From: Peacock and Smith re West Moor Park East Sent: 30 … · 2020. 3. 18. · From: Peacock and Smith re West Moor Park East Sent: 30 September 2019 16:02 To: Local Plan Subject:

From: Peacock and Smith re West Moor Park East Sent: 30 September 2019 16:00 To: Local Plan Subject: West Moor Park East - LP Reps EMAIL 1 of 3

Dear Sir/Madam

My colleague is delivering a representation in response to your Local Plan consultation in person this

afternoon.

The following 3 emails comprise the appendices which support reps to be delivered this afternoon in

relation to the site at West Moor Park East.

Please find attached Appendix A.

Alicia Dawson

Associate

Suite 9C Josephs Well, Hanover Walk, Leeds, LS3 1AB

From: Peacock and Smith re West Moor Park East Sent: 30 September 2019 16:02 To: Local Plan Subject: West Moor Park East - LP Reps - EMAIL 2 of 3 EMAIL 2 of 3

My colleague is delivering a representation in response to your Local Plan consultation in person this

afternoon.

The following 3 emails comprise the appendices which support reps to be delivered this afternoon in

relation to the site at West Moor Park East.

Please find attached Appendices C and D_part 1

Alicia Dawson

Associate


From: Peacock and Smith re West Moor Park East Sent: 02 October 2019 10:07 To: Local Plan Subject: RE: Doncaster Local Plan consultation

Please find attached 5x forms and associated reports containing our representations – with the file names of the

attached you should be able to work out which form relates to which report but let me know if you have any

queries.

Our representations refer to a number of appendices, we stress that these should be read in conjunction with our

reports. As previously mentioned, the easiest way to view these should be on disk which is on its way to you.

Sarah Lowe

Senior Planner


From: Local Plan Sent: 02 October 2019 09:33 To: Alicia Dawson Subject: RE: Doncaster Local Plan consultation The issue is we have the appendices but it is the Policy forms and explanation that we do not have. The following need emailing please: Policy 3 – the form and the explanation document of 7 pages Policy 4 - the form and the explanation document of 19 pages Policy 4 - the form and the explanation document of 9 pages Policy 4 - the form and the explanation document of 6 pages Sites - the form and the explanation document of 14 pages I can’t imagine that these are too big to email. If so, a couple of emails should do it.

Doncaster

Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

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

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

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

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

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

Title Mr

First Name Mark

Last Name Eagland

Organisation (where relevant)

Blue Anchor Leisure Limited Peacock + Smith

Address – line 1 Suite 9C, Josephs Well

Address – line 2 Hanover Walk

Address – line 3 Leeds

Postcode LS3 1AB

E-mail Address

Telephone Number

http://www.doncaster.gov.uk/localplan

Guidance Notes (Please read before completing form) What can I make comments on? You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ). Do I have to use the response form? Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form. You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination. For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan Can I submit representations on behalf of a group or neighbourhood? Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be

helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached. Question 3 (below) – What does ‘legally compliant’ mean? Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan Questions 4/5 (below) – What does ‘soundness’ mean? Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:

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

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

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

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

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

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



http://www.harrogate.gov.uk/info/20101/planning_policy_and_the_local_plan/556/local_plan_-_evidence_base


https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making

Part B Please complete this Part to make your comments. After this Publication stage, further submissions will only be

at the request of the Inspector, based on the matters and issues she/he identifies for examination.

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

or

Name / Organisation Name:

Mark Eagland (Peacock + Smith) on behalf of Blue Anchor Leisure Limited

1. To which document does your response relate? (Please tick all that apply)

Doncaster Local Plan Publication Draft ☒ Policies Map ☐

Sustainability Appraisal ☐ Habitats Regulations Assessment ☐

Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☐

2. To which part(s) of the document / map does your response relate?

Page No.: Paragraph:

Policy Ref.: Policy 3 Site Ref.:

Policies Map:

3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☐ Yes ☒

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

Positively prepared ☒ Justified ☒

Effective ☒ Consistent with National Policy ☒

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

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

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

Please see attached submission.

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

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


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

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

☒ Yes, I wish to appear at the Examination.

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations. 9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:

We have compiled a detailed submission which is underpinned by a number of technical and evidence-based

studies. We consider that it will be necessary to discuss this evidence with Officers and the Inspector at the

Examination.

Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session. Your Signature

Date 30/09/2019

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

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

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

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

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

or defamatory.


http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice

Peacock + Smith Limited Suite 9C, Joseph's Well Hanover Walk Leeds LS3 1AB

T: E:

Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)

September 2019


2 September 2019

1.1 This representation supports the 481 hectare employment land target set out in Policy 3 of the

Local Plan. However, it objects to the absence of an employment land buffer or any reserve

employment sites.

1.2 The representation should be read in conjunction with the attached review of the Council’s

employment land evidence by Hatch Regeneris (Appendix 1); the attached assessment of

employment site options by Dove Haigh Phillips (Appendix 2) and our client’s objection to Policy

4 of the Local Plan.


3 September 2019

2.1 Blue Anchor Leisure supports the requirement of Policy 3 of the Local Plan that the plan should

facilitate the delivery of at least 481 hectares of employment land over the plan period (2015-

2015).

2.2 The attached assessment of the Employment Land Need Assessment Update 2019 (ELNA) that

underpins the 481 hectare target by Hatch Regeneris (Appendix 1) demonstrates that:

• The 481 hectares is based on jobs growth of 1% p.a. This is consistent with past trends in

Doncaster and the Sheffield City Region’s growth aspirations.

• The target uses the same jobs growth assumptions as the housing-based assessment and

therefore represents a joined-up approach.

2.3 Hatch Regeneris also find that the breakdown between different use classes estimated in the

ELNA is broadly in line with past trends and therefore found to be sound. This shows that a large

share of the requirement for employment land is for strategic warehousing, as illustrated below:

• 14 Ha for office development;

• 125 Ha for industrial;

• 73 Ha for non-strategic warehousing; and

• 271 Ha for strategic warehousing.

2.4 In the light of the above we conclude that employment land requirement set out in Policy 3 is

sound. There is no justification for a lower employment land target.


4 September 2019

3.1 Whilst we support the employment land target of Policy 3, we object to the omission of an

employment land supply buffer or any reserve employment sites within the Local Plan to

minimise the risk that the ‘minimum’ 481 hectare target is not met, and to ensure that the plan is

sufficiently flexible to adapt to unforeseen circumstances.

3.2 Para 11 of the Presumption in Favour of Sustainable Development section of the NPPF requires

that plans should be sufficiently flexible to adapt to rapid change. Para 81, within the Economy

section of the Framework, echoes this requirement and states that policies should be flexible

enough to accommodate needs not anticipated in the plan; to allow for new and flexible working

practices; and to enable a rapid response to changes in economic circumstances.

3.3 In this context we are concerned that as drafted the Local Plan is insufficiently flexible and also

ill-equipped to adapt to economic change that will inevitably occur over the 20-year plan period.

Our particular concerns about the flexibility and durability of the Plan are as follows:

1. As explained in our associated comments on Policy 4 of the Local Plan, there is no buffer

or flexibility (other than a very small 1-hectare (0.2%) surplus) should any of the various

employment sites that the Council have included in the Plan not deliver at the pace

anticipated. The attached Dove Haigh Phillips assessment of employment site options

(Appendix 2) demonstrates that a delivery shortfall is very likely to occur in relation to Sites

878/1032, 001, 941 and 441 – amounting to almost 80 hectares of land. Dove Haigh

Phillips also advise that in respect of employment sites with planning permission, which

make up 201 hectares (42%) of the employment land supply, it is advisable to allow for a

modest slippage rate of 10% due to unforeseen constraints. This would amount to a further

potential 20 hectare delivery shortfall.

2. The attached Hatch Regeneris report (Appendix 1) shows that Doncaster has one of the

fastest growing economies in the north of England, with a significantly higher GVA than the

national or regional average. Industrial space leased in Doncaster since 2009 represents

37% of demand in South Yorkshire, despite the area only accounting for 20% of the South

Yorkshire population. However, in the event that there is an unforeseen requirement for

an additional large employment site to be provided over the plan period, consistent with

Doncaster’s success, for example to meet a requirement for a high profile investor seeking


5 September 2019

a site with good access to the motorway network, this would inevitably involve the use of

either Green Belt or defined Countryside because there are no opportunities close to the

motorway network that would not utilise such land.

The Countryside and Green Belt policies of the Plan would not readily allow for such a

need to be met on a windfall basis, which would mean that Doncaster would lose out to

footloose investors seeking employment opportunities that cannot be met by the limited

new allocations of the Plan. A development within the Green Belt could not take place until

a plan review had taken place, by which time an investor would be likely to look for

opportunities in other Local Authority Areas. Policy 26 of the Plan only permits a ‘rural’

enterprise to be developed in the defined Countryside.

3. The Local Plan presently provides for significant flexibility in the housing supply, as shown

at Page 44 of the plan – a 7% buffer above the residual allocation requirement; 585

dwellings with permission not included in the allocation supply; 1,345 dwellings on reserve

housing sites; and windfalls, which will be additional to the allocated supply. However,

there is no such buffer or reserve site allowance made for employment land to address the

deliverability and flexibility concerns we identify above. This is an inconsistent approach.

4. Although Table 9.31 of the Housing and Employment Site Selection Methodology refers to

a number of unimplemented UDP Employment allocations, we do not consider that these

sites represent a reserve source of employment land that can be relied on to address the

concerns we identify in this objection. Firstly, any allocation that is still available now,

some 21 years after allocation of the UDP, is likely to be constrained by physical or

ownership issues or be located in an unattractive location for employment. Secondly, most

of these sites are very modest in size and therefore unsuitable for anything but localized

business needs (the Local Plan acknowledges that five of the sites are within a defined

Employment Policy Area and they do not contribute to the total amount of employment

land). Thirdly, a number of the sites are proposed (in part or whole) to be re-allocated for

housing use.

5. The Doncaster UDP provided for a number of reserve employment sites to address the

very flexibility points we have identified, thus highlighting the inconsistency in not applying

a similar approach in the new Local Plan. Para 4.21 of the UDP states:


6 September 2019

“4.21 The provision of land within the UDP for employment purposes is likely to be more

than adequate to meet anticipated future needs. However, in order to provide additional

flexibility for the future in the event that demand proved to be higher than expected, or for

example, if a need was identified for an extensive site for a single large operator that could

not be accommodated on existing allocated sites in the borough, then the land previously

earmarked for Phases 3 and 4 of Carcroft Industrial Estate and north of Cassons Road

could be released for this purpose.”

The policy associated with Para 4.21 of the UDP, Policy EMP3, safeguarded two large

reserve employment sites amounting to approximately 80 hectares of land, as shown

below:

3.4 In the light of the above, we do not consider that Policy 3 is positively prepared, justified,

effective or consistent with national policy.

3.5 Without prejudice to our client’s associated representation to Policy 4 seeking allocation of

West Moor Park East (Site 937/1031/938/1014) for employment, we consider that site should

be identified as a reserve employment site in the event that the former request is not accepted

to bolster the employment land supply and address the flexibility concerns we set out in this

representation.


7 September 2019

4.1 The Local Plan should include a buffer of employment land supply or identify reserve

employment sites. Without prejudice to our client’s associated representation to Policy 4 seeking

allocation of West Moor Park East (Site 937/1031/938/1014) for employment, we consider that

site should be identified as a reserve employment site in the event that the former request is not

accepted

Doncaster

Local Plan









Title Mr

First Name Mark

Last Name Eagland






Postcode LS3 1AB

E-mail Address

Telephone Number


















or




Doncaster Local Plan Publication Draft ☒ Policies Map ☐

Sustainability Appraisal ☒ Habitats Regulations Assessment ☐




Policy Ref.: Policy 4 Site Ref.:

Policies Map:


















Examination.


Date 30/09/2019






or defamatory.




T: E:


September 2019


2 September 2019

1.1 Blue Anchor Leisure has concerns about the quantum and choice of employment land proposed

for allocation under Policy 4 of the Local Plan.

1.2 We are of the view that the employment site option at West Moor Park East (Site

937/1031/938/1014) is the most logical and sustainable option to remedy the problems we

identity within the employment land supply proposed by Policy 4. We also demonstrate that the

Council’s reasons for non-allocation of West Moor Park East are either inaccurate or they are

not sound reasons for rejection of the site.

1.3 In this objection we refer to a number of other documents. These include the attached

Accessibility Technical Note by Sanderson Associates (Appendix 1); the attached A1M/A19

Technical Note by Sanderson Associates (Appendix 1A); the attached Technical Note by Fore

Consulting (Appendix 2); the attached Flood Risk report by Fairhurst (Appendix 3); the attached

assessment of employment site options by Dove Haigh Phillips (Appendix 4); the attached Vision

document (Appendix 5) submitted in support of West Moor Park East in response to the October

2018 Local Plan consultation; and an attached updated Masterplan for West Moor Park East

(Appendix 6).

1.4 This representation sould be read in conjunction with our client’s associated objections to Policy

3 and the Site Selection process of the Local Plan.


3 September 2019

2.1 Policy 3 of the Plan sets out that a strategic aim is to facilitate the delivery of ‘at least’ 481

hectares of employment land over the plan period. Taking account of land already developed

for employment land, and sites with planning permission, the Plan asserts that Policy 4 provides

for employment allocations that will enable the 481 hectare requirement to be delivered.

2.2 However, as explained in our related objection to Policy 3 of the Plan, Policy 4 does not provide

for a buffer of land over and above the 481 hectare requirement (other than a 1 hectare (0.2%)

surplus), which we consider to be a high risk strategy, bearing in mind that it is difficult to

accurately predict delivery of sites over a timescale as long as the plan period (20 years).

2.3 On this basis alone we do not consider that the plan is positively prepared or justified. Whereas

the plan seeks to provide for 7% more housing allocations than the outstanding housing allocation

over the plan period (which excludes contributions from windfalls, 585 permissions as at 1/4/18

not included in the supply and 1,345 homes on reserved sites), we are concerned that no such

buffer is provided in respect of the employment land requirement.

2.4 Moreover, we consider that there is a very strong likelihood that the employment land allocations

proposed in the plan will not deliver 481 hectares of employment land, for the following reasons.

Concerns about Site 878/1032 East of Bankwood Lane, Rossington

2.5 Site 878/1032 relates to land that was allocated in the Doncaster UDP for employment/as an

employment policy area. However, this site has been occupied by an existing tanker supplier

business for almost 40 years

2.6 We consider that it is inappropriate to rely on Site 878/1032 as an employment option that will

count towards the minimum 481 hectare target. As explained in the attached report by Dove

Haigh Phillips (Appendix 4), the reality is that this site is an ‘existing’ employment site that has

been in employment use well before the base date of the new Local Plan. If it is taken up by a

new business(es) that would not represent a net addition to Doncaster’s employment land

supply; rather it would be a change in the occupier of the land.

2.7 This leaves a 17.68 hectare shortfall in land needed to meet the target.


4 September 2019

Concerns about Site 441 Land at Carcoft Common

2.8 All of this site was identified as land to be safeguarded for employment use in the adopted UDP,

but it has not been developed for new employment uses despite the passage of 21 years, which

indicates that there are some significant constraints to its development. The UDP acknowledges

that the site has significant issues, particularly in relation to access and drainage. The Local Plan

and evidence base does not provide evidence that these constraints have been overcome.

2.9 In relation to access, Paras 4.31 and 4.58 of the Local Plan and the Site Selection Report indicate

that development of Site 441 is dependent on construction of a new A1M to A19 link road.

However, whilst there is reference to this road in Policy 13 of the plan, it is no more than an

aspiration at this stage. The attached Technical Note by Sanderson Associates (Appendix 1A)

indicates that:

▪ There is no information available about the precise route of the link road. It is simply an indicative

line;

▪ The Southern Pennines Strategic Development Corridor – Strategic Outline Case (SOC) March

2019 explains that the link road is at a very early stage of assessment, with no positive funding

available. The SOC states that delivery of this transport intervention “should not be relied upon

for planning and development purposes”;

▪ The timescale for the delivery of the link road is a significant unknown if it happens at all. There

will be a need for decisions to be taken about priorities and funding, other schemes will be

competing for funding, and even when high level decisions are taken, they are susceptible to

being reviewed; and

▪ Beyond this there will be a need for technical work and compulsory purchase of land. This is

likely to take implementation beyond the Local Plan period, if the link road happens at all.

2.10 In the absence of certainty about the delivery of the A1M to A19 link road there is no certainty

about the delivery of Site 441. It is not a justified or effective allocation.

2.11 Regarding drainage, the attached report by Fairhurst (Appendix 3) shows that Site 441 is not only

in Flood Zone 3, but it is located in an area of known ponds and ditch drains, including the

presence of shallow groundwater and poor surface water drainage. This may impact on the


5 September 2019

suitability and viability of the site for employment and no evidence has been provided by the

Council to demonstrate otherwise.

2.12 In short, the assumed contribution that Site 441 will make towards the employment land supply,

12 hectares, is not sound.

Concerns about Site 001 Thorne North

2.13 The attached report by Dove Haigh Phillips (Appendix 4) comments that Thorne is not an

established hub for warehousing development and existing employment development has taken

place over a much long period of time than the pace achieved at iPort and West Moor Park.

2.14 Dove Haigh Phillips also note that Site 001 is not well related to the main urban area of Doncaster

(as recognised by the Colliers Employment Land Review 2018) and there is a limited catchment

population to provide a local labour force to support a large scale development at Thorne North

(as demonstrated at Section 3 of the attached report by Sanderson Associates (Appendix 1)).

2.15 In light of the above Dove Haigh Phillips question whether Site 001 could deliver the quantum of

land anticipated by the Local Plan (51.54 hectares) over the plan period. Dove Haigh Phillips

consider that it is more likely that the site would deliver 36.8 hectares, as estimated by the

Colliers Employment Land Review 2018 (and subsequent amendments).

2.16 This leaves a 14.74 hectares shortfall in the contribution that Site 001 would make towards the

employment land target.

Concerns about Site 941 Site 2, Land East of Poplars Farm, Hurst Lane, Auckley

2.17 The attached report by Dove Haigh Phillips (Appendix 4) explains that development of Site 941

will be contingent on the growth of the airport and airport-related businesses.

2.18 The aggregate of the adjacent Site 517 and Site 941 is 112.59 hectares, which is a large area of

land available in this location with similar characteristics. Given the scale of land available and

the remoteness from the motorway network, Dove Haigh Phillips question whether Site 941 could

deliver the quantum of land anticipated by the Local Plan (68.54 hectares) over the plan period.

Dove Haigh Phillips consider that it is more likely that the site would deliver 50% of this figure,

which amounts to 34.27 hectares.


6 September 2019

2.19 This leaves a 34.27 hectare shortfall in the contribution that Site 941 would make towards the

employment land target.

Issue 1 – Insufficient Land Allocated to Meet Employment Land Requirement in Quantitative

Terms: Conclusion

2.20 Given that Site 878/1032 is already in employment use it does not provide a net contribution to

the employment land supply of Doncaster through allocation under Policy 4. The 17.68 hectare

employment land supply contribution from this site should be deleted.

2.21 There is considerable risk about the delivery of Site 441. In the absence of certainty about the

delivery of the A1M to A19 link road there is no certainty about the Local Plan contribution of this

site. The assumed contribution that Site 441 will make towards the employment land supply,

12.32 hectares, is not sound.

2.22 Based on the professional commercial judgements of Colliers and Dove Haigh Phillips, there is

also concern about the Local Plan contribution of Sites 001 and 941. Doubt has been cast on

delivery of 49 hectares of land from these two sites during the plan period.

2.23 We therefore conclude that the total quantitative shortfall of land from allocated sources needed

to meet the minimum employment land requirement could be as high as 78 hectares. The plan

is not positively prepared, justified or effective in that regard.

2.24 This also assumes that there is no slippage of delivery from sites with planning permission.

However, as explained in our objection to Policy 3, Dove Haigh Phillips also advise that in respect

of employment sites with planning permission, which make up 201 hectares (42%) of the

employment land supply, it is advisable to allow for a modest slippage rate of 10% due to

unforeseen constraints. This would amount to a further potential 20-hectare delivery shortfall

in the employment land supply of the Local Plan.


7 September 2019

3.1 The table of the employment land portfolio proposed at Page 38 of the Local Plan indicates that

25% (118 hectares) has already been developed. A further 42% (201 hectares) of the supply

already has planning permission, leaving a balance of 34% (162 hectares) to be provided in new

allocations to meet the Policy 3 minimum requirement of 481 hectares.

3.2 Given that only a third of the employment land supply up to 2035 is therefore uncommitted, we

are concerned about the ‘choice’ of new employment land that will be available over the plan

period for large users, particularly those with needs of a strategic scale. The reasons for this

concern are as follows:

• A) our associated objection to Policy 3 shows that Doncaster has one of the fastest growing

economies in the North of England, with a significantly higher GVA than the national or

regional average. It is a high demand location – if Doncaster does not provide a sufficient

choice of large sites to meet the demands of the market it will lose potential investment

and employment to other Local Authority areas that offer such land;

• B) the ELNA Update 2019 indicates that almost three quarters of the employment land

need over the plan period is of a specific type i.e. non-strategic and strategic warehousing.

The attached report by Dove Haigh Phillips (Appendix 4) states that such employment

requires scale, proximity to high profile locations that are reaily accessible from the major

transport networks and proximity to a labour pool; and

• C) in relation to sites that already have planning permission, there are only 3 that would

be considered suitable for warehousing, the largest component of the employment land

need – Site 418 (Unity/DN7), Site 747 (iPort) and Site 1099 (West Moor Park Extension).

3.3 Having regard to the above, in this context the Local Plan only allocates 6 new sites that will

contribute to the employment land supply. Two of these, Sites 092 (Balby Carr Bank) and 258

(Plot 1 Lakeside) are less than 10 hectares in size, more suited to localised business needs and

not geared to address the considerable warehousing requirement identified by the ELNA.

3.4 Site 441 (Land at Carcoft Common) has poor access to the motorway network, and we explain

above why we do not consider that this side will contribute to the Local Plan employment land

requirement, due to the high level of uncertainty associated with the A1M/A19 link.


8 September 2019

3.5 This leaves two other sites allocated for development, Site 001 (Thorne North) and Site 941 (Site

2, Land east of Poplars Farm). Site 001 is, in our view, the only large site that is allocated within

the plan that has good access to the motorway network, albeit the labour pool is limited for this

opportunity, as stated above. As explained within the attached report by Dove Haigh Phillips

(Appendix 4), Site 941 is remote from the motorway network and its success will be connected

with the success of the airport.

3.6 In summary, we consider that Policy 4 does not provide a sufficient range and choice of sites

available for large scale users during the plan period up to 2035 and it is therefore not positively

prepared, justified or effective. The number of sites allocated is modest relative to the

acknowledged success of the Doncaster economy, and only a single site is well-suited to meet

the key warehousing requirement identified by the ELNA.


9 September 2019

/ / /

4.1 Policy 4 can be made more sound by including land at West Moor Park East (sites 1031/937,

1014 and 938) as an additional employment allocation.

4.2 West Moor Park East has been intensively promoted by our client to the Council throughout

2018/2019; numerous meetings have taken place with senior officers to keep the Authority

updated of this opportunity; and a public exhibition of the site proposals was undertaken in

Armthorpe in March 2019. Detailed representations were submitted in response to the October

2018 Local Plan consultation comprising a Vision Document with Masterplan and Access

Appraisal.

4.3 Since the October 2018 Local Plan our client has taken the opportunity to engage with the

adjacent landowner of Sites 938/1014, Vigo Group. Vigo Group has confirmed the Company’s

willingness to promote its land in collaboration with our client, and so the potential development

area of West Moor Park East has increased from 79 hectares to 88.54 hectares. A revised

Masterplan has been prepared for this larger site area, as attached at Appendix 6.

4.4 We set out below the reasons by West Moor Park East is the most appropriate option to address

the deficiencies in the employment land supply of the Local Plan that we have identified in this

objection.

Availability

4.5 As explained in the attached report by Dove Haigh Phillips (Appendix 4), the entire site is in two

ownerships who are collaborating to promote the land for comprehensive development. Vacant

Possession can be delivered at short notice. All the land necessary to deliver access is either

within public highway or the ownership of the existing land owners.

Suitability

(i) Planning Factors

4.6 Development of West Moor Park East for employment is consistent with the spatial strategy of

the plan. Policy 3 of the Local Plan indicates that Class B1/B2/B8 requirements in Main Towns


10 September 2019

(which includes Armthorpe) will be met in locations with good access to the M18/M180 network.

West Moor Park East clearly accords with this objective.

4.7 Junction 4 of the M18 is an established location for large scale employment, in particular major

warehouse buildings. The Core Strategy identifies this junction as an area of growth for

distribution warehousing in particular, as demonstrated in the extract from that plan below.

Doncaster Core Strategy (2012) Extract

4.8 Other relevant planning factors include:

• West Moor Park East is part-previously-developed, with an extant planning permission for

major motorsport and leisure uses, as explained in the attached Vision Document (Appendix

5);

• West Moor Park East comprises land of a low landscape quality, as explained in the

attached Vision Document;

• 55% (48.6 hectares) of West Moor Park East is in FZ1, the lowest zone of flood risk. As

explained in the attached report by Fairhurst (Appendix 3), our client has held discussions

with the Environment Agency to agree in principle that the remainder of the site can be

developed for employment, subject to mitigation;

• Written agreement has been reached with First Bus to extend the existing 15 Service into

the site to provide high frequency bus services, as explained in the attached reports by Fore

Consulting and Sanderson Associates (Appendices 1 and 2). First Bus have confirmed that

they anticipate that this service would be self-funding after five years;

• West Moor Park East has good links with both the built-up area of Armthorpe and the main

urban area of Doncaster. These links will be improved by the proposed dualling and other

improvements to the A630 (West Moor Link), which are funded and under construction.


11 September 2019

Table 7 of the Local Plan confirms that the West Moor Link is intended to facilitate the

unlocking of employment development along the route – which West Moor Park East would

be consistent with;

• Given the proximity of West Moor Park East to Armthorpe and the main urban area of

Doncaster, there would be a large available labour pool nearby, thus fostering sustainable

travel patterns to work opportunities and minimising in-commuting. The attached report by

Sanderson Associates (Appendix 1) shows that within 5 miles/8km the existing and proposed

population would be approximately 86,000 persons, the second highest potential labour

force compared to the proposed employment allocations of the Local Plan.

(ii) Commercial Factors

4.9 There are presently six well known commercial developers that have expressed serious interest

in the development of West Moor Park East for employment. This is a good barometer of the

commercial suitability of the site. The attached report by Dove Haigh Phillips (Appendix 4)

identifies other relevant factors as follows:

• The site comprises a significant amount of land promoted by two willing landowners which

can make a valuable contribution to the employment land requirement;

• The site has unrivalled access to the motorway network, being adjacent to Junction 4 of the

M18, approximately 5 miles north east of Doncaster town centre, but more importantly on

the opposite side of the motorway from West Moor Park which is a proven and established

employment location. None of the other sites with a draft allocation can demonstrate these

fundamental characteristics;

• The site has direct frontage to the M18 including the south bound exit slip road and frontage

from the Junction 4 roundabout into the site;

• The site is located close to existing built development extending to in excess of 2,500,000

sq ft of large format buildings and several other smaller units. Occupiers, developers and

investors are attracted to sites and locations which have a proven track record of delivering

sustainable development over may economic cycles;


12 September 2019

• The site has close proximity to the labour pool of Armthorpe. This will allow development

at the site to contribute to minimising travel to work distances (irrespective of any bus

improvements which would also provide access to a significant workforce via extension of

the No.15 service)

Achievability

4.10 The attached report by Dove Haigh Phillips (Appendix 4) concludes that due to a combination of

the key characteristics above, high quality development at West Moor Park East is eminently

achievable. Dove Haigh Phillips find that the site satisfies all of the six key occupier requirements

as set out at Section 6 of their report.

4.11 In the light of the above, we conclude that West Moor Park East is an extremely good fit to

address the employment land supply deficiencies we have identified, in both planning and

commercial terms. At Issue 4 below we respond the Council’s stated reasons for rejection of the

site as an allocation.


13 September 2019

5.1 The Council’s formal reasons for not allocating West Moor Park East are set out at Page 216 of

the June 2019 Housing and Employment Site Selection Methodology and Results Report. We

summarise each reason and provide a response as follows.

As with all the potential sites, this site fails the sequential test as it is within Flood Zone 3

5.2 Whilst part of West Moor Park East is within FZ3, 54% (48.6 hectares) of the site is located in

FZ1, with the remainder being located in FZ3a and FZ2. This quantum of land could replace

almost all of the Council’s expected Local Plan contribution of Site 001 (51.54 hectares) that is

located in FZ3a. It could replace all of the Council’s expected Local plan contribution of Site

441 (12.32 hectares) that is located in FZ3a. The attached report by Fairhurst (Appendix 3)

therefore concludes that the application of the sequential test would preferentially select West

Moor Park East to these two sites.

It scores similarly to the other sites through the Sustainability Appraisal Process

5.3 Our client’s associated objection to the Site Selection process of the Local Plan shows that West

Moor Park East is more accessible by bus than most of the other proposed employment

allocations. Our objection also includes a revised SA that demonstrates that development of

West Moor Park East would have material advantages in socio-economic terms over Site 001, a

draft allocation.

It is currently within Countryside Policy Area as designated by the UDP Proposals Map

5.4 The extent of the UDP-defined Countryside Policy Area is not up to date. The UDP was adopted

in 1998, and was only intended to provide for employment needs up to 2006.

5.5 The Core Strategy post-dates the UDP and Policy CS2 identifies a number of Countryside Policy

Areas as broad areas of growth including land around Junction 4 of the M180. This demonstrates

that the principle of use of Countryside Policy Area at West Moor Park East to help meet

employment needs reflects current policy, and should not be at issue. The Council has proposed

allocation of Site 001 for employment and all of this is within a defined Countryside Policy Area,

as is all of Site 941.


14 September 2019

The majority of the site is within the Armthorpe Neighbourhood Plan as Countryside Policy Area

(as included in the Core Strategy in Policy CS3)

5.5 As confirmed at Para 30 of the NPPF, once the Local Plan is adopted the policies within it take

precedence over the Neighbourhood Plan. In this context the Neighbourhood Plan and the Local

Plan are dealing with different issues and at different scales of geography. The Neighbourhood

was not bound to designate the employment needed by Doncaster on a Boroughwide basis in the

most appropriate place.

The Parish Council were given the opportunity to consider potential employment sites during the

preparation of the Neighbourhood Plan, and as a result of that process there is already a

substantial amount of employment land within the Parish boundary

5.6 Only part of West Moor Park East is located within the Neighbourhood Plan area, as shown by

the plan extract below. It is an area of land at the periphery of the Plan. Furthermore, the

Neighbourhood Plan was not required to consider the need for such land to meet the

employment needs of Doncaster on a strategic basis.

Armthorpe Neighbourhood Plan (2018) Proposals Map Extract 5.7 All of the employment land referred to within the Neighbourhood Plan is either developed or

under construction. The new Local Plan looks to provide for employment land needs up to 2035,

and in this context West Moor Park East is located within Armthorpe, which is a defined Main

Town. Policy 2 of the Local Plan states that such settlements will be the focus for substantial

housing growth ‘supported by appropriate levels of employment’. In addition Policy 3 states that

in Main Towns employment growth will be directed to locations that can accommodate large


15 September 2019

buildings with good access to the M18/M180 motorways. West Moor Park East therefore clearly

confirms to the spatial strategy of the Local Plan.

The site is to the east of the M18 and more isolated than other options that are available across

the Borough

5.8 The location of the site accords with the spatial strategy of the Local Plan (and also the Core

Strategy), as indicated above. West Moor Park East has good links with both the built-up area

of Armthorpe and the main urban area of Doncaster. Given the proximity of West Moor Park

East to Armthorpe and the main urban area of Doncaster, there would be a large available labour

pool nearby, thus fostering sustainable travel patterns to work opportunities and minimising in-

commuting. The extract below from the report by Sanderson Associates (Appendix 1) shows that

within 5 miles/8km the existing and proposed population would be approximately 86,000

persons, the second highest level compared to the proposed employment allocations of the

Local Plan.

Population within 8km Travel Distance

Existing Proposed Total

Site Ref. Location Population Households Population Households Population Households

937 West Moor

Park East

77,500 33,500 9,405 4,089 86,905 37,589

001 Thorne

North 29,000 12,200 2,493 1,084 31,493 13,284

441 Carcroft 83,000 36,200 7,390 3,213 90,390 39,413

878/1032 Rossington 70,300 30,800 14,472 6,292 84,772 37,092

941 Poplar Farm 55,200 23,900 12,271 5,335 67,471 29,235

5.9 In the light of the above, the site would not be isolated. The location is well related to a large

population, and would benefit from a high frequency bus service, as explained at Para 4.8 of this

objection. A key advantage of the site is that it would not be so close to the main residential

areas of Armthorpe for large employment uses to cause adverse amenity impacts in respect of

HGV movements, noise and light pollution.

5.10 We note that Site 001, a draft employment allocation, is located on the western side of the M18

to the main built up area of Thorne. That site has a similar relationship with Thorne to how West

Moor Park East relates to Armthorpe, but it does not receive similar comments in the Site

Selection Report. We do not therefore consider that the Council has been consistent in its

approach.


16 September 2019

There are other options directly adjacent to the main urban area and main towns which offer

better opportunities for securing sustainable development such as long-term public transport

access

5.11 In terms of the draft allocations in the Local Plan, neither Site 941 or Site 001 is located adjacent

to the main urban area or a main town.

5.12 The attached report by Sanderson Associates (Appendix 1) shows that the Council has not taken

account of the proposals to improve bus accessibility to West Moor Park East that were provided

to the Council at October 2018 Local Plan stage. These would provide for a high frequency

service to the site on a long-term basis, as First Bus has confirmed that the service would be self-

funding after five years. Sanderson Associates also show that compared to a number of the other

proposed employment allocations within the Local Plan West Moor Park East would have

superior accessibility, and it would also score well in terms of its ability to minimise travel to work

distances. This is demonstrated in the extract from the Sandersons report overleaf.

Site Train

Accessibility Bus

Accessibility Cycle

Accessibility Road

Access

Ability to minimise travel to

work distances

937/1031 West Moor Park East

N/A + 0 + +

001 Thorne North

- - 0 + -

092 Balby Carr

Bank - 0/+ 0 0 +

441 Carcroft Common

0 0 0 0 +

878/1032 Rossington

N/A + 0 0 +

941 Poplars Farm

- 0 0 0/+ 0

Extract from Sanderson Associates Report

There are also concerns over vehicular access from Junction 4

5.13 Section 3 of the attached report by Fore Consulting (Appendix 2) explains that access

arrangements were identified within the Transport and Access Appraisal submitted to the


17 September 2019

Council as part of our client’s response to the October 2018 Local Plan consultation. The works

comprise the widening of Holme Wood Lane, which is an adopted public highway to 7.3m

between Junction 4 of the M18 and the proposed access point.

5.14 The works that are likely to be necessary would be accommodated within land that is either

adopted public highway or on land that is controlled by the promoter. As such, works

anticipated to be required on Holme Wood Lane are readily deliverable by the promoter and

the details of this can be secured by DMBC through a future planning process.

5.15 The report by Fore Consulting also includes a capacity study that demonstrates that

development of West Moor Park East for employment use would give rise to traffic that can be

satisfactorily accommodated at Junction 4 of the M18. The main operation issues on the local

highway network relate to traffic queuing back from roundabouts on the A630 West Moor Link

at certain times. However, it is anticipated that the West Moor Link improvement scheme (the

first phase of which is under construction) will resolve the existing queuing issues on the A630

and further improve the capacity and operation of key junctions along the A630 corridor.

The allocation of this site would exceed the supply of employment land for this plan period

5.16 Policy 3 of the Local Plan indicates that the 481 hectare employment land requirement is a

minimum target. The allocation of West Moor Park East for employment would be in

accordance with Policy 3. In any event, in this objection to Policy 4 we have identified issues

with the employment land supply in quantitative and choice terms. West Moor Park East is the

logical option to address these issues.

Sites other than this one have been chosen for allocation in order to provide a balanced

distribution of employment land across the Borough

5.17 Allocation of West Moor Park East would accord with the spatial strategy of the Local Plan, as

explained at Para 5.7 above.

5.18 The employment land strategy of the Local Plan has to be deliverable to be effective. The

ELNA Update confirms that the majority of the need for employment is for warehousing

development, and operators have specific requirements, such as good access to the motorway

network, proximity to a labour pool and a high profile location. West Moor Park East is a good

fit with these needs.


18 September 2019

5.19 Allocation of employment sites such as Site 441 (Carcroft) to provide a ‘balanced distribution’

will not be effective if they do not meet the needs of the market. This objection has

demonstrated that this site is unlikely to be brought forward during the plan period due to its

dependency on the A1M/A19 link road, the delivery of which is highly uncertain.

5.20 Given all of the above, we do not consider that the Council’s stated reasons for rejection of

West Moor Park East are justified, credible or sound overall.


19 September 2019

6.1 Land at West Moor Park East (Sites 1031/937, 1014 and 938) should be included as an additional

employment allocation.

6.2 Without prejudice, if West Moor Park East is not included as an additional employment

allocation, then it should be identified as a ‘reserve’ employment allocation to provide an

additional buffer to, and flexibility in, the employment land supply. This request is consistent

with our client’s associated objection to Policy 3.

Doncaster

Local Plan









Title Mr

First Name Mark

Last Name Eagland






Postcode LS3 1AB

E-mail Address

Telephone Number


















or




Doncaster Local Plan Publication Draft ☒ Policies Map ☒





Policy Ref.: Policy 4 Site Ref.: 001

Policies Map:


















Examination.


Date 30/09/2019



• or email:

copies of this form are available to download at www.doncaster.gov.uk/localplan



or defamatory.




T: E:


September 2019


OBJECTION TO PROPOSED ALLOCATION OF SITE 001: THORNE NORTH 2 September 2019

1.1 Blue Anchor Leisure objects to the proposed allocation of Site 001 for employment.

1.2 It is considered that there are doubts about the deliverability of Site 001 for employment within

the plan period; allocation of the site fails the sequential approach; and we also have concerns

about the Sustainability Appraisal (SA) scores set out in the Council’s Site Selection Report.


Accessibility Technical Note by Sanderson Associates (Appendix 1); the attached Flood Risk

report by Fairhurst (Appendix 2); and the attached Commercial Review Report by Dove Haigh

Phillips (Appendix 3).

1.4 This representation should be read in conjunction with our client’s associated objections to

Policies 3 and 4, and the Site Selection process of the Local Plan.



2.1 Site 001 was rejected as an allocation during the October 2018 Local Plan consultation. The

Council’s stated reasons for rejection of the site within the September 2018 Site Selection

Methodology and Results Report provided at that stage were as follows:

“Although there are successful existing industrial estates to the north of Thorne which this site

could complement, and there is an outline planning application pending, there are concerns over

the site’s deliverability as there are more deliverable sites elsewhere.” (our emphasis)

2.2 The Site Selection Report for the Publication Draft Local Plan does not provide any new

information to demonstrate why the previous concerns about the deliverability of Site 001 have

now been overcome. Whilst a planning application has been submitted for the site, this was

lodged some 2 years ago and is still pending – which suggests that there are some issues

regarding the suitability of the site for employment that still need to be resolved.

2.3 The attached report by Dove Haigh Phillips (Appendix 3) comments that Thorne is not an

established hub for warehousing development and existing employment development has taken

place over a much long period of time than the pace achieved at iPort and West Moor Park.

2.4 Dove Haigh Phillips also note that Site 001 is not well related to the main urban area of Doncaster

(as recognised by the Colliers Employment Land Review 2018) and there is a limited catchment

population to provide a local labour force to support a large scale development at Thorne North.

This is demonstrated in the extract overleaf from the Sanderson Associates report (Appendix 1),

which shows that within a 5mile/8km travel distance from Thorne North there would be

approximately a third of the population that would be available witin the same distance from

rejected site option West Moor Park East (Site 937/1031/938/1014).



2.5 In light of the above, Dove Haigh Phillips question whether Site 001 could deliver the quantum of

land anticipated by the Local Plan (51.54 hectares) over the plan period. Dove Haigh Phillips

consider that it is more likely that the site would deliver 36.8 hectares, as estimated by the

Colliers Employment Land Review 2018 (and also confirmed in the subsequent amendments to

the Colliers Employment Land Review, made as recently as June 2019). We also note that the

Site Selection Report reasons project this lower employment contribution to the Local Plan, 36.8

hectares, than is assumed by the actual figure stated within the Site Selection table, 51.54

hectares. This indicates that there is a 14.74 hectares shortfall in the likely delivery from Site

001.

2.16 In summary, the Council’s previous assessment of Site 001 at the October 2018 Local Plan

consultation stage indicates that there are delivery concerns about this option, and no new

evidence has been provided at Publication stage to justify its change in status from a rejected

allocation to a draft allocation.

2.17 At best, we agree with the conclusion of Colliers and the Site Selection Report that Site 001 would

be only likely to deliver up to 36.8 hectares of land over the plan period. This leaves a 14.74

hectare shortfall in the Council’s assumed delivery from this site.

Population within 8km Travel Distance

Existing Proposed Total

Site Ref. Location Population Households Population Households Population Households

937 West

Moor Park East

77,500 33,500 9,405 4,089 86,905 37,589

001 Thorne North

29,000 12,200 2,493 1,084 31,493 13,284

441 Carcroft 83,000 36,200 7,390 3,213 90,390 39,413

878/1032 Rossington 70,300 30,800 14,472 6,292 84,772 37,092

941 Poplar Farm

55,200 23,900 12,271 5,335 67,471 29,235



3.1 Para 158 of the NPPF states that development should not be allocated or permitted if there are

reasonably available sites appropriate for the proposed development in areas with a lower risk

of flooding. This is a fundamental purpose of the sequential test for flooding. Para 159 indicates

that the exception test should only be applied if it is not possible for development to be located

in zones with a lower risk of flooding (taking into account wider sustainable development

objectives).

3.2 As explained in the attached report by Fairhurst (Appendix 2) all of Site 001 is located within

FZ3a, in an area of known ponds and ditch drains, including the presence of shallow groundwater

and poor surface water drainage. It is therefore necessary to consider whether the site can be

accommodated on a suitable site in a lower zone of flood risk.

3.3 Section 4.4 of the Fairhurst report shows that the developable area of West Moor Park East (Site

937/1031/938/1014) in FZ1 is 48.6 hectares. This quantum of land could replace all of the

expected Local Plan contribution of Site 001 we refer to within Section 2 of this objection – 36.8

hectares. It could effectively also replace the greater contribution assumed by the Local Plan –

51.54 hectares. Fairhurst therefore conclude that the application of the sequential test would

preferentially select West Moor Park East to Site 001.

3.4 As explained in our client’s general comments on Policy 4, there is no evidence to suggest that

West Moor Park East is not a suitable site for employment. It is a site that accords with the

spatial strategy of the Local Plan and the sequential test requires that it is considered prior to

allocation of land in FZ3a. We therefore consider that the Local Plan does not properly apply

the sequential test to Site 001. Allocation of this site in the context of the rejection of allocation

of West Moor Park East is contrary to national policy.



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 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 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 Train

Accessibility Bus

Accessibility Cycle Accessibility

Road Access

Ability to minimise travel to

work distances

937/1031 West Moor

Park East

N/A + 0 + +

001 Thorne North

- - 0 + -

092 Balby Carr

Bank - 0/+ 0 0 +

441 Carcroft

Common 0 0 0 0 +

878/1032 Rossington

N/A + 0 0 +

941 Poplars Farm

- 0 0 0/+ 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.



5.1 Site 001 should be deleted as an employment allocation and replaced by the site option at West

Moor Park East (Site 937/1031/938/1014). West Moor Park East is more deliverable,

sequentially preferable in respect of flood risk and it performs better than Site 001 in respect of

SA.

Doncaster

Local Plan









Title Mr

First Name Mark

Last Name Eagland






Postcode LS3 1AB

E-mail Address

Telephone Number


















or




Doncaster Local Plan Publication Draft ☒ Policies Map ☒





Policy Ref.: Policy 4 Site Ref.: 441

Policies Map:


















Examination.


Date 30/09/2019






or defamatory.




T: E:

Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/1031)

September 2019


OBJECTION TO PROPOSED ALLOCATION OF SITE 441: CARCROFT COMMON 2 September 2019

1.1 Blue Anchor Leisure objects to the proposed allocation of Site 441 for employment.

1.2 It is considered that Site 441 is not deliverable for employment within the plan period; allocation

of the site fails the sequential approach; and the Sustainability Appraisal (SA) scores set out in

the Council’s Site Selection Report are incorrect.


Accessibility Technical Note by Sanderson Associates (Appendix 1); the attached A1M/A19

Technical Note by Sanderson Associates (Appendix 2) and the attached Flood Risk report by

Fairhurst (Appendix 3).

1.4 This representation should be read in conjunction with our client’s associated objections to

Policies 3 and 4 and the Site Selection process of the Local Plan.



2.1 All of Site 441 was identified as land to be safeguarded for employment use in the adopted UDP,

but it has not been developed for new employment uses despite the passage of 21 years, which

indicates that there are some significant constraints to its development. Para 4.22 of the UDP

acknowledges that the site has significant issues, particularly in relation to access and drainage.

The Local Plan and evidence base does not provide evidence that these constraints have been

overcome.

2.2 In relation to access, Paras 4.31/4.58 of the Local Plan and the Site Selection Report indicate that

development of Site 441 is dependent on construction of a new A1M to A19 link road. However,

whilst there is reference to this road in Policy 13 of the plan, it is no more than an aspiration. The

attached Technical Note by Sanderson Associates (Appendix 2) indicates that:

■ There is no information available about the precise route of the link road. It is simply an

indicative line;

■ The Southern Pennines Strategic Development Corridor – Strategic Outline Case (SOC)

March 2019 explains that the link road is at a very early stage of assessment, with no positive

funding available. The SOC states that delivery of this transport intervention “should not

be relied upon for planning and development purposes”;

■ Whether any road is ever built and if so the timescale for the delivery of it is a significant

unknown. There will be a need for decisions to be taken about priorities and funding, other

schemes will be competing for funding, and even when high level decisions are taken, they

are susceptible to being reviewed; and

■ Beyond this there will be a need for technical work and compulsory purchase of land. This

is likely to take implementation beyond the Local Plan period, if the link road happens at

all.

2.3 In the absence of certainty about the delivery of the A1M to A19 link road there is no certainty

about the delivery of Site 441. It is not a justified or effective allocation.



3.1 Para 158 of the NPPF states that development should not be allocated or permitted if there are

reasonably available sites appropriate for the proposed development in areas with a lower risk

of flooding. This is a fundamental purpose of the sequential test for flooding. Para 159 indicates

that the exception test should only be applied if it is not possible for development to be located

in zones with a lower risk of flooding (taking into account wider sustainable development

objectives).

3.2 As explained in the attached report by Fairhurst (Appendix 3) all of Site 441 is located within

FZ3a, in an area of known ponds and ditch drains, including the presence of shallow groundwater

and poor surface water drainage. It is therefore necessary to consider whether the development

proposed can be accommodated on a suitable site in a lower zone of flood risk.

3.3 Section 4.4 of the Fairhurst Report shows that the developable area of West Moor Park East (Site

937/1031/938/1014) in FZ1 is 48.6 hectares. This quantum of land could replace all of the

Council’s expected Local plan contribution of Site 441 (12.32 hectares) that is located in FZ3a,

and twice the total area of the site available for employment use. Fairhurst therefore conclude

that the objectives of the sequential test would preferentially select West Moor Park East to Site

441.

3.4 As explained in our client’s general comments on Policy 4, there is no evidence to suggest that

West Moor Park East is not a suitable site for employment. It is a site that accords with the

spatial strategy of the Local Plan and the sequential test requires that site is considered prior to

allocation of land in FZ3a. We therefore consider that the Local Plan does not properly apply

the sequential test to Site 441. Allocation of this site in the context of the rejection of allocation

of West Moor Park East is contrary to national policy.



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, no evidence has been provided that Site 441

would be within a safe 400m walk from high frequency bus services. Existing footways between

the site and bus stops on Doncaster Road (Services 405, 408 and 409) are narrow and there is a

lack of safe crossing facilities on Doncaster Road.

4.2 There is an additional bus service (No. 412) on Doncaster Road that provides access to Carcroft.

However, this only runs very infrequently (3 services during weekdays). Therefore, the bus

accessibility to the residential population is inadequate. Given that one of the reasons for the

Council proposing to allocate the site is that it will benefit the local community, this lack of bus

access to Carcroft is a constraint.

4.3 In the absence of evidence to demonstrate that Site 441 could access high frequency bus services

safely we consider that the SA score awarded to the site under Criterion 3A(ii) should be amended

from a light green positive score to a neutral orange score.



5.1 Site 441 should be deleted as an employment allocation. The primary concern is that the site is

not deliverable due to the high level of uncertainty associated with delivery of the A1M/A19 link.

5.2 In addition, the Local Plan does not properly apply the sequential test to Site 441. Allocation of

this site in the context of the rejection of allocation of West Moor Park East is contrary to national

policy.

Doncaster

Local Plan









Title Mr

First Name Mark

Last Name Eagland






Postcode LS3 1AB

E-mail Address

Telephone Number


















or




Doncaster Local Plan Publication Draft ☐ Policies Map ☐


Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☒ Site Selection Methodology



Policy Ref.: Site Ref.: 937/938/1014/1031; 001, 092, 441 and 941

Policies Map:


















Examination.


Date 30/09/2019






or defamatory.




T: E:


September 2019


OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 2 September 2019

1.1 Blue Anchor Leisure is concerned about a number of aspects of the Council’s site selection

methodology for employment sites.

1.2 These concerns relate to the soundness of the Sustainability Appraisal (SA) methodology and

scoring points that the Council has used to assess the sustainability of employment options;

inaccurate SA scores for the rejected employment option at West Moor Park East (Site

937/1031); and inaccurate and inconsistent SA scores for proposed employment allocations 001,

092, 441 and 941.

1.3 We also have concerns about the application of the flood risk sequential test to employment site

options.

1.4 In addition we have concerns about the absence of a comprehensive update to the Colliers

Employment Land Review (February 2018) and the weight that can be accorded to that

document’s comments about West Moor Park East (Site 937/1031).

1.5 The following comments should be read in conjunction with the attached Accessibility Technical

Note by Sanderson Associates (Appendix 1); the attached Technical Note by Fore Consulting

(Appendix 2); the attached Flood Risk report by Fairhurst (Appendix 3); the attached assessment

of employment site options by Dove Haigh Phillips (Appendix 4); and the Vision document

(Appendix 5) submitted in support of West Moor Park East in response to the October 2018 Local

Plan consultation.

1.6 At Appendix 6 we also attach revised SA Scores in light of our comments on the SA methodology

and the Council’s inaccurate SA scores. At Appendix 7 we attach a letter sent to the Council

from the Inspector appointed to Examine the withdrawn Doncaster Sites and Policies DPD.



(i) Omission of Consideration of Availability of Labour for Employment Options

2.1 An essential driver of the attractiveness of an employment site is the availability of labour in the

locality. As explained at Paras 6.13 and 6.18 of the attached report by Dove Haigh Phillips

(Appendix 4), occupiers seek proximity to an appropriate labour pool and (inter-alia) and strong

communication links for the workforce. For many occupiers an available, skilled and mobile

workforce is a pre-requisite. However, this is not currently taken account of within the SA.

2.2 On a related point Para 3.1 of the attached report by Sanderson Associates (Appendix 1)

expresses concern that the site selection process has not fully take into account one of the key

objectives of local and national transport planning policy related to the need to minimise travel

to work distances, as it is clear that the location of employment sites and their proximity to the

nearby residential population will be a major influencing factor on the ability of a development

to minimise travel to work distances.

2.3 Accordingly, we consider that the absence of consideration of the available local labour pool for

employment site options is a major omission in the site selection exercise that has been carried

out by the Council. At Paras 3.5 to 3.8 of the attached Sanderson Associates report (Appendix

1) we provide data on the available population (existing and proposed) within 8km/5 miles of key

proposed allocations. This shows that the employment option at West Moor Park East is ranked

second out of five sites – Sandersons conclude that the site is well located to a large residential

population, which will allow development at the site to minimise travel distances before any

regard is taken of public transport and bus improvements.

(ii) Scoping out of Economic and Growth Criterion for Employment Options

2.4 Appendix A3 of the Housing and Employment Site Selection Methodology Report indicates that

economic and growth criteria have been removed from the SA of employment sites, but this

seems an illogical decision when considering the relative merits of different options for the

economy and job creation of Doncaster. Para 32 of the NPPF indicates that SA should consider

opportunities for net gains in economic objectives.

2.5 Some sites will clearly have greater potential than others for economic benefits to Doncaster and

it should be possible to differentiate those that would result in more modest positive effects and

those that could give rise to significant positive impacts. As demonstrated by Dove Haigh Phillips,



some sites due to their location and characteristics are not likely to be attractive to the market

and will not deliver development or at least not at the rate the Local Plan suggests. This is a

significant factor that goes to the ability to deliver and achieve the benefits and objectives of the

Plan. If a site will not be able to deliver the benefits associated with the development suggested,

this is highly relevant when taking account of the harm associated with its development in order

to determine the soundness, justified and effective nature of the Plan when compared to

reasonable alternatives.

(iii) Unnecessary Consideration of Access to Centre for Employment Options

2.6 Criteria 3B(i) seeks to compare the relative accessibility of employment options to defined

shopping centres. Whilst we agree that this is relevant to how easily occupants of housing sites

will be able to meet everyday shopping and service needs, we do not consider that this is a

relevant criterion when considering the sustainability of an employment option.

2.7 The larger scale allocations of the plan are likely to have ancillary on-site Class A3/A4/A5

facilities and many businesses have in-house canteens in order to reduce the need for employees

to leave the site to obtain lunch for example. Most industrial estates are also visited by mobile

catering companies where such facilities are not available or insufficient to meet demand. The

accessibility of an employment site to a defined shopping centre is not therefore an important or

relevant guide to its overall sustainability.

(iv) Arbitrary Flood Risk Threshold

2.8 Appendix A3 of the Housing and Employment Site Selection Methodology Report confirms that

the Council has scored all sites with 20% or greater in FZ3a with a negative score (11A(i)).

However, the rationale for a threshold as low as this is not justified, and we do not agree that this

is a sound way of comparing the relative sensitivity of sites to flood risk or for directing as much

development as possible to the lowest zones of flood risk – which is the overriding objective of

the sequential test. Para 158 of the NPPF states that:

“Development should not be allocated or permitted if there are reasonably available sites

appropriate for the proposed development in areas with a lower risk of flooding.”



2.9 By way of example, 54% (48.6 hectares) of West Moor Park East (Site 937/1031/938/10141) is

located in FZ1, with the remainder being located in FZ3a and FZ2. However, this site is awarded

(in the Council SA) the same negative (pink) score as sites 001 and 441, 100% of which are in

FZ3a. The total Local Plan contribution of Site 001 is 51.54 hectares and therefore nearly all of

it could be provided within FZ1 at West Moor Park East. The total Local Plan contribution of

Site 441 is 12.32 hectares and therefore all of it could be easily provided within FZ1 at West

Moor Park East.

2.10 In the light of the sequential test it is therefore illogical and unsound for the SA to treat all sites

with 20% or greater in FZ3a with the same negative score. We consider that the binary nature of

Criterion (11A(i)) should be amended to one that allows employment sites with a significant

proportion within FZ1 to be awarded higher scores than those that are wholly or substantially in

zones of higher flood risk.

(v) Consideration of Details of Public Transport Improvements by Site Promoters

2.11 Para 6.2.3 of the Housing and Employment Site Selection Methodology Report notes that where

robust evidence has been provided by site promoters SA scores have been revised in order to

give a post mitigation score for findings and criteria specific to the site. However, we are

concerned that this exercise does not appear to have been undertaken in a complete manner,

particularly in the case of West Moor Park East (Site 937/1031/938/1014).

2.12 At the 2018 Informal Draft Local Plan consultation stage Blue Anchor Leisure submitted a

package of information specific to West Moor Park East, 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. However, there

is no indication from Appendix S of the August 2019 SA that this information has resulted in

changes to the SA scores. By way of example, the extension of the 15 Service frequent bus route

into the site should result in a green score in relation to ‘distance to bus stop (3A(ii))’ as this would

result in a stop within centre of the proposed development, but West Moor Park East is currently

awarded a pink (negative) score.

2.13 We consider that the relative accessibility of employment site options to high frequency bus

services is of greater importance than the access to train services criterion included in the SA.

1 Please note that since submission of representations in respect of the October 2018 Local Plan Consultation the site boundary of West Moor Park East has been expanded to include Site 938/1014 – please see associated representations in respect of Policy 4.



As explained at Paras 4.4.1 to 4.2.3 of the attached report by Sanderson Associates (Appendix

1), a train service will not necessarily provide a good and convenient means of accessing an

employment site for a high proportion of the population as it is very dependant on the location

of train routes and stations.

(vi) Consideration of Importance of Nature Conservation Site and Potential for Mitigation in

Biodiversity Criterion

2.14 Appendix A3 of the Housing and Employment Site Selection Methodology Report indicates that

under criterion 12A(i) all sites that overlay (in part or whole) a defined wildlife site will be awarded

a double negative (red) score irrespective of the importance of the designation or the scope for

mitigation. In our view this is an unsophisticated and crude approach to assessment of the

biodiversity impact of employment sites.

2.15 Para 171 of the NPPF states that plans should distinguish between the hierarchy of international,

national and locally designated sites and allocate land with least environmental value. However,

at present criteria 12A(i) would award the same score to a site that overlays a local wildlife site

(even if that overlay were on a very small area of the site in question) to one that fully overlays a

SSSI or SAC, contrary to national policy. There is also no attempt within the SA to differentiate

the degree of harm to the designation, taking into account the amount of overlap with the

designation.

2.16 We are also concerned that there is no consideration of the likely actual impact on designated

sites where a site promoter has supplied appropriate mitigation/enhancement information to the

Council. In the case of West Moor Park East (Site 937/1031/938/1014), the SA makes reference

to the fact that the site incorporates a small local wildlife site, Holme Wood. However, the Vision

Document provided in our client’s response to the 2018 Informal Draft Local Plan consultation

(Appendix 5) not only shows that no employment development is proposed in that part of the

site, but it also indicates that new vegetation and SUDs features would be provided to enhance

the setting of Holme Wood and create new wildlife habitat. At present criterion 12A(i) does not

allow these benefits to be reflected in a SA score.

2.17 We therefore consider that criterion 12A(i) should be amended to distinguish between the

hierarchy of international, national and locally designated sites; the degree of harm to the

designation; and to allow for mitigation/enhancement to be considered where site promoters

have provided such information.



(vii) Highways Capacity

2.18 The Highways Capacity for housing and employment options is considered in a separate SA

Technical Appendix. However, as explained in the attached Technical Report by Sanderson

Associates (Appendix 1), this relates to a very high-level assessment undertaken in 2015 of

potential impacts on key junctions on the trunk road network only. No quantitative or qualitative

assessment of the impact of allocations on the local road network has been undertaken. It is

therefore considered that the scoring criterion is inaccurate and unreliable and it provides an

insufficient basis upon which to consider operation to the highway network and access to

employment sites.

2.19 In respect of West Moor Park East (Site 937/1031/938/1014), the attached Technical Note by

Fore Consulting (Appendix 2) includes a capacity study that demonstrates that development of

this option for employment use would give rise to traffic that can be satisfactorily accommodated

at Junction 4 of the M18. The current main operation issues on the local highway network relate

to traffic queuing back from roundabouts on the A630 West Moor Link at certain times. The

West Moor Link improvement scheme (the first phase of which is already under construction) will

resolve the existing queuing issues on the A630 and further improve the capacity and operation

of key junctions along the A630 corridor.

2.20 Given the above, there is no justification for the current red (considerable traffic impact) ranking

of West Moor Park East within the Council’s Highway’s Capacity Study.



/

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 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).



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.

Thorne North (Site 001)

4.2 3A(i) Access to train station – Thorne North is further than 1.2km of Thorne train station once

practical walking distances are taken into account.

4.3 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 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.

4.4 The neutral (orange) score that has been awarded against this criterion should therefore be

changed to a red (negative) score.

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.



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 (orange) score.

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.



5.1 We attach at Appendix 6 revised SA scores for West Moor Park East (Site 937/1031/938/1014)

and the other sites we refer to under Issue 3 where we identify inaccurate scores that the Council

has applied.

5.2 Whereas the Council’s site selection document asserts that Sites 001, 441 and West Moor Park

East score similarly to other sites through the SA process, our revised scores show material

differences – between Site 001 and West Moor Park East in particular. West Moor Park East has

more green scores than Site 001 (7 versus 4), less red scores than Site 001 (1 versus 1) and less

pink scores than Site 001 (3 versus 6).

5.3 In our view this casts considerable doubt over the soundness of the Council’s SA process as a

way of informing the site selection process for employment site options. This is before

assessment of the delivery of sites has been taken into account in terms of market attractiveness

that would only serve to underscore these outcomes in favour of the West Moor Park East site.



6.1 As explained under Issue 1, Para 158 of the NPPF states that development should not be

allocated or permitted if there are reasonably available sites appropriate for the proposed

development in areas with a lower risk of flooding. This is a fundamental purpose of the

sequential test for flooding.

6.2 However, Section 4.4 of the attached report by Fairhurst (Appendix 3) shows that the

developable area of West Moor Park East Site 937/1031/938/1014 in FZ1 is 48.6 hectares. This

quantum of land could replace almost all of the Council’s expected Local plan contribution of

Site 001 (51.54 hectares) that is located in FZ3a. It could replace all of the Council’s expected

Local plan contribution of Site 441 (12.32 hectares) that is located in FZ3a. Fairhurst therefore

conclude that the application of the objectives of the sequential test would preferentially select

West Moor Park East to these two sites.

6.3 In the light of the above we consider that the application of the sequential test to employment

site options is flawed. This is an issue of considerable concern given that the sequential test was

identified by the Inspector for the withdrawn Doncaster Sites and Policies DPD in a letter dated

3 June 2014 (Appendix 7). At Para 42 of that letter the Inspector concluded:

“42. I am not persuaded that the Council has applied these tests as stringently as the NPPF

requires. I do not consider that the Council’s starting point has been to seek to steer development

away from areas with the highest probability of flood risk. I have seen no evidence that this

objective has been properly weighed against wider sustainability objectives or that such an

exercise has demonstrated that it is ‘not possible’ to locate development in areas of lower

probability of flooding. It is only when these matters have been fully assessed that the Exceptions

Test should be applied. As its name suggests the test should involve only exceptional cases. Again

I have seen no clear evidence that the Council has weighed the risk from flooding against the

wider sustainability benefits to the community which would accrue. Site-specific flood risk

assessments have not been carried out in all cases.”

6.4 Until the sequential test is correctly applied for employment site options (which would inevitably

require land to be allocated at West Moor Park East in preference to Sites 001 and 441) we

consider that there is a considerable risk that the Local Plan will be found unsound for similar

flood risk reasons as identified in respect of the Sites and Policies DPD.



7.1 We note that the Council’s evidence base includes an addendum to the Colliers Employment

Land Review (February 2018) that has been produced in light of the 2018 Informal Draft Local

Plan consultation. However, this is only a very selective update. For example, the Addendum

does not update the assessment of West Moor Park East (Site 937/1031/938/1014) in the light

of the substantive response to the 2018 Informal Draft Local Plan consultation provided by Blue

Anchor Leisure, and the considerable consultation that has taken place between our client and

the Council.

7.2 In the absence of such an update we do not consider that the assessment of West Moor Park

East provided within the Colliers Employment Land Review, a key element of the Local Plan

evidence base for employment options, should be relied upon when considering the merits of

this site for employment. However, we agree with the conclusion of Colliers at Appendix 3 that

West Moor Park East is well located and a potential extension to the established employment

destination at West Moor Park.

7.3 In the light of the various concerns referred to above we consider that the Site Selection

Methodology is not positively prepared, justified, effective or consistent with national policy.

Considerable amendments are required to the Council’s approach in order to make it sound.

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Documents

From: Peacock and Smith re West Moor Park East Sent: 30 … · 2020. 3. 18. · From: Peacock and Smith re West Moor Park East Sent: 30 September 2019 16:02 To: Local Plan Subject: