from: peacock and smith re west moor park east sent: 30 … · 2020. 3. 18. · from: peacock and...
TRANSCRIPT
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
Suite 9C Josephs Well, Hanover Walk, Leeds, LS3 1AB
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
Suite 9C Josephs Well, Hanover Walk, Leeds, LS3 1AB
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
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
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).
Please see attached submission.
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.
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
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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:
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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
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
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
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 4 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).
Please see attached submission.
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.
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
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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;
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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
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
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
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 4 Site Ref.: 001
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).
Please see attached submission.
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:
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.
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
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
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 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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO PROPOSED ALLOCATION OF SITE 001: THORNE NORTH 3 September 2019
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).
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO PROPOSED ALLOCATION OF SITE 001: THORNE NORTH 4 September 2019
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
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO PROPOSED ALLOCATION OF SITE 001: THORNE NORTH 5 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO PROPOSED ALLOCATION OF SITE 001: THORNE NORTH 6 September 2019
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
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO PROPOSED ALLOCATION OF SITE 001: THORNE NORTH 7 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO PROPOSED ALLOCATION OF SITE 001: THORNE NORTH 8 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO PROPOSED ALLOCATION OF SITE 001: THORNE NORTH 9 September 2019
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
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
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
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 4 Site Ref.: 441
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).
Please see attached submission.
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.
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: 937/1031)
September 2019
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/1031)
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.
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 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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/1031)
OBJECTION TO PROPOSED ALLOCATION OF SITE 441: CARCROFT COMMON 3 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/1031)
OBJECTION TO PROPOSED ALLOCATION OF SITE 441: CARCROFT COMMON 4 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/1031)
OBJECTION TO PROPOSED ALLOCATION OF SITE 441: CARCROFT COMMON 5 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/1031)
OBJECTION TO PROPOSED ALLOCATION OF SITE 441: CARCROFT COMMON 6 September 2019
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
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
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
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): ☒ Site Selection Methodology
2. To which part(s) of the document / map does your response relate?
Page No.: Paragraph:
Policy Ref.: Site Ref.: 937/938/1014/1031; 001, 092, 441 and 941
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).
Please see attached submission.
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.
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
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 3 September 2019
(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,
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 4 September 2019
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.”
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 5 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 6 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 7 September 2019
(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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 8 September 2019
/
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).
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 9 September 2019
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).
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 10 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 11 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 12 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 13 September 2019
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.
Representations on behalf of Blue Anchor Leisure West Moor Park East (Site Ref: 937/938/1014/1031)
OBJECTION TO LOCAL PLAN SITE SELECTION PROCESS 14 September 2019
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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