Meeting documents

 

Agenda Item No: 8

22 January 2013

                  

 

 

Corporate Report Format

 

 

To the Chair and Members of the

Regeneration and Environment Overview and Scrutiny Panel

 

Local Development Framework Sites and Policies Development Plan Document

 

Relevant Cabinet Member(s)	Wards Affected	Key Decision
Peter Davies, Mayor of Doncaster (Development Portfolio Holder)   Councillor Barbara Hoyle (Housing Portfolio Holder)   Councillor Paul Coddington (Environment Portfolio Holder)	All	K1117

 

EXECUTIVE SUMMARY

 

1.     This report provides an update on the Sites and Policies Development Plan Document (hereafter the S&PDPD) and the timeline for formal approval process up to Full Council in March 2013. 

 

2.     The Local Development Framework Core Strategy was adopted in 2012 and sets the overall approach for planning policy, but does not identify individual development sites or contain detailed policies.  The S&PDPD is intended to provide this finer grain of detail, building on the approach established by the Core Strategy. 

 

EXEMPT REPORT

 

3.        N/A

 

RECOMMENDATIONS

 

4.       The panel are asked to note and endorse:

 

A.       the proposed responses to the main points raised from the consultation as set out in appendix 1;

B.       the proposed amendments in relation to housing and employment sites as set out in appendix 2; and

C.       the approach to Full Council approval, including the items for which delegated authority will be sought.

 

 

 

BACKGROUND

 

5.       The S&PDPD forms part of our Local Development Framework which is a collection of documents which make up the statutory development plan (or local plan) for Doncaster. The development plan informs decisions on planning applications and a range of implementation plans.  As well as this S&PDPD, the Local Development Framework includes a Core Strategy and a separate Joint Waste Plan.  Further detail on some individual policies is also provided in separate Supplementary Planning Documents. 

 

6.       The Core Strategy was adopted by Full Council in 2012 and sets the overall approach for planning policy, including housing and employment land targets, but does not identify individual development sites or contain detailed policies.  The S&PDPD is intended to provide this finer grain of detail, building on the approach established by the Core Strategy including specifically the sites needed to meet the Core Strategy housing target.  It is therefore important that the two documents are read together.  To help with this, the topics within this plan are ordered as per the Core Strategy, and with the same chapter headings.

 

7.       The adopted Joint Waste Plan (JWP) has been produced with Barnsley and Rotherham, and includes not only the overall approach for waste, but also the relevant site allocations and detailed policies.  Therefore it is not envisaged that this document will need to include any detail in relation to waste, although the Proposals Map will need to reflect the site allocations made in the JWP and set out the detailed boundaries of the existing landfill sites identified within the JWP.

 

Recommendation to Full Council

 

8.       The Local Government Act requires the approval of statutory planning policy to be a Full Council decision.  The formal decision to adopt the plan will be made after the Examination in Public (and subject to the inspector’s report finding the plan sound).  However, only very minor amendments can be made at that stage.  It is therefore important that at this stage Full Council are satisfied that the S&PDPD is fit-for-purpose and in accordance with our aspirations for the borough set out in the Borough Strategy.

 

9.       It will therefore be recommended in March 2013 that Full Council approve the S&PDPD to progress to the Publication stage and, subject to no new major issues being raised during the Publication stage, the submission of the document to government.  This will include the content summarised below.

 

A.       The draft policies (as consulted on over the summer, amended and updated in light of the consultation for presentation to Full Council).

 

B.       The proposed development allocations, including:

 

·                     Housing sites;

·                     Gypsy and Traveller sites;

·                     Employment sites (new and existing major and local employment sites);

·                     Mixed-use sites; and minerals.

 

C.       Other proposed allocations, including:

 

·                  Town centres;

·                  Primary and secondary shopping frontages;

·                  Green wedges; and

·                  Bentley Flood Corridor.

 

10.     It is will also be recommended that Full Council give delegated authority to:

 

A.       approve any minor amendments necessary to finalise the plan for publication, (including both the written document and the other map layers which will be set out in an appendix – these will include the precise Green Belt/Countryside Policy Protection Area, Residential Policy Areas and Open Space); and

 

B.       approve the necessary evidence base and procedural documentation required to progress the plan, including the Sustainability Appraisal and Habitats Regulation Assessment.

 

Timescale

 

11.     The timescale up to publication is summarised in the table below.  Publication is a statutory stage and must last for six weeks.  The formal Publication stage is planned towards the end (or just after) PERP - as it is not 'consultation' but only an opportunity for Soundness challenges.  Legal and Democratic Services have confirmed previously for the Core Strategy that submission during PERP is acceptable.

 

12.     Following publication we will assess the representations received and prepare the document for submission.  We cannot make any significant changes post-publication, but we can make editorial amendments and finalise/update evidence base.  As was the case for the Core Strategy, when we seek Full Council approval for publication, we will also seek delegated powers to proceed to submission if no new major issues are raised as a result of publication.  If necessary, a meeting of the LDF Project Board will be held to help make this judgement.  The Core Strategy went through Publication on 21/03/11 and was submitted on 29/07/11 (so took four months), based on similar timescales submission of the S&PDPD would be in September 2013.

 

Date	Meeting
30/01/13	Executive Board (As Draft Cabinet Report)
05/02/13	Planning Committee
13/02/13	Cabinet – including a verbal update of any issues raised by Planning Committee
07/03/13	Full Council

 

OPTIONS CONSIDERED / REASONS FOR RECOMMENDED OPTION

 

13.     There are a number of key areas where we are considering options:

·       wording of draft policies

·       housing sites and overall distribution of housing;

·       gypsy and traveller sites;

·       employment sites;

·       mixed-use sites;

·       mineral sites;

·       developer requirements; and

·       other map layers.

 

14.     Appendix 3 sets out a summary of the approach in relation to the key issues of housing sites and overall distribution of housing.

 

15.     The comments from various meetings, including the R&E O&S panel will inform how these options are finalised for consideration by Full Council in March 2013.

 

IMPACT ON THE COUNCIL’S KEY PRIORITIES

 

16.     This report seeks to progress Doncaster’s planning policy framework.  Planning policies support the investment in Doncaster, including the creation of new jobs and creation of new homes prioritising the use of well-located brownfield sites. They seek to protect and enhance Doncaster’s countryside, heritage and natural environment. Up-to-date policies give greater certainty to the development management process, and ensure that the development proposals brought forward in the Borough take account of the Council’s aspirations and priorities.

Priority Theme	Mayor’s Priorities	Implications of this Initiative
1. Creating a strong, connected and inclusive economy	·                 Drive forward the Doncaster economy ·                 Get the balance of public and private transport right ·                 Promote Doncaster as a tourist destination ·                 Regenerate Doncaster's town centres	Planning policies will raise confidence that Doncaster is a good place to invest in, and provide a level of certainty to developers, thus supporting housing and economic growth.
7. Creating a cleaner and better environment	·                 Continue to protect the environment from developers, decay and architectural vandalism	Planning policies will help to ensure that development takes account of environmental issues such as flooding, and also contains policies to protect the countryside, wildlife and heritage.

 

RISKS AND ASSUMPTIONS

 

17.     The final version of the S&PDPD is decided not by the Council but by government.  Following publication and submission to government, a government inspector will oversee an examination in public to test whether the plan is sound (fit for purpose).  Only if the subsequent inspector’s report concludes that the plan is sound can it then be adopted by the Council.  The National Planning Policy Framework states at paragraph 182 that to be sound a plan must be:

 

Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

 

Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

 

Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

 

Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the framework.

 

18.       In light of the consultation responses and internal discussion, this gives a number of key issues, as summarised below.  We are working through these issues in more detail, informed by the proposed discussions at the various meetings set out previously.

 

·         Level of Housing Provision

·         Settlement Hierarchy and Balance of Sites

·         Infrastructure (Education, Flooding and Transport)

·         Viability (Development Requirements and CIL)

·         Interim Applications/appeals and 5 year housing land supply

·         Sites in Council ownership

·         Providing land for jobs

·         Neighbourhood Planning

·         Cross Boundary Working

·         Gypsies and Travellers

 

Neighbourhood Planning

 

19.     There are currently five emerging Neighbourhood Plans in the borough:

 

·       Tickhill (Core Strategy identifies as being suitable for infill development only, so no housing target);

·       Burghwallis (Core Strategy identifies as being suitable for infill development only, so no housing target);

·       Rossington (CS gives it a target of 1200 houses);

·       Armthorpe (CS gives target of 646-923 houses); and

·       Thorne and Moorends (CS gives Thorne a target of 646-923 houses.  Moorends is one of four Renewal Towns with a combined target of up to 1660 houses).

 

20.     The NPPF indicates at paragraph 184 that, “Neighbourhood plans must be in general conformity with the strategic policies of the Local Plan”.  In Doncaster’s case we interpret this to mean the policies within our Core Strategy (which sets out housing targets to settlements, but doesn’t include any strategic site allocations). 

 

21.           Furthermore, paragraph 185 goes on to state that, “Local planning authorities should avoid duplicating planning processes for non-strategic policies where a neighbourhood plan is in preparation”.  This would seem to suggest that we should simply exclude the areas for which Neighbourhood Plans are being prepared from our proposals map, and that if subsequent NPs are produced in the future, they will effectively redraw the proposals map for the relevant neighbourhood.

 

22.           Anecdotal evidence shows that Doncaster is considerably more advanced than many other local authorities in respect to working through the issues, and establishing a way forward for accommodating the relatively new Neighbourhood Planning agenda. However, we are concerned that although Neighbourhood Plans are being prepared for some areas, there are numerous issues and problems that may result in them being significantly delayed (if not altogether abandoned), and that even if progressed to referendum, they may not be supported by 50%+ of those that vote. 

 

23.           An option we are therefore exploring for most of the areas for which a Neighbourhood Plan is being prepared is to progress a borough-wide proposals map, and to do our best to align this to the emerging Neighbourhood Plans (so where we are duplicating we are at least allocating the same sites), and this is reflected in the sites put forward for the second round of consultation.

 

24.           However, Armthorpe Neighbourhood Plan is considerably more advanced in its preparation in comparison to the other Neighbourhood Plans being prepared, and as such we did not include any preferred housing or employment sites within Armthorpe parish for the second round of our consultation, to avoid being seen to undermine their process. There are potentially 3 options for how we resolve this issue:

 

·       Option 1 – work on the assumption that the Neighbourhood Plan consultation exercise will conclude within the next few weeks. In which case we should know the outcome and, subject to this not being in conflict with our approach, be in a position to feed-in and take forward as part of our plan before the S&PDPD goes to Cabinet;

·       Option 2 – as per option 1 but, should there be subsequent revisions to the proposed Neighbourhood Plan approach, withdraw the part of our plan which relates to Armthorpe post-publication; or

·       Option 3 – do not include the Armthorpe Parish within our plan (but if the Neighbourhood Plan is not adopted within the next 2-3 years we could consider producing an addendum to our plan to cover Armthorpe).

 

Gypsies & Travellers

 

25.     The proposed S&PDPD Gypsy & Traveller Policy supports Core Strategy Policy CS13 and meets the requirements of the new national traveller policy published in 2012. CS13 set down the overall strategy for addressing the need for new pitches, and the criteria for determining planning applications. The new national traveller policy however also requires local plans to identify a five year supply of specific deliverable sites. The latest Needs Assessment has not been finalised pending an ongoing review and the outcome of a number of appeals but it is intended that the five year figure will be included in the Publication DPD.

 

26.     The approval of planning applications from travellers on private sites in accordance with CS13 will be the most practical way of meeting needs over the plan period and maintaining a rolling five year deliverable supply of pitches as required by the new national traveller policy. In terms of specific sites the S&PDPD Policy also identifies the proposed extensions to the Council sites at Thorne and Armthorpe (16 new pitches with HCA funding secured) and disposal of the former Council Transit site at Thorne (10 new private pitches). The Policy also rolls forward the existing Gypsy allocations at Station Road, Dunscroft (currently vacant) and Stocksbridge Lane Bentley (currently underused) and commits to exploring the extent to which existing unauthorised pitches can be authorised and thereby counted towards the five year supply.

 

27.     There is some risk that the above approach will be found unsound because of the uncertainties associated with delivery of those sites that are not wholly under Council control and if the final five year figure is much larger than expected. However the proposed Policy approach is considered the most appropriate way forward for the following reasons:

 

• the identified sites have the potential to more than meet the draft five year figure for gypsy pitches (although not for travelling show people);
• applications approved in accordance with CS13 will also contribute to the five year figure; there are a number of pending applications for both gypsy and show people sites;
• sites need the "buy in" of the travelling community for them to be deliverable; there is little merit in allocating land without this and no sites have been proposed by the travelling community for allocation; and
• before Publication it is intended that the final five year figure will be established and that further progress will have been made in terms of site delivery.

 

LEGAL IMPLICATIONS

 

28.       As indicated in the report the approval of Full Council is required for adoption of this document which will form part of the Council’s Local Development Framework and be part of the Statutory Development Plan for Doncaster.  In order for the report to be adopted by Council it will need to be found sound by a government inspector. The report sets out in detail the steps to be taken for this process.

 

FINANCIAL IMPLICATIONS

29.       There are no specific financial implications to the recommendations of this report. Costs incurred in the production of the Sites and Policies Development Plan Document and consultation e.g. printing and staff time are being met from the existing Strategy and Programmes core budget.

 

30.       Further costs will be incurred when the document has been approved by Full Council to progress to publication stage, including printing, advertising and more significantly public inspection costs and the cost of producing or updating supporting documents. It is difficult to determine what the inspection costs will be as this depends on a number of factors e.g. how long the inspection takes. However, to give an idea, the Core Strategy inspection costs were approximately £60k. £64.5k has been allocated within the Planning and Economic Strategy budget to cover inspection costs in 2013/14 (subject to the approval of the 2013/14 budget).

 

CONSULTATION

 

31.     We consulted over the summer on the draft policies, a long list of sites and an interactive proposals map from 06/08/12 to 21/09/12.  This was followed by consultation on proposed housing/mixed use/employment and minerals sites from 01/11/12 to 28/11/12.  In addition to the above consultations, we have, and are continuing to, carry out targeted consultations on various issues.  The next stage is to go to Full Council to seek approval for Publication, and as part of this process reports have/will be taken to various meetings, including the LDF Project Board, the R&E Scrutiny Panel and Planning Committee.  

 

32.     As part of agreeing with the LDF Project Board the sites for the second round of consultation, the following points were discussed.

 

·       Concerns were expressed that proposed sites included those which utilise countryside and green belt.  There was discussion over whether or not such locations were needed to provide a range of sites, spread growth and meet the Core Strategy Housing targets. It was recognised that, if this was necessary, it would be better to do this where sites would not create large-scale extensions of the urban area into the countryside (and thus potentially future pressure for further loss of Green Belt).  On this basis it was reluctantly agreed that Broad Axe Field could go forward for consultation, although reservations about the site were noted.  The housing site proposed at Mere Lane was not supported due to loss of countryside and the potential for merging of Edenthorpe and Armthorpe.

·       Concern was raised about loss of Green Belt near Adwick.  However, it was accepted that the Red House employment site should go forward, given local support, but with a reduced site area to protect the setting of the cemetery.  It was therefore accepted that in order to meet the housing target for Adwick that the housing site to the South of Red House could also go forward (but with a reduced site area).  It was noted that the alternative large site at Adwick was near a sewage treatment works.

·       There was support for strategic warehousing sites in the M18 but avoiding Bradholme, taking account of public opinion and previous decision by Planning Committee.

·       There was support in particular for mixed use development sites in the town centre.

·       It was noted that the mineral sites proposed were extensions to existing sites.  There was support for the proposal not to support an extension to the Hazel Lane Quarry site.

 

33.     The consultation comments from the two rounds of consultation raised a number of issues.  It should be noted that understandably consultation comments received were often contradictory, therefore the proposals set out in this report reflect an attempt to strike an appropriate balance. Appendix 1 summarises the points raised and the proposed response.  The main points are in relation to:

 

• flexibility - in finalising the document we need to ensure that the flexibility/brevity that was built into Core Strategy is carried into final version as far as possible to ensure consistency of approach;

 

• developer requirements – we need to be clear that we are not implementing CIL at the current time, but ensure that remaining developer requirements are flexible and can respond to market conditions/subject to viability assessments;

 

• housing deliverability and attractiveness to the market - this is a key soundness risk as we need to ensure we have a five year housing supply and allocate sites that will come forward (we could also consider how we apply the Core Strategy phasing policy);   

 

• reflecting local communities’ concerns – especially in relation to development on greenfield sites, to strike a balance between attractiveness to market and residents views; and;

 

·       Retail and town centre uses – we need to clarify our approach to a number of issues, including non-employment uses on employment sites.  We also need to clarify our approach to the airport on a number of issues.

 

34.     There was considerable support from the public in relation to the proposed site allocations, including the proposal not to allocate Alverley Lane and Mere Lane sites, and the proposed approach to Thorne and Moorends.  However, the response from the development industry raised a number of issues, but a common theme was concern that there was a lack of sites which are attractive to the market and so can be brought forward in the short term.  Appendix 2 sets out the proposed changes in relation to housing and employment sites, which include the following points.

 

·       To ensure that we have sufficient employment land, make the best of Doncaster’s assets and provide some flexibility, it is proposed to allocate both Thorne North (site 1) and North of West Moor Park (site 4), alongside DN7 for distribution warehousing (including within the sites some allowance for other employment uses).

·       Include as part of the Thorne North Allocation the three smaller sites to the South of it (sites 167, 153 and 152). 

·       Reallocate Chase Park (employment site 182) for housing (rather than retain as an existing, but undeveloped, employment allocation). 

·       Allocate all of the Pastures Road sites at Mexborough (housing site MEX01, employment site 27) as housing. 

·       Allocate all of Red House Lane (site 85) for housing. 

·       Allocate sites 45 (Clayfield Avenue) and 430 (Land adjacent sewage works, West of Pastures Road). 

·       Allocate site 511 (off. Raymond Road Bentley) for housing

·       In addition to the above we could consider allocating the Alverley Lane site at Balby (site 400).  The site could accommodate approximately 254 houses, however there is strong public opposition to the site, including on highway grounds.

 

This report has significant implications in terms of the following:

 

Procurement		Crime & Disorder
Human Resources		Human Rights & Equalities
Buildings, Land and Occupiers	X	Environment & Sustainability	X
ICT		Capital Programme	X

 

 

 

BACKGROUND PAPERS

 

Core Strategy DPD, adopted May 2012, available via:

www.doncaster.gov.uk/ldfcorestrategy

 

Joint Waste Plan, adopted March 2012, available via:

www.doncaster.gov.uk/sections/planningandbuildings/localdevelopmentframework/Barnsley_Doncaster_and_Rotherham_Joint_Waste_Plan.aspx

 

Sites & Policies DPD Consultation Material Summer 2012, including:

• Housing & Employment Sites Options Maps;
• Proposed Housing, Employment and Minerals Sites Report
• Minerals Sites Proposals - Preferred Options & Identifying Areas of Search

Available via: www.doncaster.gov.uk/sections/planningandbuildings/localdevelopmentframework/LDF_Sites_and_Policies_DPD/index.aspx

 

 

REPORT AUTHOR & CONTRIBUTORS

 

Steve Butler (Planning Policy Manager: Natural Environment)

01302 734560         stephen.butler@doncaster.gov.uk

 

Peter Dale

Director of Regeneration & Environment

APPENDIX 1: MAIN POINTS FROM CONSULTATION

 

Broad Issue	Points Raised	Responses
Employment Land Supply and Retail	Bentley Moor Lane (BML) is undeliverable	The changes proposed in terms of site allocations mean that if BML does not happen, there will still be enough local manufacturing and light industry land to meet the Core Strategy target
	Policies need to be flexible, especially in relation to uses on mixed/ use and employment sites	The Core Strategy sets out the distinction between Major and Local Sites (with more flexibility for non-employment uses on Local, but ancillary uses allowed on both).  We can review which sites are Local and which Major, however key sites such as the large distribution sites in the M18 corridor (including the Rossington SRFI).
	We should allow changes of use from A1 within Primary Shopping Areas	Whilst all policies need to be flexible we have been criticised in the past for allowing non-retail uses in the primary retail areas. The policy does not apply to the whole of the town centre – just to our primary retail area where it is important that we maintain a critical mass of retail uses.
	We should allow offices in out-of-town locations subject to meeting the sequential test, and without making reference to this we are not in conformity.	Para 3.11 explains that we are allocating employment land for employment uses (B1b, B2 and B8) and land within Town Centres for town centres uses, such as offices (B1a).  This is our approach.  The NPPF says that where town centre uses are proposed outside town centres a sequential test should be applied, starting with town centres.  This process is set out in the NPPF (para. 24) and offers flexibility, which our plan does not take away.  However, we are not proactively planning to direct town centre uses away from town centres, and this is in the spirit (and wording) of the NPPF.  Adding the proposed wording would simply repeat national policy, and is therefore not considered necessary.   We could also clarify that although the Airport business park is proposed as a Major Employment Site (and so theoretically restricted to B1, B2, B8 and ancillary) we would support other uses where they are related to the airport (for example hotel) – as per Core Strategy policy CS6D(8).
	We should allow non-airport related uses at the airport business park.  A flexible approach was agreed in this regard by Doncaster Council in respect of the Phase 2 Business Park application where Outline Permission was granted for up to 60,700sqm for use classes B1, B2 and B8. Wording should be included clarifying that airport business parks are not limited to airport related uses only. This would respond to current economic conditions and business needs.	We broadly agree with the comment, however do not feel that a change is required.   The supporting text states that, “ it is anticipated that sectors which will locate on Major Employment suites will include …. Air related business (at Robin Hood Airport)…”.  We are proposing to allocate land at the airport to take advantage of this important economic asset, and it is envisaged that if air-related uses wish to locate to Doncaster they will be most likely to locate at the airport.  The conditions on the existing planning permission are still extant, and do restrict the uses on part of the airport business park.  However, there is nothing in the policy which either restricts air-related uses on sites away from the airport or vice versa.
	We should clarify our approach to Airport Safeguarding areas and Public Safety Zones	We will review the wording within the document, and if necessary add some text to policy (and/or supporting text) or create a new policy.
Housing Land Supply	Not enough development in the main urban area, as per inspector’s report	The Core Strategy sets a target of 50-64% of housing growth in MUA.  We proposed 58% for consultation and our proposed changes for site allocation will take this up to 60%.  Inspector found CS range sound, but said at or near top end of range would be most appropriate.  We feel 60%, given existing permissions across borough, is justifiable.
	Town centre regeneration projects are undeliverable	These remain key Council projects.   We are working with colleagues in 3D and assets to ensure we can present information to show how the sites are being/will be delivered.  The housing numbers attributed to these sites have been reduced already, to take account of the reduced demand for flats, and so it is considered that the overall contribution in terms of housing numbers, assumed from these sites is realistic for the plan period.
	There is too much reliance on brownfield sites and existing UDP housing. There needs to be a policy that commits to a 5 year deliverable supply plus 20% and that includes a pragmatic approach to urban extensions where there is not a deliverable supply.	The Hatfield Lane/Lazarus inquiry result shows we do have a five year supply, although this is not as large as we argued.  Our overall supply is made up of allocations plus windfalls.  We are proposing to allocate land for approximately 1000 additional units on greenfield sites (which equates to approximately 5% of the total allocations target).   There have also been comments that we should be doing more to prioritise brownfield sites, for example from opponents to DN7 and greenfield urban extensions, such as Broad Axe Field, therefore we are taking a balanced approach.
	There is no evidence to support the estimated under-delivery of 1000; don't believe that the sites currently identified will be sufficient and it is better to over-allocate than under-allocate
Environmental Constraints	Too much development in flood risk areas, given recent events and insurance issues this is not appropriate	We are discussing with developers who are promoting flood risk sites to see how they are responding to the insurance issue.  We are working with internal drainage colleagues and the IDB to make sure we understand the flood issues for proposed allocations and how they might be mitigated.  We will undertake full Sequential Test for publication stage.  As part of this we will need to show why we have rejected Flood Zone 1 sites within the Countryside Policy Protection Area (for example Mere Lane), but have allocated sites in Flood Zone 3 and Green Belt.
	Full Green Belt review should be undertaken, as per inspector’s report	Inspector’s report said CS approach of not doing one for allocations was acceptable.  Given the relatively limited modest amount of proposed development in GB, we feel this approach is still appropriate.  It is noted that the calls for GB review are mainly from developers who want this process undertaken in order to remove land from the GB, not to extend it.
Viability	Onerous planning obligations can make development unviable and flexibility is required and schemes need to be assessed on a case by case basis, including an independently assessed viability assessment.	There are a number of policies which relate to developer contributions, as summarised below.  We need to be sure that these policies do not make sites unviable when viewed collectively, and also that we will not be asking for contributions once through policies and once through CIL.    The outcome of this work will either be to keep the policies broadly as they are, to make some amendments or to streamline and combined them into SP48 (with some of the detail of SP36 and 39 going into the design policies) and retaining part of SP16.   SP9:Local Employment Opportunities, SP10; Town Centre Boundaries (in relation to public realm improvements), SP16: Transport Requirements (partly about assessments and DC lines, but partly about contributions), SP17: SRN and Major Scheme Funding and SP18: Sustainable Transport Infrastructure SP23: Community Facilities (no draft policy but asked if there should be one), SP36: Delivering GI Provision (partly about needs for applications and partly about funding), SP39: Open Space Provision within Residential Proposals and SP48: Developer Contributions.
	It should set out what contributions will be secured through S106 and what through CIL, including whether the Council intends to adopt CIL. The LPA should not try to collect contributions through S106 that are within the legal framework of CIL
	POS range too big and we should ask for more/aren’t asking for enough, should have a flat rate (c10%) and/or should specify requirements for individual sites.  Provision is based on average density of 38dph which is too high and makes contributions excessive.
Environmental Protection	All sites need to have an archaeological review	We will discuss this with SYAS, who raised the issue.  There is not the time or resources to undertake this work, which we feel is excessive (it would be covered at the planning application stage).  We could undertake targeted appraisal of large new sites key prior to EIP, if we feel that this is necessary (for example where the developers have not provided sufficient information as part of their submissions).
	Should be policies on light pollution and ground water pollution	Light pollution is covered in supporting text to CS policy CS1: Quality of Life at para 3.5.  Ground Water is covered by CS policy 18: Air, Water and Agricultural Land.
	Some felt we should have a policy on NIAs, some felt this was excessive.	We will show the existing boundaries on the proposals map, for information.  The purpose of NIAs will be referenced in the supporting text to the Biodiversity Opportunity Area policies.
	Need to clarify what the purpose of a green wedges are	The policy wording will be revisited and expanded for policy SP37: Key Green Wedges
Other Issues	G&T assessment is flawed	Work is being undertaken to update this and our overall approach to the issue
	Neighbourhood Planning	Some developers have criticised our approach to NP, indicating that we should be more proactively in planning for areas which are producing a NP.  We feel our approach is in the spirit of the NP process and in conformity with the relevant legislation and policy
	Minerals Issues	It is clear we will need to compile robust evidence in order to comply with the Local Aggregate Assessment requirement of the NPPF and to justify the decision not to allocate an extension to Hazel Lane.  We did not received objections to the proposed reduced extension to Sutton Quarry, and are seeking confirmation from Ward Members and the Parish Council that this is correct.
	Internal discussion on our approach for community facilities and existing POS.	We will show schools, hospitals and prisons on the proposals map.  There won’t be a policy, but the supporting text will say we expect them to continue in their present use an, if not, proposals for reuse will be considered on a case-by-case basis.  For POS the consultation shows we do need a policy to protect it, although it is acknowledged that there may be times when its redevelopment is supported by local communities.  The draft policy consulted on is therefor considered broadly fit-for-purpose.  This  establishes a presumption against its redevelopment but sets out the process required if, on balance, its redevelopment is considered appropriate
	There should policies on  telecommunications	NPPF says this is optional, we don’t consider this detail is necessary
	We should identify preferred sites or areas of search for renewable energy	NPPF says this is optional, we don’t consider this detail is necessary

 

 

 

 

APPENDIX 2:

 

 

PROPOSED CHANGES – HOUSING AND EMPLOYMENT SITES

 

A2.1   The response from the development industry raised a number of issues, but a common theme was concern that there was a lack of sites which are attractive to the market and so can be brought forward in the short term.  Given the current exceptionally adverse economic conditions, the following changes are proposed to respond to this.

 

A.    For the consultation we assumed that the operational land provided by the Major Employment Sites allocated within the M18 corridor which do not currently have planning permission, will be split 85% B8 and 15% B2.  However, as these are key sites which are attractive to the market, it may be more realistic to assume a 70/30% split (noting that the Core Strategy policy and EIP indicated that we would not prescribe this split, therefore this assumption is only required as part of the evidence base to ensure our land targets are met).

 

B.    To ensure that we have sufficient employment land, make the best of Doncaster’s assets and provide some flexibility, it is proposed to allocate both Thorne North and North of West Moor Park, alongside DN7 (but not Bradholme).  This would provide an additional 34.5 Ha of light industry and manufacturing, and an additional 31.5 Ha of distribution warehousing, compared with just allocating North of West Moor Park (based on a 70/30 split).  For the consultation we had indicated that we would definitely allocate M18 sites which had planning permission, and to meet the targets we would need two more sites.  There are four potential sites:

 

·       Bradholme (employment site 2) which was not proposed;

·       DN7 (employment site 89) which was proposed (as it would contribute not only to the delivery of employment land, but the wider DN7 project);

·       Thorne North (employment site 1) which was proposed as an option; and

·       North of West Moor Park (employment site 4) which was proposed as an option.

 

C.    Include as part of the Thorne North Allocation the three smaller sites to the South of it.  Individually we would have delivery concerns about this site, but the owners have said they would be willing to work together.  These sites could be developed as part of Thorne North (and so be part of a ‘Major’ allocation), but nominally for light industry and manufacturing, giving an additional 6.99 Ha (site 167 = 3.58, site 153 = 2.78 and site 152 = 0.63). 

 

D.    Reallocate Chase Park (employment site 182) for housing (rather than retain as an existing, but undeveloped, employment allocation).  This would provide land for approximately 100 houses, and would mean a loss of 2.64Ha of proposed employment land (for light industry/manufacturing).  The agents have supplied information to show that they have unsuccessfully tried to market the site for employment use, and this indicates there is a lack of demand for the site.

 

E.    Allocate all of the Pastures Road sites at Mexborough (housing site MEX01, employment site 27) as housing.  The site was proposed in the 2^nd round of consultation as mixed use, including 3Ha of employment land.  Based on 38 dwellings per hectare, this change would result in the 3 ha of employment land providing land for 114 houses.

 

F.    Allocate all of Red House Lane (site 85) for housing.  In the preferred site stage of consultation we identified part of this site for 206 units.  The Estate promoters previously considered the whole site could accommodate 1,000 units, however, they now consider the site can deliver a total of 606 units.  It is proposed to allocate the full site, given a net increase of 400 units.  However, as the site is Green Belt it would be phased towards the end of the plan period, and so would be unlikely to be fully built-out by 2028 (the end of the plan period).  On that basis the additional 400 units are not included in our assumed supply at Adwick and provide an additional supply/flexibility.

 

G.   Allocate sites 45 (Clayfield Avenue) and 430 (Land adjacent sewage works, West of Pastures Road).  Site 430 is currently designated as open space however it is not used as such (it is agricultural land).  The site could be developed as an extension to the Pastures Road development and could potentially accommodate 142 units.  Although the site is next to a sewage-works, this is proposed for decommissioning.  Site 45 is an existing Unitary Development Plan allocation.  If viewed in isolation we would propose for de-allocation as it is landlocked, however as it is adjacent to site 430 it could be developed as an extension to is.  The site could potentially accommodate 63 units.  Neither of these sites are currently Green Belt.

 

H.    Site 597 (Adj. Ringways) and 511 (off. Raymond Road Bentley) for housing have a potential total combined capacity of approximately 145 (rather than retain as part employment – site 23, and part proposed open space – UDP site RL5/15).  It is within a PCT community boundary that is deficient in formal open space and parks, however because the site is a proposed open space it does not contribute towards addressing this deficiency as it is not open to the public.  Both of these sites were included in the SHLAA as they were being promoted by Persimmon Homes, however Persimmon have now confirmed they are only promoting site 511.  On balance it is proposed to allocate site 511 as housing, this small 0.5 Ha site will potentially delivery 19 units and a contribution towards POS improvement in the vicinity.  The part of site 597 which is currently employment (site 23) would remain as such.    

 

I.      In addition to the above we could consider allocating the Alverley Lane site at Balby (site 400).  This is a Green Belt site but is a triangle with development on two sides, so could be seen as a ‘filling in’ and would lead to a defensible Green Belt boundary moving forward (so a similar position to Broad Axe Field).  The site could accommodate approximately 254 houses, however there is strong public opposition to the site, including on highway grounds.

 

Significant Main Urban Area Sites not proposed for Allocation

 

A2.2   Two of the key issues are the proportion of housing growth within the Main Urban Area, and the number of significant greenfield sites (mainly urban extensions) proposed.  The responses from the housing industry suggest that the proportion should be increased and that this should be achieved by allocating additional greenfield urban extensions (and the assumed level of delivery achieved by some of the proposed brownfield allocations should be reduced, again meeting the resulting shortfall with additional greenfield urban extensions). 

 

A2.3   However, a balanced approach is required and local communities have indicated that brownfield sites should be prioritised and loss of countryside avoided.  The proposed approach therefore includes allocating some additional greenfield sites, but not to allocate a number of the sites consulted on previously and identified as potentially developable, including those set out below.

 

A2.4   It should be noted that there are also a number of sites which could be allocated as part of the Main Urban Area but have not been proposed as they are not deemed to be developable.   The potential housing site “land off Rosehill Rise, Bessacarr” (site 25) was included in the strategic housing land availability assessment as undeliverable, as the council had indicated that they are unwilling to sell the land for development.  On that basis the site is not proposed for inclusion within the plan and will be designated as countryside protection policy area instead.

 

Site Number	Site Name	Reason not proposed for allocation
83	Land off Back Lane Cusworth	This site is potentially attractive to the market and could accommodate approximately 1000 units.  However, it is Green Belt and would result in an extension into the wider Green Belt, being exposed on three sides.  It is also close to Cusworth Park and English Heritage have raised serious concerns in relation to its potential allocation.
140	Land of Melton Road/Ings Lane, Sprotbrough	This site is potentially attractive to the market and could accommodate approximately 150 units.  However, it is Green Belt and would result in an extension into the wider Green Belt and so is considered less appropriate than the proposed allocations.
399	Land off Challenger Drive, Richmond Hill	This site is potentially attractive to the market and could accommodate approximately 183 units.  However, it is Green Belt and would result in an extension into the wider Green Belt and so is considered less appropriate than the proposed allocations.
487	Land at Stocksbridge & East of the Avenue Bentley	This site is a poor strategic fit as it is both Green Belt and Flood Zone 3
529	Land off Mere Lane, Edenthorpe	This site is potentially attractive to the market and could accommodate approximately 1679 units.  It is a good strategic fit as it is Countryside Protection Policy Area, rather than Green Belt, and it is Flood Zone 1.  However, discussions with the LDF Project Board have indicated concerns in relation to the level of development in the area (given potential sites at Armthorpe) and the potential for settlements to merge, and on that basis it is not proposed for allocation.
532	Land East of Scawsby Lane, Scawsby	This site is potentially attractive to the market and could accommodate approximately 1000 units.  However, it is Green Belt and would result in an extension into the wider Green Belt and so is considered less appropriate than the proposed allocations.
666	East of Warning Tongue Lane	Site proposed in response to the site options consultation.  This site is potentially attractive to the market and could accommodate a significant number of units.  It is a good strategic fit as it is Countryside Protection Policy Area, rather than Green Belt, and it is Flood Zone 1.  However, the site has poor access to services, is located close to sewage treatment works, would have a negative impact upon biodiversity, trees and hedgerows, would sterilise sand underneath the site and would include loss of Grade 3 agricultural land.  On that basis it is not proposed for allocation.
667	Land off Armthorpe Lane	Site proposed in response to the site options consultation.  This site could accommodate a significant number of units.  It is a good strategic fit as it is Countryside Protection Policy Area, rather than Green Belt, and it is Flood Zone 1.  However, power-lines cross the through the site and on that basis it is not considered appropriate for allocation.

 

 

 

APPENDIX 3: DISTRIBUTION OF HOUSING

 

Note: the figures within this appendix are based on the inclusion of the changes made in appendix 3 and include working assumptions, which may need to be further revised prior to publication.

 

A3.1   The proposed overall distribution of housing allocations is summarised in the table below.

 

Settlement	Total capacity of site allocations	Estimated plan period allocation capacity based on proposed phasing	% of 18450
MUA	11,528	11,064	60
Thorne	1,015	1,015
Mexborough	1,294	1,294
Conisbrough	903	646
Adwick	1,146	946
Armthorpe	785	785
Askern	917	917
PTs Total	6,060	5,603	30
Rossington	1,243	1,033
Stainforth/Hatfield	1,524	1,424
PGTs Total	2,767	2,454	13
Renewal Towns	1,860	1311	7
Gross Total		20,432	110
Existing planning permissions to be discounted		-1000	-5%
Net Total		19,432	105%

 

Note: It is proposed that all sites with planning permission for 10 or more units will be allocated, however it is accepted that not all sites with planning permission will be built.  Therefore the Core Strategy indicates that the plan will include all relevant permissions as at 31/03/2011 with an additional 1000 units to be allocated to make up any non-implementations etc. (this is part of the reason why the gross total shown above is more than 100%).

 

Discounting

 

A3.2   When allocating sites for including within the Sites and Policies Development Plan document (hereafter ‘the plan’).  The potential capacity of a site is based on a rough estimate of 38 dwellings per hectare except where planning permission or other information indicates otherwise.  However we are also required to make an estimate of how many units each proposed allocation will deliver during the plan period (i.e. by 2028).

 

A3.3   In some cases a housing site has been put forward by landowners or developers but not all of the site will be allocated because part of the site may be in appropriate for development.  For example, the site boundary might include an area of land which is a Local Wildlife Site and so this portion of the site may be removed from the area allocated for development.  This is therefore about the principal of whether development is appropriate.  In such circumstances the capacity of the site is removed from that shown in documents such as SHLAA, because it is considered that only a lower overall level of development on the site is acceptable.

 

A3.4   In other cases, particularly on larger sites (for example 500 units) the net developable area of an allocation and therefore the estimated capacity will be less than the gross allocated site (for example part of the site is required to accommodate a new school).

 

A3.5   In some other cases sites are allocated where it is considered that all of the site area if suitable for development (subject to the normal requirements for provision of landscaping, open space etc.), but it is not anticipated that the site will be fully built out during the plan period.  Therefore although a site may be capable (and considered suitable) of accommodating a number of units, and the whole of the site may be allocated and obtain planning permission during the plan period, a number of these units will be built after the plan period – this will be likely for allocations in phase 2 or 3 (see below).  This is therefore about the timing of when development might happen.  Depending on market conditions it may be that such sites actually deliver more units that it is allocated for, and the plan allows for this – the only restrictions would be those imposed by the phasing policy.

 

Phasing

 

A3.6   Core Strategy policy CS10 (Housing Requirement, Land Supply and Phasing) states that, “Housing allocations will be phased as set out in Table 5. Allocations will normally be released in accordance with this phasing subject to infrastructure delivery and maintaining a 5-year supply of deliverable sites. Phase 2/3 urban allocations will be released earlier if delivery constraints can be satisfactorily addressed. Phase 2/3 urban extension allocations will be released sooner where proposals for their development are accompanied by proposals that would help deliver one or more urban brownfield sites (housing or mixed-use allocations) within an agreed timescale”.  Table 5 is shown below.

 

Phasing	Sites
No phasing	A. Housing renewal sites B. Sites with permission (unless phasing is part of the permission)
Phase 1- 2011 onwards	C. Existing housing/mixed use allocations (except where flood-risk or other delivery issues cannot be resolved) D. New urban allocations in all settlements (except where unlikely to be delivered in Phase 1; these will be assigned to Phases 2 and 3)
Phase 2 – 2016 onwards	E. New urban extension allocations to the Main Urban Area and Principal Towns that are identified as the most sustainable and deliverable alternatives necessary to meet the Phase 2 requirement F. New urban extension allocations to the Potential Growth Towns (but only in accordance with Policy CS2 and so could be in Phase 1 or Phase 3)
Phase 3 – 2021 onwards	G. Other urban extensions to the Main Urban Area and Principal Towns necessary to meet the Phase 3 requirement H. New urban extension allocations to the Renewal Towns (provided suitable sites can be identified)

 

A3.7   An Urban Allocation is one which does not involve the loss of any land currently shown within the Unitary Development Plan as Green Belt or Countryside Policy Area and is not a greenfield UDP allocation on the edge of a settlement.  Whereas, an Urban Extension is one which does involve the loss of any land currently shown within the Unitary Development Plan as Green Belt or Countryside Policy Area or is a greenfield UDP allocation on the edge of a settlement and which has not yet been implemented. 

 

A3.8   Therefore where an urban extension is a current UDP allocation proposed to be rolled forward, it would normally be within phase 1.  New urban extensions (i.e. those which are not current UDP allocations) would normally be in later phases.  This reflects the potential for applications to be brought forward in accordance with the current development plan (the UDP) up until the adoption of the Sites and Policies plan in early 2014.

 

Strategic Fit

 

A3.9   The Core Strategy sets out three strategic principles for allocating sites (within policies CS2: Growth and Regeneration Strategy, CS3: Countryside and CS4: Flooding).

 

·       Prioritising brownfield sites

·       Minimising development within the countryside; and

·       Where possible, directing development to the areas at lowest risk of flooding.

 

A3.10 In appraising potential sites, once sites have been filtered out which are non-developable or not in conformity with the Core Strategy, the sites have been ranked the sites in the order set out below.  In general the proposed allocations for each settlement have been on the basis of this (i.e. sites which score B will be allocated before sites that score C, C before D, and so on).  In this way a sequential approach is taken to flooding which takes account of the wider plan objectives in line with Policy CS4 of the Core Strategy.

 

A3.11 However, a finer grain of detail has been applied and regard has also been had to other detailed sustainability considerations (such as protection of heritage and biodiversity) and the results of public consultation.  Therefore in some instances these more detailed considerations have justified allocating a site with a lower ‘strategic fit’ rather than a site with a higher ‘strategic fit’.

 

Strategic Fit Order

 

A = The site has planning permission or is a committed housing renewal site.

 

B = Brownfield, not within Green Belt or Countryside Policy Area and at the lowest risk of flooding.

 

C = Greenfield, not within Green Belt or Countryside Policy Area and at the lowest risk of flooding.

 

D = Brownfield, not within Green Belt or Flood Zone 3, but one of Countryside Policy Area or Flood Risk Zone 2.

 

E = Greenfield, not within Green Belt or Flood Zone 3, but one of Countryside Policy Area or Flood Risk Zone 2.

 

F = Brownfield, not within Green Belt or Flood Zone 3, but both Countryside Policy Area and Flood Risk Zone 2.

 

G = Greenfield, not within Green Belt or Flood Zone 3, but both Countryside Policy Area and Flood Risk Zone 2.

 

H = Brownfield, one of Green Belt or Flood Risk Zone 3, but not within Countryside Policy Area or Flood Risk Zone 2.

 

I = Greenfield, one of Green Belt or Flood Risk Zone 3, but not within Countryside Policy Area or Flood Risk Zone 2.

 

J = Brownfield, and either:

·                    Green Belt and Flood Zone 2; or

·                    Countryside Policy Area and Flood Zone 3.

 

K = Greenfield, and either:

·       Green Belt and Flood Zone 2; or

·       Countryside Policy Area and Flood Zone 3.

 

L = Brownfield, Green Belt and Flood Zone 3.

 

M = Greenfield, Green Belt and Flood Zone 3.

 

N.B. The Countryside Policy Area relates to current boundaries as defined in the Unitary Development Plan.

 

SETTLEMENT HIERARCHY

 

Main Urban Area

 

A3.12 The Core Strategy allocates 80-85% of housing growth to the Main Urban Area and Principal Towns (50-64% of growth to the Main Urban Area and 21-30% to the Principal Towns).  The inspectors report found this to be sound but did note at para 15 of his report that, “Rightly, bearing in mind such matters as its range of services and RSS Policy YH4, the Doncaster Main Urban Area (DMUA) will be the main focus for growth and regeneration for housing, employment, shopping, leisure, education, health and cultural facilities.  The indicative housing allocation is 9,225-11,808 dwellings, but the assets, challenges and potential of the town require a figure at or very near the top of that range”.

 

A3.13 The inspector which considers the plan will have regard to the Core Strategy inspector’s report, and although he did not insist on a change in relation to the Main Urban Area, his comments are instructive.  Given all the considerations (including the number of existing permissions within the Principal Towns and Renewal Towns), it is considered that 60% is a reasonable allocation to the Core Strategy that can be justified at the Examination in Public.  It is considered that a lower allocation (especially lower than 57% or half-way through the range) would be difficult to justify at Examination in Public.

 

Principal Towns

 

A3.14 In terms of Thorne para 16 states, “In the summer of 2010 there was a worrying number of vacant buildings, and maybe a significant amount of additional development at about the top of the indicative range of 646-923 dwellings and its retention as a Principal Town would bolster the retail offer and other facilities” and in terms of Mexborough para 17 states “It is rightly identified as a Principal Town and should achieve a growth at about the top of the indicative range (646-923 dwellings)”.

 

A3.15 The allocation for Mexborough (1,294) reflects the existing planning permissions, which are more than sufficient to provide housing at the top end of the range.  The allocation for Thorne (1015), which largely reflect the views of the Town Council (and so will presumably eventually be reflected in a Neighbourhood Plan) is also at the top end of the range.

 

A3.16 He notes at para 18 that in the 4 other Principal Towns (Conisbrough, Askern, Adwick and Armthorpe) “the range of shops and other facilities falls a good deal short of that at Thorne and Mexborough, but the size of these settlements, the services and facilities which they offer and their character, role and appearance as small towns rather than large villages should ensure their retention as Principal Towns.  The evidence for this conclusion is compelling, and they should be suitable for a level of growth towards the bottom end of the indicative range (646-923)”.

A3.17 The proposed allocations for the Principal Towns are as follows:

·         Conisbrough (646) – the potential capacity of the sites is 257 units higher, but this has been discounted due because it is not anticipated that the Land south of canal & opposite former Earth Centre (site 382) will be fully built out by the end of the plan period (2028), although all of the site would be allocated

·         Adwick (946) –this is towards the top of the growth range (even allowing for the majority of site 85 being developed after the plan period.  However there are a limited number of sites at Adwick and a significant amount of the supply is made up by the 400 units with permission on the former colliery site.  Some of these 400 units are included within the 1000 units with planning permission to be discounted from the headline figure as per the Core Strategy, and so to not include them in the supply at Adwick would be to discount them twice.

·         Armthorpe (785) – a formal application for the Neighbourhood Plan has been submitted by the Parish Council and approved by Doncaster Council.  The Parish Council have appointed a consultant to progress the plan, and set out a timescale for its production.  They have indicated that they do not wish to comment on potential allocations at this stage, as this may prejudice their forthcoming public consultation (and Doncaster Council has followed this stance).  Therefore we have assumed that their allocation will be at the middle of the range.

·         Askern (917) – this is the only Principal Town allocation that does not follow the inspector’s advice.  However, it is considered that this is justified given the high level of existing permissions (652) and the fact that the additional proposed capacity is all within the settlement boundaries: it is not proposed to allocate any land within the Green Belt. 

Potential Growth Towns (Rossington; and; Hatfield, Stainforth, Dunsville and Dunscroft)

A3.18 Para 19 states, “it is reasonable to suppose that the 2 Potential Growth Towns could each accommodate 1200 or so dwellings in line with a co-ordinated approach to major new infrastructure provision, regeneration and job creation”.  The proposed allocation reflects this.

 

A3.19 The Core Strategy sets a housing target for the Potential Growth Towns of 1200 in each.  We have indicated for Rossington that although planning permission has been granted on the collier for 1200 units, we would assume 5 years for the tip washing to complete, then 80 – 100 units build out per annum for 11 years.  There is another site off Bankwood Lane which has permission for 43 units.  The plan period capacity of both sites is therefore assumed to be 1033 units represents an additional discounting of 210 units on top of the overall 1000 units from the total sites with permission.  For DN7 we noted there were 324 sites with planning permission and that the DN7 project would deliver at least 1100 units within the plan period (total allocation of 1424).  However, we would support allocation within DN7 for land for at least 1200 units and if these could be delivered in the plan period, the policies would not prevent this.  This approach therefore gives a potential extra 100 units of flexibility.

 

Renewal Towns

 

A3.20 Para 20 states, “The range, number and type of services and facilities in the 4 Renewal Towns is generally more limited than in the Principal Towns and so they are suitably identified for regeneration and housing renewal, not for market-led growth.  A total of up to 1660 dwellings between them is proportionate, and should serve to consolidate and enhance local services”.

The Core Strategy target (up to 9%) is a total for the four renewal towns, which is not broken down into a target for each town.  In theory therefore, all of the renewal town allocation could be allocated to a single renewal town.

 

A3.21 The proposed level of growth (7%) reflects the advice for the Main Urban Area and Principal Towns, together with a pragmatic reflection of existing permissions and emerging Neighbourhood Plans.  Any higher level of growth would require a reduction in growth elsewhere (most likely Askern).  The growth is split as follows:

 

·         Moorends: 197 - although this would include the allocation of sites with a total capacity of 746 which could theoretically be brought forward during the plan period, subject to compliance with the phasing policy.  This reflects the consultation comments of the Town Council in supporting development at Moorends, and their intention to produce a Neighbourhood Plan.

·         Carcroft/Skellow: 143 – this is an existing permission plus an HRA site.

·         Denaby: 149 – this is existing permission plus an HRA site.

·         Edlington: 822 - it should be noted that both the Thompson and Dixon site (E02) and the Granby Estate (E03) are housing renewal schemes (508 units in total) and whilst technically net growth, they will not increase the footprint of the settlement (demolitions are deducted from the net housing delivery figures in the year they occur, the replacement units can be counted as ‘new’ units in the year in which they occur). 

 

A3.22 This means that the settlement where it is proposed to allocate the most land for housing growth is effectively Moorends, although it is not anticipated that all this land will be built out during the plan period.