alternative” to the preferred plan, is not a “reasonable alternative”. An option which will, or sensibly may, achieve the objectives is a



a) The impact of making housing allocations to meet the need to 2035.

b) The impact of making housing allocations to accommodate 1,073dpa for the period 2015‐2032 (or any higher alternative figure to support the demand for job‐led growth to 2035).

3.3.3 In respect of point a), the August 2019 SA Report at Appendix H presents an appraisal of four

spatial options for meeting the need for the Borough’s housing to 2035, that is: Option 1 - the Core Strategy approach: business-as-usual; Option 2 - Doncaster and main towns focus; Option 3 - a more dispersed strategy; Option 4 - hybrid approach.

3.3.4 The preferred spatial strategy approach of the Local Plan is a so-called ‘hybrid approach’ which proposes urban concentration and dispersal as a means of allocating growth. In practice this means a focus on the main urban area (Doncaster) and the main towns (Dunscroft, Dunsville, Hatfield, Stainforth, Thorne and Moorends, Mexborough, Conisbrough and Denaby, Armthorpe and Rossington). Slightly more than 90% of the Borough’s housing growth is proposed in these locations, which have the most capacity to accommodate development. In addition, it proposes modest housing growth (up to 10%) in ten other service towns and villages (e.g. Bawtry and Tickhill) so as to extend the approach of meeting housing needs locally within different parts of the Borough.

3.3.5 The indicative and proposed distribution of homes is sets out in Table 3.3 below.

Table 3.3 Indicative and Proposed Distribution of Homes by Settlement

Settlement Indicative Distribution of Homes (Policy 3)

Proposed Distribution (15,871 homes)

Doncaster Main Urban Area At least 50% of Borough’s Total 7,361 (46.4%) Doncaster 6,805 – 7,315 7,361

Main Towns About 40% of Borough’s Total 6,171 (38.9%) Dunscroft, Dunsville, Hatfield, Stainforth 575 – 1,085 1,860

Thorne and Moorends 510 – 1,020 723 Mexborough 475 – 985 310

Conisbrough and Denaby 465 – 975 528 Armthorpe 420 – 990 1,049 Rossington 285 – 895 1,219

Adwick and Woodlands 255 – 765 482 Service Towns and Larger Villages About 10% of Borough’s Total 2,339 (14.7%)

“reasonable alternative”. The SEA Directive admits to the possibility of there being no such alternatives in a particular case: if only one option is assessed as meeting the objectives, there will be no “reasonable alternatives” to it. (vi) The question of whether an option will achieve the objectives is also essentially a matter for the evaluative judgment of the authority, subject of course to challenge on conventional public law grounds. If the authority rationally determines that a particular option will not meet the objectives, that option is not a reasonable alternative and it does not have to be included in the SEA Report or process.”



Settlement Indicative Distribution of Homes (Policy 3)

Proposed Distribution (15,871 homes)

Carcroft - Skellow 250 307 Edlington 230 622

Tickhill 165 74 Askern 165 691

Auckley – Hayfield Green 125 255 Bawtry 110 90

Barnby Dun 105 104 Sprotbrough 95 80

Barnburgh - Harlington 60 66 Finningley 55 50

Commentary on Policy 3: The Indicative and Proposed Distribution of Housing 3.3.6 In terms of housing, Policy 3 sets out the settlement targets in line with the plan period

requirement and the proposed distribution; in the case of the Main Urban Area and Main Towns, this is expressed as a range and linked to the economic-growth-led component of the Objectively Assessed Need: Allocations have been identified in line with the ranges (or the single local housing need

settlement figure in the case of the Service Towns/Villages) where sustainable and deliverable/developable sites have been identified through the site selection process.

However, not all settlements have managed to meet their target (Mexborough being the prime example, but also Tickhill) which is due to the fact that sites cannot be found e.g. Mexborough’s housing options are ruled out due to HS2 safeguarded route to the east and the site to the west is a very sensitive Green Belt site in the Borough due to it merging Mexborough with Swinton (Rotherham MBC) based on the Green Belt Review.

A few settlements are just short of their target (e.g. Sprotbrough, Bawtry) but to make good the difference would require allocation of large Green Belt sites due to the lack of choice and there are no exceptional circumstances to justify for a handful of dwellings in the context of other sources of supply e.g. windfalls, permissions on sites 1-4 units which are not being allocated.

Settlements, such as Askern and Edlington, which have an allocation far higher than the requirement is due to the supply of extant permissions. The supply from such settlements has been capped at the target so that the excess in these locations does not take away from the target for other settlements.

Where there is a shortfall against the settlement’s target, this has been made good through sufficient allocations at the Main Urban Area and Main Towns as per the approach consulted on in the 2016 Homes & Settlements consultation.

Likewise, the leftover baseline housing that is not being allocated at the 40 Defined Villages for sustainability/settlement strategy reasons has been added to the economic growth requirement and redirected to the Main Urban Area/Main Towns as part of the calculations.

3.3.7 In support of the approach taken to the appraisal of the 920dpa housing provision figure, the Sustainability Appraisal Report (p.56) states that:



5.3.5 The Council, in line with the Sheffield City Region, has aspirations for economic growth. The Sheffield City Region SEP Refresh, whilst not setting new housing targets for the city region (thus reverting to the previously published 7,000 dpa), does set a target for jobs growth of 1% per annum. The city region does not connect jobs and housing targets – the former being based on a general aspiration to improve life chances of local people, and the latter on demographic modelling. However, in order to provide an overall housing target, the ‘Economic Forecasts and Housing Needs Assessment’ (2018) does reconsider the Doncaster housing target, based on the updated Sheffield City Region job target. It has been calculated that if the housing target follows the standard methodology method (as per the NPPF) and is based on the aspirations of the emerging Sheffield City Region jobs target (1% uplift), then the housing target for Doncaster is 912dpa. This is very similar to the local plan’s objectively assessed housing need target of 920 dpa, as identified through the earlier Housing Needs Assessment (2015), which has been subject to consultation previously. Given this, the local plan is proposing to retain the 920 dpa target and hence Option 1 is the Council’s preferred option.

3.3.8 In terms of employment land requirement, the figure has increased to 481ha as the Publication version of the plan had to extend the plan period by 3 years (was 2032, now 2035) to align with revisions to NPPF in 2018 that requires 15 years from adoption. In order to address this change and the assertion that a higher, jobs-led housing target of 1,073dpa should be appraised, Appendix I of the SA Report (Appraisal of Options for Housing and Employment Growth) has been updated (see Appendix D of this Addendum). The appraisal in Appendix D demonstrates that the likely effects will be similar to Option 1 (920dpa and 481 ha of employment land) but with greater uncertainty in respect of the jobs-led delivery of housing, placing potential strain on community identity (Objective 1), the delivery of affordable housing (Objective 5), effects on social exclusion (Objective 6) and health and well-being (Objective 9) through access to services, and access to education and training (Objective 10).

3.4 Summary of Representations on Site Scoring and Responses (see also Appendix B)

3.4.1 Table 3.4 summarises the responses to representations made on site scoring, assessing their significance and whether changes to the site scores need to be made. A total of five changes are proposed, in relation to the following sites: Site 160 Objective 12Ai Biodiversity - revised from a single negative (- light red) to neutral (0

amber) Site 160 Objective 12Bi Landscape Capacity – revised from a single negative (- light red) to

neutral (0 amber) Site 160 Objective 14Ai Minerals sterilisation – revised from uncertain (? blue) to positive (+

light green) Site 160 Objective 14Aii Best & Most Versatile Agricultural Land – revised from a single

negative (- light red) to neutral (0 amber) Site 446 Objective 14Aii Best & Most Versatile Agricultural Land – revised from uncertain (?

blue) to positive (+ light green) 3.4.2 Table 3.5 presents the graphic summary of these changes to the scoring.



Table 3.4 Assessment of Significance of Site Scoring Challenges and Proposed Changes

Represen-tation Reference, Name

DMBC/Wood Response Significance for the SA/Action

04955 & 04956

Barton Wilmore on behalf of Barratt & David Wilson Homes Ltd

The SA criteria were subject to previous consultation where changes were made to address the responses where appropriate. Sites have been assessed consistently and primarily using objective criteria. SA guidance and best practice seeks to avoid using mathematical or numerical scoring approaches to such matters. The site selection methodology sets out why sites have been supported/rejected which in this case is largely based on the findings of the Green Belt review alongside consideration of other sites/housing supply towards the settlement's plan period target as opposed to the findings of the SA stage.

As per the above, the Council has purposefully not used a numerical scoring approach so dispute that the Council claims that there are cumulative scores for these, or any sites, in the borough. The Representation has calculated these and not the Council therefore.

Objective 3Ai - proximity to train station - all of the sites in Bawtry perform the same for this criteria as the nearest rail station is Doncaster Town Centre which is a considerable distance from Bawtry (circa 12 miles). It does not state 'within' 1200m but 'over' 1200m which is the score for the majority of the Borough's sites. As such, changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores. The single negative (- light red) score is justified and consistent with the SA methodology.

Objective 3Aii - the entire site is within the 400m-800m buffer for access to bus stops which provides for a score of neutral (0 amber). The score is justified and consistent with the SA methodology. Changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 3Aiii - the site is well beyond the 100m buffer for access to cycle network. The neutral (0 amber) score is justified and consistent with the methodology. Changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 3Bi - the site is mainly in the 400m-800m buffer (with an area that is in the over 800m buffer). The neural (0 amber) score is justified and consistent with the methodology. Changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 3Bii - access to primary school. Some of the site is within the 400m-800m buffer, with the majority being in the 800m+ buffer. The neutral (0 amber) score id justified and consistent with the methodology. Changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 3Biii - access to secondary school. All of the sites in Bawtry are identified as being 2km+ away from a secondary school due to the settlement not having such as facility. The single negative (- light red) score id justified and consistent with the methodology. Changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 3Biv - access to GP. The methodology has been applied consistently. Changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 5Di - Housing Market Failure - the Representation is not clear how/why a Greenfield/Green Belt site which would form an extension to Bawtry (not an area identified previously as being subject to policy interventions in the housing market) should be treated the same as a brownfield/cleared housing market renewal site in towns such as Edlington, Mexborough etc. The criteria is justified and has been applied consistently. None of the sites in Bawtry are identified as performing positively against this criteria. Changes to the methodology would lead to all sites performing better/the same.

Objective 8Aiii - Landfill sites - the neutral scoring (0 amber) is justified and has been applied consistently. Changes to the methodology would lead to all sites performing better/the same.

8Bi - Highways Capacity - The scoring has been based on work undertaken for the Council by Highways England. It is considered that a site which has no significant impact on the SRN rightly performs better (+) than a site which is identified as having an impact, even where mitigation is committed. The score (neutral (0) amber) is justified and has been applied consistently.

Not significant – no changes required.





Objective 8Biii - Primary school capacity - sites have been assessed by colleagues in the Council's School Places Admissions Team using a standard methodology and is justified and consistent. Changes to the methodology would lead to all sites performing better/the same.

Objective 8Biv - Secondary school capacity - see response above to primary school capacity.

Objective 9Ai - Access to POS - the score is justified and has been consistently applied. All sites have the ability to provide new POS as part of the development, and/or make a commuted sum to existing open space. Changes to the methodology would lead to all sites performing better/the same.

Objective 12Ai - Biodiversity - The criteria was put forward by Natural England following the consultation on the SA criteria and has been applied consistently and is justified. Changes to the methodology would lead to all sites performing better/the same.

Objective 12Bi - Landscape Capacity - The site has been assessed in line with the methodology and is consistent/justified. Changes to the methodology would lead to all sites performing better/the same.

Objective 13Ai & 13Bi - Heritage Impacts & Archaeology - The site has been assessed in line with the methodology and is consistent/justified. Changes to the methodology would lead to all sites performing better/the same.

Objective 14 - The site has been assessed in line with the methodology and is consistent/justified. Changes to the methodology would lead to all sites performing better/the same.

Overall conclusion - as set out above, the criteria have all been subject to consultation and changes made to address responses prior to being used for site assessment. Changes to the SA scoring would have to be applied consistently to all sites in Bawtry (and indeed the borough). The Representation fails to appreciate that such changes become relative therefore as other sites in the town also perform stronger. Disagree that the rejected site performs better than other allocations at the town, whether based on the current scoring or if accepting the Representation’s revisions to the methodology.

05190

Carter Jonas on behalf of Harworth Group

Site 160

Objective 11Ai - Flooding from Main Rivers - Sites have been assessed consistently using the EA Flood Map for Planning which shows the vast majority of the site to be flood zone 3.

Objective 11Aiii - Benefiting from Existing Defences - as the methodology makes clear, the sites have been assessed suing the EA's areas benefitting from existing defences map and not based on site-specific flood risk assessments so sites have been assessed consistently and the score is justified. The Council is aware of the site-specific appraisal work that has been undertaken but contend site options should be assessed using objective appraisal criteria wherever possible.

Accessibility criteria - welcome that the Representation comes to the same conclusion on how the site has performed against these criteria. Bus service - the methodology makes clear that it looks at high-frequency bus network which is provided by SYPTE and an hourly service is not classed as being high-frequency. Scope for improvements/increased patronage is noted but would be true of all employment site options thus the improved score is relative as all sites would perform more strongly.

8Bi - Highways Capacity - The scoring has been based on work undertaken for the Council by Highways England - see SA Technical Appendices for the details. It is noted that the Representation is not challenging the SA finding, rather confirming that any issues can be overcome.


Objective 12Ai - Biodiversity - The criteria has been revised from a single negative (- light red) to neutral (0 amber) to reflect the Representation and that the survey undertaken as part of a previous application concluded the site is located outside all sites and buffers. Amending to a neutral rather than a positive is consistent with other sites where scores have been amended to reflect site-specific material - see table of amendments to SA baseline.

Not significant – however, changes to the following SA scoring:

12Ai Biodiversity - revised from a single negative (- light red) to neutral (0 amber)

12Bi Landscape Capacity – revised from a single negative (- light red) to neutral (0 amber)

14Ai Minerals sterilisation – revised from uncertain (? blue) to positive (+ light green)

14Aii Best & Most Versatile Agricultural Land - revised from a single negative (- light red) to neutral (0 amber)





Objective 12Bi - Landscape Capacity - Note that the site promoter's own study identifies an alternative conclusion so proposed to make amendment to the SA baseline to reflect - see schedule of amendments to SA baseline for details.

Objective 14Ai - Minerals sterilisation - Note that the site promoter has undertaken an assessment and shown that the deposits are not viable for extraction so agree to revised SA score - see schedule of amendments to SA baseline for details.

Objective 14A(ii) Avoidance of Best & Most Versatile Agricultural Land - Note that the site promoter has undertaken an onsite survey that demonstrates that the site is mainly 3b. Agree to revise SA scoring - see schedule of amendments to SA baseline for details.

05197

Peacock & Smith on behalf of Blue Anchor Leisure Ltd

Objective 3A(ii) - Distance to Bus Stop - The correspondence from First Bus was taken into account when submitted as part of the 2018 consultation. However, all sites have the potential to improve public transport accessibility through develop contributions etc so such material has not been used to revise SA scoring as set out in the methodology. No change required, the site is currently located 800m+ from the high frequency bus network.

Objective 8A(i) - Reuse of Land & Buildings - The vast majority of the site is greenfield and the current neutral scoring is considered appropriate and justified. Buildings associated with farming uses are still classed as being Greenfield.

Objective 13B(i) - Archaeology - sites have been independently assessed by consultants and the findings are considered justified and consistent.


05197


Objective 3Aii - Access to high frequency bus service - the SA methodology for this criteria is clear that it is based on SYPTE’s high frequency bus network (actual bus stops shown in GIS) from which sites have been assessed using straight line as the crow flies distances using the closest site boundary. Part of the site is within the 400m buffer of the bus stops on Dryden Rd/ Weston Rd, Balby and hence the positive (+ green) score


05197


Objective 3Aii - Access to high frequency bus service - the SA methodology for this criteria is clear that it is based on SYPTE’s high frequency bus network (actual bus stops shown in GIS) from which sites have been assessed using straight line as the crow flies distances using the closest site boundary. Part of the site is within the 400m buffer of the bus stops on Askern Rd, Toll Bar and hence the positive (+ green) score


05197


Objective 3A(i) Access to Train Station - The methodology is clear that distances are as the crow flies and based on the closest site boundary and has been applied consistently. The methodology does not make any judgements in respect to services. A large part of the site boundary is in the 800m-1.2km buffer so the neutral scoring is appropriate.


05197



Objective 3B(ii) Distance to Bus Stops - note the Representation agrees with the SA scoring for this criteria. In line with the response above, scores have not been revised to take into account possible improvements that may come about from developer contributions.

Overall conclusions on SA scoring are noted. The Site Selection Methodology and Results report sets out reasons for why sites have been supported/ rejected which includes a number of considerations as well as the SA process.


05286

Walker Morris LLP on behalf of Mr Oliver Lund

Agree the land is not agricultural land now, but disagree the site is Greenfield so reject any revisions to the SA scoring for Objective 8A(i) Encourage the re-use of land and buildings, but propose to revise the scoring to Objective 14A(ii) Avoidance of Best & Most Versatile Agricultural Land through the Addendum.

Not significant – however, amend scoring for Objective 14A(ii) Best & Most Versatile Agricultural Land – revised from





uncertain (? blue) to positive (+ light green

05286


The SA criteria are considered to reflect BF land sufficiently and it is noted that Representations to the Local Plan Publication version cite that there is too much weight/priority to BF land over GF which they claim is not in conformity with NPPF. Notwithstanding this, see response above that the Council disputes that the site is Brownfield anyway.


05286


Objective 3B(i) - Access to Existing Centre - the site is located partly in the 400m-800m buffer and partly in the 800m+ buffer from the Neighbourhood Shopping Parade at Auckley so the current score (neutral 0 amber) is correct and justified/consistent.

Objective 3B(ii) - Access to Primary School - the site is located entirely in the 400m-800m buffer for primary schools at both Auckley (Auckley School) and Hayfield Green (Hayfield Lane Primary) so the current score (neutral 0 amber) is correct and justified/consistent.

Sites have been assessed using primarily objective criteria and supporting evidence has been published (both 2018 consultation and at Publication stage) to support the findings e.g. the interactive SA map and supporting technical appendices.


01937

Lichfields on behalf of Theakston Estates

The revised capacity is noted, however it is not considered that the revision down from an estimated 969 to 800 homes would change the way the site performs through the SA. This is because the criteria that use a site threshold to determine how a site scores use thresholds much lower than the 969 or 800 units (e.g. affordability and re-use of land and buildings use a much lower 100 units). The previous representations rebuttal to archaeology and surface water pollution was considered prior to the Publication version of the SA report being prepared. The Publication SA Report (and Site Selection Report) confirms that the site's score for Objective 14B(ii) Pollution to Surface Water Bodies was changed from significant negative effects (--) to neutral (0) and states the reason being that the site promoter has confirmed that the only water body identified is on the southern field which is to be excluded from the development so the developed area will be located 25m+ from the surface water body. The SA tables in the site selection report also show this updated score for the site.

Likewise, the Council considered the site promoters/ Northern Archaeological Associates Ltd’s report and looking at the masterplan considered it was appropriate to revise Objective 12 B(i) from significant negative effects (--) to neutral effects (0).

Not significant – no changes required

Table 3.5 Proposed Amendments to Site SA Scores

Site Ref & Name

SA Criteria Baseline Score (existing)

Baseline Score (revised)

Justification

160

Thorne South Urban Extension, Bradholme Farm, Thorne

Objective 12Ai - Biodiversity

-

Site within the buffer of a

designated site or would trigger a NE

consultation

0

Site is located outside all sites

and buffers

The criteria has been revised from a single negative (- light red) to neutral (0 amber) to reflect the Representation and that the survey undertaken as part of a previous application concluded the site is located outside all sites and buffers. Amending to a neutral rather than a positive is consistent with other sites where scores have been amended to reflect site-specific material.

160


Objective 12Bi – Landscape Capacity

-

Site located in a broad area

assessed as having 'low to no' landcape

capacity

0

B8 Strategic Distribution site

located in a broad area

assessed as having

‘moderate’

Note that the site promoter's own study identifies an alternative conclusion so proposed to make revision to existing score



Site Ref & Name

SA Criteria Baseline Score (existing)

Baseline Score (revised)

Justification

landscape capacity

160


Objective 14Ai - Minerals sterilisation

?

Sand and/or gravel underlies the site

but not possible to distinguish whether soft sand or sharp sand and gravel

+

Urban site where pre-

extraction is not feasible

regardless of mineral resource or borehole data

is provided showing the site

is soft sand

Note that the site promoter has undertaken an assessment and shown that the deposits are not viable for extraction so agree to revised SA score.

160


Objective 14A(ii) Avoidance of Best & Most Versatile Agricultural Land

-

Site is located on grade 2 agricultural land (or proven to

be grade 3a through site survey)

0

Site is located on grade 5 or 4 agricultural land (or proven to be

grade 3b through site

survey)

Note that the site promoter has undertaken an onsite survey that demonstrates that the site is mainly 3b. Agree to revise SA scoring.

446

Blaxton Quarry Phase 2, Mosham Road, Auckley

Objective 14A(ii) Avoidance of Best & Most Versatile Agricultural Land

?

Site is located on grade 3 agricultural

land and it is not possible to

ascertain whether best or most versatile (3a)

without survey work on site

+

Site is located on urban on

non-agricultural land


3.5 Appraisal of Cumulative Effects

Cumulative Effects Arising from the Publication Local Plan 3.5.1 Sections 7.3 and 8.5 of the August 2019 SA Report present an overall judgement on the cumulative

effects of the proposed policies and site allocations of the Plan. The changes proposed to the policies and the additional appraisal of Policy 3 (Section 3.3) do not affect the findings of the August 2019 SA Report in this regard.

Cumulative Effects Arising from other Plans and Programmes 3.5.2 The policies and proposals contained in the Publication Local Plan sit within the context of a

number of other plans and programmes including the local plans of surrounding local authorities. No significant negative effects were identified, and this conclusion remains valid in light of the changes.



3.6 Mitigation and Enhancement 3.6.1 The appraisal of the Publication Local Plan identified measures to help address potential negative

effects and enhance positive effects associated with the implementation of the Local Plan. These measures are highlighted within the detailed appraisal matrices contained at Appendices H, I & J of the August 2019 SA Report and will be considered by the Council in preparing the final Local Plan. No additional mitigation measures have been identified as a result of the appraisal of the changes.





4. Conclusions, Monitoring and Next Steps

4.1 Conclusions 4.1.1 This Addendum to the August 2019 SA Report has presented the findings of the appraisal of the

Suggested Changes to the Publication Local Plan. The appraisal has confirmed that the conclusions of the SA Report remain valid that: “The preferred option will see housing and employment growth over and above that required to meet local needs, with additional effects associated with the loss of additional greenfield land, consumption of resources and greenhouse gas emissions. There will therefore be additional effects within the Plan area. The Local Plan seeks to mitigate such effects where it can, e.g. by promoting transport choice and optimising the use of previously developed land and buildings. The preferred option could have significant positive effects at the city region scale associated with additional employment growth, re-balancing of the economy and a contribution to wider housing needs.”

4.1.2 No additional significant adverse effects have been identified through the appraisal of the proposed changes to the Plan. The single change identified was found to enhance the policy in question and as such, was not subject to further appraisal. Several were changes to the scores attributed to two sites, none of which amounted to a change in the overall conclusions reached on the merits of the sites.

4.2 Next Steps 4.2.1 The Submission Local Plan will be submitted to the Secretary of State (together with the August

2019 SA Report and this Addendum) and subject to independent Examination.

4.3 Monitoring and Implementation 4.3.1 Appendix E to the August 2019 SA Report identifies a number of potential indicators that could be

used for monitoring the sustainability impacts of the emerging Local Plan. In addition, the Council is intending to resume production of an Authority Monitoring Report (AMR) each year. This report will contain both authority-wide and local level data which could be used to monitor the effects of the Local Plan against a number of the SA objectives. Where appropriate, these indicators have informed the proposed monitoring framework in Appendix E to the August 2019 Report.



A1 © Wood Environment & Infrastructure Solutions UK Limited


Appendix A Schedule of Suggested Changes to the Publication Local Plan



Chapter Page Number

Section/ Policy Number/ Ref

Para Ref Amendment required Reason for amendment Significant for the SA? (Wood classification)

6 – Meeting the Need for New Homes

60 Policy 10 – Houses in Multiple Occupation (HMOs)

Policy 10 – Part D

The existing dwelling or building is capable of conversion without causing harm to the area or the amenity of nearby residents particularly with noise and disturbances or over-looking, and in areas of flood risk do not result in ground-floor or basement level self-contained rooms, and;

Responds to objection raised by Environment Agency to Reg 19 Publication

Not significant

61 Policy 10 – Houses in Multiple Occupation (HMOs) – explanatory text

Para 6.16 This can be best achieved through preventing the over concentration of such properties in particular areas and encouraging a more even distribution across the Borough. Proposals that lead to self-contained rooms at ground floor or basement level in areas at risk of flooding are unlikely to be supported as such accommodation must be able to provide satisfactory mitigation against residual flood risk and there are likely to be challenges around providing a safe point of refuge.


Not significant

7 – Transport, Access & Infrastructure

78 Policy 17 – Cycling in Doncaster

Policy 17 – Part C3

Provide appropriate cycle access and sufficient secure cycle parking facilities in accordance with the latest Council standards, and for new development for employment uses provide changing and showering facilities; and,

Responds to objection raised by CPRE to Reg 19 Publication

Not significant

10 – Green Infrastructure

99 Policy 27 – Green Infrastructure (strategic policy)

Policy 27 – Part A

Third sentence…All mMajor development proposals of 30 family dwellings15 1 hectare or more will be required to provide a GI masterplan demonstrating how the development…:

Clarify that all major residential and non-residential development proposals should contribute to GI

Not significant – technical clarification

103 Policy 28 – Protecting Open Space & Non Designated Open Space

Policy 28 – Part B

Criteria B – new part 6 6. The space does not contribute to the character of a Conservation Area or the setting of a designated heritage asset.

Representation from Historic England -– Many of the Borough’s Conservation Area Appraisals identify open spaces which are considered to make an important contribution to their character. The loss of these areas therefore would result in harm to their historic character and should be reflected in the policy.

Not significant – reinforcement of existing commitments to heritage protection appraised as a positive under Objective 13, Appendix J

105 Policy 29: Open Space Provision in New Developments – explanatory text

10.22 The policy indicates that proposals must address open space needs and deficiencies with developments of 20 family dwellings or more, providing either 10 or 15% of the red line boundary as onsite open space per family dwelling

Clarify policy position Not significant – technical clarification

105 10.22 4th sentence…On larger applications where open space provision will equate to 0.4 hectares or more the amount type of open space to be provided should consider be broken down in to a minimum of 32% on-site open space suitable for children’s play in the first instance with the remainder taking the form of recreational sports fields, woodlands, nature conservation areas, allotments, or green infrastructure corridors, depending on the type of identified need in the area.

Representation from DLP to help clarify policy position

Not significant – technical clarification

105 10.22 last line

Where three or more open space deficiencyies types are identified in the audit, 15% onsite open space provision or commuted sum will be required, otherwise the requirement will equate to 10%.

Clarify policy position Not significant – technical clarification of financial requirements

105 10.25 As with the on-site open space requirements, where three or more open space deficiency types are identified in the green space audit, 15% commuted sum will be required, otherwise the requirement will equate to

Add additional sentence at the end of paragraph 10.25 to clarify the amount of commuted sum required.

Not significant – technical clarification of financial requirements



10% of the value of the red line boundary of the site (with planning permission).

(identified through soundness self-assessment check list)

111 Policy 31 – Valuing Biodiversity & Geodiversity

Part C Proposals that may either directly or indirectly negatively impact Sites of Special Scientific Interest will not normally be supported. Proposals should seek to protect and enhance Sites of Special Scientific interest wherever possible and maintain, strengthen, and bridge gaps to link them to the wider ecological network wherever possible.

Representation from CPRE – changed to reiterate the importance of the ecological network with respect to SSSI’s.

Not significant – reinforcement of existing commitment to the protection of natural resources, appraised as a significant positive under Objective 12, Appendix J

10.40 The use of the mitigation hierarchy will ensure that the most valuable ecological features of a site are protected and harm to biodiversity is minimised. In line with best practice, the provision of compensation to account for residual biodiversity impacts will not be allowed unless the prior steps of the mitigation hierarchy have been followed, and all opportunities to avoid and then minimise negative impacts have first been pursued. Impacts on irreplaceable habitats such as ancient woodland and lowland raised mire will not be supported and cannot be accounted through a Net Gain approach. Using the latest DEFRA biodiversity metric is an effective way of accounting for the impacts of a proposal on biodiversity and demonstrating that a net gain will be delivered. It also provides flexibility and encourages projects to consider biodiversity from the outset. Use of the metric rewards schemes that minimise their impacts but also gives options to developers in terms of whether necessary mitigation is delivered on or off site. A minimum 10% net gain will be expected unless national standards increase this in the future. In order to properly inform applications, surveys will be required in line with the latest British Standard (BS42020 2013 or its replacement). It is expected that compensation will be directed towards projects that contribute to Doncaster’s Nature Recovery Network and other biodiversity and landscape scale conservation priorities. Proposals can sometimes affect land surrounding, or neighbouring, local sites as well as impacting them directly.

Representation from Natural England

Not significant – reinforcement of existing commitment to the protection of natural resources, appraised as a significant positive under Objective 12, Appendix J

116 Policy 34 - Landscape

Paragraph before Criterion F

Where development proposals will most likely result in a significant impact on the Borough’s landscape the proposals should assess the potential impact (including cumulative impact) and propose how any negative effects will be minimised. In doing so consideration should be given to:

Respond to suggestion made by CPRE to Reg 19 Publication

Not significant – reinforcement of existing commitment to landscape protection.

11 – The Historic Environment

126 Policy 38 – Conservation Areas

Part B Amend final sentence to read:

“Proposals that may result in potential harm to a conservation area will be refused unless the harm is outweighed by public benefits arising from the development.”

To improve clarity of policy wording. Not significant – commitment to Conservation Area protection remains.

13 – Health, Well-being & our Communities

151 Policy 55 – Pollution

Opening Paragraph

Development proposals that are likely to cause pollution, or be exposed to pollution, will only be permitted where it can be demonstrated that pollution can be avoided, or where mitigation measures (such as those incorporated into the design and layout of development) will minimise

Responds to concern raised by Mineral Products Association to Reg 19 Publication

Not significant



significantly harmful impacts to acceptable levels that protect health, environmental quality and amenity. When determining planning applications, the agent of change principle will be applied, and particular consideration will be given to:

151 Policy 55 – Pollution

Part D D) any adverse effects on the quantity, quality and ecology features of water bodies and groundwater resources, including contamination to Source Protection Zones.


Not significant – clarification of scope.

152 Policy 55 D) – Pollution – explanatory text

13.22 (new para)

13.22 Groundwater is an important resource that we rely on everyday and provides the majority of drinking water, sustains baseflow and ecology in our rivers, and supports lakes and wetland ecosystems. Contamination in or on land can present unacceptable risks to human health and the wider environment, including to groundwater. Doncaster’s water supply depends on groundwater abstractions in the Principal aquifer which has high permeability and needs to be protected to avoid any kind of contamination. The protection is given by buffer zones around the source of drinking water called Source Protection Zones which are divided into 3 zones (inner, outer, and source catchment protection). The Environment Agency provides further guidance on what activities are possible in these zones – see also Policy 61.


Not significant – the SA includes the presumption that drinking water supplies will be protected through appropriate reference to Environment Agency guidance.

152 Policy 55 E) – Pollution – explanatory test

13.23 (new para) (supporting text to policy 56) becoming 13.24

13.23 The impacts of artificial lighting (light pollution) are comprehensively considered in national guidance and best practice including for example the use of the most up to date ‘Bats and artificial lighting guidance note’. These measures are of particular importance in the areas such as Thorne and Hatfield Moors Special Protection Area’s (SPA).

Responds to request raised by Yorkshire Wildlife Trust to Reg 19 Publication

Not significant – procedural clarification.

152 Policy 56 Contamination & Unstable Land – explanatory text

13.22 National planning policy states that any potentially contaminated or unstable land being assessed for development through the planning process should be dealt with at this stage ensuring that it poses no unacceptable risk to future occupiers or the wider environment. Adequate site investigation information, prepared by a competent person, is required to consider the requirements of Policy 56. Should any proposed site, currently or previously, have been subject to land-use(s) which have the potential to have caused contamination of the underlying soils and groundwater then any planning application must be supported by a Preliminary Risk Assessment to demonstrate that the risks posed to ‘controlled waters’ by any contamination are understood by the applicant and can be safely managed. It is recommended that developers consider using the National Quality Mark Scheme for Land Contamination Management which involves the use of competent persons to ensure that land contamination risks are appropriately managed and refer to the contaminated land pages on GOV.UK for more information.


Not significant – procedural clarification.

14 – Climate Change, Mineral Resources & Energy

159 Policy 59 – Low Carbon & Renewable Energy

Policy 59A – new Part 1 with consequential amends to

A) Proposals will be supported which give priority to: 1. Community energy schemes that are in full or part community ownership; 2. biomass and energy crop schemes especially to the north and south east of the main urban area, for example mixed woodland, single

In response to comments from CPRE

Not significant – ownership is not a matter for the SA.



numbering thereafter

species short rotation forestry and large-scale forestry, outside of areas of high quality arable farmland;

161 Policy 61 – Protecting & Enhancing Doncaster’s Soil & Water Resources

New text for Part E (with existing Part E text becoming Part F)

E) Proposals will be supported which will: 1. make positive progress towards achieving ‘good’ status or potential under the Water Framework Directive in the borough’s surface and ground waterbodies; and, 2. promote water efficiency measures which take account of current water availability (e.g. informed by Catchment Abstraction Management Strategies) and future demand;

Objection from Environment Agency to Reg 19

Not significant – the wording changes reinforce existing policy commitments to the protection of water resources which are appraised as significant positive (Appendix J, Objective 14)

168 Policy 62 – Providing for & Safeguarding Mineral Resources – Table 10

Table 10 From this…

iTo this… (See end note for larger view of tables)

…to make the table of mineral provision clearer in the Local Plan (there are no changes to the numbers / calculations. The new table shows the additional provision from local plan proposals and additional contribution to landbank)ii To address issue identified by East Riding of Yorkshire Council (rep number 0009)

Not significant – details of supply only.

168 Policy 62 – Providing for & Safeguarding Mineral Resources – explanatory text

Para. 14.45

Table 10 identifies the mineral requirements Doncaster can supply during the Local Plan period using the 2018 LAA (and 2017 data). The table below shows a reserve of 5.6Mt (at 2017), plus additional sand and gravel provision from Local Plan allocations (see table 12 later in this document).

Further to changes in Table 10 above additional wording is required in the explanatory text. To address issues identified by East Riding of Yorkshire Council (rep number 0009)


168 Policy 62 – Providing for & Safeguarding Mineral Resources – explanatory text

Notes for Table 10

Notes: 1. The reserve at 2017 is taken from the 2018 LAA, which reports on

minerals monitoring for the year 2017. 2. The landbank of permissions at 2017 is taken from the 2018 LAA. 3. The ‘Local Provision for the plan period is based on ten year

average sales (as required by national planning policy and identified in the 2018 LAA) multiplied the remaining life of the plan (in this case 18 years)

4. The remaining provision is the estimated reserve (what we have now) minus the apportionment for the plan period (what Doncaster can supply).

Further to changes in Table 10 minor amendments are required to the notes text supporting the table To address issue identified by East Riding of Yorkshire Council (rep number 0009)




5. Note - figures are also given based on three year annual sales for comparison (required for consideration by national policy to gauge short term fluctuations,

6. Mt = Million tonnes. 7. Not achievable. Landbank will deplete in 11.2 years, without new

proposals

168 Policy 62 – Providing for & Safeguarding Mineral Resources – additional table explanatory notes

New Table See end note for table detail…

To address issue identified by East Riding of Yorkshire Council (rep number 0009)

Not significant

168 Policy 62 – Providing for & Safeguarding Mineral Resources – explanatory notes

14.46 Figures from the 2018 LAA (see Table 10 above) indicates that the Council may not be able maintain a supply of sand and gravel to meet our provision up to the end of the plan period. At 2017 Based on ten year average extraction levels (of 0.31Mt), the reserve of equals 5.6Mt and the landbank of permissions equates to nearly over 18 years in 2017. Should extraction levels continue at three year average sales (of 0.5Mt), the 5.6Mt reserve will last 11.2 years. Two allocations in the Local Plan (see table 12) will provide for an additional 1.9Mt of sand and gravel during the plan period. The allocations will provide an additional six years of supply, based on ten year average sales or 3.8 years supply based on three year average sales. Doncaster’s Local Provision will equate to 0.42Mt of sharp sand and gravel during the plan period in accordance with the figures in Table 10 and xx. ** Given only …

The text explains and clarifies the changes to table 10 and additional table To address issue identified by East Riding of Yorkshire Council (rep number 0009)

Not significant – details of supply only

169 Policy 62 – Providing for & Safeguarding Mineral Resources – paragraph 14.46

14.48 The 2018 LAA identifies the limestone apportionment for Doncaster is healthy with a 51.7 Mt reserve and a 30 year landbank (based on ten year average sales), or 22 years provision based on three year average sales. Based on historic extraction figures, Doncaster’s Local Provision will equate to 2Mt of crushed rock during the plan period. The Council acknowledges…

The text explains and clarifies the changes to table 10 and additional table xx To address issue identified by East Riding of Yorkshire Council (rep number 0009)


169 Policy 62 – Providing for & Safeguarding Mineral Resources – Explanatory text paragraph 14.48

14.49 … landbank. The new mineral allocations (preferred areas) listed in Table 12 are Doncaster’s best options for increasing contributing towards the landbank of permissions during the plan period. The ‘preferred areas’ will potentially provide 1.9Mt of sand and gravel increasing the land bank by 6 years based on ten year average extraction rates of 0.33Mt or 3.8 years based on the three year average extraction rate of 0.5Mt.

Additional text Identifies quantity of additional sand and gravel to contribute toward landbank of permissions To address issue identified by East Riding of Yorkshire Council (rep number 0009)


15 – Implementation & Monitoring

181 Policy 66 – Developer Contributions (Strategic Policy)

Part A4 New Part A4 as follows: 4. pooled contributions for schemes necessitated as a result of the cumulative impact of a number of developments.

Request from Highways England to reinstate akin to previous wording of the policy and now that limitations on pooling have been lifted

Not significant – financial delivery

16 – Spatial Proposals

196

Policy 68 – Doncaster Town

199 2nd paragraph New and improved pedestrian and cycle links, crossing facilities and greenspaces (including a new urban park and where feasible a

Responds to concern raised by Canal and River Trust to Reg 19 Publication

Not significant – implementation detail



Centre – explanatory text

footbridge over the river Don) will also be created, connecting the waterfront with the rest of the town centre.

212 Policy 70 – Unity Regeneration Project

Part D & new criteria G

Part D Criteria 4 & new Part G 4. other uses, including leisure, which will be supported where they lead to the long term conservation of the grade II listed headstocks. G) Development of the site should help to secure the long-term conservation of the Grade II Listed headstocks. Detailed Masterplanning should seek to maximise the potential of the headstocks as a focal point for the development and place-shaping.

Representation from Historic England - The Grade II Listed Headstocks are the defining feature of this area and their future conservation together with how any future development relates to them are matters which all development in the area needs to consider. Policy 70 therefore needs to set out a framework to secure their future and how they will be incorporated into development proposals to maximise place-making.

Significant - Change SA score from uncertain to positive reflecting reinforcement of the heritage aspect of the Policy. Appendix J appraised the effect of Policy 70 on heritage assets as neutral uncertain with the following rationale: “The supporting text to Policy 70 includes a requirement for development of the former colliery area to assess the impact on the setting of the former headstocks, which are a grade II listed building. Views from the south of the former colliery site are also of heritage significance. Uncertain effects are identified in terms of the effects of this policy.”

225 Main Town _ Rossington – Table H2(G) - Housing Allocations without planning permission (as at April 2018)

Table H2(G)

Rossington Colliery Housing Allocation (Site Ref: 247) – amendment to the boundary of the site to align with the Outline permission site (Ref:662) due to the permission boundary being incorrectly mapped as part of the Development Management process. Consequential changes to the site area and capacity as necessary, including revised site plan for Appendix 2 – developer requirements pg.275 and amendment to Policies Map.

Representation from landowner (Harworth Group) identifies correction required to southern boundary of the permissioned site and therefore the remaining site area/capacity has been understated

Not significant



Appendix 1 – Glossary

251 Policy 65 Glossary text

Conventional Hydrocarbons Reservoir: Delete the previous definition and replace with… A reservoir in which buoyant forces keep hydrocarbons in place below a sealing caprock. Reservoir and fluid characteristics of conventional reservoirs typically permit oil or natural gas to flow readily into wellbores. The term is used to make a distinction from shale and other unconventional reservoirs, in which gas might be distributed throughout the reservoir at the basin scale, and in which buoyant forces or the influence of a water column on the location of hydrocarbons within the reservoir are not significant. (Sourced from the Schlumberger Oilfield Glossary. https://www.glossary.oilfield.slb.com/ )

Amend reference in response to UKOOG / Igas / Ineos comment

Not significant

252 Policy 65 Glossary text

Unconventional Hydrocarbons Resource: Delete the previous definition and replace with… An umbrella term for oil and natural gas that is produced by means that do not meet the criteria for conventional production. What has qualified as unconventional at any particular time is a complex function of resource characteristics, the available exploration and production technologies, the economic environment, and the scale, frequency and duration of production from the resource. Perceptions of these factors inevitably change over time and often differ among users of the term. At present, the term is used in reference to oil and gas resources whose porosity, permeability, fluid trapping mechanism, or other characteristics differ from conventional sandstone and carbonate reservoirs. Coalbed methane, gas hydrates, shale gas, fractured reservoirs, and tight gas sands are considered unconventional resources. (Sourced from the Schlumberger Oilfield Glossary. https://www.glossary.oilfield.slb.com/)

Amend reference in response to UKOOG / Igas comment

Not significant

Appendix 2 – Development Requirements

266 Site 133 – St Nicholas Rd, Thorne

Conservation & Heritage

Conservation & Heritage The site makes an important contribution to the conservation area and the setting of Thorne House (key unlisted building). The contribution of the site to the significance of these heritage assets will need to be

Representation from Historic England – site is an important setting to Conservation Area and

Not significant



Requirements

assessed in a heritage statement where it should also be demonstrated that 24 units would not result in harm to this significance. Potential tree

planting and landscaping should…

concerns about number of units identified

Policies Map Policies Map

Hooton Pagnell Hooton Pagnell

Green belt boundary for the Defined Village of Hooton Pagnell does not reflect the existing Green Belt boundary as defined on the UDP. This is a misinterpretation rather than an intended change. Correct UDP version…

Correction to reflect current statutory development plan/ existing Green Belt boundary

Not significant – mapping amendment only.



End Notes…

Incorrect Local Plan interpretation…



Additional table to clarify average annual provision during the plan period







B1 © Wood Environment & Infrastructure Solutions UK Limited


Appendix B Schedule of Representations on the Sustainability Appraisal and Response

Representation Reference

Representation Name

On behalf of… Verbatim Representation Comment Officer Summary of Representation Comment

DMBC/Wood Response

0014 Environment Agency

N/A We note that our previous comments have been accepted and reported in the SA report. We have no further comments to make.

Previous comments have been accepted and reported in the SA Report; no further comments

Noted

0016 Historic England N/A In terms of our area of interest, we would broadly agree with the evaluation and conclusions regarding the likely impact which the Policies and proposals of the Plan might have upon the historic environment and, where an adverse effect has been identified, support the proposed mitigation measures which have been proposed to reduce that harm. This opinion is based on the information provided by you in the document dated August 2019 and, for the avoidance of doubt, does not affect our obligation to advise you on, and potentially object to any specific development proposal which may subsequently arise from this or later versions of the plan which is the subject to consultation, and which may, despite the SA/SEA, have adverse effects on the environment.

Broadly agree with the evaluation and conclusions regarding the likely impact which the Policies and proposals of the Plan might have upon the historic environment and, where an adverse effect has been identified, support the proposed mitigation measures which have been proposed to reduce that harm.

Support welcomed

02989 Gladman Developments Limited

N/A In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies set out in Local Plans must be subject to Sustainability Appraisal (SA) and also incorporate the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 The SA/SEA is a systematic process that should be undertaken at every stage of the Plan's preparation, assessing the effects of the Doncaster Local Plan's proposals on sustainable development when judged against reasonable alternatives. The Council should ensure that the results of the SA clearly justify the policy choices. In meeting the development needs of the area, it should be clear from the results of the assessment why some policy options

Refers to the need for the Local Plan to satisfy the requirements of Sustainability Appraisal.

Noted and agree - see response below in respect to reasonable alternatives.




Representation Name


DMBC/Wood Response

have been progressed and others have been rejected. This must be undertaken through a comparative and equal assessment of each reasonable alternative. The Councils' decision making and scoring should be robust, justified and transparent.

03116 DLP Planning Ltd Minerals Investments Ltd

3.1 This objection relates to the fact that although the site at Brodsworth Quarry has been previously promoted to the Council as a reasonable alternative to accommodate a mixed use development compared to sites that are subject to flood restraint or are suitable for agricultural use, it has failed to be considered in the development of the strategy as a "reasonable alternative" within the Sustainability Assessment. 3.2 As well as being promoted to the Authority it has also been subject to a memorandum on the Office of the Deputy Prime Minister website which sets out that the land owner and Persimmon Homes have previously undertaken consultations with the local community adjoining the site about developing the site as a Millennium Village. The memorandum sets out that there is an appreciation amongst the local population that the redevelopment of the site could have positive impacts on the wider communities, such as improved access to facilities and services, and an improvement to the overall image of the area which is one of Doncaster's more disadvantaged locations. 3.3 The Council's approach to identifying the likely significant effects has not had sufficient regard to the evidence base for the Local Plan (including its assessment of full objectively assessed housing need, see SPRU objection to Policy 3). This limits the degree to which the Local Plan's proposals can be shown to have been developed as part of an iterative process, taking account of the appraisal's findings at each stage of preparation as required by Planning Practice Guidance (ID: 11-018-20140306). 3.4 The Council has not ensured that realistic alternatives are considered for key issues, and that the reasons for choosing them are documented, as part of assessing the plan's strategic priorities and how these might be delivered. This is a requirement of legislation for Sustainability Appraisal. Specifically, it is a requirement that all reasonable alternatives tested are realistic and deliverable (ID: 11-018-20140306). This is

Although Brodsworth Quarry has been previously promoted to the Council as a mixed use development, it is not considered as a "reasonable alternative" with the Sustainability Assessment. It has also been subject to a memorandum on the ODPM website setting out that the land owner and Persimmon Homes have previously undertaken consultations with the local community adjoining the site about developing the site as a Millennium Village. There is an appreciation amongst the local population that the redevelopment of the site could have positive impacts on the wider community. The Council's approach to identifying the likely significant effects has not had sufficient regard to the Local Plan evidence base (including its assessment of full objectively assessed housing need). This limits the degree to which the Local Plan's proposals can be shown to have been developed as part of an iterative process, taking account of the appraisal's findings at each stage of preparation as required by Planning Practice Guidance.

The Council has assessed all sites that are capable of contributing towards the plan's vision and objectives and in line with the preferred spatial strategy. This required less detailed assessment of sites in and around the Defined Villages, such as Highfields. Court Ruling on reasonable alternatives:

An alternative is not reasonable if it does not meet the objectives of the plan. i.e. it is up to the authority.

(iv) “Reasonable alternatives” does not include all possible alternatives: the use of the word “reasonable” clearly and necessarily imports an evaluative judgment as to which alternatives should be included. That evaluation is a matter primarily for the decision-making authority, subject to challenge only on conventional public law grounds.

(v) Article 5(1) refers to “reasonable alternatives taking into account the objectives… of the plan or programme …” (emphasis added). “Reasonableness” in this context is informed by the objectives sought to be achieved. An option which does not achieve the objectives, even if it can properly be called an “alternative” to the preferred plan, is not a “reasonable alternative”. An option which will, or sensibly may, achieve the objectives is a “reasonable alternative”. The SEA Directive admits to the possibility of there being no such alternatives in a particular case: if only one option is assessed as meeting the objectives,




Representation Name


DMBC/Wood Response

not the case for the scenarios tested as part of the Council's Sustainability Appraisal, which in-turn means the Sustainability Appraisal does not provide an accurate understanding of the potential effects of the selected strategy compared to other reasonable alternatives. 3.5 The PPG requires all reasonable alternatives to be assessed against the same baseline environmental, economic and social characteristics (following paragraph 152 of the NPPF 2012). Furthermore, it makes it clear that reasonable alternatives must be assessed to the same level of detail: "The sustainability appraisal needs to compare all reasonable alternatives including the preferred approach and assess these against the baseline environmental, economic and social characteristics of the area and the likely situation if the Local Plan were not to be adopted?. ?The sustainability appraisal should identify any likely significant adverse effects and measures envisaged to prevent, reduce and, as fully as possible, offset them. The sustainability appraisal must consider all reasonable alternatives and assess them in the same level of detail as the option the plan-maker proposes to take forward in the Local Plan (the preferred approach.)" 3.6 Planning Practice Guidance anticipates that a comprehensive range of options will be undertaken under 'Stage B' of the requirements for preparing the Sustainability Appraisal and align with the process for preparing the Local Plan at Regulation 18 stage (see ID: 11- 013-20140306) 3.7 This has been considered through the Courts in Heard v Broadland [2012] EWHC 344 (Admin). In particular, see paragraphs 53 to 73, where the approach to the process of SA and alternatives are considered. In summary Ouseley J in paragraph 73 states: "?the aim of the directive, which may affect which alternatives it is reasonable to select, is more obviously met by, and it is best interpreted as requiring, an equal examination of the alternatives which it is reasonable to select for examination alongside whatever, even at the outset, may be the preferred option. It is part of the purpose of this process to test whether what may start

The Council has not ensured that realistic alternatives are considered for key issues, and that the reasons for choosing them are documented. This is a requirement of legislation for Sustainability Appraisal. Specifically, it is a requirement that all reasonable alternatives tested are realistic and deliverable. This is not the case for the scenarios tested as part of the Council's SA, which in-turn means the SA does not provide an accurate understanding of the potential effects of the selected strategy compared to other reasonable alternatives. There is a summary of the PPG requiring all reasonable alternatives to be assessed and a court case is also mentioned Heard v Broadland [2012] EWHC 344 (Admin) including, see paragraphs 53 to 73, where the approach to the process of SA and alternatives are considered. In summary Ouseley J in paragraph 73 states: "the aim of the directive, which may affect which alternatives it is reasonable to select, is more obviously met by, and it is best interpreted as requiring, an equal examination of the alternatives which it is reasonable to select for examination alongside

there will be no “reasonable alternatives” to it.

(vi) The question of whether an option will achieve the objectives is also essentially a matter for the evaluative judgment of the authority, subject of course to challenge on conventional public law grounds. If the authority rationally determines that a particular option will not meet the objectives, that option is not a reasonable alternative and it does not have to be included in the SEA Report or process.”




Representation Name


DMBC/Wood Response

out as preferred should still end up as preferred after a fair and public analysis of what the authority regards as reasonable alternatives?" 3.8 This is not the approach that has been taken by the Council in its assessment of reasonable alternatives. As such, its assessment is flawed in fundamental respects and does not follow the Regulations/the SEA Directive nor case law. 3.9 One such reasonable alternative is the site at Brodsworth Quarry which comprises of approximately 61 hectares of land adjacent to the western settlement boundary of Highfields, and immediately south of Adwick le Street, as illustrated in Figure 2. (SEE EMAIL FOR Figure 2. Site Location) 3.10 The site is a former limestone quarry that has been partly restored to low grade agricultural land. Due to its former use the site lies below the level of the surrounding land, which provides screening from surrounding sensitive uses. This is a very underutilised site with little or no environmental or ecological value and yet other sites have been considered more appropriate for promotion for development with the draft Plan. 3.11 While the site is connected to Highfields, it is also connected to Adwick le street to the North and as such represents a very sustainable site. Review of Sustainability Criteria of Brodsworth Quarry 3.12 There are several local facilities and services in close proximity to the site, including, but not limited to, the following: - Allotments - Located to the north east (< 600 metres) - Highfields Primary School - Located to the east (< 800 metres) - Highfields Community Centre - Located to the east (< 800 metres) - Weldricks Pharmacy - Located to the north (< 800 metres) - The Woodlands Primary School - Located to the north (< 900 metres) - All Saints Church - Located to the north (< 900 metres)

whatever, even at the outset, may be the preferred option. It is part of the purpose of this process to test whether what may start out as preferred should still end up as preferred after a fair and public analysis of what the authority regards as reasonable alternatives?" This approach has not been taken by the Council. Therefore the assessment is flawed in and does not follow the Regulations/the SEA Directive nor case law. Brodsworth Quarry (61 hectares) adjacent to the western settlement boundary of Highfields, and immediately south of Adwick le Street is a reasonable alternative (see Figure 2 in email for site location). It is a former limestone quarry which has been partly restored to low grade agricultural land. It lies below the level of the surrounding land, providing screening from surrounding sensitive uses. It is very underutilised site with little or no environmental or ecological value and yet other sites have been considered more appropriate for promotion for development within the Plan. Review of Sustainability Criteria of Brodsworth Quarry




Representation Name


DMBC/Wood Response

- Aagrah (Indian restaurant) - Located to the north east (< 1 kilometre) - Lloyds Bank - Located to the north (< 1.1 kilometres) - Woodlands Post Office - Located to the north (< 1.1 kilometres) - Woodlands Community Library and Hub - Located to the north (< 1.2 kilometres) - Outwood Academy - Located to the north (< 1.3 kilometres) - Adwick Leisure Complex - Located to the north east (< 1.4 kilometres) - Doncaster North Park and Ride - Located to the east (< 1.7 kilometres) 3.13 In addition to the above, it is of note that Adwick train station is located under 2.5 kilometres to the north east of the site. Northern services to Doncaster, Sheffield and Leeds are available from the station. 3.14 There are also several bus stops within 1.3 kilometres of the site in the Highfields settlement. The stops provide access to the following services: - 50: Doncaster - Skellow - 50a: Cantley - Doncaster - Carcroft - 50b: Doncaster - Skellow - 51: Doncaster - Skellow - Askern (Instoneville) - 51a: Doncaster - Skellow - Askern (Instoneville) via Campsall - 52: Doncaster - Woodlands - Redhouse - South Elmsall - 54: Doncaster - Scawthorpe - Woodlands Circular - 203: Doncaster - Scawthorpe - Highfields - Pickburn - Hooton Pagnell - Clayton - Thurnscoe - Middlecliffe - Wombwell Site Description and accessibility of Brodsworth Quarry 3.15 The site is relatively flat with a gentle decline in land levels towards Langthwaite Dyke to the north of the site. 3.16 To the north of the site beyond some significant tree coverage is the Adwick-le-Street and Woodlands settlement which comprises of predominantly residential development with a vast range of public transport links and local facilities and services. To the south east of the site along / beyond Green Lane there is a small amount

There are several local facilities and services in close proximity to the site, including allotments; 2 primary schools; a community centre; a Pharmacy; a church; restaurants; a post office; library/community hub; secondary school; leisure centre; Park and Ride site and Adwick train station. There are also several bus stops in the Highfields settlement with services across and beyond the borough boundary. The site is relatively flat with a gentle decline in land levels with significant tree coverage to the north. Adwick-le-Street and Woodlands are predominantly residential with a vast range of public transport links and local facilities and services. There is a small amount of development to the south which is predominantly residential and there is greenfield land to the south west. To the east is Highfields which is predominantly residential development, and to the west is the Brodsworth Community Woodland. Further to the west is the A1(M) Doncaster Bypass, and to the north west beyond the Brodsworth Community Woodland there is a garden centre and pet shop and employment units.




Representation Name


DMBC/Wood Response

of development which is predominantly residential, and to the south west beyond Green Lane there is greenfield land. 3.17 To the east of the site is the Highfields settlement which comprises of predominantly residential development, and to the west is the Brodsworth Community Woodland. Further to the west is the A1(M) Doncaster Bypass, and to the north west beyond the Brodsworth Community Woodland there is a garden centre and pet shop, a B&Q distribution centre and an Asda depot warehouse. 3.18 There are several existing pedestrian access points along Green Lane and South Street, and it is considered that vehicular access to the site could be provided from Green Lane. 3.19 Footpath "Brodsworth 6" runs along the south eastern boundary of the site, and footpath "Brodsworth 8" (Roman Ridge) runs directly adjacent to the eastern boundary of the site. 3.20 There are currently no utilities on the site. However, the proximity of the site to the urban area suggests that the service network could be extended to serve this site. 3.21 The site is located entirely within Flood Zone 1 on the Environment Agency's flood maps, which means that the site has a less than 1 in 1,000 annual probability of flooding from a river or sea. It is of note that the National Planning Practice Guidance sets out that residential development is an appropriate land use in Flood Zone 1 areas (Paragraph 066, reference ID 7-006-20140306). 3.22 The site is not located within a Conservation Area and there are no listed buildings or scheduled monuments on the site. The Woodlands Conservation Area is located to the north of the site beyond the tree coverage. Roman Ridge, which is a scheduled monument, runs directly adjacent to the eastern boundary of the site. 3.23 Within the site towards the eastern / south eastern boundary is the Tithe Barn Plantation which contains some agricultural buildings. The landowner has

There are several existing pedestrian access points along Green Lane and South Street, and vehicular access could be provided from Green Lane. There are footpaths on the site but no utilities but these could be extended to serve the site. It is within Flood Zone 1 and is not located within a Conservation Area and there are no listed buildings or scheduled monuments on the site. The Roman Ridge, which is a scheduled monument, runs directly adjacent to the eastern boundary of the site. The ground conditions of the site have been dealt with by Wardell Armstrong who dealt with the restoration of the site, and a review of the site for contamination has been undertaken. A review of the site for mixed use and transport links has been undertaken, and an ecological assessment is available. The Deliverability of Brodsworth Quarry The site is entirely within single ownership and there is a strong interest in bringing the site forward for a mixed use development with previous interest from Persimmon Homes. There are no physical constraints and the site provides opportunities to deliver significant economic and




Representation Name


DMBC/Wood Response

previously sought preapplication advice from Doncaster Metropolitan Borough Council regarding "Refurbishment and conversion of existing barn group into dwellings around existing central courtyard and demolition of steel framed barn adjacent" in the plantation area. The landowner intends to submit a planning application for the proposals in the near future. 3.24 It is understood that the ground conditions of the site have been dealt with by Wardell Armstrong who dealt with the restoration of the site, and a review of the site for contamination has been undertaken. Further to this, it is understood that a review of the site for mixed use and transport links has been undertaken, and an ecological assessment is available. The Deliverability of Broadworth Quarry Available 3.25 The site is entirely within Mr Brealey's ownership. Mr Brealey has a strong interest in bringing the site forward for a mixed use development, and there has been previous interest in the site from Persimmon Homes. Suitable 3.26 The site does not have any physical constraints which suggest that a carefully designed mixed use development could not be brought forward during the plan period. Deliverable 3.27 Given the size of the site and its potential capacity, the site provides opportunities to deliver significant economic and housing growth, and vast developer contributions such as affordable housing, education and open space (subject to viability). 3.28 The Housing and Economic Land Availability Assessment (HELAA) housing map identifies Brodsworth Quarry (reference 184) as a deliverable / developable site which does not currently have planning permission. This is supported. 3.29 The HELAA 2017 - 2018 housing sites update firstly describes the site as a 61.379ha greenfield urban

housing growth, and vast developer contributions such as affordable housing, education and open space (subject to viability). The HELAA (ref 184) identifies the site as deliverable / developable and this is supported. The HELAA description as greenfield belies the fact that the land levels are clearly a result of the previous activity and the very low level of utility of the current land. The site is mentioned in the housing update report and the HELAA 2017 - 2018 employment sites update. The Site Selection Methodology and Results Report (June 2019) Appendix A1 makes reference to sites that have been removed from the process as part of the housing and employment land availability assessment stage. A number of employment sites are referenced which are considered to be suitable and available, but not marketable and therefore not deliverable, including this site. The site was marketed by Fisher German in 2017. The Employment Land Review (dated February 2018) does not reference the site and it is considered that the HELAA is amended and the site is assessed by the Council in the same




Representation Name


DMBC/Wood Response

extension site which is proposed as a mixed use allocation but describes the site as greenfield. this description belies the fact that the land levels are clearly a result of the previous activity and the very low level of utility of the current land. 3.30 The housing update report describes the site as suitable for development (but with national policy constraints or physical constraints), available and deliverable, with a potential capacity of 1519 dwellings. Of these 1519 dwellings, 0 are considered developable in 0 - 5 years, 350 are considered developable in 6 - 10 years, 350 are considered developable in 11 - 15 years, and 819 are considered not developable beyond 15 years. 3.31 The HELAA 2017 - 2018 employment sites update also describes the site as suitable (but with national constraint) and available for economic development, but not marketable and therefore not deliverable. There is no reference to timeframe for delivery. 3.32 Similarly, the Site Selection Methodology and Results Report (dated June 2019) has an appendix (Appendix A1) which makes reference to sites that have been removed from the process as part of the housing and employment land availability assessment stage. Within the appendix, a number of employment sites are referenced which are considered to be suitable and available, but not marketable and therefore not deliverable. The site is included as one of these sites. (SEE EMAIL FOR Appendices) 3.33 In addition to the memorandum, it is understood that the site was also marketed by Fisher German in 2017. 3.34 It is also noted that the Council's employment land review (dated February 2018), which qualitatively assesses the suitability of potential sites that could become allocations for employment use, does not reference the site. 3.35 In light of the above, it is requested that the information in the HELAA is amended and the site is assessed by the Council in the same manner as the other sites in the employment land review were.

manner as the other sites in the Employment Land Review were.




Representation Name


DMBC/Wood Response

04955 & 04956 Barton Wilmore Barratt & David Wilson Homes

The Council have commissioned Wood Environment & Infrastructure Solutions UK limited ('Wood') to undertake a Sustainability Appraisal (SA), and this includes an assessment of all sites that have been put forward for consideration as potential housing allocations. The SA sets out a series of sustainability objectives, which have a number of sub objectives along with a bullet point summary of how the objectives will be achieved. A qualitative scoring system has been adopted which is set out in Table 2 of the SA and copied below for ease of reference: (SEE EMAIL FOR image) The scoring system used has four possible responses with: - (+) Green being positive i.e. likely to assist with sustainable development, - (-) red being a negative or incompatible i.e. likely to compromise sustainable development, - (0) white/blank being neutral i.e. likely to involve both compatible and incompatible effects; and - (?) Unlikely to be related or Uncertain i.e. effects cannot be judged at this stage. Our Client has interests in site ref: 141 on Westwood Road but our view remains that our Clients site ref: 146 scores more favourably than site 499, Land off North Avenue and should be allocated. In order to make a robust comparison, we have added a simple numerical scoring system as follows: (+) Green = 2 (neutral) = 1 i.e. likely to involve both compatible and incompatible effects; and (-) red = 0 (?) Unlikely to be related or Uncertain i.e. effects cannot be judged at this stage. Based on these numerical scores we have compared site ref: 499 Land off North Avenue, Bawtry against our Clients' site ref: 146 Tickhill Road, Bawtry. As it stands the Council claim that site ref: 146 - Tickhill Road, Bawtry has a cumulative score of 35 and that site ref: 499 - Land off North Avenue, Bawtry has a

Has concerns with the Sustainability Appraisal in respect to site 'scoring'. Contends that rejected site ref 146 should 'score' better than site ref 149 (allocated). Says assessment contains inaccuracies which result in site 146 being downgraded. With 'inaccuracies' corrected site 146 scores better than 149.

The SA criteria were subject to previous consultation where changes were made to address the responses where appropriate. Sites have been assessed consistently and primarily using objective criteria. SA guidance and best practice seeks to avoid using mathematical or numerical scoring approaches to such matters. The site selection methodology sets out why sites have been supported/rejected which in this case is largely based on the findings of the Green Belt review alongside consideration of other sites/housing supply towards the settlement's plan period target as opposed to the findings of the SA stage.

As per the above, the Council has purposefully not used a numerical scoring approach so dispute that the Council claims that there are cumulative scores for these, or any sites, in the borough. The Representation has calculated these and not the Council therefore.

Objective 3Ai - proximity to train station - all of the sites in Bawtry perform the same for this criteria as the nearest rail station is Doncaster Town Centre which is a considerable distance from Bawtry (circa 12 miles). It does not state 'within' 1200m but 'over' 1200m which is the score for the majority of the Borough's sites. As such, changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores. The single negative (- light red) score is




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DMBC/Wood Response

cumulative score of 41. Having reviewed the Council's assessment of our Client's site (at Appendix N), we have concluded that a number of the assessments are incorrect, and our Clients' site has been downgraded based on inaccurate information. The inaccuracies are as follows: Objective 3A and Sub Objectives i), ii) and iii) relate to the promotion of the use of public transport. The commentary notes that the site lies within 1200m of a train station and between 400m - 800m of a high frequency bus stop. The site is also within recognised cycle distances of a cycle network and local services. Based on nationally recognised guidance the site is actually within walking or cycling distance of local schools, shops, employment opportunities and local amenities in Bawtry, all within 2km walking distance and 5km cycling distance of the site. These measures are drawn from the Institution of Highways and Transportation (IHT) document 'Guidelines for Providing for Journeys on Foot' (1998) which details the preferred maximum walking distance of 2km. The IHT and Department for Transport (DfT) document 'Cycle Friendly Infrastructure: Guidelines for Planning and Design' (1996) provides a guide on suggested cycle speeds associated with cyclists of varying confidence and ability. Using a speed of 10mph (16kph) a catchment of 5km would be available within approximately 20 minutes' cycle time. The Council have identified our site as Red (0) but given that the site falls within recognised walking and cycling distance of a train station and bus stop that this site should have been assessed as Green (2) Sub Objective 3B i) Will the site be accessible to an existing centre? Given the accepted distances highlighted above, relating to journeys on foot and by bicycle, the site is well located to an existing centre and shopping parade. We propose that the scoring of neutral (1) is assessed as green (2).

justified and consistent with the SA methodology.

Objective 3Aii - the entire site is within the 400m-800m buffer for access to bus stops which provides for a score of neutral (0 amber). The score is justified and consistent with the SA methodology. Changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 3Aiii - the site is well beyond the 100m buffer for access to cycle network. The neutral (0 amber) score is justified and consistent with the methodology. Changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 3Bi - the site is mainly in the 400m-800m buffer (with an area that is in the over 800m buffer). The neural (0 amber) score is justified and consistent with the methodology. Changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 3Bii - access to primary school. Some of the site is within the 400m-800m buffer, with the majority being in the 800m+ buffer. The neutral (0 amber) score id justified and consistent with the methodology. Changes to this criteria would mean all




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DMBC/Wood Response

Sub Objective 3B ii) Will the site be accessible to a primary school? The Council state that the site lies within 400m - 800m of a primary school which is within widely accepted walking distances. The Council have scored a neutral (1); we propose the site is assessed as green (2). Sub Objective 3B iii) Will the site be accessible to a secondary school? The Council comment that the site lies over 2km away from a secondary school, but it is worth pointing out that the site is within 800m of a bus stop. In addition, children of secondary school age are capable and more likely to travel to and from school by bus. We propose the negative Red (0) score is assessed as a neutral (1) score. Sub Objective 3B iv) Will the site be accessible to a GP? The Council comment that the site lies within 800m of a GP surgery and is given a Green (2) score. We support this score but question why the accessibility of a GP surgery attracts a higher score than the accessibility of an existing centre or a primary school. We reiterate that the respective scored for access to those facilities should be assessed as Green (2). In summary, it is clear that the neutral and negative scores on this site in relation to accessibility should have been assessed as green (2) rather than amber (1) and red (0). The Council's assessment of the site is a flawed assessment as the site is located adjacent to the village boundary, 500m from the primary school and 600m from the GP Surgery with good public transport links. 5D i) related to availability and specifically asks "Has the site been identified as an opportunity to address housing market failure?". The Council have given the score of neutral (1) and their reasons for doing so is that the site is not a formerly cleared housing site. The site is a green field agricultural site, adjacent to the settlement limits and is available for

the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 3Biii - access to secondary school. All of the sites in Bawtry are identified as being 2km+ away from a secondary school due to the settlement not having such as facility. The single negative (- light red) score id justified and consistent with the methodology. Changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 3Biv - access to GP. The methodology has been applied consistently. Changes to this criteria would mean all the other sites in Bawtry (and indeed the majority of the borough) would also receive more favourable scores.

Objective 5Di - Housing Market Failure - the Representation is not clear how/why a Greenfield/Green Belt site which would form an extension to Bawtry (not an area identified previously as being subject to policy interventions in the housing market) should be treated the same as a brownfield/cleared housing market renewal site in towns such as Edlington, Mexborough etc. The criteria is justified and has been applied consistently. None of the site sin Bawtry are identified as performing positively against this criteria. Changes to the methodology would lead to all sites performing better/the same.




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DMBC/Wood Response

development as demonstrated within our previous representations. This objective should have been assessed as a Green (2) as opposed to a neutral (1). 8A iii) Will the site avoid known areas of landfill sites? And; iv) Will the site avoid known areas of unstable land? The Council have confirmed that the site not located within an area identified as containing a closed landfill site. Therefore, the site will avoid known areas of landfill and therefore fully complies with the objective. The site is an agricultural field that has not had any buildings or alternative uses and the Council's neutral (1) rating is unfounded, the rating should be Green (2) as it wholly complies with that element of the objective. 8B relates to infrastructure. Sub-objective i) asks "Will the site have an impact on the Strategic Road Network?" The Council comment that the impact upon the Strategic Road Network (SRN) is expected to be mitigated but other, committed, schemes. As such the Council are claiming that there is no impact upon the SRN. In light of this the score should be assessed as Green (2) rather than neutral (1). Sub-objective iii) Will any additional demand for primary school places be likely from the site? The council note that the site is located within the catchment of a primary school with additional places needed. The latest Ofsted report (note 1 - https://reports.ofsted.gov.uk/provider/21/106737) for the Bawtry Mayflower Primary School states that the school is currently under capacity with a surplus of spaces for new children to join. Given this evidence we propose that the negative red (0) score be assessed as a Green (2) score. Sub-objective iv) Will any additional demand for secondary school places be likely from the site? The council note that the site is located within the catchment of a primary school with additional places needed. The gov.uk website (note 2 -

Objective 8Aiii - Landfill sites - the neutral scoring (0 amber) is justified and has been applied consistently. Changes to the methodology would lead to all sites performing better/the same.

8Bi - Highways Capacity - The scoring has been based on work undertaken for the Council by Highways England. It is considered that a site which has no significant impact on the SRN rightly performs better (+) than a site which is identified as having an impact, even where mitigation is committed. The score (neutral (0) amber) is justified and has been applied consistently.

Objective 8Biii - Primary school capacity - sites have been assessed by colleagues in the Council's School Places Admissions Team using a standard methodology and is justified and consistent. Changes to the methodology would lead to all sites performing better/the same.

Objective 8Biv - Secondary school capacity - see response above to primary school capacity.

Objective 9Ai - Access to POS - the score is justified and has been consistently applied. All sites have the ability to provide new POS as part of the development, and/or make a




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https://www.compare-school-performance.service.gov.uk/school/137141/serlby-park-academy/absence-and-pupil-population) quotes the latest data and states that the total number of pupils attending the school is 831. The latest Ofsted report (note 3 - https://reports.ofsted.gov.uk/provider/28/137141) states that the capacity of the school is 834. Given that the school is currently slightly under capacity and that planning contributions would form part of any application on this scale we propose that the negative red (0) score be assessed as a Green (2) score. Objective 9 relates to improvement in the health and well-being of the borough's population. Sub Objective 9A i) asks "Does the site have access to formal and informal open spaces?" The Council's response is that the site is within the catchment of either a formal or informal open space. However, the Council have failed to acknowledge that a development of this size will no doubt include public open space with the development proposal and/or pay a commuted sum for the provision of such opportunities through associated legal agreements. We suggest the site is assessed as Green (2) rather than neutral (1). Objective 12 seeks to protect, increase and enhance the natural environment, including the landscape, its underlying geology and wildlife habitat. Sub Objective 12 A i) asks, Will the site affect biodiversity? The site is an agricultural field but the Council's assertion that development of the site would negatively affect biodiversity is unfounded. As part of a comprehensive submission the proposed scheme could in fact result in a net gain in terms of biodiversity. The Council have scored this element as a negative red (0). We believe the site should be assessed as a neutral (1), potentially moving up to a Green (2) with suitable mitigation. Similarly, sub objective 12 B i) relating to the impact upon Landscape, states that the site located in a broad area assessed as having 'moderate' landscape capacity. The council have scored the impact as a neutral (1) however, with a comprehensive Landscape

commuted sum to existing open space. Changes to the methodology would lead to all sites performing better/the same.

Objective 12Ai - Biodiversity - The criteria was put forward by Natural England following the consultation on the SA criteria and has been applied consistently and is justified. Changes to the methodology would lead to all sites performing better/the same.

Objective 12Bi - Landscape Capacity - The site has been assessed in line with the methodology and is consistent/justified. Changes to the methodology would lead to all sites performing better/the same.

Objective 13Ai & 13Bi - Heritage Impacts & Archaeology - The site has been assessed in line with the methodology and is consistent/justified. Changes to the methodology would lead to all sites performing better/the same.

Objective 14 - The site has been assessed in line with the methodology and is consistent/justified. Changes to the methodology would lead to all sites performing better/the same.

Overall conclusion - as set out above, the criteria have all been subject to consultation and changes made to




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DMBC/Wood Response

Visual Impact Assessment potential impacts could be mitigated and further enhanced. As such we believe the scoring should be Green (2). Objective 13 seeks to protect, conserve and enhance the historic and cultural heritage. The Councils comments relating to the impact upon heritage assets and archaeological features are essentially that there are no heritage assets that would be impact upon, and no known archaeological objection to the proposed allocation of the site. So, bearing in mind, the development will not affect a conservation area, a listed building or its setting, non-designated heritage assets, registered historic park or gardens, registered battlefields or a scheduled ancient monument. However, the Council consider that these objectives are assessed as neutral (1). We propose that, given there is no known impact, this objective should be assessed as Green (2). Objective 14 seeks to Protect and enhance soil, air and water quality (watercourses and ground water) Sub-Objectives B and C relate to water and air quality respectively. The council state that the site is located 25m or further from an identified surface water body and located outside of an AQMA or National Exceedance Area. Given that there appears to be no immediate impact, and that any application would include a suite of mitigation measures we proposed that these elements are assessed as Green (2), as opposed to neutral (1). Taking the numerous inaccuracies outlined above into account, we set out below how the site should be assessed, had the approach been fair and consistent. Site ref: 146 - Tickhill Road, Bawtry = 51 Scoring considerably higher than the allocated land off North Avenue. As noted from the above commentary, the Council's assessment is inaccurate and has led our Clients land interest being substantially downgraded, when in fact it scores higher than the other proposed allocations within the settlements of Bawtry.

address responses prior to being used for site assessment. Changes to the SA scoring would have to be applied consistently to all sites in Bawtry (and indeed the borough). The Representation fails to appreciate that such changes become relative therefore as other sites in the town also perform stronger. Disagree that the rejected site performs better than other allocations at the town, whether based on the current scoring or if accepting the Representation’s revisions to the methodology.




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DMBC/Wood Response

05190 Carter Jonas Harworth Estates

Flood Risk We note that the site has been given a negative score within the Sustainability Appraisal of the Doncaster Local Plan 2015 - 2035: Publication Version for main river flooding under Criterion 11 Ai. Current and earlier strategic and site specific Flood Risk Assessment (FRA) work has demonstrated the significant distance of Bradholme Farm from the River Don and the River Trent system. There are intervening barriers (motorway, railway) between the River Don and Bradholme Farm.

Whilst much of the site is currently shown to be located within Flood Zone 3 of the EA’s flood map, the EA themselves, IDB and LLFA have all confirmed that Site 160 is located outside of the area of risk of flooding from Main Rivers, and the main source of flood risk is due to the potential failure of a pumping station, which pumps water from the Brierholme Carr Drain into the South Soak Drain. Further to this, the EA and LLFA do not regard Site 160 as being located within the design standard floodplain and therefore the development of this site will not result in any loss of floodplain to the surrounding area and will not increase flood risk elsewhere.

Therefore, there is no requirement for any floodplain compensation on the site. There has also been no history of flooding at Bradholme Farm. The Flood Risk Note prepared by BWB contained within Appendix 6 confirms that Bradholme Farm is outside of areas at risk from Main River Network. We therefore consider that the site should have been scored as positive or at the very least neutral for Criteria 11 A(i).

In relation to criterion 11A (iii) Areas Benefitting from Flood Defences, Bradholme Farm has been scored as negative. We note that the comment in the Bradholme Farm Site 160 assessment matrix at page 49 of the Sustainability Appraisal Appendix O states “the proposal is not within an area benefitting from flood defences and is at risk of main river flooding (FRZ2/3)”. We assume that this is based on the SFRA or simple flood risk zone rating and takes no account of site specific FRA work past and current. Nor does it take account of the mitigating effect of barriers and distance between the site and the River Don. Bradholme Farm does benefit from flood risk defences relating to land drainage. We therefore consider that the site should have been scored as neutral for Criteria 11 A(iii).

Flood Risk

Site 160 has been given a negative score under Criterion 11 Ai. Although much of the site is shown as Flood Zone 3 on the EA's flood map, the EA, IDB and LLFA have confirmed that the site is located outside of the area at risk of flooding from main rivers and that the main source of flood risk is due to the potential failure of a pumping station. The development of the site will not result in any loss of floodplain and will not increase flood risk elsewhere. There is no requirement for any floodplain compensation. The site should be scored as positive or neutral for Criteria 11 Ai.

Site 160 has been given a negative score for Criteria 11 Aiii - Areas benefiting from Flood Defences. Assume this is based on the SFRA or simple flood risk zone rating and takes no account of site specific FRA work past and current. It does not take account of the mitigating effect of barriers and distance between the site and the River Don. Site 160 does benefit from flood risk defences relating land drainage. The site should be scored as neutral.

This has been raised previously and it is worrying that this information has not been considered as part of the SA process which

Objective 11Ai - Flooding from Main Rivers - Sites have been assessed consistently using the EA Flood Map for Planning which shows the vast majority of the site to be flood zone 3.

Objective 11Aiii - Benefiting from Existing Defences - as the methodology makes clear, the sites have been assessed suing the EA's areas benefitting from existing defences map and not based on site-specific flood risk assessments so sites have been assessed consistently and the score is justified. The Council is aware of the site-specific appraisal work that has been undertaken but contend site options should be assessed using objective appraisal criteria wherever possible.

Accessibility criteria - welcome that the Representation comes to the same conclusion on how the site has performed against these criteria. Bus service - the methodology makes clear that it looks at high-frequency bus network which is provided by SYPTE and an hourly service is not classed as being high-frequency. Scope for improvements/increased patronage is noted but would be true of all employment site options thus the improved score is relative as all sites would perform stringer.

8Bi - Highways Capacity - The scoring has been based on work undertaken for the Council by Highways England - see SA Technical Appendices for the




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DMBC/Wood Response

The above information has been raised during earlier representations and a recent pre-application enquiry. It is therefore worrying that this technical information has not been considered as part of the Sustainability Appraisal and demonstrates significant flaws in the Councils evidence base which has been used to inform the Publication Draft Local Plan.

Accessibility A review of the accessibility of Site 160, Bradholme Farm is contained within the Accessibility Review prepared by Development Planning Limited in support of these representations and is included within Appendix 4. It should be read alongside the comments raised below.

The site scores relatively well within the Council’s Sustainability Appraisal, and is identified as having a positive effect for criterion 3(Ai) promotion of the use of trains, a neutral score for criterion 3(Aii) the proximity to high frequency bus services and a positive score for criterion 3Aiii) the proximity to a cycleway. We agree with the rating of criterion 3(Ai) and 3(Aiii) for the reasons set out below.

The site is located adjacent to the southern boundary of Thorne, with continuous footways available from around 60m north of the site, once across the lightly trafficked canal bridge. For cycling, South End passes by the northern boundary of the site and provides a lightly trafficked low speed route into Thorne.

The closest railway station to Bradholme Farm is Thorne South railway station. Thorne South is on the routes to Scunthorpe and Doncaster. The railway station is located around 600m (7minute’s walk) from the boundary of the site. The travel time to Doncaster from Thorne South is 21 minutes.

The walking experience to the railway station is the same as a pedestrian accessing Thorne and is considered to be pleasant.

We disagree however with the neutral score for criterion 3Aii). The site currently benefits from bus routes 8, 8A and 84 passing the site. Overall, the services provide an approximate hourly frequency of buses in both directions, operating during the day from around 06:57am to 23:32pm. With the exception of the 06:00am

demonstrates flaws in the Council's evidence base.

Accessibility

This is supported by an Accessibility Review prepared by Development Planning Limited. Site 160 scores relatively well within the Sustainability Appraisal. Agree with the rating of criterion 3(Ai) and 3(Aiii) but disagree with the neutral score for criterion 3Aii).

The site benefits from bus routes 8, 8A and 84 passing the site and the services provide an approximate hourly frequency of buses in both directions. Consider that Site 160 should have a positive score for criteria 3Aii) as there are a number of bus services which pass the site.

Site 160 is significantly more accessible and sustainable then than Site 001.

Highways

Site 160 is scored as negative within criterion 8Ai. Additional work has been prepared by Development Planning Ltd. It considers the existing and forecast local transport environment and potential implications of a mixed use employment scheme. It identifies that M18 Junction 5 has strategic importance for access to the site and also in terms of its inter-urban

details. It is noted that the Representation is not challenging the SA finding, rather confirming that any issues can be overcome.


Objective 12Ai - Biodiversity - The criteria has been revised from a single negative (- light red) to neutral (0 amber) to reflect the Representation and that the survey undertaken as part of a previous application concluded the site is located outside all sites and buffers. Amending to a neutral rather than a positive is consistent with other sites where scores have been amended to reflect site-specific material - see table of amendments to SA baseline.

Objective 12Bi - Landscape Capacity - Note that the site promoter's own study identifies an alternative conclusion so proposed to make amendment to the SA baseline to reflect - see schedule of amendments to SA baseline for details.

Objective 14Ai - Minerals sterilisation - Note that the site promoter has undertaken an assessment and shown




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DMBC/Wood Response

24-hour shift pattern start time, all other typical start and finish times can be accommodated on the existing services. Additional patronage could increase revenues on those services by £100k to £150k per year, helping to ensure their longer-term viability. We therefore consider that Site 160, Gateway 180, Bradholme Farm site should have a positive score for criteria 3Aii) as there are a number of bus services which pass the site.

Overall it is considered that Site 160, Bradholme Farm is significantly more accessible and sustainable then than Site 001, Thorne North. This is highlighted in the comparison table contained within the Accessibility Review in Appendix 4.

Highways With regards to Highways Capacity (criterion 8(Ai) Bradholme Farm scores a negative rating within the Sustainability Appraisal of the Doncaster Local Plan 2015 - 2035: Publication Version.

An initial Preliminary Feasibility Study (dated February 2017) and subsequent Technical Note in relation to M180 Junction 1 (January 2018) have also been prepared by Development Planning Limited (copies attached in Appendix 7).

The Feasibility Study considers the existing and forecast local transport environment and potential implications of a mixed use employment scheme (and residential development – now discounted).

The study identifies that a key junction on the local highway network is M18 Junction 5 due to its strategic importance for access to the site and also in terms of its inter-urban connections across the region. M18 Junction 5 was improved in 2015 as part of the Highways Agency Pinch Point funding programme. At the time of the study further improvements were proposed as part of the Unity development (west of the M18) which result in a very similar junction to that previously proposed as the highway mitigation scheme for the Hatfield Colliery site.

connections across the region. M18 Junction 5 was improved in 2015 as part of a Highways Agency funding scheme.

The Transport Assessment for the Unity development forecasts that, with the exception of the Unity site access ("MOTO") arm of the roundabout, the fully improved M18 Junction 5 could operate satisfactorily in 2038. The 2008 Transport Assessment for Bradholme Farm forecast that the improvements proposed at M18 Junction 5 for the Hatfield Colliery site could accommodate the development proposals with no further improvement.

It should be noted that the 2008 Transport Assessment for Bradholme Farm considered as part of application ref. 08/03189/FULM forecast that two additional local junctions could require signalisation as part of the development proposals.

The Officers Report for the previous application for Bradholme farm in 2008 stated that there ref. 08/03189/FULM at Bradholme Farm states that: "subject to the improvements referred to both Junction 5 and the slip roads at Junction 1 of the M180 are able to accommodate the traffic from the proposed development." Therefore there are no significant

that the deposits are not viable for extraction so agree to revised SA score - see schedule of amendments to SA baseline for details.

Objective 14A(ii) Avoidance of Best & Most Versatile Agricultural Land - Note that the site promoter has undertaken an onsite survey that demonstrates that the site is mainly 3b. Agree to revise SA scoring - see schedule of amendments to SA baseline for details.




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DMBC/Wood Response

The Transport Assessment for the Unity development forecasts that, with the exception of the Unity site access (“MOTO”) arm of the roundabout, the fully improved M18 Junction 5 could operate satisfactorily in 2038. The 2008 Transport Assessment for Bradholme Farm forecast that the improvements proposed at M18 Junction 5 for the Hatfield Colliery site could accommodate the development proposals with no further improvement.

It should be noted that the 2008 Transport Assessment for Bradholme Farm considered as part of application ref. 08/03189/FULM forecast that two additional local junctions could require signalisation as part of the development proposals.

The Officers Report for the previous application ref. 08/03189/FULM at Bradholme Farm states that: “It will be necessary to improve two junctions on the local road network; the A18 Tudworth Road junction with the M180 westbound on-slip, and the A18 Tudworth Road/A614 Stone Hill junction, in order to accommodate the traffic generated by the proposed development. Both junctions are currently 'give-way' type layouts; it is proposed to signalise them to provide additional capacity. The Traffic Assessment has taken into account 'committed development' such as the Hatfield Power Park and other development around Junction 5 of the M18. Those proposals include the signalisation and widening of the Junction 5 roundabout but the assessment also provides for alternative highway works that could be implemented in the event of that committed development not taking place for whatever reason. The conclusion is that subject to the improvements referred to both Junction 5 and the slip roads at Junction 1 of the M180 are able to accommodate the traffic from the proposed development.” There were therefore no significant issues in relation to highways capacity in relation to this proposal. For a new B8 proposal on the Bradholme Farm site the forecast scale of traffic impact could result in a similar conclusion or marginal additional traffic impact. The traffic generation from a B2 land use is higher than that for a

issues in relation to highways capacity in relation to this proposal. A new B8 proposal could result in a similar conclusion or marginal additional traffic impact.

The traffic generation from a B2 land use is higher than that for a B8 land use and, as such, a predominantly B2 proposal could result in additional offsite highway works being required. All All traffic impacts would need to be modelled in detail.

The Technical Note in relation to junction 1 of the M180 identifies that a previous traffic study for the site provided a forecast traffic distribution of 90% of light vehicles and up to 100% of heavy vehicles being likely to route to the west of the site on the M180, or to local destinations via local routes to the north or south of the site.

The residual (circa) 10% of vehicles which were forecast to travel to the east of the site are likely to use the A18, which provides a direct link to Scunthorpe (for light vehicles) and, also, provides access to the M180 (east) using the A161.

Both the A18 and the A161 carry signs which confirm that they are recommended routes for goods vehicles. As such, if there are any HGV movements to or from the east they are able to




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DMBC/Wood Response

B8 land use and, as such, a predominantly B2 proposal could result in additional offsite highway works being required. All traffic impacts would need to be modelled in detail to confirm the mitigation requirements. The Technical Note in relation to junction 1 of the M180 identifies that a previous traffic study for the site provided a forecast traffic distribution of 90% of light vehicles and up to 100% of heavy vehicles being likely to route to the west of the site on the M180, or to local destinations via local routes to the north or south of the site. The residual (circa) 10% of vehicles which were forecast to travel to the east of the site are likely to use the A18, which provides a direct link to Scunthorpe (for light vehicles) and, also, provides access to the M180 (east) using the A161. Both the A18 and the A161 carry signs which confirm that they are recommended routes for goods vehicles. As such, if there are any HGV movements to or from the east they are able to access the M180 (east) using

the A18. The forecast impact on the A18 is around one additional vehicle movement per minute during the peak hours. Such a small impact is likely to have a minimal or negligible impact on the operation of an ‘A’ classification road.

A Transport Assessment Scoping has been undertaken by Development Planning Limited dated September 2019 and was included as part of the EIA Scoping Request which was submitted to Doncaster Council on 24 September. A copy is included within Appendix 7. The Assessment Scoping sets out the how the highways assessment will be undertaken. It includes full details of route choices and the traffic generation within the appendices. Initial discussions have taken place with Highways England and a copy has been sent to them for consideration in order to agree the scope of the Traffic Assessment, including the junctions which are to be analysed. Contact has also been made with Doncaster Council Highways Department to agree the objectives of the Transport Assessment.

Overall it is considered that subject to the necessary Transport Assessments and modelling it is highly likely that an appropriate solution to highways capacity can be reached.

access the M180 (east) using the A18.

The forecast impact on the A18 is around one additional vehicle movement per minute during the peak hours. Such a small impact is likely to have a minimal or negligible impact on the operation of an 'A' classification road.

A Transport Assessment Scoping has been undertaken by Development Planning Limited (Sept 2019) and was included as part of the EIA Scoping Request (submitted to the Council on 24 Sept 2019). A copy is included (Appendix 7). Overall it is highly likely that an appropriate solution to highways capacity can be reached.

Public Open Space

Site 160 has a neutral score for criterion 9Ai. The illustrative masterplan (Appendix 8) shows a significant areas of public open space within the centre of the site. It is considered that the score should be positive.

Ecology

Site 160 has a negative score for criterion 12Ai. There are no Statutory Designated Sites within the site boundary. There are three Statutory Designated Sites of International nature conservation interest within proximity. Thorne & Hatfield Moors Special Protection Area (SPA), Thorne Moor




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Public Open Space We note that Bradholme Farm, Site 160 has a neutral score for criterion 9(Ai) within the Sustainability Appraisal. The illustrative masterplan included within Appendix 8 shows a significant areas of public open space within the centre of the site. Given the potential to include public open space within the site it is considered that this score should be positive.

Ecology For criterion 12(Ai) of the Council’s Sustainability Appraisal, Bradholme Farm, Site 160 scores a negative rating. From an ecological perspective there are no Statutory Designated Sites within the site boundary. There are three Statutory Designated Sites of International nature conservation interest within proximity. Thorne & Hatfield Moors Special Protection Area (SPA), Thorne Moor Special Area of Conservation (SAC) and Hatfield Moor SAC, which both form part of the SPA. Thorne Moor lies 2.9km to the north east and Hatfield Moor 2.9km to the south east of the site. There is only one Statutory Designated Site of National nature conservation interest, Buntings Wood, Thorne Local Nature Reserve (LNR) which lies 1.0km to the north west of the proposed development site. In line with the NPPF (paragraph 170 d) the development of the site will seek to minimise impacts on and provide net gains for biodiversity.

To date there has been ecological input into the illustrative masterplan to ensure that mitigation is built-in to the proposed development design to retain key features, such as ditches, hedgerows and mature trees so that ecological effects are be avoided as far as possible. Additional mitigation measures that may be required includes:

• protection of ditches, hedgerows and trees during construction (e.g. with temporary fencing);

• new habitat creation within the development, e.g. hedgerows, wildflower meadow, native tree and

Special Area of Conservation (SAC) and Hatfield Moor SAC, which both form part of the SPA. There is only one Statutory Designated Site of National nature conservation interest, Buntings Wood, Thorne Local Nature Reserve (LNR) which lies 1.0km to the north west of the proposed development site.

In line with the NPPF (para 170 d) the development of the site will seek to minimise impacts on and provide net gains for biodiversity.

The illustrative masterplan shows that mitigation is built-in to the proposed development design to retain key features, such as ditches, hedgerows and mature trees. Additional mitigation measures that may be required include:

- protection of ditches, hedgerows and trees during construction;

- new habitat creation within the development, e.g. hedgerows, wildflower meadow;

- measures to avoid direct impacts to protected species;

- minimisation of lighting during construction; and

- Provision of features to benefit protected and notable species.

The previous planning application received a positive response from Natural England and the




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shrub planting and wetland creation;

• measures to avoid direct impacts to protected species; e.g. undertaking vegetation clearance

outside bird nesting season utilising method statements where required;

• minimisation of lighting during construction (e.g. using low-level motion-activated security lighting)

and ecological input to development lighting design to minimise impacts to bats and other

nocturnal species; and

• Provision of features to benefit protected and notable species such as bird and bat boxes.

We note that the previous application at Bradholme Farm ref: 08/03189/FULM received a positive response from Natural England with regard to the proposed biodiversity improvements. The principles applied to the previous application will be applied to the forthcoming planning application Given that there is potential for a range of biodiversity improvements we consider that Site 160, Bradholme Farm should have a positive score for Biodiversity.

Landscape The Sustainability Appraisal rates Bradholme Farm, Site 160 neutrally in relation to landscape capacity (criterion 12Bi). The 2008 application (ref: 08/03189/FULM) for this site included an assessment which took into the Landscape Character Assessment and Capacity Study of 2007 which concluded that the capacity of this area for strategic employment development is generally limited. The assessment submitted in support of the application included a detailed survey of the specific area within a 5 kilometre radius of the site.

The report demonstrated the capacity in this location is higher than the general area, due to disturbed and degraded elements of the landscape not typical of the landscape character area as a whole. Large scale built development and disturbance associated with the motorways is found on the edge of Thorne in the

same principles will be applied to the forthcoming application. Consider that Site 160 should have a positive score for Biodiversity.

Landscape

Site 160 has a neutral score for criterion 12Bi.

The 2008 application included an assessment taken from the 2008 Landscape Character Assessment and Capacity Study. The Study concluded that the capacity of this area for strategic employment development is generally limited. The Council is still referring to the Study within the evidence base for the Publication Draft, therefore the assessment undertaken as part of the 2008 application still stands: the capacity in this location is higher than the general area, due to disturbed and degraded elements of the landscape not typical of the landscape character area as a whole.

The development of the site can be designed to incorporate mitigation measures and new areas of biodiversity would be included.

Minerals

Site 160 has been given a '?' rating for criterion 14 Ai. A Mining and Minerals Report (included with the 2008 planning application) (also in Appendix 10) identified that the




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immediate vicinity of the site. It was accepted that the development proposed as part of the 2008 application would not be noticeably harmful to the generally undeveloped rural character of the area beyond, nor would it encroach into the intact farmland buffer zone around Thorne and Hatfield Moors. A copy of the Officer Report confirming the acceptance of the assessment in support of the 2008 application is included within Appendix 10.

We note that the Council is still referring to the Landscape Character Assessment and Capacity Study of 2007 within the evidence base for the Publication Draft and therefore consider that the assessment undertaken as part of the 2008 application still stands: the capacity in this location is higher than the general area, due to disturbed and degraded elements of the landscape not typical of the landscape character area as a whole. The development of the site can be designed to incorporate mitigation measures such as coloured cladding to enable better assimilation into the background, fringing trees would be species native to the area and would soften, though not screen, the mass of the buildings. New areas of biodiversity would be included.

Minerals We note that Bradholme Farm has been given a ‘?’ rating in relation to criterion 14 A(i) Minerals sterilisation on the Sustainability Appraisal. A Mining and Minerals Report was included within the planning application ref: 08/03189/FULM. This report identified that the thicknesses and lateral consistency of the deposits under

Bradholme Farm are irregular, and together with an unfavourable overburden to mineral ratio, the deposits are not viable for commercial extraction. Over time three separate aggregate companies have surveyed the site and decided not to pursue further investigations. A copy of the Minerals and Mining Report is included within Appendix 10 for reference.

thicknesses and lateral consistency of the deposits under the site are irregular and are not viable for commercial extraction. Three separate aggregate companies have surveyed the site and have decided not to pursue further investigations.

Consider that the site should be rated positively in relation to criterion 14 Ai.

Agricultural Land

Site 160 has been given a negative rating for criterion 14 Aii. An Agricultural Land Assessment (Appendix 11) was submitted as part of the original planning application in 2008. It identifies that the majority of the site has little agricultural potential - 85% of the site is assessed as subgrade 3b. This was reflected in the officer's report to the 2008 application. All necessary information will be submitted as part of a forthcoming planning application.




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We therefore consider that Site 160, Bradholme Farm should be rated positively in relation to criterion 14 A(i).

Agricultural Land Criterion 14 A(ii) of the Sustainability Appraisal relates to best and most versatile agricultural land. We note that Bradholme Farm has been given a negative rating. This is despite the availability of an Agricultural Land Assessment by Agricultural Systems Analysis Limited from a previous application (ref: 08/03189/FULM) on

this site. A copy of this report is included within Appendix 11 and the relevant illustrations are included below.

The assessment identifies that the majority of the site has little agricultural potential, with 85% of the site assesses as subgrade 3b.

Figure 1 Agricultural Land Classification Maps – Bradholme Farm

Survey work involved the examination of auger borings on a 100 metre grid and by examination of 1.5 metre deep soil profile pits, to ascertain stoniness subsoil structure and drainage class. The site is mainly composed of heavy clay loams, falling within similar severe wetness class grade IV, limiting the majority of the site to Grade 3b.

We also note the officer’s report from the previous application (ref: 08/03189/FULM) concluded: “the application site comprises mainly Grade 3b agricultural land (according to the DEFRA classification) with approximately 12 hectares of Grade 3a. The loss of the better quality land is not assessed as significant bearing in mind that the capital accrued from the sale of the land will enable the farming business to re-invest in other more appropriate land. Moreover the topsoil from the better quality land would be re-used on and off the site”. All necessary additional information, including if required a Soil Management Plan will therefore be submitted as part of a forthcoming planning application. It is not




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considered that any potential significant effects will arise from the loss of agricultural land as part of the development of Gateway 180.

05197 Peacock & Smith Blue Anchor Leisure

Inaccurate Sustainability Appraisal Scores for West Moor Park East (Site 937/1031) 3A(ii) Distance to Bus Stop 3.1 In addition to the concerns regarding the SA appraisal approach relating to public transport accessibility, which are detailed in the attached Sandersons Associates report (Appendix 1), there is a clear inaccuracy regarding the scoring of SA 3A(ii). 3.2 As explained above, at the 2018 Informal Draft Local Plan consultation stage Blue Anchor Leisure submitted a package of information specific to West Moor Park East (Site 937/1031/938/1014), including written confirmation with costs from First Bus that an existing frequent bus route (Service 15) can be extended into the site; and that this service could become viable after five years without subsidy. 3.3 The extension of the 15 Service frequent bus route into the site should result in a light green score in relation to 'distance to bus stop (3A(ii))' as this would result in a stop within the proposed development, but West Moor Park East is currently awarded a pink (negative) score. 8A(i) Encourage the Re-use of Land and Buildings 3.4 In the SA West Moor Park East (Site 937/1031/938/1014) is awarded an orange (neutral) score in relation to the re-use of land and buildings (8A(i)) which indicates that it is wholly a greenfield site that has not been previously-developed. 3.5 However, the land occupied by West Moor Park East accommodates numerous roads, tracks, car parking areas and structures associated with the existing motorsport uses on the site; and abandoned buildings associated with the former Holme Wood Farm - as demonstrated by the pictures and site description provided to the Council in the Vision document that was submitted at the 2018 Informal Draft Local Plan consultation stage (Appendix 5). It is inaccurate to refer to it as a wholly greenfield site. The site should be awarded a light green score (site is located on brownfield land and would bring back into effective use previously-developed land and/or buildings (gross area up to 4 ha). 13B(i) Archaeology 3.6 The SA identifies that there would be significant negative effects (red score) on archaeology (13B(i)) with the development of West Moor Park East (Site 937/1031/938/1014) that may not be possible to

Inaccurate Sustainability Appraisal Scores for West Moor Park East (Site 937/1031)

Objective 3A(ii) - Distance to Bus Stop - The correspondence from First Bus was taken into account when submitted as part of the 2018 consultation. However, all sites have the potential to improve public transport accessibility through develop contributions etc so such material has not been used to revise SA scoring as set out in the methodology. No change required, the site is currently located 800m+ from the high frequency bus network.

Objective 8A(i) - Reuse of Land & Buildings - The vast majority of the site is greenfield and the current neutral scoring is considered appropriate and justified. Buildings associated with farming uses are still classed as being Greenfield.

Objective 13B(i) - Archaeology - sites have been independently assessed by consultants and the findings are considered justified and consistent.




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mitigate. However, the part of the site identified as having a constraint already has a part implemented and extant planning permission for major motorport and leisure uses (LPA refs: 09/00728/OUTA and 10/01593/REMM) - which is a clear indication that development is acceptable. The proposed development of the site for employment would give rise to no greater impact on archaeology than this fallback position and therefore it should be awarded an orange (no adverse impact) score. At worse the score should be pink (adverse impact which may be possible to mitigate). (SEE SUPPORTING DOCS for Appendices)


Site Selection - Inaccurate Sustainability Appraisal Scores for Balby Carr Bank (Site 092) 4.1 Notwithstanding the concerns regarding the SA appraisal approach relating to public transport accessibility, which are detailed in the attached Sandersons Associates report (Appendix 1), there are also inaccuracies in the scoring of the Council's assessment for a number of employment site options. These are set out below. Balby Carr Bank (Site 092) 4.5 3A(ii) Access to bus services - the bus services along Balby Carr Bank are not high frequency services, which is a requirement of the criterion. The nearest high frequency bus stops are approximately 700m from Site 092 and therefore this site should be awarded a neutral (orange) score rather than the light green positive score in the Council's SA. (SEE SUPPORTING DOCS for Appendices)

Inaccurate Sustainability Appraisal Scores for Balby Carr Bank (Site 092) Balby Carr Bank (site 092) also has inaccuracies for the SA criterion for A(ii) Access to bus services. The bus services along Balby Carr Bank are not high frequency, which is a requirement of the criterion. The nearest high frequency bus stops are 700m from the site. This site should be awarded a neutral (orange) score rather than a green positive score.

Objective 3Aii - Access to high frequency bus service - the SA methodology for this criteria is clear that it is based on SYPTE’s high frequency bus network (actual bus stops shown in GIS) from which sites have been assessed using straight line as the crow flies distances using the closest site boundary. Part of the site is within the 400m buffer of the bus stops on Dryden Rd/ Weston Rd, Balby and hence the positive (+ green) score


Site Selection - Inaccurate Sustainability Appraisal Scores for Carcroft Common (Site 441) 4.1 Notwithstanding the concerns regarding the SA appraisal approach relating to public transport accessibility, which are detailed in the attached Sandersons Associates report (Appendix 1), there are also inaccuracies in the scoring of the Council's assessment for a number of employment site options. These are set out below. Land at Carcroft Common (Site 441) 4.6 3A(ii) Access to bus services - no evidence has been provided that Site 441 would be within a safe 400m walk from high frequency bus services. The light green positive score awarded in the Council's SA should therefore be amended to a neutral

Inaccurate Sustainability Appraisal Scores for Carcroft Common (Site 441)

Objective 3Aii - Access to high frequency bus service - the SA methodology for this criteria is clear that it is based on SYPTE’s high frequency bus network (actual bus stops shown in GIS) from which sites have been assessed using straight line as the crow flies distances using the closest site boundary. Part of the site is within the 400m buffer of the bus stops on Askern Rd, Toll Bar and hence the positive (+ green) score




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(orange) score. (SEE SUPPORTING DOCS for Appendices)


Site Selection - Inaccurate Sustainability Appraisal Scores for Land East of Poplars Farm, Auckley (Site 941) 4.1 Notwithstanding the concerns regarding the SA appraisal approach relating to public transport accessibility, which are detailed in the attached Sandersons Associates report (Appendix 1), there are also inaccuracies in the scoring of the Council's assessment for a number of employment site options. These are set out below. Site 2, Land east of Poplars Farm, Auckley (Site 941) 4.7 3A(ii) Access to bus services - the bus services that operate along A638 Great North Road do not represent a high frequency service. As explained in the attached report by Sanderson Associates (Appendix 1), this is confirmed in the Local Highway Authority consultation responses to the pending planning application for Site 941, where the highways officer has commented that the services are not regarded as high frequency. 4.8 The walking distance to the bus stops on the A638, close to the junction with High Common Lane, are approximately 500m from the proposed access junction for Site 941 and this walking distance will increase as a result of a new roundabout access. The site should therefore be awarded a neutral (orange) score rather than the light green positive score in the Council's SA. (SEE SUPPORTING DOCS for Appendices)

Inaccurate Sustainability Appraisal Scores for Land East of Poplars Farm, Auckley (Site 941) Regarding land east of Poplars Farm, Auckley (Site 941) and SA score 3A(ii) access to bus services - the services that operate along A638 Great North Road do not represent a high frequency service and this is confirmed in the Local Highway Authority consultation response to the pending planning application for Site 941 - the highways officer has commented that the services are not regarded as high frequency. The bus stops are approximately 500m from the proposed access junction and this will increase as a result of a new roundabout access. The site should therefore be awarded a neutral (orange) score rather than the light green positive score in the Council's SA.



Site 001 - Sustainability Appraisal Scores 3A(i) Access to train station 4.1 As stated in the attached report by Sanderson Associates (Appendix 1) and in our client's associated objection to the Site Selection Process, Thorne North is further than 1.2km of Thorne train station once practical walking distances are taken into account. 4.2 Furthermore, is it relevant to note that Thorne train station is served by an hourly train service that operates between Hull and Sheffield, via Doncaster. Between Doncaster and Thorne North, the service stops at Kirk Sandall and Hatfield & Stainforth only. Therefore, even if future occupiers of the Thorne North site were willing to walk or cycle to the train

Inaccurate Sustainability Appraisal Scores for Site 001 - Thorne North.





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station, the available services are limited and are unlikely to be a viable option for most people; and will not necessarily provide a good and convenient means of accessing an employment site for a high proportion of the population, dependent very much on the location of stops and routes. 4.3 The neutral (yellow) score that has been awarded against this criterion should therefore be changed to a red (negative) score. 3A(ii) Distance to Bus Stop 4.4 Site 001 is located over 800m from a bus stop. Therefore, the negative red score currently provided for bus accessibility is considered to be correct. 4.5 It is noted that a number of planning applications have been submitted for the site (Applications No. 15/02252/OUTM & 16/02136/OUTM), which suggest that bus service improvements may be provided for the site, which could involve the diversion of the No. 87 bus service. However, the attached report by Sandersons (Appendix 1) notes that no details have been provided to confirm what, if any, bus service improvements would be delivered. Furthermore, it is noted that in the SYPTE consultation response to planning application no. 15/02252/OUTM, it was confirmed that whilst a further diversion of bus service No. 87 (that currently diverts to The Range on Mount Pleasant Road twice per day) may be feasible, this service is not commercially viable and would require long term funding from the development. As such, Sandersons are of the view that the long-term viability of any bus service that may be re-routed to serve the site is not secure. 4.6 Sandersons further note that the No.87 bus service that the applicant has suggested may be diverted is made up of 3 bus routes (87, 87a and 87b) that serve different routes between Thorne and Doncaster. Therefore, the prospect of diverting multiple routes is unlikely and casts further doubt on whether a high frequency bus service could be provided for the development. 4.7 It is concluded by Sandersons that without evidence to the contrary, even with development S106 funding, Site 001 would not be served by a high-quality bus service; and therefore the negative bus accessibility is considered to be correct for this site. This is particularly so in the context for the need for a service to be self-funding when any developer subsidy is finished. Overall SA Scoring 4.8 The Site Selection Report asserts that Site 001 scores similarly to other scores through the SA process. However, the revised SA scores provided in the attached report by Sandersons indicates that there are considerable

Objective 3B(ii) Distance to Bus Stops - note the Representation agrees with the SA scoring for this criteria. In line with the response above, scores have not been revised to take into account possible improvements that may come about from developer contributions.

Overall conclusions on SA scoring are noted. The Site Selection Methodology and Results report sets out reasons for why sites have been supported/ rejected which includes a number of considerations as well as the SA process.




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differences between Site 001 and West Moor Park East (Site 937/1031/938/1014) in respect of accessibility - as shown by the extract from the Sandersons report below. Site: 937/1031 West Moor Park East Train Accessibility: N/A Bus Accessibility: + Cycle Accessibility: 0 Road Access: + Ability to minimise travel to work distances: + Site: 001 Thorne North Train Accessibility: - Bus Accessibility: - Cycle Accessibility: 0 Road Access: + Ability to minimise travel to work distances: - Site: 092 Balby Carr Bank Train Accessibility: - Bus Accessibility: 0/+ Cycle Accessibility: 0 Road Access: 0 Ability to minimise travel to work distances: + Site: 441 Carcroft Common Train Accessibility: 0 Bus Accessibility: 0 Cycle Accessibility: 0 Road Access: 0 Ability to minimise travel to work distances: + Site: 878/1032 Rossington Train Accessibility: N/A Bus Accessibility: + Cycle Accessibility: 0 Road Access: 0 Ability to minimise travel to work distances: + Site: 941 Poplars Farm Train Accessibility: - Bus Accessibility: 0 Cycle Accessibility: 0 Road Access: 0/+ Ability to minimise travel to work distances: 0 4.9 In our client's associated objection to the Site Selection process we also demonstrate that there are material differences between Site 001 and West Moor Park East in respect of other SA criteria, with the latter site performing better overall. 4.10 In the light of the above, we consider that the SA process does not support allocation of Site 001 in preference to West Moor Park East. The proposed allocation of Site 001 is not justified in that regard. (SEE SUPPORTING DOCS for Appendices)

05286 Walker Morris LLP A A Lund 3.1 The Site was previously in use as a sand and gravel quarry from the 1940s to the 1960s. The use of the quarry was discontinued in the 1960s and since then no activity or remediation has taken place. 3.2 Appearance 3.3 The quarry retains its artificial land features, where the excavation of the quarry is visible, in uniform parcels separated by raised paths/old roads formed by bunds. The top soil has been removed and very little ruderal vegetation is able to grow. The absence of any remediation since the discontinuance of the quarry render the Site unsuitable for agriculture. 3.4 The uneven topography is itself an alien feature in the landscape, which is unlike any of the surrounding flat fields. The Site is plainly dissimilar to the surrounding landscape. The Site has not "blended

Previously developed land (PDL) Includes justification as to why land should be classified as PDL including various legal cases. No conditions were imposed re the remediation of the site post use as a quarry. There has been no 'Review of Old Mineral Permissions' (ROMP) on the site. Given length of time since the end of quarrying any residual or unidentified restoration requirements in





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into the landscape" (Note 1 - 1 See previously developed land definition, page 70 National Planning Policy Framework.) 3.5 The Site is well enclosed by boundary mature hedgerows and trees. There are limited views into the site from the roads (Hurst Lane and Mosham Road). 3.6 Conditions 3.7 We understand the quarry did not go through the Review of Old Minerals Permissions (ROMP) and no conditions regarding the remediation were ever attached to permissions for the Site (or if so are no longer enforceable). 3.8 In the absence of any conditions or other development management procedure making provision for the site's restoration, the Site is 'previously developed land' as defined in the Glossary, Annexe 2 of the Framework. 3.9 Sustainability Appraisal / Strategic Environmental Assessment 3.10 The relevance and significance of whether the land is classified as previously developed land is evident in the Sustainability Appraisal, prepared by Wood Environment and Infrastructure Solutions UK Limited. The Site (ref: 446) is identified in the Appraisal section as being Greenfield, rather than Brownfield. In the assessment matrix, the Site is scored '0' for being "located on greenfield land that has not previously been developed". The commentary for the Site also states this is on Grade 3 agricultural land, but that it is not possible to ascertain whether this is best and most versatile land. The land is not in agricultural use and almost all of the topsoil has been stripped form the land. The Site is Previously Developed Land. As such the Sustainability Appraisal cannot be relied upon to give an accurate assessment of the Site's suitability and sustainability, while these errors remain uncorrected. 3.11 Assessment of Previously Developed Land Definition 3.12 There is an interesting history to the definition of PDL. The 7th March 2000 version of PPG3 contained a longer definition than appears in the current version of the Framework which appeared to have two tests. That formulation of language was considered by Mr Justice Sullivan in Dodds and Hands v Secretary of State for the Environment, Transport and the Regions [2002] EWHC 84 (Appendix A) Admin which found the "clear reason" that could outweigh the reuse of the site was a separate distinct test. Subsequently, the June 2011 version of PPS3 dropped the second limb of the test but kept the same language in respect of the provisions relating to "blended into the Landscape in the process of

a relevant planning permission would be unenforceable. Re site 'returning to nature' - it is an artificial landscape - difficult to say it has blended back into surrounds. Sustainability Appraisal (SA) 1. Contends that the Sustainability Appraisal (SA) for the site is flawed and has errors. 2. Site shown at Greenfield when it should be BF, Previously Developed Land (PDL). 3. Site shown as Grade 3 agricultural land - it is not possible to ascertain if it is 'best' or 'most versatile' land as all topsoil has been stripped. 4. SA part 3B is incorrect re proximity to local services. 5. Scoring re proximity to schools is also wrong. 6. SA is not consistent with the NPPF. 7. Site is a Brownfield (BF) site. 8. SA is flawed in not prioritising BF sites as per LP aims. 9. LP is releasing GF land whilst retaining BF sites (such as 446) in the Countryside.




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time (to the extent that it can reasonably be considered as part of the natural surroundings)". The 2012 version of the Framework dropped the words in brackets from its predecessor definition. The 2018 version of the Framework dropped the words "in the process of time". The 2019 version maintains that wording, thus the present definition is "and land that was previously developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape". 3.13 The approach to the interpretation of PDL has been considered by the Courts on a number of occasions. This was recently considered in the Court of Appeal in Dartford Borough Council v Secretary of State for Communities and Local Government and others (2017) EWCA Civ 141 (Appendix B). Essentially the language is to be given its ordinary common sense meaning in context. There is no need to look at previous iterations of policy in order to understand the meaning of the language used in its current context. 3.14 The relevant context is that the current Framework provides significant emphasis and importance to the reuse of Previously Developed Land, especially in urban areas. Paragraph 118 (c) requires substantial weight to be given to the value of using suitable brownfield land within settlements; paragraph 68 confirms the importance of using brownfield registers to identify housing land; paragraph 84 encourages the use of PDL for employment uses; even in the greenbelt paragraph 145(g) facilitates the complete redevelopment of PDL. 3.15 Although the language surrounding the concept of "blended into the landscape" has been reduced there is absolutely no reason to suppose that the trimming down of the language has altered its meaning or the policy. The fact that the phrase "to the extent that it can be reasonably considered as part of the natural surroundings" has been deleted does not alter its meaning. The words "blended into the landscape" must mean that a relevant site has blended into something to which it is adjacent ie, the surrounding landscape. This point has been before the Courts in R (Bristol City Council v First Secretary of State (i) and Edward Ware Urban Renewal Limited (ii) 2004 EWHC 1934 (Admin) (Appendix C). In that case an Inspector had referred to the fact that the subject site was within an urban area and that "there are no natural surroundings". It was suggested by the Claimants (paragraph 16) that this was a misapplication of National Policy (then in Annexe C PPG3) and was




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irrational. Mr Justice Sullivan dismisses the argument (see paragraphs 18 and 19) confirming that the test is "not to be applied in a mechanistic way". In concluding that there were no "natural surroundings" the Inspector had not been purporting to lay down some principle of general application but this was a factor that could be taken into account. The Court dismissed the challenge. 3.16 The phrase "permanent structure" is deliberately not confined to buildings. Thus, an artificial dome of a landfill or excavated quarry bottom and bunds would constitute such a structure in and of themselves, the latter remain readily apparent on the Site. 3.17 The Dodd and Hands case dealt with railway sidings. In Mrs Olive Mrs Edwards v Rhondda Cynon Taff County Borough Council [2014] UKUT 0435 (Appendix D) the Court considered whether a disused railway cutting would qualify under the PDL definition. In both cases it is clear that 'structures' which create an artificial land form are plainly considered to qualify. A Secretary of State decision and Inspector's report (Appendix E and F) dealt with a former mineral site and the artificial structures of what remained qualified under the definition of PDL. Paragraphs 13.5 to 13.7 set out the Inspector's views on the nature of the site and whether it constituted PDL. In that case, there was a significant amount of mounding, rubble and tracks on the site. Photographs showed extremely uneven land and lines of tracks. That site had a very unnatural and artificial landform as a result of its previous use. The mounding of the tracks were visible and had not blended into the landscape and bore no resemblance to any part of its surroundings. 3.18 The first relevant exclusion in the PDL definition is that the site is: "land that has been developed for mineral extraction or waste disposal by landfill, where provision for the restoration has been made through development management procedures." However, it appears that no conditions were imposed to ensure the remediation of the site and no ROMP took place here. The absence of any conditions or review of minerals permissions indicates there has been no development management procedures to restore this Site. This exclusion in the PDL definition does not therefore apply to the Site. 3.19 Given the substantial amount of time since the cessation of quarrying activities to the present day, any residual or unidentified restoration requirements in a relevant planning permission, would be unenforceable. 3.20 The question then remains as to whether the site can be




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judged to have blended into the landscape. All of the cases referred to above provide discussion on this topic and do provide some helpful insights, but each case must be judged on its own merits. Ultimately, this is a matter of judgment for the decision maker. The bunds and excavations can clearly be seen on the Site which appear as an artificial and alien landform in the surrounding landscape. The vegetation which has grown is tall ruderal species, but with the majority of the site uncovered earth. The on-site views indicate a clearly artificial landscape which is distinct from surrounding fields and quarries and could not be said to have blended into the landscape. 3.21 The Sustainability Appraisal makes an erroneous reference to this Site being 'Greenfield' and to its agricultural land classification. The Sustainability Appraisal's assessment of this Site is not consistent with the Framework and is unsound for this reason.

05286 Walker Morris LLP A A Lund 4.1 There is a policy presumption in favour of considering brownfield land in preference to other sites. 4.2 The National Planning Policy Framework 4.3 Paragraph 117 of the Framework endorses a 'brownfield first' approach to promoting land to meet the need for homes "in a way that makes as much use as possible of previously developed or 'brownfield land'". 4.4 Paragraph 118.c) of the Framework is requires planning policies to give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land. Paragraph 118.c) also promotes and supports the development of under-utilised land and buildings, especially where it would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively. 4.5 In Doncaster, where Green Belt land is being released for housing, paragraph 137 of the Framework is notable and significant to the consideration of previously developed land. Paragraph 137 requires local panning authorities to have examined fully all reasonable alternatives to meeting its identified need, before exceptional circumstances exist to justify the release of Green Belt land. 4.6 Doncaster Local Plan Publication Draft 4.7 The presumption in favour of considering brownfield land first is also a policy requirement and objective in the subject Doncaster

The SA has not given priority to the use of brownfield sites ahead of greenfield which is in conflict with NPPF. Further to this, there has not been a proper assessment of the avoidance of Green Belt first and foremost which could be achieved through the use of Brownfield non-Green Belt sites.

The SA criteria are considered to reflect BF land sufficiently and it is noted that Representations to the Local Plan Publication version cite that there is too much weight/priority to BF land over GF which they claim is not in conformity with NPPF. Notwithstanding this, see response above that the Council disputes that the site is Brownfield anyway.




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Local Plan Publication draft. Paragraph 3.5 lists a series of objectives in order to achieve the Local Plan's objectives. These include: 4.7.1 encourage the re-use of sites and buildings, especially well located and underused brownfield land (e.g. redundant/unused land and empty properties and underused floorspace) to help revitalise areas of low demand and stimulate growth; 4.8 The 'Plan, Monitor and Manage' definition in the Glossary of the Local Plan reinforces the priority to use brownfield sites first, stating: 4.8.1 Approach to housing delivery replacing predict and provide, housing sites are released (i.e. granted planning permission) only as and when they are needed so as to avoid an oversupply of land and so that development can be tied to planned infrastructure improvements and meet sustainability objectives such as ensuring brownfield sites are developed before greenfield sites 4.9 This representation raises no specific objections to the aims and objectives of the Local Plan or its preference to using brownfield land first. The objection focuses on the misapplication of the Framework's and Publication Local Plan's policies to brownfield sites. The Site is previously developed and its re-use for housing or an alternative use is encouraged in the Local Plan and Framework. The site scoring in the Sustainability Appraisal, which ultimately feeds into the prospective allocation of land in the Local Plan, is flawed and does not give priority to previously developed sites such as this. 4.10 It is notable that the Local Plan Publication draft proposes the release of land from the Green Belt to meet its identified housing need, while brownfield sites adjacent to villages such as this are prospectively retained as Countryside. 4.11 The allocations in the Local Plan Publication draft are contingent on accurate scoring in the Sustainability Appraisal. Whilst the Local Plan policies seek to give priority to brownfield land first, this objective is not carried through in the Sustainability Appraisal or the identification of land for housing. Consequently the evidence on which the Local Plan allocations are based is inaccurate and the Local Plan is unsound and inconsistent with national policy. The omissions in the Sustainability Appraisal also fail to consider reasonable alternatives to Green Belt release, and release of greenfield land, while brownfield land is available. The Local Plan is therefore unsound and fails to meet the 'Justified' test in the Framework.




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05286 Walker Morris LLP A A Lund 5.1 The omissions in the Sustainability Appraisal are not limited to the Site's definition as Greenfield land in agricultural use. At part 3B) Accessibility to Local Services, the Site is marked '0' for access, within 400m-800m to a neighbourhood shopping parade. The neighbourhood shopping parade in Auckley lies some 550m to the north of the Site. The score of '0' is defined in the Sustainability Appraisal as 'Neutral - Proposal is unlikely to create any significant effects (positive or negative) at present or in the future'. The score of '0' for a site which plainly meets the 400m-800m requirement is difficult to reconcile. It is assumed this is another error within the report and the Site should score a '+' 'Positive effects - The proposal will have a positive effect on the SA Objective when compared to the current and future baseline conditions. Minor adverse effects may result but the overall effect will be positive.' 5.2 Similarly, the Sustainability Appraisal scores the Site '0' on proximity to a primary school (within 400m-800m). However, the Site lies within 600m of Hayfield Lane Primary School and 600m of Auckley Junior and Infant School. This clear omission is unexplained and is assumed to be an error. 5.3 The Local Planning Authority's site selection process is reliant on the scoring in the Sustainability Appraisal. Where clear errors of scoring do occur, such as the case here, these errors feed into the allocations process. The errors in scoring therefore lead to a skewed site selection process which omit sites as being unsustainable when in fact they meet the assessment criteria. 5.4 The evidence base and Local Plan is therefore unjustified as it fails to consider reasonable alternatives.

Contends that the Sustainability Appraisal (SA) for the site is flawed and has errors. Part 3B is incorrect re proximity to local services. Scoring re proximity to schools is also wrong.

Objective 3B(i) - Access to Existing Centre - the site is located partly in the 400m-800m buffer and partly in the 800m+ buffer from the Neighbourhood Shopping Parade at Auckley so the current score (neutral 0 amber) is correct and justified/consistent.

Objective 3B(ii) - Access to Primary School - the site is located entirely in the 400m-800m buffer for primary schools at both Auckley (Auckley School) and Hayfield Green (Hayfield Lane Primary) so the current score (neutral 0 amber) is correct and justified/consistent.

Sites have been assessed using primarily objective criteria and supporting evidence has been published (both 2018 consultation and at Publication stage) to support the findings e.g. the interactive SA map and supporting technical appendices.

04444 Johnson Mowat Strategic Land Group

Having analysed the actual allocations in the Local Plan against the proposed target distribution in Policy 3 it is apparent that the distributions differ (see table on previous page). It is apparent that the Council's Sustainability Appraisal ('SA') has not considered the actual distribution of homes. Indeed the Sustainability Appraisal fails to assess the proposed distribution or the Local Plan target distribution. 2.60 The SA to accompany the 2015 Local Plan Issues and Options document included 6 alternative approaches to delivering the Boroughs growth needs and aspirations. This was refined following the consultation and a new hybrid option was developed which was appraised in the Growth Options SA Report in March 2016. The alternative options have then remained unchanged in

The actual amount of homes distributed around the borough has not been assessed in the SA, which only considers the target distribution. The options have remained unchanged since the 2015 SA. The level of distribution in the SA does not reflect the actual distribution. Of the 18 settlements in the hierarchy, only 8 are proposing to deliver a level of housing that meets the distribution

Section 3.3 of this Addendum sets out the justification for the indicative and proposed distribution amongst the Borough’s settlements. The indicative range has been assessed (Appendix I of the SA Report) and the overall level of housing delivery remains at the same figure of 920dpa which has consistently been the subject of appraisal.

Appendix J of the Publication SA appraises the proposed policies including Policy 3 which concerns the




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the SA of the Informal Consultation Draft Policies and Proposed Sites (2018) and the SA of the Publication Draft (2019). All of alternative options have been based on a requirement of 920 dpa. The four SA options are: Option 1: Core Strategy approach Option 2: Doncaster and Main Town focus Option 3: Greater dispersal strategy Option 4: Hybrid option: urban concentration and dispersal 2.61 Option 4 is the preferred approach which is a combination of Options 1 and 2. The appraisal of the 4 SA Options concludes that options 2 and 4 score best against the sustainability criteria. In summarising the preferred hybrid option the SA States at paragraph 5.2.10 that "It will maximise the regeneration of poorer urban areas, brownfield sites and existing service centres although could generate indirect regeneration benefits associated with greater delivery on higher value sites. This will ensure the benefits of growth, including jobs and housing, can be spread more widely across the Borough." 2.62 The SA of the Growth Options in March 2016 included a table of the distribution of the 920 dpa requirement in accordance with the 4 alternative distribution options. This is repeated overleaf in our Table 2. The distribution information of the individual options contained in the 2016 Growth Option SA is not repeated in the 2018 Informal Consultation SA or the 2019 Publication Draft SA, but the 2016 SA report is referred to. (SEE EMAIL FOR Table 2: Source SA of Doncaster's Growth Options - March 2016) 2.63 The Hybrid Option in the above table is the preferred approach which is included in the Publication Draft SA. This distribution however differs from the Local Plan target distribution and the actual proposed distribution of allocations included in the Local Plan. Table 3 overleaf demonstrates this. It compares the actual housing distribution in the Local Plan with the 4 SA options. To assist in interpreting the figures the settlements shaded in green are settlements where the actual proposed allocations in the Local Plan fall within the SA Option 4 range (or within 20% of the Option 4 fixed target). Settlements highlighted in red are those settlements where the actual proposed allocations falls outside the SA Option 4 range (or more than 20% of the SA Option 4 fixed target). Of the 18 settlements in the hierarchy, only 8 settlements are proposing to deliver a level of housing that meets the distribution in the SA preferred Option 4. The Publication Draft SA therefore does not assess the Local Plan housing target distribution or the actual Local Plan proposed housing

that is in the SA preferred option 4. It does not assess the target distribution or the actual Local Plan allocation distribution. This is a failing of the SA.

distribution of growth, whilst Appendices H and I appraise the strategic growth options and options for housing and employment growth respectively.




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allocation distribution. This is a failing of the SA. Doncaster Main Urban Area SA Option 1: 6900-8832 SA Option 2: 7590-9660 SA Option 3: 6210-7590 SA Option 4 (Hybrid): 7136-7696 Local Plan Allocations: 7441 Local plan Target Distribution (Policy 3): 6805 - 7315 Main Towns Adwick - Woodlands SA Option 1: 483-690 SA Option 2: 497-690 SA Option 3: 497-690 SA Option 4 (Hybrid): 270-829 Local Plan Allocations: 482 Local plan Target Distribution (Policy 3): 255 - 765 Armthorpe SA Option 1: 483-690 SA Option 2: 497-690 SA Option 3: 497-690 SA Option 4 (Hybrid): 800 Local Plan Allocations: 1049 Local plan Target Distribution (Policy 3): 420 - 990 Conisborough & Denaby SA Option 1: 828-1035 SA Option 2: 497-690 SA Option 3: 497-690 SA Option 4 (Hybrid): 450-1009 Local Plan Allocations: 528 Local plan Target Distribution (Policy 3): 465 - 975 Dunscroft, Dunsville, Hatfield & Stainforth SA Option 1: 897 SA Option 2: 497-690 SA Option 3: 497-690 SA Option 4 (Hybrid): 1174 Local Plan Allocations: 1968 Local plan Target Distribution (Policy 3): 575 - 1805 Mexborough SA Option 1: 483-690 SA Option 2: 497-690 SA Option 3: 497-690 SA Option 4 (Hybrid): 465-1024 Local Plan Allocations: 310 Local plan Target Distribution (Policy 3): 485 - 985 Rossington SA Option 1: 897 SA Option 2: 497-690 SA Option 3: 497-690 SA Option 4 (Hybrid): 934 Local Plan Allocations: 1219 Local plan Target Distribution (Policy 3): 285 - 895 Thorne & Moorends SA Option 1: 828-1035 SA Option 2: 497-690 SA Option 3: 497-690 SA Option 4 (Hybrid): 450-1009 Local Plan Allocations: 736 Local plan Target Distribution (Policy 3): 510 - 1020 Service Towns and Larger Villages Askern SA Option 1: 483-690 SA Option 2: 138-276 SA Option 3: SA Option 4 (Hybrid): 165 Local Plan Allocations: 691 Local plan Target Distribution (Policy 3): 165 Auckley - Hayfield Green SA Option 1: 0 SA Option 2: 0 SA Option 3: Up to 207 SA Option 4 (Hybrid): 105 Local Plan Allocations: 255 Local plan Target Distribution (Policy 3): 125 Barnburgh - Harlington SA Option 1: 0 SA Option 2: 0 SA Option 3: Up to 207 SA Option 4 (Hybrid): 105 Local Plan Allocations: 66 Local plan Target Distribution (Policy 3): 60 Barnby Dun SA Option 1: 0 SA Option 2: 0 SA Option 3: Up to 207 SA Option 4 (Hybrid): 105 Local Plan Allocations: 104 Local plan Target Distribution (Policy 3): 105 Bawtry SA Option 1: 0 SA Option 2: 138-




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276 SA Option 3: 276-414 SA Option 4 (Hybrid): 105 Local Plan Allocations: 90 Local plan Target Distribution (Policy 3): 110 Carcroft - Skellow SA Option 1: Up to 345 SA Option 2: 138-276 SA Option 3: 276-414 SA Option 4 (Hybrid): 255 Local Plan Allocations: 307 Local plan Target Distribution (Policy 3): 250 Edlington SA Option 1: Up to 345 SA Option 2: 138-276 SA Option 3: 276-414 SA Option 4 (Hybrid): 226 Local Plan Allocations: 665 Local plan Target Distribution (Policy 3): 230 Finningley SA Option 1: 0 SA Option 2: 0 SA Option 3: Up to 207 SA Option 4 (Hybrid): 45 Local Plan Allocations: 50 Local plan Target Distribution (Policy 3): 55 Sprotbrough SA Option 1: 0 SA Option 2: 0 SA Option 3: Up to 207 SA Option 4 (Hybrid): 90 Local Plan Allocations: 80 Local plan Target Distribution (Policy 3): 95 Tickhill SA Option 1: 0 SA Option 2: 138-276 SA Option 3: 276-414 SA Option 4 (Hybrid): 165 Local Plan Allocations: 74 Local plan Target Distribution (Policy 3): 165 Table 3: Comparison between the 4 SA Options and a comparison of SA Option 4 with the Local Plan Allocations. 2.64 The SA also appears to consider the Borough wide issue of flooding. It states at paragraph 5.2.23 that "Option 4 focusses more growth around the cluster of villages and towns in the south west of the Borough (e.g. Finningley, Auckley and Hayfield Green and Tickhill) where there are no known flood risk constraints." However, in reality, the actual proposed allocations in the Local Plan only collectively allocate/deliver 379 homes in those three named settlements (just 2.4% of the total). This hardly equates to a growth focus to the south west. 2.65 Whilst SA Option 4 purports to have taken into account flood risk - and its choice as the preferred option was partly justified on that basis - the final proposed distribution in the Local Plan bears little relation to Option 4, with only 8 out of the 18 settlements falling within the range or within 20% of the proposed Option 4 target. It is therefore not clear to what extent - if at all - flood risk has been taken into account in arriving at the proposed distribution of development. 2.66 Whilst the Housing and Site Selection Methodology and Results Report includes information following the Flood Risk Sequential and Exception Tests and individual site assessment results, there does not appear to be any information within the Publication Draft or evidence base that outlines the overall quantum of development proposed within the Borough in areas of high flood risk.




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While this information may be made available in the Flood Risk Topic Paper which will be issued at Plan Submission it should be available now to allow a proper consideration of whether flood risk has been adequately reflected. 2.67 The justifying text to Policy 3 at paragraph 4.41 states that: "The economic-led element of the housing allocation requirement (approximately 4.905 homes) is directed to the most sustainable and deliverable sites in the Doncaster Main Urban Area and Main Towns in accordance with defined 'growth ranges'; these ranges provide flexibility to select the most sustainable and deliverable sites across these settlements. The flood sequential approach is applied to urban sites and sustainable urban extensions across these settlements subject to the growth ranges. The Settlement Audit shows that Doncaster and the seven Main Towns are larger and have a greater service function than other settlements in the Borough. (underlining is our emphasis) 2.68 It appears from the above explanation, that the proposed distribution of dwellings has been considered ahead of the sequential test. This would be the inverse of the correct approach - the results of the sequential test should be a determining factor in establishing the proposed distribution. 2.69 Carrying out an SA of the Local Plan is a legal requirement which the Council have not met - instead they have carried out an assessment of an arbitrary housing distribution which bares little resemblance to the actual one being pursued. Nor has the SA considered a Spatial Distribution which seeks to minimise the amount of development to be delivered in the Green Belt and in areas at risk of flooding. Given national policy requirements in respect of both of those designations, that must be considered a reasonable alternative. The Local Plan is therefore unsound as it is not justified and is not reflective of national policy.

03116 DLP Minerals Investments Ltd

Objection to the Sustainability Appraisal

The Sustainability Appraisal fails to consider reasonable alternatives. The SA considers the impact of the following:

a. The planned housing allocations to meet the need to 2033 not 2035,

b. The planned provision of 889 dpa for the period 2018 to 2033 and not the higher requirement based on

Objection to the Sustainability Appraisal



The Plan and SA Report cover the period 2015 – 2035

The matter of the consideration of jobs-led growth was address in the August SA Report (p.56) as follows:

5.3.5 The Council, in line with the Sheffield City Region, has aspirations for economic growth. The Sheffield City Region SEP Refresh, whilst not




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meeting future economic growth which would be 1,073 dpa for the period 2015-2032.

The reasonable alternatives that the SA has failed to consider are as follows:

a. The impact of making housing allocations to meet the need to 2035,

b. The impact of making housing allocations to accommodate 1,073 dpa for the period 2015-2032 (or any higher alternative figure to support the demand for job-led growth to 2035).

3.0 REASONABLE ALTERNATIVES AND THE SUSTAINABILITY APPRAISAL

3.1 These soundness concerns with the approach to identifying the housing requirement have clear implications for the Council’s chosen spatial strategy and the scale and extent of housing allocations identified.

3.2 Paragraph 5.3.1 of the Council’s August 2019 Sustainability Appraisal lists the range of growth options tested and confirms that 920 dwellings per annum is the highest number tested. Paragraph 5.3.3 goes on to explained:

“All options would meet local needs, but Option 1 goes further by contributing to the Sheffield City Region Strategic Economic Plan and the broader aspirations of the northern powerhouse area, through employment-led housing growth and a higher target for employment land that provides for flexibility over the plan period;”

3.3 It is nonetheless the case that 920dpa does not in-fact reflect a figure to support the forecast demand for labour supply over the full plan period to 2035. The Council’s EFHNA 2018 provides a clear basis to test a further reasonable alternative of 1,073dpa. This would represent a more ambitious level of growth associated with planning positively for a full 15 year plan period from adoption. The associated requirement can be calculated as follows:

Jobs-led scenario 2015 – 2035 = 1,073 * 20 = 21,460 dwellings

3.4 This would represent an increase of +3,060 dwellings (21,460 vs 18,400) compared to the requirement indicated in Policy 3 of the Pre-Submission

b. The planned provision of 889 dpa for the period 2018 to 2033 and not the higher requirement based on meeting future economic growth which would be 1,073 dpa for the period 2015-2032.


a. The impact of making housing allocations to meet the need to 2035,


setting new housing targets for the city region (thus reverting to the previously published 7,000 dpa), does set a target for jobs growth of 1% per annum. The city region does not connect jobs and housing targets – the former being based on a general aspiration to improve life chances of local people, and the latter on demographic modelling. However, in order to provide an overall housing target, the ‘Economic Forecasts and Housing Needs Assessment’ (2018) does reconsider the Doncaster housing target, based on the updated Sheffield City Region job target. It has been calculated that if the housing target follows the standard methodology method (as per the NPPF) and is based on the aspirations of the emerging Sheffield City Region jobs target (1% uplift), then the housing target for Doncaster is 912 dpa. This is very similar to the local plan’s objectively assessed housing need target of 920 dpa, as identified through the earlier Housing Needs Assessment (2015), which has been subject to consultation previously. Given this, the local plan is proposing to retain the 920 dpa target and hence Option 1 is the Council’s preferred option.

In respect of the presentation of reasonable alternatives, an alternative is not reasonable if it does not meet the objectives of the plan. i.e. it is up to the authority to determine which alternatives are likely to meet this condition. The following Court Ruling applies:

The Queen on the Application of Rlt Built Environment Limited v The Cornwall Council v St Ives Town Council, 10/2016




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Local Plan. The Sustainability Appraisal also seeks to provide justification for the selected option with reference to the Council’s previous Housing Need Assessment (2015) indicating a requirement of 920 dwellings per annum. However, there is no clear relationship between these sources. In particular the 2015 Assessment was prepared substantially before the introduction of the government’s standard method to assess housing need so does not follow the same approach as the EFHNA 2018 in calculating local housing need plus an economic-led component. The 920dpa figure in the 2015 Assessment has not itself been subject to independent examination, albeit it was successfully challenged in earlier planning appeals determined under the NPPF20122.

3.5 Secondly, the 2015 Housing Needs Assessment is based on a different set of official subnational population and household projections. Finally, section 2.4 of the 2015 Housing Needs Assessment appears to indicate that 920dpa was identified as a requirement for the full 2015-2032 period. The more appropriate comparison in terms of the relevant timeframes is the 1,073dpa identified in the EFHNA to meet requirements in the Sheffield City Region for a minimum period of 15 years. This is the approach necessary to ensure that the Local Plan is consistent with national policy.

(iv) “Reasonable alternatives” does not include all possible alternatives: the use of the word “reasonable” clearly and necessarily imports an evaluative judgment as to which alternatives should be included. That evaluation is a matter primarily for the decision-making authority, subject to challenge only on conventional public law grounds.

(v) Article 5(1) refers to “reasonable alternatives taking into account the objectives… of the plan or programme …” (emphasis added). “Reasonableness” in this context is informed by the objectives sought to be achieved. An option which does not achieve the objectives, even if it can properly be called an “alternative” to the preferred plan, is not a “reasonable alternative”. An option which will, or sensibly may, achieve the objectives is a “reasonable alternative”. The SEA Directive admits to the possibility of there being no such alternatives in a particular case: if only one option is assessed as meeting the objectives, there will be no “reasonable alternatives” to it.

(vi) The question of whether an option will achieve the objectives is also essentially a matter for the evaluative judgment of the authority, subject of course to challenge on conventional public law grounds. If the authority rationally determines that a particular option will not meet the objectives, that option is not a reasonable alternative and it does not have to be included in the SEA Report or process.”

01937 Lichfields Theakston Estates Ltd

The Sustainability Appraisal: indicates that the site was rejected on the basis of this report. The capacity assessed in this report (969) is actually now approx. 800 homes and so Theakston Estates request the report is

The revised capacity is noted, however it is not considered that the revision down from an estimated 969 to 800 homes would change the way the site




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re-done. Previous information submitted to the Council in 2018 does not appear to have been considered in the published Sustainability Appraisal.

Two urban area Green Belt sites have been promoted: 033 and 115. Below are the compared scores:

Site Ref: 115

Site Name: Alverley Lane, Balby

Positive Score: 15

Negative Score: 7

Overall Score: 8

Site Ref: 003

Site Name: Land adjacent to 163 Sheffield Road, Warmsworth

Positive Score: 14

Negative Score: 7

Overall Score: 7

Site Ref: 436

Site Name: Land at Scawsby Lane

Positive Score: 13

Negative Score: 8

Overall Score: 5

With regards to archaeology, a report is appended which assesses the archaeological constraints and identifies mitigation measures to limit development impacts. Furthermore, it is considered the Roman Ridge in this location an enclosed corridor enclosed by hedgerows and therefore retains rural character and limits the views of development. The appended report considers development would not physically impact on this, and impacts can be mitigated through design such as reinforcing planting, applying buffer zones between development and the Roman Ridge, and incorporating open space in the buffer zone. Knowledge panels could also be provided to enhance the local understanding of the Roman Ridge - a new public benefit.

performs through the SA. This is because the criteria that use a site threshold to determine how a site scores use thresholds much lower than the 969 or 800 units (e.g. affordability and re-use of land and buildings use a much lower 100 units). The previous representations rebuttal to archaeology and surface water pollution was considered prior to the Publication version of the SA report being prepared. The Publication SA Report (and Site Selection Report) confirms that the site's score for Objective 14B(ii) Pollution to Surface Water Bodies was changed from significant negative effects (--) to neutral (0) and states the reason being that the site promoter has confirmed that the only water body identified is on the southern field which is to be excluded from the development so the developed area will be located 25m+ from the surface water body. The SA tables in the site selection report also show this updated score for the site.

Likewise, the Council considered the site promoters/ Northern Archaeological Associates Ltd’s report and looking at the masterplan considered it was appropriate to revise Objective 12 B(i) from significant negative effects (--) to neutral effects (0).




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The assessment also shows that there is likely a deserted medieval village with potential remaining earthworks in the southern field. LiDAR imagery indicates that in the southern field the remains are likely to be a combination of crofts and tots, road and ridge and furrow. Any cropmarks which have been indicated are common across this part of South Yorkshire and are not considered to be a constraint to development. The report recommends this is excluded from development and made open space, which would help facilitate a green corridor along Barnsley Road with better access and permeability. The proposals will also ensure the listed buildings are separated from the development and the wider site does not impact on these buildings, nor would development harm their significance.

It is considered careful master planning can help manage heritage impacts, and therefore the Sustainability score for heritage impacts should be neutral. There is also an error in the report related to the conclusion that the development will have a negative impact on pollution to surface water bodies - it is unclear how. Any concerns would be dealt with at application stage, the assessment should again be neutral.

An indicative masterplan is attached showing 800 new homes, a new school and other community shops and facilities, as well as a community park land to the west of Scawsby Lane. This would help address deficiencies in open space highlighted in the Settlement Background Paper. The parkland would include sports facilities, woodland play, allotments and wildlife habitats. This is a significant benefit which aligns with NPPF para. 138, the Settlement Background Paper and Local Plan Objective 13. Playing fields could also deliver additional education benefit by providing provision or car parking to support the existing schools on Barnsley Road. The masterplan details how this can all be achieved.

To ensure a sound plan, Theakston Estate recommends the site should be reassessed in the Sustainability Appraisal to change heritage impacts and pollution to surface water bodies to neutral (bringing the site in line with 033). Scoring should also be amended for 'Access to existing centre', 'biodiversity', and 'access to public open space' as the site can provide outcomes which are not currently recognised. This would give the Sustainability Appraisal a score of 9 - higher than the




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other Green Belt sites. The current scoring is wrong and based on false evidence - contrary to NPPF.

Proposed change: Site 436 should be allocated in the Plan, and the housing requirement for the plan period, the share for the urban area, the use of reserve development sites and the Sustainability Appraisal are all incorrect.

03116 DLP Plannign Ltd Mr Ian Brealey, Minerals Investments Ltd



b. The planned provision of 889 dpa for the period 2018 to 2033 and not the higher requirement based on meeting future economic growth which would be 1,073 dpa for the period 2015-2032.


a. The impact of making housing allocations to meet the need to 2035.


Failure to considerable the reasonable alternative 0f 1,073dpa

See section 3.3 on the Appraisal of the proposed spatial distribution which covers the plan period to 2035.

In order to demonstrate the likely effects of providing for a higher figure, Appendix C of this Addendum sets out an update to Appendix I (Appraisal of Options for Housing and Employment Growth) with an Option of a higher housing growth figure of 1,073.



C1 © Wood Environment & Infrastructure Solutions UK Limited


Appendix C Update to Appendix J of the Publication Local Plan - Appraisal of Policies Chapter 16: Spatial Proposals Policy 68: Doncaster Town Centre Policy 69: Key Doncaster Town Centre and main urban area mixed use sites Policy 70: Unity regeneration project Policy 71: Mexborough Town Centre Policy 72: Thorne Town Centre

Objective Sub-objective

68 69 70 71 72 Commentary 1. Maintain and increase Doncaster’s growth/prosperity and diversify its economic base

a) Local economy (maintain and strengthen) b) Diversify the economic base

++ ++ ++ ++ ++ Likely Significant Effects These policies provide a balanced approach to supporting retail uses across the Borough which should in turn help to strengthen the local economy and enhance overall prosperity. The policies are criteria-based which clearly sets out the expectations associated with their implementation. Policies, including Policy 50 include specific provision for employment land. Short/Medium/Long Term effects Effects are likely over the short, medium and longer term. Cumulative effects A significant positive cumulative effect would result in combination with other sustainable design policies, as all policies share a common goal to protect and enhance distinct characteristics of an area. Mitigation None required. Assumptions & Uncertainties The intention of the policies should yield significant positive effects but the dynamism and uncertainty of retailing could yield different effect, particularly in some vulnerable localities.




68 69 70 71 72 Commentary 2. Reinforce and support community identity and pride

a) Support community identity and pride

+? +? +? +? +? Likely Significant Effects Vibrant and successful retail centres should help to reinforce community identity and pride because of their role as focal points of activity. However, the precise extent of this relationship is uncertain, given the diversity of local centres and the varying needs and identities of the population. Short/Medium/Long Term effects No specific temporal difference in effects is predicted. Cumulative effects None identified Mitigation None required. Assumptions & Uncertainties None.

3. Improve accessibility to place and services, both within and outside of the borough

a)Accessibility to places b) Accessibility to services

+ + ++ + + Likely Significant Effects Balanced provision of retail and other town centre services will help to ensure that there is equitable access for the whole community. Policy 70 includes improvements to the Hatfield and Stainforth Railway Station facilities, park and ride and a new pedestrian footbridge. It also includes a new link road from Junction 5 of the M18. Policies seek to improve the public realm, which will also contribute towards this objective. Short/Medium/Long Term effects No specific temporal difference in effects is predicted. Cumulative effects A minor positive cumulative effect is identified as proposals will improve accessibility across a range of locations. Mitigation None required. Assumptions & Uncertainties None

4. Ensure resources are available and efficiently used to sustain development and reduce waste and

a) Energy resources b) Minerals and construction c) Efficient use of waste

~ ~ ++ ~ ~ Likely Significant Effects Policy 70 includes the use of existing materials on site (subject to satisfactory contamination investigations) and proposals for energy related developments, education and technological and research facilities. The policy will make a significant positive contribution to this objective. There is no immediate connection between other policies and this objective. Short/Medium/Long Term effects




68 69 70 71 72 Commentary consumption NA

Cumulative effects NA Mitigation NA Assumptions & Uncertainties The exact scale of waste arisings will be dependent on a number of factors including: the design of new development; waste collection and disposal regimes; and individual behaviour with regard to recycling and reuse.

5. Provide affordable, good quality housing that is available to everyone, including vulnerable and disadvantaged groups

a) Affordability b) Quality c) Mix and range of homes

~ + ++ ~ ~ Likely Significant Effects Allowance for residential uses in appropriate circumstances could contribute to the supply of appropriate housing for the Borough’s population, Policy 69 includes provision for appropriate uses. Policy 70 includes provision of 1,200 new homes at the Unity regeneration project in the plan period and requires replacement of 20 Gypsy and Traveller Pitches, a significant positive effect is identified. Short/Medium/Long Term effects No specific temporal difference in effects is predicted. Cumulative effects None Mitigation None required. Assumptions & Uncertainties None

6. Reduce social exclusion and disadvantage

a) Social exclusion b) Social disadvantage

+ + ++ + + Likely Significant Effects Balanced provision of retail and other town centre services will help to ensure that there is equitable access for the whole community. Policy 70 seeks to help secure the regeneration of the communities of Hatfield, Stainforth, Dunscroft and Dunsville. Short/Medium/Long Term effects No specific temporal difference in effects is predicted. Cumulative effects The policies will provide a range of opportunities and improved built environment that can contribute towards the reduction of social exclusion and disadvantage and a minor positive effect is identified.




68 69 70 71 72 Commentary Mitigation None required. Assumptions & Uncertainties None

7. Make places that are safe, attractive, culturally interesting and distinctive to live, work and travel in

a) Attractive and

distinctive places

b) Safety and security

+? + ++ +? +? Likely Significant Effects Vibrant and successful retail centres should help to reinforce the character and quality of centres across the Borough. However, there is a degree of uncertainty associated with how this can be achieved in the context of a dynamic retail environment which can profoundly change use mixes and hence the character of centres. Policy 70 includes a range of development requirements that will help ensure that the Unit regeneration project makes a significant positive contribution towards this objective. Short/Medium/Long Term effects No specific temporal difference in effects is predicted. Cumulative effects A minor positive cumulative effect is identified as proposals will improve a range of locations in accordance with this objective. Mitigation None required. Assumptions & Uncertainties Dynamism of the retail environment. The extent to which the local plan can deliver safer communities is in part dependent on a number of socio-economic factors outwith the Local Plan and planning process.

8. Renew and reuse existing buildings, land and infrastructure

a) Land and buildings b) Infrastructure

+ + ++ + + Likely Significant Effects These policies should assist in the positive use of buildings within centres, including those which can be developed for alternative uses (which may not include retail). The Unity Regeneration project will make a significant positive contribution to the re-use of previously developed land. Short/Medium/Long Term effects No specific temporal change in effects is predicted. Cumulative effects A minor positive effect is identified in relation to cumulative effects of the policies in this chapter as they provide the context for renewal across a range of locations. The effects of these policies would occur in combination with other policies, as well as policies which seek to redevelop individual brownfield sites for housing or mixed use. Mitigation




68 69 70 71 72 Commentary The policies could make reference to the re-use of previously developed land which could otherwise help reinforce wider objectives around maximising opportunities to redevelop brownfield land and creating vibrant places. Assumptions & Uncertainties None.

9. Improve the health and well-being of the borough’s population

a) Health b) Well being

+ ++ ++ + + Likely Significant Effects Balanced provision of retail and other town centre services will help to ensure that there is equitable access for the whole community. Proposals for new health facilities are included within Policy 69 and a significant positive effect is identified. Policy 70 delivers new Green Infrastructure (over 80 ha). Short/Medium/Long Term effects No specific temporal difference in effects is predicted. Cumulative effects A minor positive cumulative effect is identified as the policies address a range of factors that contribute to good health. Mitigation None required. Assumptions & Uncertainties None.

10. Provide education and training provision to build the skills and capacity of the population

a) Education b) Skills and training

~ ~ ++ ~ ~ Likely Significant Effects Policy 70 requires the Unity regeneration project to deliver a 3-form entry primary school by 2020 and a training centre associated with energy related developments. Short/Medium/Long Term effects No specific temporal difference in effects is predicted. Cumulative effects None. Mitigation None. Assumptions & Uncertainties None.

11. Manage and adapt to climate change

a) Flood risk b) Greenhouse

~ ~ ++ ~ ~ Likely Significant Effects Policy 70 provides research and energy related developments that will help transition to a low carbon economy.




68 69 70 71 72 Commentary gas emissions c) Water supply and drainage

Short/Medium/Long Term effects No specific temporal difference in effects is predicted. Cumulative effects None. Mitigation None. Assumptions & Uncertainties None.

12. Protect, increase and enhance the natural environment, including the landscape, its underlying geology and wildlife habitat

a) Biodiversity (habitats and species) b) Geodiversity c) Landscape

~ + ++/? ~ ~ Likely Significant Effects Policy 69 includes proposals for Marshgate and seeks to ensure that ecological networks alongside the canal are supported. Policy 70 includes a requirement for a landscaping and biodiversity strategy that includes off – setting for impacts on habitats and continued protection of the Hopyard Hay Meadow local wildlife site and linkages to other nearby habitats. A site-wide ecological assessment is also required, so at this stage an uncertain effect is identified. Short/Medium/Long Term effects No specific temporal difference in effects is predicted. Cumulative effects None. Mitigation None. Assumptions & Uncertainties None

13. Protect, conserve and enhance the historic and cultural heritage

a) Historic places b) Cultural heritage

+? +? ? + +? +? Likely Significant Effects Vibrant and successful retail centres should help to reinforce the character and quality of centres across the Borough and thereby the protection of valued historic and cultural assets. However, there is a degree of uncertainty associated with how this can be achieved in the context of a dynamic retail environment which can profoundly change use mixes and hence the character of centres. The supporting text to Policy 70 includes a requirement for development of the former colliery area to assess the impact on the setting of the former headstocks, which are a grade II listed building, as well as seeking to maximise the potential of the headstocks as a focal point for the development and place-shaping. Views from the south of the former colliery site are also of




68 69 70 71 72 Commentary heritage significance. Uncertain effects are identified in terms of the effects of this policy. The site has been separately assessed as a proposed allocation (Site 418) and the detailed site appraisal provides more information. Short/Medium/Long Term effects No specific temporal difference in effects is predicted. Cumulative effects There are minor positive but uncertain effects in relation to built heritage – policies set out an appropriate framework and proposals have been informed by Heritage Impact Assessment. The combined effects of development, including unallocated developments that come forward in these areas are however uncertain. Mitigation None required. Assumptions & Uncertainties Dynamism of the retail environment.

14. Protect and enhance soil, air and water quality (watercourses and ground water)

a) Land and soil b) Water c) Air

~ ~ ~ ~ ~ Likely Significant Effects There is no immediate connection between these policies and this objective. Short/Medium/Long Term effects No specific temporal difference in effects is predicted. Cumulative effects None Mitigation None Assumptions & Uncertainties None

Summary Likely Significant Effects These policies are positive in their intentions and likely outcomes, reflecting the desire and need to maintain balanced retail provision across the Borough such that the longer term viability of the various centres can be secured. Positive sustainability effects are likely across economic, social and environmental measures, although given the dynamism of the retail environment, there is a high degree of uncertainty as to the precise effect of the policies that relate to town centres and sites within them and their ability to address wider economic and social trends. The policies set the development framework for key sites across the Borough, including the Unity Regeneration Project. The appraisal of the policies identified the potential for significant positive effects associated with the delivery of key infrastructure, employment and other benefits, by their nature these benefits are specific to the site that the policy relates to, so for example Policy 70 includes improvements to the Hatfield and Stainforth Railway Station facilities, park and ride and a new pedestrian footbridge. It also includes a new link road from Junction 5 of the M18, making a significant positive contribution to SA objective 3 ‘Accessibility.’ This is reinforced by the inclusion of specific commitments to promote active travel, benefitting quality of life through air quality improvement and health and well-being, Policies seek to improve the



public realm, which will also contribute towards this objective. On the same basis a number of site-specific issues have been identified and are reflected in the Local Plan, for example the supporting text to Policy 70 includes a requirement for development of the former colliery area to assess the impact on the setting of the former headstocks, which are a grade II listed building, as well as seeking to “maximise the potential of the headstock as a focal point for the development and place-shaping”. Views from the south of the former colliery site are also of heritage significance. Uncertain effects are identified in terms of the effects of this policy. The site has been separately assessed as a proposed allocation (Site 418) and the detailed site appraisal provides more information. Short/Medium/Long Term effects Effects are likely over the short, medium and longer term. Cumulative effects Cumulative effects are likely in respect of the implementation of these policies with other plan policies relating to design, for example. Mitigation None identified. Assumptions & Uncertainties The dynamism of the retail environment and associated social and economic trends. The extent to which the local plan can deliver safer communities is in part dependent on a number of socio-economic factors outwith the Local Plan and planning process. The exact scale of waste arisings will be dependent on a number of factors including: the design of new development; waste collection and disposal regimes; and individual behaviour with regard to recycling and reuse.

D1 © Wood Environment & Infrastructure Solutions UK Limited


Appendix D Update to Appendix I of the Publication Local Plan - Appraisal of Options for Housing and Employment Growth (updated text in red) Options for housing and employment land provision

Option 1: 920 dwellings per annum (dpa) and 481 ha of employment land Option 2: 585 dpa and 103 ha of employment land Option 3: 753 dpa and 242 ha of employment land Option 4: 1,073 dpa and 481 ha of employment land

Objective Sub-objective Option 1 Option 2 Option 3 Option 4 Commentary 1. Maintain and increase Doncaster’s growth/prosperity and diversify its economic base

a) Local economy (maintain and strengthen) b) Diversify the economic base

++ ++ ++ ++

Likely Significant Effects All options would be expected to have a significant positive effect on economic growth in Doncaster, with each option proposing to allocate over 100ha of employment land. Options 1, 3 and 4 would provide employment land to meet the growth aspirations of the Sheffield City Region for the Borough (1% economic growth per annum), Option 1 provides a degree of flexibility over the plan period. . Option 1 includes an element of employment-led housing growth and is considered to be in accordance with the growth aspirations of the Sheffield City Region Strategic Economic Plan9 and the broader aspirations of the northern powerhouse area. It seeks to capitalise on the opportunities offered by the Sheffield City Region Integrated Infrastructure Plan10. Option 2 provides for 103ha of employment land. This lower growth rate may be easier to achieve; however, it does not accord with the Council’s desire to re-balance the local economy away from the public sector and achieve higher rates of economic growth. Nor would it contribute to the broader ambitions of the Sheffield City Region. Option 4 would provide a greater level of housing growth to accompany and promote economic growth (i.e. jobs-led), in turn potentially offering greater certainty that the aspirations for the economic development of the Borough will be realised over the medium and longer term. Short/Medium/Long Term effects

9 Sheffield City Region Local Enterprise Partnership (2014) Sheffield City Region Strategic Economic Plan. Available at: https://sheffieldcityregion.org.uk/wp-content/uploads/2018/01/SCR-Growth-Plan-March-2014-1.pdf 10 Sheffield City Region (2016) Sheffield City Region Integrated Infrastructure Plan. Available at: https://sheffieldcityregion.org.uk/wp-content/uploads/2018/01/Integrated-Infrastructure-Plan_Executive-Summary.pdf



Objective Sub-objective Option 1 Option 2 Option 3 Option 4 Commentary The short, medium and longer-term effects of the options are all considered to be a significant positive as a result of the annual build out of employment floorspace. Mitigation None required. Assumptions & Uncertainties None.

2. Reinforce and support community identity and pride

a) Support community identity and pride

++? ++ ++ ++?

Likely Significant Effects All options will help to deliver community identity and pride by helping to ensure that housing and employment needs within existing settlements are met, thereby contributing to sustainable communities. It is anticipated that Option 1 would be of greater benefit as a result of the higher level of housing and employment floorspace to be delivered, helping to promote the local economy and support local communities. Whilst all four options are considered to be a significant positive, there is a degree of uncertainty given the complexity and timing of implementation of economic development proposals. Some of the strongest effects could be associated with urban and town centre renewal. The higher levels of growth suggested under SA objective 1 might suggest the need for initiatives around community development/integration, especially in relation to larger schemes to ensure that community pride and identity are optimised. Equally, under Option 4, too rapid a rate of growth associated with some communities could detrimentally affect their ability to assimilate growth with consequent effects on community cohesion. Short/Medium/Long Term effects Effects are likely to grow over the lifetime of the plan, although specific attribution to economic development could be difficult to measure. Mitigation Consider the need for initiatives around community development / integration associated with Options 1, 3 and 4. Assumptions & Uncertainties None.

3. Improve accessibility to places and services, both within and outside of the borough

a) Accessibility to places b) Accessibility to services +? + + +?

Likely Significant Effects All options would be expected to improve access to services and facilities by locating new homes and employment opportunities in area with high accessibility. The effect has been assessed as a minor positive as none of the options are explicitly accompanied by new services, and high growth rates could be detrimental to service capacity (see also Objectives 9 and 10). Short/Medium/Long Term effects



Objective Sub-objective Option 1 Option 2 Option 3 Option 4 Commentary Effects are likely to grow over the lifetime of the plan. Mitigation Ensuring service provision matches housing growth. Assumptions & Uncertainties None.

4. Ensure resources are available and efficiently used to sustain development and reduce waste and consumption

a) Energy resources b) Minerals and construction c) Efficient use of waste

++/-- +/- ++/-- ++/--

Likely Significant Effects All options would be expected to increase resource use in the Borough, e.g. associated with the construction and occupation of new housing and employment. The increased level of house building under Options 1, 3 and 4 are expected to require a higher level of resource use. Improvements in efficiency in construction and waste management is likely to offset this. In addition, once in use modern housing is typically more efficient in terms of heat, energy and water use. More widely the extent of the effect depends upon other factors such as wider regulation, in particular the Building Regulations, and economic incentives. Short/Medium/Long Term effects Effects are likely to grow over the lifetime of the plan. Mitigation None required. Assumptions & Uncertainties None.

5. Provide affordable, good quality housing that is available to everyone, including vulnerable and disadvantaged groups

a) Affordability b) Quality c) Mix and range of homes

++ ++ ++ ++?

Likely Significant Effects All of the options would make a significant contribution to this objective. Option 2 meets needs arising within the Borough. Options 1, 3 and 4 would deliver housing to meet wider needs and contribute to housing led economic growth. The higher housing growth target is considered to be better aligned with the broader growth and development ambitions of the broader Sheffield City Region, taking advantage of planned improvements to transport infrastructure11 and ambitious growth plans12. Whether the jobs-led growth housing target of Option 4 is desirable or achievable is considered to be uncertain. Short/Medium/Long Term effects Effects are likely to grow over the lifetime of the plan.

11 Sheffield City Region (2016) Sheffield City Region Integrated Infrastructure Plan. Available at: https://sheffieldcityregion.org.uk/wp-content/uploads/2018/01/Integrated-Infrastructure-Plan_Executive-Summary.pdf 12 Sheffield City Region Local Enterprise Partnership (2014) Sheffield City Region Strategic Economic Plan. Available at: https://sheffieldcityregion.org.uk/wp-content/uploads/2018/01/SCR-Growth-Plan-March-2014-1.pdf



Objective Sub-objective Option 1 Option 2 Option 3 Option 4 Commentary Mitigation None required. Assumptions & Uncertainties None.

6. Reduce social exclusion and disadvantage

a) Social exclusion b) Social disadvantage

++ ++ ++ ++?

Likely Significant Effects All options will help to provide a focus for positive action through the planning system as part of the promotion of growth which should be to the benefit of all residents. It is considered that in planning for higher levels of economic development, the scale of development associated with Options 1, 3 and 4 means that it could help address social exclusion and disadvantage in areas outside of the Borough (as there is an element of housing-led economic growth). This will depend on how well targeted the new homes and jobs are., and for Option 4 this relationship introduces an element of uncertainty. Short/Medium/Long Term effects Effects are likely to grow over the lifetime of the plan. Mitigation None required. Assumptions & Uncertainties None.

7. Make places that are safe, attractive, culturally interesting and distinctive to live, work and travel in

a) Attractive and distinctive places

b) Safety and security

+ + + +

Likely Significant Effects New homes and employment spaces would be expected to apply design principles to ensure a safe and secure environment, such as Secured by Design. Short/Medium/Long Term effects The short, medium and longer-term effects of the policies are all considered to be a minor positive. Mitigation None required. Assumptions & Uncertainties None.

8. Renew and reuse existing buildings, land and infrastructure

a) Land and buildings b) Infrastructure ? ? ? ?

Likely Significant Effects All options would be expected to utilise a mix of both greenfield and brownfield land, with the potential to re-use existing buildings also inherent to both options. It is anticipated that the higher level of housing and employment growth in Options 1, 3 and 4 would require additional greenfield land.



Objective Sub-objective Option 1 Option 2 Option 3 Option 4 Commentary Short/Medium/Long Term effects Uncertain Mitigation None required Assumptions & Uncertainties None.

9. Improve the health and well-being of the borough’s population

a) Health b) Well being

+ + + +?

Likely Significant Effects The linkages between access to good quality environments, housing, employment and health are recognised in the National Planning Policy Framework. Both options could help to encourage health improvements (mental and physical) across the Borough (and further afield under Option 1) through promoting economic development and increasing the provision of suitable housing. An increased population would increase the pressure on local health services, such as GPs and Hospital’s, however as the growth in population is anticipated it is assumed that additional heath infrastructure will be provided to meet the needs of growing communities. The higher housing growth rate associated with Option 4 could introduce stress on service provision (see also Objectives 3 and 10). Short/Medium/Long Term effects The short, medium and longer-term effects of the options are all considered to be a minor positive. Mitigation None required Assumptions & Uncertainties None

10. Provide education and training provision to build the skills and capacity of the population

a) Education b) Skills and training

++ + ++ ++?

Likely Significant Effects All options would be expected to promote skills and training as a result of economic development leading to new skills training and apprenticeship opportunities. The larger amount of employment floorspace in Options 1, 3 and 4 would be expected to create more opportunities and is considered a significant positive in this respect. An increased population would increase the pressure for school places on existing schools, however as the grown in population is predictable it is considered that additional schools will be provided to meet the needs of growing communities or existing schools expanded where feasible and appropriate. The higher housing growth rate associated with Option 4 could introduce stress on service provision (see also Objectives 3 and 9). Short/Medium/Long Term effects Effects are likely to grow over the lifetime of the plan.



Objective Sub-objective Option 1 Option 2 Option 3 Option 4 Commentary Mitigation None required. Assumptions & Uncertainties None.

11. Manage and adapt to climate change

a) Flood risk b) Greenhouse gas emissions c) Water supply and drainage

-/? -/? -/? -/?

Likely Significant Effects The Borough has extensive areas of land at risk from flooding from various sources, including the rivers Don and Dearne in the west and rivers Torne and Trent in the south, and the watercourses that feed to them, plus tidal flooding within the low lying Humberhead Levels. Large parts of the borough are therefore identified as being in medium and high flood risk based on the Environment Agency Flood Map for Planning. There are also areas of the borough where surface water and groundwater flooding poses significant challenges. A significant negative effect in relation to flood risk from the options is considered unlikely due to the framework of national policies, including the NPPF and Planning Practice Guidance, which emphasise the need to avoid inappropriate development in high flood risk areas and the need to mitigate the contribution that new development would otherwise make to increased flood risk. An increased population would place increasing demand on local water supplies, with the greater demand resulting from Options 1, 3 and 4. A notable difference between the options is the ratio of employment land to homes, with Option 1 creating approximately 3 times as many new dwellings per hectare of employment space than Option 2. The net result of this difference on climate change mitigation is uncertain as it depends on the impact on commuting patterns. For example, where there is a high level of in-commuting, a lower housing to employment floorspace ratio as per Option 1 may be preferable in reducing daily vehicle movements into the area. At present the economy is reasonably self-contained with 3.4% of residents commuting to Sheffield and 0.5% travelling from Sheffield to Doncaster. Also important is how improvements to public transport combined with the location of new employment opportunities effect the mode of transport that residents use to travel to work. Across the Sheffield City Region census data indicates that around 70% of residents travelled to work by car. Short/Medium/Long Term effects The predicted positive effect would occur in relation to new developments consented during the lifetime of the Local Plan (i.e. the short to medium term term) and would persist into the long term throughout the lifetime of these developments. Therefore there is no specific temporal difference in predicted effects. Mitigation None required.



Objective Sub-objective Option 1 Option 2 Option 3 Option 4 Commentary Assumptions & Uncertainties Uncertainties in relation to the capacity of water treatment facilities in the area and impacts on Greenhouse gas emissions associated with motorised journeys to work.

12. Protect, increase and enhance the natural environment, including the landscape, its underlying geology and wildlife habitats

a) Biodiversity (habitats and species) b) Geodiversity c) Landscape

? ? ? ?

Likely Significant Effects Given the scale of development considered by all options, it is likely that some sites of importance for nature conservation could be adversely affected in the absence of mitigation. It is also anticipated that the development brought forward would incorporate measures to enhance biodiversity. As the location of all sites to be developed is not known, the scale of the effect is uncertain at this stage Short/Medium/Long Term effects Uncertain Mitigation None required. Assumptions & Uncertainties None.

13. Protect, conserve and enhance the historic and cultural heritage

a) Historic places b) Cultural heritage

? ? ? ?

Likely Significant Effects Given the scale of development considered by all options, it is likely that some historic assets might be adversely affected in the absence of mitigation. It is also anticipated that the development brought forward would incorporate measures to mitigate any potential effects, for example through the use of appropriate screening. As the location of all sites to be developed is not known, the scale of the effect is uncertain at this stage Short/Medium/Long Term effects Uncertain. Mitigation None required. Assumptions & Uncertainties None.

14. Protect and enhance soil, air and water quality (watercourses and ground water)

a) Land and soil b) Water c) Air

++/-- ++/-- ++/-- ++/--

Likely Significant Effects Given the scale of development proposed by all options It is anticipated that development would both remediate existing contaminated land and lead to the loss of land classified as Grade 1 – 3a agricultural land. As such all options are considered to have both a significant positive and significant negative effect against this objective. Short/Medium/Long Term effects Effects are likely to grow over the lifetime of the plan.



Objective Sub-objective Option 1 Option 2 Option 3 Option 4 Commentary Mitigation None required. Assumptions & Uncertainties None

Documents

Addendum to the Publication Plan Sustainability Report...plan policies including development requirements for the proposed site allocations. Proposed Amendments 1.2.5 Consultation