from: spawforths on behalf of fisure homes sent: 30 september …€¦ · 2.5. this document...

From: Spawforths on behalf of Fisure Homes Sent: 30 September 2019 16:44 To: Local Plan Subject: Doncaster local plan representations Importance: High

Please find attached representations to the Doncaster Local Plan on behalf of Firsure Homes, in

respect of their interests in Doncaster.

The representation covers the following matters:

General Comments

Policy 2 – Spatial strategy and settlement hierarchy

Policy 3 – Level and distribution of growth

Policy 6 – Housing Allocations – Sites 302 and 305: Stripe Road, Rossington

Policy 8 – Delivering the necessary range of housing

Policy 19 – Development affecting public rights of way

Policy 20 – Access, design and layout of public rights of way

Policy 29 – Open space provision in new developments

Policy 46 – Housing design standards

Policy 66 – Developer contributions

Policy 67 – Development viability

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

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

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

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

HANNAH LANGLER

Principal: Chartered Town Planner

BSc (Hons), Dip CRP, MRTPI

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

Development Plan Representation

Doncaster Local Plan: 2015-

2035: Publication Version (June

2019) On behalf of Firsure Ltd (Stripe Road, Rossington)

September 2019

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

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

Local Plan 2015-2035 Publication Version and for their site at Stripe Road, Rossington.

1.2. Appended to these representations is a report assessing the housing requirement, prepared

by Regeneris Consulting.

1.3. Firsure welcomes the opportunity to contribute to the emerging Local Plan for Doncaster

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

and the Yorkshire and Humber Region as a whole.

1.4. Firsure has significant land interests in the area, which can positively contribute towards the

economic and housing growth agenda.

1.5. Firsure would like to make comments on the following topics and sections in the Doncaster

Local Plan 2015-2035 Publication Draft:

• General Comments

• Policy 2 – Spatial strategy and settlement hierarchy

• Policy 3 – Level and distribution of growth

• Policy 6 – Housing Allocations

o Sites 302 and 305: Stripe Road, Rossington

• Policy 8 – Delivering the necessary range of housing

• Policy 19 – Development affecting public rights of way

• Policy 20 – Access, design and layout of public rights of way

• Policy 29 – Open space provision in new developments

• Policy 46 – Housing design standards

• Policy 66 – Developer contributions

• Policy 67 – Development viability

1.6. In each case, observations are set out with reference to the provisions of the Framework and

where necessary, amendments are suggested to ensure that the Local Plan is found sound.

1.7. Firsure welcomes the opportunity for further engagement and the opportunity to appear at

the Examination in Public.


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

consideration to these comments.

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


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2. National Planning Policy Context and Tests of Soundness

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

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

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

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

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

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

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

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

and deliver a wide choice of high quality homes.

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

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

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

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

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

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

tests of soundness and establishes that:

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

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

sounds. Plans are ‘sound’ if they are:

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

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

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

consistent with achieving sustainable development

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

based on proportionate evidence;


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

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

the statement of common ground; and

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

accordance with the policies in the Framework.

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

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


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

content and the evidence base does not reflect national guidance.

Test of Soundness

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

Which test of soundness are comments about?

X Positively Prepared X Effective

X Justified X Consistency with National Policy

Justification

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

is concerned that the housing requirement does not reflect economic growth ambitions, the

level of employment allocations, nor is it sufficient to meet the identified needs for affordable

housing. Further Firsure are concerned that there are insufficient housing allocations to meet

the housing requirement.

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

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

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

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

justify key policies.

3.5. Firsure consider that the Policies in the Local Plan are not justified and does not provide an

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

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

policy.


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3.6. In these circumstances, Firsure do not consider the Doncaster Local Plan, in its

current form, to be sound.

3.7. However, Firsure consider that the plan can be made sound subject to proposed changes as

set out within the following sections of these representations. Firsure will continue to work

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

Proposed Change

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

• Identify a higher housing requirement to meet economic and affordable housing

ambitions and needs.

• Identify sufficient supply of housing to meet the identified housing requirement.

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

representations.

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

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

specific proposed changes under each policy.


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4. Policy 2: Spatial Strategy and Settlement Hierarchy (Strategic Policy)

4.1. Firsure is concerned that the Doncaster Local Plan 2015-2035 Publication Version is

deficient in its content and evidence base and does not reflect national guidance.

Test of Soundness

4.2. Firsure considers that the Local Plan is unsound.




Justification

4.3. Firsure is concerned with the Spatial Strategy and distribution. Firsure would expect the

spatial strategy and distribution to provide an appropriate development pattern and support

economic growth and sustainable development within all market areas.

4.4. The Strategy at present focusses growth towards Doncaster, followed by the Main Towns and

then a smaller element in the Service Towns and Larger Villages and then no development in

other defined villages. Therefore no new housing is proposed in the rural economy in

settlements which are relatively sustainable. This approach is broadly consistent with the

strategy set out in the UDP and subsequent Core Strategy. Firsure are concerned that this

focuses development in less viable areas and risks under delivery.

4.5. The implementation of the Spatial Strategy will be discussed in response to Policy 6 and the

proposed allocations.

4.6. Doncaster is an integral part of the Sheffield City Region and the ambitious growth aspirations.

The Strategic Economic Plan sets out the Sheffield City Region’s plans to transform the local


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economy over the next decade. At the heart of the plan is the creation of 70,000 new private

sector jobs and 6,000 new businesses.

4.7. Therefore, to achieve the aspired growth that the City Region is seeking to achieve and is

securing Government funding for the level of new housing needs to reflect the ambitions of

the Strategic Economic Plan.

4.8. Furthermore, the Sheffield City Region Integrated Infrastructure Plan states:

A quality housing offer has a crucial role to play in the future economic growth of the City Region. It

is essential to attracting and retaining a skills base that supports inward investment as we as meeting

existing and future community needs and retention of Sheffield City Region (SCR) talent.

It has been identified that between 70,000 and 100,000 additional homes are needed in SCR to

support the proposed economic growth over the next 10 years. These will have the dual benefit of

providing accommodation that underpins the proposed increase in employment (70,000 jobs), as well

as the wider economic benefits that housing investment brings.

Housing forms a key component of the SCR construction sector. The CBI [CBI (2012) Bridging the

Gap – Backing the Construction Sector to Create Jobs] estimates that every £1 spent on construction

projects yields a total of £2.84 expenditure in the wider economy. It is estimated that approximately

£2,000 per annum per household spending on local convenience goods, and approximately £2,700

per annum per household spending on local comparison goods can be attributed to residents in new

housing. (Over the lifetime of the SEP, a similar amount would generate at least £400 million for the

SCR economy). The GVA benefits that can be attributable to new housing are as follows:

• Construction: material, labour professional skills and other services for construction, compounded

by supply chain benefits

• Household Maintenance Spend: Spend on products and services associated with each new

household

• Direct Job Uptake: GVA resulting from new productive workers moving into SCR, compounded by

their spend on SCR products and services

• Indirect (Chain) Benefits): As SCR residents move up the housing chain, this creates new available

space in different sub-markets.


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• Preventing Displacement: The type and location of construction may be important in mitigating

losses of households from the city region that might otherwise occur.

4.9. Within this context it is important that the Council plans for new jobs and associated new

homes in accordance with the Strategic Economic Plan growth aspirations.

4.10. To achieve this approach, Firsure consider the Local Plan should:

• Focus the majority of development upon Doncaster Main Urban Area

but review the likely housing yield from existing sites with planning

permission and proposed allocations to ensure that they can all be

delivered within the Plan Period. This is explained further in response

to Policy 3.

• To focus growth and regeneration on the Main Towns of appropriate scale for

their needs and the economic growth aspirations of the Borough. Rossington

should be an area of growth given the provision of new infrastructure, its location

near to Doncaster Airport, and the scale of economic growth planned at IPort.

Thorne and Moorends should grow to reflect its location, regeneration ambitions

connected with the logistics and employment parks, and level of facilities available

within the designated town and local centres. Within that context Carcroft and

Skellow is of similar scale to the Main Towns and should be identified as such,

particularly with its provision of employment parks and location on the A1(M)

and focus on regeneration and growth.

• Provision should be made in the Service Towns and Larger Villages to reflect their

scale and function. These are sustainable towns and villages which serve a

hinterland. Wadworth is of a similar scale and function of these settlements and

should therefore be defined as such, recognising its proximity and connectivity to

the Main Urban Area.

• Defined Villages are sustainable villages serving a rural economy and should

accommodate a level of development appropriate to their scale and function in

line with the provisions Framework (paragraph 78).


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4.11. Firsure consider that the above approach meets the Local Plan vision and objectives identified

within the Local Plan but is also one that is more aligned with the principles of sustainable

development.

4.12. Policy 2 establishes the strategic approach to the Green Belt within Doncaster and states that

the general extent of the Green Belt will be retained. Firsure is concerned that Green Belt

boundaries have been drawn tightly around settlements and proposed allocations and as such

does not have regard to the intended permanence in the long term so that the boundaries

can endure beyond the Plan period. Policy 3 and 6 do not identify any safeguarded land. The

Plan does identify reserve sites. However these sites have significant technical constraints.

Firsure do not consider that they are suitable pool of sites due to the significant constraints

and object to their identification in the Plan.

4.13. Whilst there is no definitive guidance indicating the amount of land which should be

safeguarded the Framework (2019) is clear that where necessary Local Plans should ‘identify

areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term

development needs stretching well beyond the plan period’, and that local authorities should ‘be

able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan

period’. Given that the council considers that the majority of sites will be delivered within the

plan period. It is highly likely that further alterations to the green belt will be required at the

next review of the Plan. This is not consistent with the provisions of the Framework.

4.14. Firsure consider that Policy 2 should establish the approach to Safeguarding land and that

safeguarded land should be identified, not only provide a robust long-term Green Belt

boundary but will also provide certainty for residents and developers alike in terms of likely

growth locations beyond the end of the plan period. Firsure therefore suggest that such land

be allocated in the Plan across the spatial hierarchy, including smaller settlements per the

earlier spatial approach.

4.15. Firsure consider that the policy in its current form is not justified and is not consistent

with the Framework the Plan in its present form could fail to deliver sustainable

development in accordance with policies in the Framework. In these circumstances, we

do not consider the Doncaster Local Plan in its current form to be sound.


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4.16. However, Firsure consider that with the proposed changes to the strategy and establishing

the approach to safeguarding land the Local Plan can be found sound. Firsure will continue to

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

Proposed Change


• Reflect economic and housing growth aspirations

• Amend the Spatial Strategy as indicated

• Identify safeguarded land or suitable Reserve Development Sites across the spatial

hierarchy


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5. Policy 3: Level and Distribution of Growth (Strategic Policy)

5.1. Firsure is concerned that the Doncaster Local Plan Draft Policies and Proposed Sites is

deficient in its content and evidence base and does not reflect national guidance.

Test of Soundness





Justification

5.3. Firsure have a number of concerns in relation to the Level and Distribution of Growth. The

concerns relate to the following:

• The Local Plan housing requirement is not sufficient and is not fully aligned with

forecast economic growth.

• The Local Plan identifies significantly more employment land than the target for

provision established in Policy 3.

• There is a significant mismatch between the level of employment land allocated

and the level of housing land allocated in the Plan period; and

• The identified supply is not sufficient to meet the Councils identified

requirement.

Need


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5.4. Firsure is concerned with the proposed level of new housing being planned for in the Local

Plan. Policy 3 makes provision for 18,400 dwellings to be delivered between 2015 and 2035,

equivalent to 920 net new homes each year. Policy 3 states that there should be sufficient

allocations for 15 years supply, which is 13,230 new homes.

5.5. Firsure has commissioned Regeneris Consulting to review the OAN and the Economic

Forecasts and Housing Needs Assessment (2018). The Regeneris report is attached to these

representations. Regeneris conclude that:

• The target delivers the minimum level of housing need for Doncaster based on

the standard method (585 dpa) and makes an upward adjustment to support

economic growth.

• The upward adjustment was based on evidence produced by PBA which

recommended housing need is presented as a range between 585 dpa (the

minimum) and 912 dpa. The upper limit was based on matching Jobs growth

aspirations of the Sheffield City Region LEP (1,420) over the period 2016 to

2026.

• However, PBA have made unjustified and unrealistic assumptions for a number

of factors which all suppress the level of housing required to support future

employment growth. In particular, we disagree with their assumptions about

commuting, double jobbing and household formation rates.

5.6. Regeneris consider that:

• Doncaster has been one of the fastest growing economies in Yorkshire and

Humber. The district has created around 24,000 jobs between 2000 and 2017,

representing a growth rate of 1.1% p.a

• Doncaster’s key asset is its connectivity by road, rail and air which has made it

a highly attractive location for inward investment, particularly for industrial and

logistics occupiers, with over 1.1m sq m of industrial/warehouse space taken up

since 2010.

• The strong performance is also due to a significant improvement in key

economic indicators, including skills and levels of enterprise. The business


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start-up rate has more than doubled since 2010 and is now in line with the

national average. These improvements have removed a key barrier to growth

and mean that Doncaster is well placed to continue its high rate of growth.

• The Local Plan has set a target of delivering 481 hectares of employment land

between 2015 and 2035 and a number of ELR’s shows there continues to be

very strong market demand for industrial space in Doncaster. There is

therefore strong potential for Doncaster to accommodate high levels of inward

investment in future which would also drive jobs growth.

5.7. Firsure have concerns that the proposed housing requirement does not represent an

appropriate figure once consideration is given to the potential for economic growth and job

formation. Firsure continue to consider that an appropriate balance should be sought between

employment growth aspirations and the provision of homes.

5.8. The Framework (2019) reaffirms the Governments’ commitment to ‘significantly boosting the

supply of homes’ and states that ‘it is important that a sufficient amount and variety of land can

come forward where it is needed, that the needs of groups with specific housing requirements are

addressed’. It goes on to state ‘ to determine the minimum number of homes need, strategic policies

should be informed by a local housing need assessment, conducted using the standard method in

national planning guidance – unless exceptional circumstances justify and alternative approach which

also reflects current and future demographic trends and market signals’.

5.9. NPPG is clear that the standard method identifies a minimum annual housing need figure and

that it does not produce a housing requirement figure Paragraph 002 Reference ID: 2a-002-

20190220. It is also clear that the affordability adjustment within the standard methodology is

just to ensure that the minimum housing needs starts to address affordability of homes. It

therefore does not fully address affordability issues. Paragraph 006 Reference ID :2a-006-

201902020.

5.10. NPPG goes on to identify the circumstances when it is appropriate to plan for a higher housing

need figure than the standard methodology identifies. ‘The government is committed to ensuring

that more homes are built and supports ambitious authorities who want to plan for growth. The

standard method for assessing local housing need provides the minimum starting point in determining

the number of homes needed in an area…it does not predict the impact of future government policies,

changing economic circumstances or other factors that might have an impact on demographic


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behaviour. Therefore there will be circumstances where it is appropriate to consider whether actual

housing need is higher than the standard method indicate.

5.11. This will need to be assessed prior to and separate from, considering how much of the overall need

can be accommodated. Circumstances where this may be appropriate include, but are not limited to

situations where increases in housing need are likely to exceed past trends because of:

5.12. Growth strategies for the area that are likely to be deliverable, for example where funding is in place

to promote and facilitate additional growth

5.13. Strategic infrastructure improvements that are likely to drive an increase in the homes needed

locally;

5.14. An authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement

of common ground.

5.15. There may, occasionally be situations where previous levels of housing delivery in an area, or previous

assessments of need (such as a recently produced SHMA) are significantly greater than the outcome

from the standard method. Authorities will need to take this into account when considering whether

it is appropriate to plan for a higher level of need that the standard model suggests’. Paragraph 010

Reference ID: 2a-010-20190220.

5.16. The Council need to recognise that the development of new housing will bring forward

additional economic benefits to the area. The relationship between economic performance

in an area and housing is complex, but having the right quantity, quality and balance of housing

in an area is necessary for economic growth. The development of new housing can therefore

support local economic growth, both through direct job creation through the construction

phase of the scheme, but also through the increased population which will create sustainable

local jobs from the increased demand for goods and services. This provides an important

sustainable development opportunity for Doncaster.

5.17. Importantly the HBF released in July 2018 its report on “the economic footprint of house

building in England and Wales”, which shows that house building in England and Wales is now

worth £38bn a year and supports nearly 700,000 jobs. House building activity contributes

economically in different ways including providing jobs, tax revenues and contributing funding

for local infrastructure and communities. House building supports the economic in a wider

sense through being drive for economic growth; delivering jobs and economic value;


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supporting labour market mobility; creating skills and employability; enhancing place

competitiveness; creating quality of place and reusing brownfield land.

5.18. An important conclusion of the report and the wider economic benefits is that a healthy, well-

functioning labour market requires a good supply of housing that is affordable for local people

to enable them to move jobs freely and match up skills supply with employer demand. A

dysfunctional housing market can inhibit labour market mobility, in turn stifling economic

growth.

5.19. Regeneris consider that Doncaster’s housing need over the plan period should be

1,100 dpa to support future economic growth. Regeneris consider that the target

of 920 dpa would risk constraining the future economic growth of Doncaster.

5.20. Furthermore, it is evident that the council are seeking to align economic growth with housing

growth and have identified provision above the local housing need figure to which the council

considers accounts for Job Led growth. However, the jobs led growth figure is based on jobs

growth forecast between 2015-2032. It is not clear whether consideration has been given to

the additional job growth expected to the end of the plan period. Therefore Firsure consider

there is potential for the jobs led scenario to underestimate the jobs growth over the full plan

period. The associated uplift to the housing requirement will therefore not be sufficient to

meet the full needs over the plan period.

5.21. Additionally, the Council have identified a requirement for 481 hectares of employment land

based on the Job Led scenario, and accounts for the extended plan period 2032-2035. The

explanatory text considers that this requirement is met through 117 hectares of land

developed between 2015-2018, 201 hectares of land benefiting from planning permission, and

164 hectares of allocated sites. However, there is a discrepancy between the totals in

paragraph 4.61 of the Plan and the figures arising from Tables E1 to E8. The sites that benefit

from planning permission in tables E1 to E8 equate to 284.09 ha of employment land available

within the Plan period. This leads to a total provision of 565.77 hectares of

employment land against a requirement of 481 hectares. It should be noted that

within the permissions identified in tables E1 to E8 that additional employment land is available,

adding to the potential supply. There is therefore a significant mismatch between the level of

planned employment provision in Policy 4 and the planned housing provision. Therefore, the

housing requirement needs to be uplifted to reflect the identified level of

employment land provision.


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5.22. As stated above NPPG indicates that consideration can be given to delivery rates, for the last

three years completions have been consistently higher than the proposed local plan target.

Net completions amount to 3211 dwellings, with annual completions as follows:

Year Net Completions

2015-16 1,025

2016/17 1,049

2017/18 1,137

Total 3,211

5.23. This demonstrates that there is sufficient demand to support a requirement above 920

dwellings per annum.

5.24. The Councils Economic Forecasts and Housing Needs Assessment (PBA, 2018) considers the

housing requirement prior against both the standard methodology, standard methodology

with an uplift for economic growth and previous approach for identifying housing need.

Following the earlier approach, PBA consider that an aspirational job led figure, based on the

SEP ambitions, would equate to a requirement of 1,073. PBA considered that it would be

prudent to plan for between 562 and 1073. To ensure that the requirement was realistic. It is

worthy of note that the Employment Land Needs Assessment (2019). Considers that the Job

led scenario was ambitious but realistic and notes the significant growth in Doncaster within

the previous 15 years in line with SCR growth aspirations. And further the evidence of land

take up and jobs growth for the period 2015-2018 was on target to meet 1% jobs growth per

annum. This would support a target at the higher end of the range.

5.25. There is therefore evidence of both delivery at a higher rate and recently published evidence

that indicates a higher need for housing. As stated above NPPG is clear that this evidence

should be taken into account when determining the housing requirement.


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5.26. When using the standard method the housing need figure was 585, applying a job led figure

to match the SEP led to a requirement of 912 (PBA, 2018). However this is not based on the

Jobs growth over the full plan period.

5.27. Firsure consider further evidence is required to demonstrate whether the affordable housing

needs of Doncaster can be met based on a target of 920. The explanatory text states that

the current need for affordable housing, 209 affordable units, represents 23 % of the Local

Plan requirement for housing. Paragraph 6.9 states that this does not take into account current

completions or viability. The completions affordable completions for the last three years (first

three years of the Local Plan) are as follows:

Year Affordable

Completions

Total Completions Affordable

completions

(%)

15/16 151 1,088 13.88

16/17 161 1,067 15.09

17/18 166 1,208 13.74

5.28. The total affordable completions falling below the identified affordable need, even when total

completions are higher than the proposed Local Plan requirement of 920. Further, Policy 8

identifies a requirement for 23% affordable housing in high/medium value areas and 15% in low

value areas. An as indicated in response to Policy 8 and Policy 67, this is demonstrated to be

unviable for a number of sites, including all types of sites in low value areas. Firsure are

therefore concerned that a target of 920 dwellings will not deliver sufficient number and range

of affordable homes to meet the identified need for affordable homes in the Borough. In order

to deliver 209 affordable dwellings per year, a requirement of at least 1,393 would be required.

This assuming the achievement of an average of 15% affordable housing, which represents the

highest achieved over the last three years of monitoring.

5.29. Firsure consider that there is sufficient evidence to pointing to the need for further uplift in

the Local Plan housing requirement, based on the significant mismatch between housing and


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employment land allocations, the need to support the local plans economic ambitions,

evidence of delivery and the need to ensure sufficient delivery of affordable housing.





5.31. However, Firsure consider that with a higher requirement, of at least 1,100 to meet the

economic growth aspirations, and further uplifts to balance housing allocations with the

employment land allocations, and to ensure that the needs for affordable homes can be met

(up to 1393) that the Local Plan can be found sound. Firsure will continue to work with the

Council to develop appropriate modifications to the Local Plan

Housing Supply and Delivery

5.32. Firsure is concerned that the Council’s approach to delivering the housing requirement does

not appear to reflect national guidance.

5.33. The Council is not demonstrating sufficient flexibility in the supply of housing land to ensure

that the Plan can meet identified needs in full. The Framework is clear that plans should be

sufficiently flexible to adapt to rapid change, and emphasises the importance of ensuring that

a sufficient amount and variety of land can come forward where it is needed.

5.34. PPG is clear that careful attention should be given to providing an adequate supply of land,

and the Plan needs to be realistic about what can be achieved and when. Authorities need to

ensure that policies setting out contributions expected from development do not undermine

the deliverability of the Plan. (Paragraph 59 Reference ID: 61-059-20190315.

5.35. At present based on the Councils figures presented in the Local Plan, a Plan requirement of

18400, completions equating to 3400 and allocations equating to 16,055, there is a flexibility

of around 1055 dwellings which equates to 5% of the Local Plan Requirement. Firsure consider

that this is insufficient given the potential for non-delivery and under delivery of sites,

particularly from the dependency on a number of large sites. As set out in our response to a

number of policies within the plan and specifically Policies 8, 46, 66 and 67, Firsure are

concerned that some of the policies may undermine the deliverability of sites, or lead to the

need for further site specific viability testing impacting on the timing of delivery and therefore


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there is a need for greater flexibility in the housing supply. Specific sites are identified later in

this section.

5.36. Firsure have a number of concerns relating to the supply in the Plan in terms of completions,

the allocations from permissions and the new allocations.

5.37. It is noted that the supply attributed to completions appears to be resultant from gross

completions rather than net completions. The Plan indicates that completions between 2015

and 2018 equate to 3400, However data in the Residential Land Availability Report indicates

that net completions amount to 3211. Which would serve to increase the residual

requirement based on an OAN of 920 to at least 15,189, and reduce the flexibility in the Plan

to 866 dwellings (4.7%).

5.38. With regards to overall supply from permissions and allocations, a housing trajectory has been

provided. Firsure are concerned that this demonstrates that the Council will struggle to

maintain a continuous supply of housing particularly in the later phases of the Plan period.

Only four sites are identified as being capable of delivery in the final years of the plan period

and two sites delivering beyond the plan period.

5.39. Furthermore, the Council’s HELAA and Residential Land Availability Report have a base date

of March 2018, thus a whole monitoring year is presently absent. This evidence base should

therefore be updated.

5.40. In terms of existing commitments it appears that the Council assumes 100% delivery and no

discount has been applied. Best Practice and Guidance suggests that at least a 10% discount

should be applied on sites with extant planning permission but this could vary depending on

site specific constraints and complexity. Firsure supports the discounting of sites with planning

permission but consider it may be beneficial to include a higher level of discount for large sites

to take into account unforeseen circumstances and delivery delays. Firsure consider therefore

that from a commitments pot of 9,488 dwellings a discount of at least circa 948 should be

applied, however this could feasibly be higher given the history and constraints of a number

of sites.

5.41. Firsure is concerned with the reliance on some existing housing sites with planning permission

and their potential delivery, particularly as some are fairly historic brownfield sites with

viability concerns in market challenging areas. There are a considerable number of outstanding


22

planning permissions in poor market areas, some of which are also constrained by flood risk.

Evidence of developer interest in such sites should be a fundamental requirement to provide

confidence on delivery. For example, a brief review of some sites being shown as

commitments shows considerable concern:

Site Ref Site Name No. of Dwellings Firsure Comment

838 Hexthorpe 930

There have been a number of planning applications and proposed schemes over the years, but there has been no delivery on site. Countryside PLC has submitted a planning application which the Environment Agency has objected to and recommended refusal. There is conflicting evidence in terms of delivery rates, with the Local Plan and the HELAA. There are significant flooding constraints affecting the site. No further deliverability evidence has been produced in the Doncaster 5 Year Deliverable Housing Land Supply Statement. The Residential Land Availability Study notes that at 31/03/2018 there were no completions and the site is not currently being developed.

843 Manor Farm, Bessacarr 1,009

This is a Persimmon / Charles Church scheme. However, delivery has become frustrated by the need to deliver infrastructure to complete development. Since there is only one developer on the site the development trajectory is likely to be modest and development of the site is unlikely to be achieved during the plan period. The Residential Land Availability Report indicates 39 completed in 17/18 which is below the rates expected in the Local Plan and HELAA. Which assumes delivery rates of around 70 dwellings a year. This is not realistic based on current delivery.

418 Unity/DN7 Initiative 905

The site has outline planning permission for 3,100 homes. No reserved matters have been submitted The site is in significant multiple ownership and understand that CPO procedures will be employed to facilitate the delivery of requisite infrastructure. Homes England is also assigning public funding to support the development. Given the presence of multiple landowners, the need for considerable public funding, the likelihood of a protracted timeframe to open up the site for development and the absence of confirmed market interest, the site is unlikely to deliver the Council’s prediction of 1015 homes in the plan period. The HELAA does not anticipate a start on site until years 6 to 10. However the local plan indicates a 175 completions in the first five years. Higher rates of delivery are expected in the following years (70 dwellings per annum). These rates are overly optimistic especially when compared to annual completions for individual sites recorded in the residential land availability report.


23


569 Askern Saw Mills 220

This is a long standing, unimplemented planning permission that has been available but has remained undeveloped. There is no developer interest and consequently the assumed delivery of 220 new homes is optimistic. Indicated in the Residential Land Availability Report that the outline permission has lapsed.

984 Former McCormick Tractors 600

This site has significant constraints. There is an outline permission relating to the development of the site. The Local Plan assumes a delivery rate of 56 dwellings per in the first five years and 64 dwellings per annum in the following years. This is overly optimistic and not consistent with the planning status and constraints on site.

940 E1 and E2

Land east of Poplars Farm 280/920

Site 940 is allocated in the plan for development of up to 280 dwellings (Part E1), Part E2 is identified as a reserved housing site for up to 920 dwellings. This site does not form a true reserve site. The council have identified a release mechanism which restricts the release of housing to net additional jobs delivered at the airport.

5.42. Firsure understands that no allowance has been made for demolitions. No evidence is

apparent and Firsure consider it would be appropriate for this evidence to be forthcoming.

5.43. The availability of land is crucial. To be considered deliverable the land needs to be available

now and in terms of developable there needs to be a reasonable prospect that land will be

available at the point envisaged. Firsure consider that sites which are not available or are

unknown should not be included in the Plan or a buffer should be provided due to the

uncertainty on delivery.


1028 Tickhill 74

This site does not have access, therefore cannot be considered to be deliverable. Further, the capacity of the site is unrealistic. This is a 1.5 hectare site, a capacity of 44 dwellings would reflect the assumptions on net to gross developable area and density set out in the Viability Study.


24


662/247 Colliery Site, Rossington 897/237

The delivery rates on the site are overly optimistic. In 2017/18 there were only 49 completions on site 662. Assuming delivery rates based on past performance at this site then it is considered that only 600 dwellings will be capable of coming forward within the Plan period. This is significantly less than the 1127 homes forecast within the Plan.

081/343 Thorne 207

This is a longstanding allocation and there is little evidence available through the councils evidence base to demonstrate that there is developer interest or that the site will come forward in the short term.

795 Thorne 13

This site had permission which has since lapsed. There appears to be little developer interest in this site. The site is not considered to be deliverable.

510 Thorne 25

This is a narrow and constrained infill site, with railway forming the southern boundary of the site. There is little evidence available through the Councils evidence base to indicate any developer interest in the site.

165/186 Carcroft 300

This site is located to the western edge of the settlement and is relatively distant from the key services and facilities such as the train station, and employment opportunities. Other sites are located nearer to key services.

5.44. A high level assessment of some of the proposed allocations shows that some proposals are

at risk and hence one of the reasons why Best Practice suggests a buffer to the housing

requirement should be included in the Plan. Furthermore, would appear to have leant heavily

on allocating sites that already have planning permission as an alternative to identifying a

sufficient supply of new allocation sites to meet its requirement for the plan period.

Consequently, a number of settlements with strong sustainability credentials would appear to

have insufficient allocations to meet their needs through the life of the plan.

5.45. It would appear in some instances that there are unrealistic assumptions on gross to net

developable site areas and on the resultant yields from proposed allocations, especially when

considering some of the development requirements. Firsure therefore suggest that further

sites should be identified.

5.46. The Council therefore need a wider choice of sites across a number of different areas and

market areas to gain traction and increase build rates. To achieve the housing requirement


25

the Council need at least 30-35 housing outlets operating across the Borough for every year

of the Plan and Firsure do not believe the Plan can deliver this, particularly in the middle to

later years.

5.47. Firsure considers the Council should be more realistic on the potential delivery on sites,

particularly on sites which have not commenced preparations of securing the relevant planning

permission and developer interest and on build rates. Firsure consider that the sites with no

planning permission should not be providing completions until 2023/24 (which is two years

post adoption) as there is significant work and preparations to commence on site, including

time to prepare and submit the planning application, gain planning permission, discharge

conditions, legal agreements, site preparations, and commence house building. This process

can take around 2 years.

5.48. Firsure would be happy to work through the specific sites in detail with the Council to seek

to reach agreement on the HELAA and current housing commitments. Interestingly, in line

with the general direction of travel for this Local Plan the new Framework (2019) defines the

term Deliverable in the glossary stating that sites can only be considered deliverable where

they have detailed planning permission. If they have outline planning permission or are

allocated in a plan a site can only be considered if there is clear evidence that housing

completions will begin on site within five years. The level of evidence that must be provided

to demonstrate that sites are deliverable has therefore been tightened.

5.49. Firsure considers that the main risks to the delivery of the housing requirement are slippages

in the delivery of allocations, longer lead-in times, reduced housing capacity on sites, sites no

longer coming forward as result of viability from policy obligations set out in the Local Plan.

Given these risks Firsure would suggest a greater flexibility is incorporated into the Local Plan

especially in light of Firsure’ conclusions on the actual housing requirement.

5.50. Firsure would encourage the Council to review the existing commitments to ensure this is

still deliverable, whether there is a housebuilder on board and whether there are any

constraints preventing development from coming forward. Firsure would also ask the Council

to look at the proposed delivery of site allocations to determine whether the delivery rates

are appropriate and the sites are deliverable in light of the policy obligations proposed in the

Local Plan.

5.51. Taking into account the above, the Council should be making provision for:


26

Council Figures Firsure’s View

Annual Housing Requirement 920 1,100

Total Requirement (2015-2035) – which is 15 years post

adoption

18,400 22,000

Completions 3,400 3,211

Total Commitments 9,488 9,488

Non-Delivery Allowance (at least 10%) 948.8 948.8

Total Allocations 6,567 6,567

Total Supply 18,506 18,317.2

Residual homes to be identified -106.2 3,682.2

5.52. Therefore, on a best case scenario Firsure consider as a minimum there needs to be

circa 3,682 new homes to be identified in the Plan to account for net completions, and

economic growth.

5.53. This does not account for the uplift required to ensure affordable housing need is met in full,

which as indicated in paragraph 5.28, would lead to a requirement of 1,393 dpa and a plan

requirement of 27,860. Based on the current supply of 3,211 completions, 9,488

commitments, an allowance for 10% non–implementation, and the currently proposed

allocations of 6,567 homes, this would lead to need for a further 9,542 additional homes.

5.54. Significantly, the scenarios above do not balance housing provision with the additional

employment allocations. The additional employment allocations amount to 83.77 hectares

above the requirement, this is the equivalent of an additional 3.5 years supply of land. As a


27

result in order to balance the housing provision with the additional employment supply circa

3850 additional homes would be required, this amounts to an annual requirement of 1,292.5

dpa. Firsure consider circa 7,532 additional homes are required in order to balance

the Housing with Employment supply, account for net completions and

appropriate non-implementation rates.

Firsure’s View

Employment requirement 2015-2035 481 hectares

Annual employment requirement 24 hectares

Employment land developed 2015-2018 117

Sites with planning permission Tables E1 to E8 284.09

New employment allocations Policy 4 164.68

Total Allocations 565.77

Amount of land allocated over the requirement 83.77

Additional homes required to balance with

employment land supply

3,850

Residual homes to be identified 7,532.2

5.55. These figures assume no changes to the currently identified housing sites, which, in response

to policy 3 and policy 6, Firsure have raised significant concerns, particularly with regards the

deliverability, capacity, and delivery rates of some sites and the overreliance on existing


28

permissions or longstanding allocations. This does not account for additional economic

growth associated with the airport

5.56. Furthermore, there does not appear to be any safeguarded sites or genuinely deliverable

reserve sites identified within the Draft Plan. This is concerning given Policy 6 states that the

Plan will designated Reserve Development Sites. However, it states that the reserves sites

identified are not considered developable in the plan period. Paragraph 4.43 of the Plan

indicates that the reserve sites have flood risk mitigation issues or safeguarding issues

associated with HS2 preventing them from coming forward. Firsure would suggest, in order

to assist with flexibility, that safeguarded sites be proposed in accordance with national

guidance. The only other reserve site is related to direct job growth at the Airport and is

strictly controlled, thus does not provide flexibility for the Plan as a whole.

5.57. The above scenarios do not include a detailed analysis of existing commitments and proposed

allocations, however from a high level analysis it is evident that the Council’s trajectory and

analysis of sites is optimistic.

5.58. Therefore, with an increased housing requirement, reduced potential from

existing planning permissions sites and incorporation of a flexibility allowance,

further land will need to be identified.

5.59. Firsure consider that the appropriate areas and sites to accommodate growth would be:

• Site 302 and 305: Stripe Road, Rossington

5.60. A brief summary is provided for this site in response to Policy 6. Technical information

and a report on the Role and Growth of Rossington is submitted alongside these

representations. This report will be supported by significant technical information and the

report will demonstrate that the sites are available, suitable and achievable and therefore

deliverable in accordance with the Framework and PPG.






29

5.62. However, Firsure consider that with an appropriate uplift to the housing requirement,

consideration of net completions, non-implementation rates and the allocation of additional

land and safeguarded sites that the Local Plan can be found sound. Firsure will continue to

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

Proposed Change


• Increase housing requirement to 1,100 to 1,300 dwellings over the plan period.

• Reduce the potential from current commitments and include a non-delivery

allowance.

• Identify safeguarded land.

• Allocate:

o Site 302 and 305: Stripe Road, Rossington


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6. Policy 6: Housing Allocations (Strategic Policy)

6.1. Firsure objects to Policy 6 and the proposed distribution of housing and that the following

site is not a proposed allocations:


6.2. The site is summarised below and technical information and advocacy report have

been submitted alongside earlier representations. Further a report on the Role

and Growth of Rossington is submitted alongside these representations.

Test of Soundness

6.3. Firsure considers that the Local Plan is currently unsound.




Justification

6.4. Firsure is concerned that the Local Plan is not producing sufficient homes across the Borough.

Further to comments in relation to Policy 3 Firsure recommends that further sites are

identified to meet and exceed the requirement but also to provide a sufficient buffer to deal

with any under-delivery which is likely to occur from some sites. Such an approach would be

consistent with the Framework requirements for the plan to be positively prepared and

flexible.

6.5. Firsure is concerned that the proposed distribution of new homes does not reflect the spatial

strategy, but importantly does not address the focus for economic and housing growth across

the Sheffield City Region and Yorkshire and Humber as a whole.


31

6.6. The proposed distribution against the Council’s own targets shows a deficiency and a

significant under provision in:

• Doncaster • Adwick • Conisbrough – Denaby • Mexborough • Thorne – Moorends • Sprotbrough • Tickhill • Bawtry

6.7. Firsure, as explained in response to Policy 2 and the spatial strategy considers that the spatial

strategy is incorrect, that it does not provide for the growth of the Borough and does not

reflect the role, function and location of the settlements.

6.8. Firsure, as explained in response to Policy 2 and 3, considers that there needs to be further

provision of housing and a slightly amended approach to the spatial strategy, which focusses

growth towards Doncaster. There should be further growth of Rossington to address

regeneration and the provision of new infrastructure. There should be growth in Thorne-

Moorends, and a regeneration focus in Carcroft-Skellow which should elevate the status of

the settlement commensurate to its role and function. New housing should be provided in

Tickhill to address the current under provision. Wadworth should accommodate some new

housing to reflect its role and function and provision should also be made in the villages to

address the rural economy.

6.9. Firsure is particularly concerned that in Rossington there is only a single small housing

allocation and an over reliance on one large allocated (formed by site 662 and 247). The role

of Rossington should be the focus for growth and regeneration, given its strategic location

next to the M18 with new infrastructure in the form of the Great Yorkshire Way, provision

of major employment opportunities at i-Port and the airport, forming the largest employment

allocations within Doncaster, which are adjacent to the settlement. Furthermore, the

proposed new PGA golf course is adjacent to Rossington. With major expansion plans at the

airport ‘Aetropolis’, Rossington is in a prime strategic location to benefit from such plans and

associated housing should be provided to ensure Doncaster benefits from such inward

investment. Firsure proposes that their site at Stripe Road can accommodate new housing


32

6.10. Further Firsure are concerned about the deliverability of a number of allocations within

Rossington.

6.11. Site 662 and 247: The Colliery site. The Role and Growth of Rossington document considers

the delivery rates currently achieved at the site. In 2017/18 there were 49 completions on

site. Assuming delivery rates based on current and past performance at this site, then Firsure

consider that only approximately 600 units will come forward on the Colliery site(s) within

the Plan period. This is significantly below the delivery expected within the Local Plan which

anticipates that 1127 homes can be delivered across the Colliery site(s). No further evidence

on this site is put forward in the Doncaster five year deliverable housing land supply statement

6.12. Site 1056 – Former Torndale School Playing fields, This relatively small site is considered to

be capable of delivering 92 dwellings. This is overly optimistic given the irregular shape of the

site. The local plan identifies the site as delivering in years 6-10, thus the site does not appear

to be capable of assisting with short term delivery in Rossington.

6.13. Based on the above it is clear that the deliverability and delivery rates of some of the sites in

Doncaster ought to be reviewed to ensure that they reflect the site specific circumstances.

Further allocations are required in to ensure that the delivery of the plans strategy.

6.14. Furthermore, there does not appear to be any safeguarded sites identified within the Local

Plan. This is concerning given Policy 6 states that the Plan will designated Reserve

Development Sites, yet those identified are not considered to be developable within the Plan

Period due to significant constraints relating to flood risk and HS 2 Safeguarding, thus could

not be relied on to maintain the supply of housing should other sites fail to deliver in the Plan

period. As indicated in response to Policy 3 Firsure suggest, that safeguarded sites be

proposed, to provide additional flexibility in accordance with national guidance.





6.16. However, Firsure consider that with the allocation of site 302 and 305: Stripe Road,

Rossington and adjustment in anticipated delivery within the plan period of sites 662 and 247


33

that the Local Plan can be found sound. Firsure will continue to work with the Council to

develop appropriate modifications to the Local Plan.

6.17. To address these deficiencies in the Plan Firsure therefore suggest that the following sites be

allocated:


6.18. A short summary of the site is in the following sub-section and technical

information and advocacy report have been attached to earlier representations.

The Role and Growth of Rossington report is attached in support of the site.

Site 302 and 305: Stripe Road, Rossington

6.19. Firsure is particularly concerned that in Rossington there is only a single small housing

allocation and an over reliance on one large existing commitment. The role of Rossington

should be the focus for growth and regeneration, given its strategic location next to the M18

with new infrastructure in the form of the Great Yorkshire Way, provision of major

employment opportunities at i-Port and the airport, which are adjacent to the settlement.

Furthermore, the proposed new PGA golf course is adjacent to Rossington. With major

expansion plans at the airport ‘Aetropolis’, Rossington is in a prime strategic location to

benefit from such plans and associated housing should be provided to ensure Doncaster

benefits from such inward investment. Firsure proposes that their site at Stripe Road can

accommodate new housing to meet that need.

6.20. Firsure objects that Site 302 and 305 at Stripe Road, Rossington site is not allocated

and should be identified as a housing site. It is noted that the councils site selection

summary indicates that this is because Green Belt release cannot be justified as housing need

is being met. However in our response to Policy 2, 3 and 6, Firsure maintain that the Plan

does not identify sufficient sites to meet the needs of the area,

6.21. Firsure considers the proposed site is available, suitable and achievable and is therefore in

accordance with the Framework a deliverable site able to come forward in the short term.

6.22. The deliverability and benefits of the Stripe Road, Rossington site is as follows:

Overview of Proposals


34

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

to the full range of services and facilities located within Rossington. The site is surrounded by

urban development with residential development on two sides and the East Coast Mainline.

The site is approximately 18.5ha gross and could accommodate in the region of 500 new

homes.

Deliverability

6.24. The site at Stripe Road, Rossington provides a development opportunity that is available,

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

with national planning policy and guidance. It is promoted by Firsure which further

demonstrates the site’s deliverability within the plan period.


35

Availability

6.25. The land is being promoted by Firsure. The site is therefore available in accordance with the

Framework and the National Planning Practice Guidance (PPG).

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

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

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

Suitability

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

east and west. The site is within easy walking distance to local centres with a range of facilities

provided there as well as greater facilities within Doncaster Town Centre, a bus ride away.

There are a large number of primary and a secondary schools in the vicinity of the site.

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

Doncaster and beyond with access to Doncaster Railway Station.

6.29. The development will provide additional quality development that will benefit Rossington and

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

that the development is suitable.

Green Belt

6.30. Due to the significant need and demand for housing and aspirations for economic and housing

growth there is clearly a requirement for a strategic review of the approach to locations for

future growth within the district. In order to plan for appropriate for the plan period there

is a need to review the Green Belt boundaries. A thorough review of the development limits

of Doncaster settlements would ensure a holistic approach to the location of development

for the future of the Borough.

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

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

Green Belt land will need to be released for new housing land. Stripe Road, Rossington is a

unique opportunity to positively use the Green Belt and meet the housing need for the area.


36

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

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

surrounding urban areas.

6.33. The Framework explains that there are five purposes of including land within the Green Belt,

which is:

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

2. To prevent neighbouring towns merging into one another;

3. To assist in safeguarding the countryside from encroachment;

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

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

6.34. Contextually, the site is “contained” by development and activity being a “tongue” of land

which protrudes into the urban area of Rossington surrounded by residential properties and

the East Coast Main Line, beyond which is non-Green Belt countryside. Within this context

the release of the site from the Green Belt has limited impact on “openness” and that

redevelopment of the site would have low impact on the purposes of including land within the

Green Belt.

6.35. The Framework states that Green Belt boundaries should be drawn so as not to include land

which it is unnecessary to keep permanently open. The impact on the openness of the Green

Belt will be limited. The site is bounded by the urban area to the north, and partially to the

east and west. To the south is an established track from Stripe Road to a level crossing with

a tree belt to the south of it. This track and tree belt form a robust new urban boundary. The

tree belt will prevent views between the remainder of the Green Belt and the site.

6.36. The site is therefore “contained” and will not lead to unrestricted sprawl or encroachment.

The site is a protrusion of Green Belt into Rossington and is contained within its setting. The

site would not therefore lead to the coalescence of towns. Whilst the development would

result in development of some countryside the degree of encroachment into the countryside

would be minimised. The site has no impact upon the setting of a historic town.


37

6.37. Firsure propose that the new Green Belt boundary follows Stripe Road, Common Lane and

the East Coast Main Line which is clear and well defined and would be a “rounding off” of

Rossington. This boundary would accord with the Framework and ensure that the Green Belt

is clearly defined using readily recognisable features to ensure permanency reinforcing the

urban context whilst providing a robust boundary for the future.

6.38. All the boundaries have the potential to be further reinforced within the site through

additional planting to ensure an effective transition between the development and the

countryside beyond.

Achievable

6.39. A range of technical work is being undertaken and further survey work is ongoing. From the

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

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

in accordance with national guidance. The technical assessments will be submitted in due

course and are available upon request.

Effective Use of Land

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

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

The site is easily accessible and the proposed main access is off Stripe Road. The scheme is

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

Delivering a Flexible Supply of Housing

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

housing need. Firsure considers that the site at Stripe Road, Rossington is deliverable in the

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

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

years.

A Positive Response to the Key Objectives of the Framework

6.42. The Framework sets out that the Governments key housing policy goal of boosting

significantly the supply of housing and proactively driving and supporting sustainable economic


38

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

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

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

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

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

infrastructure.

6.43. In relation to the Framework:

• The proposal responds positively towards national guidance.

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

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

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

Benefits of Stripe Road, Rossington

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

housing that would meet the needs of the Rossington and Doncaster Borough housing market.

Therefore this site provides a unique opportunity in a sustainable location.

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

• The site is suitable for housing and can deliver circa 500 new homes.

• The proposal will deliver high quality housing.

• The proposal will deliver affordable housing.

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

and need in the area.

• The scheme uses land efficiently and effectively.

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


39

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

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

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

after construction.

6.46. The proposal is an appropriate site to provide for the housing needs of Rossington and

Doncaster in the short term. The allocation of the site would confirm its potential to help

continue the provision of a balanced housing supply in the Borough in sustainable locations.

The site can deliver a full range and mix of housing and a sustainable community. Development

of the site would deliver housing and affordable housing. Doncaster needs to have a robust

housing trajectory and the site at Stripe Road, Rossington would assist with this delivery in

the short term. The site is situated within a prime location suitable for residential

development and as such would facilitate the development of land in a more effective and

efficient manner. Development of the site would not harm or undermine the areas wider

policy objectives, but seeks to reinforce the need to develop sites within sustainable locations

as a priority.

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

Framework.

Proposed Change


• Allocate:

o Site 302 and 305: Stripe Road, Rossington


40

7. Policy 8: Delivering the Necessary Range of Housing

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

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

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

Test of Soundness





Justification

7.3. Firsure is concerned with a number of approaches and criteria established within Policy 8.

Housing Mix

7.4. Firsure is supportive of the principle of providing a broad mix of housing. However the Local

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

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

housing.

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

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

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

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

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

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


41

the housing need survey 2019, however the full study is not yet publically available Firsure

reserve the right to comment further when this becomes available.

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

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

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

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

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

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

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

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

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

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

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

7.8. Firsure recommend that a flexible approach is taken regarding housing mix, which recognises

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

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

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

element of aspiration to ensure working people and families are retained within the area. The

evidence presented in the plan is time limited, and only identifies current deficits. Firsure has

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

right for further comment in this regard. However, Firsure considers that the mix required

by policy 8 has not been appropriately tested in terms of viability and considers Policy 8 Part

A to be unsound. The policy should be amended to encourage to reflect the identified mix

rather than require it.

Affordable housing

7.9. Firsure is supportive of the need for affordable housing. The Framework is however clear that

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

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

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

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


42

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

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

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

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

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

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

the 15 percent required by this policy.

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

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

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

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

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

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

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

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

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

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

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

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

7.14. Firsure are concerned that there is little evidence to support an affordable housing target of

15% in low value areas. Firsure consider that further viability evidence is required to support

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

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

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

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

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

viability.

7.15. Firsure is concerned that with all the policy requirements the Local Plan details this could

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

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

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


43

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

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

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

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

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

are deliverable.

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

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

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

should occur occasionally rather than routinely.

Adaptable and Accessible Homes

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

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

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

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

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

Custom and Self Build Homes

7.18. Firsure understands the need and supports the delivery of Self-Build and Custom Build

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

its potential contribution to the overall housing supply.

7.19. Firsure consider that further evidence should be provided in respect of the level of demand

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

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

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

policy.

7.20. Firsure consider that the requirements in Policy 8 are not justified and do not provide an

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

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

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

is not consistent with national policy.


44

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


7.22. However, Firsure consider that with increased flexibility in Part A, revised affordable housing

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

evidence supporting the requirements the Local Plan can be found sound. Firsure will continue

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

Proposed Change


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

the identified mix on schemes rather than require it”.

• Review the approach to affordable housing to ensure it reflects the new Framework

(2019) and that the evidence base and viability approach is robust and credible.

• Include a flexible approach on accessible and adaptable homes and ensure the evidence

base is robust and credible.

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

evidence base is robust and credible.


45

8. Policy 19: Development affecting public rights of way

8.1. Firsure is concerned with aspects of Policy 19.

Test of Soundness





Justification

8.3. Firsure is concerned with part D of the policy which states that “unrecorded routes or desire

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

of way.

8.4. Firsure considers that such an approach on non-definitive footpaths is onerous and restrictive

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

with requirements for on-site open space, national space standards, requirements on mix and

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

delivery and the ability to achieve the housing requirement.

8.5. Firsure consider that the Policy as it stands is not justified and does not provide an

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

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

8.6. Firsure consider that the policy with increased flexibility or removal of part D of Policy 19 it

can be made sound. Firsure will continue to work with the Council to develop appropriate

wording.


46

Proposed Change


• Incorporate flexibility or remove part D of the policy.


47

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

9.1. Firsure is concerned with aspects of Policy 20 and therefore consider that the Policy 20 is

unsound.

Test of Soundness





Justification

9.3. Firsure is concerned with parts B and C of the policy which specifies the routes and

dimensions of public rights of way.

9.4. Firsure considers that such an approach is onerous and restrictive and could hinder the

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

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

required.

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

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

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

housing requirement.

9.6. Firsure consider that the policy in its present form is not justified and consider that

the Plan is unsound.


48

9.7. Firsure consider that the Plan with greater flexibility or the removal of the restrictive elements

of Policy 20 the Plan can be made sound. Firsure will continue to work with the Council to

develop appropriate wording.

Proposed Change


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

policy.


49

10. Policy 29: Open Space Provision in New Developments

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

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

Test of Soundness





Justification

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

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

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

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

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

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

their delivery and the ability to achieve the housing requirement.

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

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

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

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

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

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

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


50

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

reasonably related in scale and kind to the development.

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

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

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

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

flexible approach to planning obligations”.

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

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

undermine the delivery of housing.

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

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

the policies in the Framework.



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

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

appropriate modifications to the Local Plan.

Proposed Change


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

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

and

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

requirements of the Framework.


51

11. Policy 46: Housing Design Standards 11.1. Firsure is concerned with Policy 46 and consider that the Policy 46 is unsound.

Test of Soundness





Justification

11.3. Firsure is concerned that part A of this policy is seeking to implement national space

standards without the requisite justification and evidence.

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

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

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

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

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

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

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

account of the following areas.

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

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

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


52

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

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

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

space standard is to be adopted.

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

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

future land acquisitions’.

11.9. Firsure welcomes the provision of new evidence on Housing Design Standards Policy. Firsure

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

affordability issues and reduce customer choice. In terms of choice some developers will

provide entry level two, three and four-bedroom properties which may not meet the optional

nationally described space standards but are required to ensure that those on lower incomes

can afford a property which has their required number of bedrooms. The housebuilding

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

Described Space Standards, can therefore impact on the delivery of affordable products, and

can serve to stifle innovative design.

11.10. On NDSS Firsure would encourage the Council to recognise the larger land take such houses

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

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

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

11.11. Firsure note that the viability assessment has applied an average house size which is stated to

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

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

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

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

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

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

consider that there needs to be greater flexibility in Policy 46 with regards to the use of NDSS.

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

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

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


53

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

standards of Building regulation requirement M4 (2).

11.13. Firsure is generally supportive of providing homes for older and disabled persons. However,

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

homes the Council should only do so by applying the criteria set out in the PPG. The SHMA,

Economic Forecasts and Housing Needs Assessment and subsequent Housing Design

Standards Policy Evidence paper unfortunately does not provide sufficient evidence and does

not justify the Council’s position identified in the policy. The Housing Needs Assessment 2019,

whilst referred to in the background paper and Local Plan was not available at the time of

writing. Firsure reserve the right to comment further when this is made available.

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

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

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

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

housing tenures; and the overall viability.

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

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

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

considered, in accordance with the NPPG.

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

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

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

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

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

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

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

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

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

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

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

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


54

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

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

other relevant factors including the impact on project viability.

11.18. Firsure does not dispute the population is ageing. However, it is unclear how this ageing

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

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

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

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

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

specified in Policy 46.

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

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

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

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

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

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

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

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

requirement of 65% based on evidence of need.

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

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

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

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

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

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

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

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

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

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

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

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


55

11.21. Firsure consider that the requirements in Policy 46 are not justified and does not provide

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

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

national policy.



11.23. However, Firsure consider that with increased flexibility in Part A in relation to NDSS, and a

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

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

to the Local Plan.

Proposed Change


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

space standards

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

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


56

12. Policy 66: Developer Contributions 12.1. Firsure is concerned with aspects of Policy 66.

Test of Soundness





Justification

12.3. Firsure is supportive of the need for developer contributions. The Framework is, however,

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

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

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

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

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

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

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

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

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

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

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

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


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

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


57

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

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

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

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

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

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





12.7. Firsure are concerned that the policy requirements of the Plan are not justified and are not

consistent with the Framework.



Proposed Change


• Review and update the viability assessment and modify the policy requirements to

reflect the findings and representations contained herein.


58

13. Policy 67: Development Viability 13.1. Firsure is concerned with aspects of Policy 67.

Test of Soundness





Justification

13.3. Firsure is supportive of the need for developer contributions. The Framework is, however,

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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


59

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

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

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





13.7. Furthermore, Firsure considers that there may be some circumstances where this policy and

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

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

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

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

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

considers that this policy causes unnecessary uncertainty and additional risk for developers,

and therefore the policy could become an impediment to the development process and

compromise the deliverability of large sites particularly those phased and implemented over

long time periods.

13.8. Firsure are concerned that the whole plan viability does not fully consider the in combination

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

certainty. Firsure considers that the Plan is not justified and are not consistent with the

Framework.



13.10. Firsure consider that with increased flexibility in the Plan requirements and review of the

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

Council to develop appropriate modifications.

Proposed Change



60

• Review and update the viability assessment.

• Provide clarity on Part B or remove.


61

Appendix 1: Regeneris Report

Review of Doncaster's Housing Requirement

A Draft Report by Hatch Regeneris 18 September 2019

Spawforths


18 September 2019

www.hatchregeneris.com


Contents Page 1. Introduction 1

2. Policy and Methodological Context 2

3. The Economic Performance of Doncaster 7

4. Our View of Need in Doncaster 10

Evidence base for current housing policy 10

Alternative assessments of housing need in Doncaster 11

What explains the difference between the assessments of need? 11

Conclusions 17

5. Summary of Key Points 19


1

1. Introduction 1.1 Doncaster Council is consulting on the Publication Version of its Local Plan which will

shape development in the borough between 2015 and 2035. Policy 3 of the Draft Plan states that at least 920 (net) new homes per annum will be delivered over the plan period (18,400 homes in total).

1.2 Hatch Regeneris has been appointed by Spawforths, on behalf of a consortia of housebuilders, developers and landowners to review the available evidence and provide advice on whether this level of provision will be sufficient to meet the needs of the future population and economy of Doncaster.

1.3 Hatch Regeneris are experts in assessing housing need and have prepared NPPF/PPG compliant evidence in over 50 local authority areas in England.

1.4 The report is structured as follows:

• Section 2 reviews the current planning policy and guidance which sets out how housing need should be assessed

• Section 3 reviews the recent economic performance of Doncaster to understand the potential for future growth.

• Section 4 reviews recent housing need assessments undertaken for Doncaster and provides our conclusions on the level of housing required to support economic growth.

• Section 5 summarises the key findings and conclusions.


2

2. Policy and Methodological Context • Government is committed to delivering more housing and delivering economic growth.

This is made clear in NPPF and in numerous other policy statements.

• Rebalancing the UK economy is another central objective of government policy. Growing the economic prosperity of the North of England is a primary policy goal.

• The revised NPPF and PPG has set out a standard method for determining the minimum level of housing that local planning authorities need to deliver. This removes the requirement to align housing policies with the future economic growth of an area. LPAs can still make an upward adjustment to support growth although this will now be discretionary.

• Criticism of the new approach centres on the risk it will “lock” areas into a cycle of low inward migration and low housing delivery. There are also concerns that the standard method will work against the aim of narrowing the north-south divide by under-providing the housing required to support growth in northern economies.

Planning Policy

2.1 The revised National Planning Policy Framework (NPPF) was published in February 2019. This retains the three overarching objectives contributing to sustainable development from earlier versions; building a strong, responsive and competitive economy, supporting strong, vibrant and healthy communities and protecting and enhancing the environment.

2.2 The revised framework also retains the explicit and unambiguous target to significantly boost the supply of housing (para 59) but introduces a new standard method for determining the minimum number of homes needed in local areas (see below). The framework continues to highlight the importance that local planning authorities adopt policies which support economic growth in their area, stating “Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development” (para 80). It also states that planning policies should “seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment” (para 81).

Addressing the North-South Divide

2.3 The UK Government has also stated its intentions to address regional imbalances in the UK economy. The 2018 Industrial Strategy White Paper recognised that regional disparities in the UK are wider than in other western European nations and states that “many places are not reaching their full potential”. The strategy contains many measures orientated towards addressing regional disparities across broad areas like skills, transport and research and development.

2.4 The Government’s commitment to rebalancing the UK economy has been seen in policy measures, such as the establishment and strengthening of Metro Mayors across city regions, the opening of regional transport bodies like Transport for the North to link regional transport priorities with economic ones and committing funds, such as the £400m Northern Powerhouse Investment Fund.

2.5 The Northern Powerhouse Strategy was published in 2016. This set out the Government’s intention to continue developing the Northern Powerhouse. It outlines the Government's strategy to tackle productivity barriers and realise the full economic potential of the North


3

of England, including investment in transport infrastructure, measures to raise skill levels and ensure the North is an excellent place to start a business.

2.6 In 2019, the new Prime Minister Boris Johnson showed his continued commitment to the Northern Powerhouse by confirming the Government will fund a new high speed, trans-Pennine rail line between Manchester and Leeds.

How should housing need be calculated?

2.7 As stated above, the new NPPF introduces a new simplified method for determining the minimum level of housing needed in an area, which replaces the previous method.

The previous method

2.8 Under the earlier planning framework and guidance, the objectively assessed need for housing was calculated using a three step process:

• Establish the demographic starting point: plan-makers needed to use the latest available household projections to establish the baseline level of housing need. They could then make adjustments specific to their local circumstances based on alternative assumptions about demographic projections and household formation.

• Consider whether an uplift was required to support employment growth: an adjustment to the starting point should be considered to ensure that sufficient housing is provided to meet the needs of the economy. This was based on an assessment of the projected labour supply compared to future jobs growth.

• Consider whether an uplift is required to address market signals: a further adjustment should be applied if there is evidence of an imbalance between the demand for and supply of housing. Relevant indicators include house prices, rents affordability and overcrowding.

The new standard method

2.9 The new standard method for calculating local authorities’ housing need is based on a simple formula. This involves the following steps:

• Step 1: Setting the baseline: the 2014 based household projections continue to be used as the demographic baseline for each local authority area1. This should be based on the average annual household growth over a 10 year period.

• Step 2: An adjustment to take account of affordability: the baseline should be adjusted using a formula based on the affordability ratio (the ratio of median house prices to median earnings). For each 1 per cent increase in the affordability ratio above four, this would result in a quarter of a per cent increase in need above projected household growth.

1 Although more recent projections have now been published (the 2016 based projections prepared by ONS), these

pointed to a much lower level of housing need across the UK. The revised PPG therefore states that “the 2014-based household projections are used within the standard method to provide stability for planning authorities and communities, ensure that historic under-delivery and declining affordability are reflected, and to be consistent with the Government’s objective of significantly boosting the supply of homes”.


4

• Step 3: Capping the level of any increase: the standard method caps the level of any increase at 40%. For those authorities that have adopted their plan in the last five years, this cap is applied to the annual requirement figure in the local plan. For those that do not have an up-to-date local plan it is capped at 40% above whichever is higher of the projected household growth for their area over the plan period, or the annual housing requirement figure set out in their local plan.

2.10 The main change to the previous method is that local plan makers are no longer compelled to align their housing need figure with anticipated jobs growth. This would now be a discretionary policy decision for the local planning authority: “the standard method for assessing local housing need provides the minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore there will be circumstances where actual housing need may be higher than the figure identified by the standard method.” (paragraph 10).

2.11 Based on the standard method, the minimum housing need for Doncaster is 563 dpa. Although Doncaster is free to set a higher number which may be based on expected future jobs growth.

Response from Housebuilding Industry

2.12 Since the standard method was first proposed, a number of stakeholders from the planning or housebuilding industry have raised concerns about the changes. The key points are summarised below.

Removing the link between housing need and economic growth could stifle growth in some areas and widen regional disparities in economic performance

2.13 The main concern amongst stakeholders from the development industry was that removing the need to consider future jobs growth from the housing need assessment will result in housing policies that constrain economic growth. This is a particular risk in large areas of the north of England and the midlands where housing is more affordable than London and the south east, but which face major labour market challenges as a result of an ageing population.

2.14 In these areas, new housing is needed to address labour shortages, regenerate former industrial areas and to support the Government’s aspirations to rebalance the economy away from the overheating south east. A number of responses raised concerns that the standard method will work against these aims:

• “the failure of the methodology to factor economic growth into Objectively Assessed Needs calculations subsequently leads to a significant suppression of housing growth across the North of England which would stifle current economic growth” – Johnson & Mowat on behalf of the Leeds City Region Developers Consortium

• “the proposed methodology is inconsistent with the Government’s aim to boost growth in the Northern Powerhouse and Midlands Growth Engine, stifling growth in these areas.” – Bidwells

• “the draft methodology… will boost the housing requirement in the South and East, while depressing it in the North. We believe this contradicts wider economic policies such as the industrial strategy and Northern Powerhouse which aim to rebalance the UK economy”. – Northern Housing Consortium


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• “the outcome of the new approach will be additional housing growth pressure on London and the greater south east, and continuing limitations on the contribution that housing growth could make to rebalancing England’s economy” – Regeneris

• “We believe that if the methodology is introduced in its current form it could seriously damage some areas of the UK, especially northern cities such as Leeds and Manchester… In order for the methodology to work outside of London there needs

to be some level of account taken for future growth projections” – British Property Federation

• “There is the possibility that growth objectives of many northern towns and cities will be undermined, with implications for the Northern Powerhouse”. Indigo Planning

• “There are flaws that, if left unchecked, could lead to less housing being built in some areas and a widening of the North-South divide – the opposite of the Government’s intentions. Unless authorities are progressive in their thinking and understand the link between housing and the economy, the methodology could have dire consequences, not only for economic growth but also their regeneration ambitions and affordability” – White Young Green (WYG)

• “Action will need to be taken to ensure that the relatively lower levels of need in the north of England do not undermine future economic well-being” - Lichfields

There is a risk of carrying forward past constraints

2.15 Household forecasts are based on recent population trends and household formation rates which are both influenced by past rates of housing delivery, affordability and economic trends. By relying on the 2014 based household projections for the demographic baseline, there is therefore a risk that past underperformance caused by economic conditions or a failure to meet housing targets are projected forward under the new method.

2.16 This leads the BPF to warn that the methodology risks “locking in recessionary trends

across much of the north and Midlands”. WYG state: “It fails to recognise that areas that have previously delivered low levels of housing growth will effectively be given a mandate to continue doing so. Similarly, areas of higher growth are more likely to see a continuation of this trend. This is because, as recognised in the PPG, the household projections are based on past demographic trends and household formation rates. If migration has been constrained by supply, this constraint will be projected into the future. The uplift is unlikely to adequately compensate for this”.

There is a risk that housing and employment land policies are not joined up

2.17 The previous approach set out in PPG encouraged plan makers to consider housing and economic development needs alongside one another and to use consistent assumptions about jobs growth.

2.18 In contrast the proposed approach, which no longer requires any consideration of economic trends, means some councils may adopt housing and economic development policies which are inconsistent or in direct conflict with one another. The BPF argue that “this undermines a plan-led approach whereby you plan to meet housing and economic needs together, rather than planning for one and letting the other fall behind”.


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Implications for this review

2.19 The standard method provides the statutory methodology for determining the minimum level of housing that Doncaster should provide over the plan period. This is calculated as being 563 dpa. This review does not question this figure.

2.20 However, as stated above, Doncaster is free to identify a higher number to support economic growth. The focus of this review is on identifying what this higher number should be. Although this is no longer a statutory requirement, it is still important that Doncaster’s housing target is aligned with other policies to support economic growth in the draft Local Plan (eg its employment land provision) and that it addresses some of the potential barriers to future growth, such as its ageing population.


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3. The Economic Performance of Doncaster • Doncaster has the fastest growing economy in Yorkshire and Humber and one of the

fastest growing in the north of England. The district has created around 24,000 jobs between 2000 and 2017, representing a growth rate of 1.1% p.a.

• Doncaster’s key asset is its connectivity by road, rail and air which has made it a highly attractive location for inward investment, particularly for industrial and logistics occupiers, with over 1.2m sq m of industrial/warehouse space taken up since 2010.

• The strong performance is also due to a significant improvement in key economic indicators, including skills and rates of enterprise. The business start-up rate has more than doubled since 2010 and is now in line with the national average. These improvements have removed a key barrier to growth and mean that Doncaster is well placed to continue its high rate of growth.

• The draft Local Plan has set a target of delivering 481 hectares of employment land between 2015 and 2035 and the 2018 ELR and 2019 update shows there continues to be very strong market demand for industrial space in Doncaster. There is therefore strong potential for Doncaster to accommodate high levels of inward investment in future which would also drive jobs growth.

3.1 Doncaster is one of the fastest growing economies in the north of England. Real Gross Value Added (GVA)2 increased at a rate of 2.5% p.a. between 2000 and 2017, which is significantly higher than the national and regional average (1.7% p.a. and 1.4% p.a. respectively) and higher than any other district in Yorkshire and Humber (see Figure 3.1).

Figure 3.1 Annual average growth rate in Gross Value Added for local authorities in Yorkshire and Humber (2000 to 2017, 2016 prices)

Source Nominal and real regional gross value added (balanced) by industry, Office for National Statistics

2 GVA is the measure of the value of goods and services produced in an area, industry or sector of an economy


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3.2 This growth has driven increased demand for labour in Doncaster, creating around 24,000 new jobs between 2000 and 2017. Figure 3.1 shows that the rate of jobs growth in Doncaster has matched the national average and outperformed the average for Y&H. This has been driven by a number of sectors including logistics, retail, professional and business services and the public sector.

Figure 3.2 Employment change index, 2000-2017 (2000=100)

Source Jobs density data, Nomis

3.3 Table 3.1 shows how this translates to average annual growth rates over different time periods. Over each time period, Doncaster has achieved a minimum annual growth rate of 0.8% p.a. Average annual growth was lower over the ten-year period because it is skewed by the economic downturn which occurred between 2008 and 2011.

Table 3.1 Jobs growth rates over different time periods Doncaster Y&H GB

5 year (2012-2017) 2.8% 2.1% 2.1% 10 year (2007-2017) 0.8% 0.8% 1.2% 15 year (2007-2017) 1.1% 0.8% 1.1% Source: Jobs density data, Nomis

3.4 Doncaster’s strong performance has been driven by a number of factors. The borough has excellent connectivity across a number of modes of transport, including road, rail and air, which has made it a highly attractive location for inward investment.

3.5 Doncaster has also been extremely successful in addressing some of the challenges which have acted as a constraint on growth in the past. Figure 3.2 shows how the business start-up rate, measuring levels of enterprise in Doncaster, has risen from four new businesses per 1,000 working age people in 2010 to over 10 businesses in 2016. Doncaster’s residents now display levels of enterprise in line with the national average and well above the average for Yorkshire. Doncaster has also seen a significant improvement in the skills


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of its workforce, particularly among younger residents. The Annual Population Survey shows that the proportion of people with no qualifications (a key barrier to growth) fell from over 15% in 2010 to just 9% in 2018, bringing it in line with the average for Yorkshire and much closer to the national average.

Figure 3.3 Business start up rate, 2010-2016

Source ONS Business Demography and mid-year population estimates

3.6 The strong performance of Doncaster is due in part to the actions taken as part of the Doncaster Economic Growth Plan. This outlined a number of measures to promote new business and improve skills. Policies to support start-ups included access to start-up advisors and mentors with established local businesses. Skills measures included an apprenticeships programme and improved careers advice and guidance.

3.7 The improvement in its skills and business base led to Doncaster being recognised as one of the fastest improving cities in PWC’s Good Growth for Cities Index. As key drivers of productivity and economic performance these improvements have also addressed barriers to growth and positioned Doncaster to achieve high levels of growth in the future.

3.8 The Economic Growth Plan also outlined measures to increase inward investment by improving response times to planning decisions and increasing the stock of modern industrial and office premises. Analysis of take-up of new business floorspace shows that Doncaster is a highly attractive location for investors, particularly for industrial and distribution occupiers. Over 1.2m sq m of industrial space has been taken up since 2010, representing 37% of gross take-up in South Yorkshire (despite only accounting for 20% of its population). This is therefore a key source of competitive advantage for Doncaster.

3.9 The draft Local Plan seeks to build on this competitive advantage by setting a target of delivering 481 hectares of employment land over the plan period (2015 to 2035). The 2018 Employment Land Review and 2019 update also provide market evidence that new industrial and logistics space is in high demand and viable to deliver.

3.10 In summary, there are a number of grounds to be optimistic for the future growth of Doncaster. The district’s strong record of jobs growth, significant improvement in key economic indicators and large supply of high quality sites for inward investment all mean Doncaster is well positioned to achieve high levels of growth over the plan period


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4. Our View of Need in Doncaster • The Publication Local Plan sets a target of delivering 920 dpa between 2015 and 2032.

The target delivers the minimum level of housing need for Doncaster based on the standard method (585 dpa) and makes an upward adjustment to support economic growth.

• The upward adjustment was based on evidence produced by PBA which recommended housing need is presented as a range between 585 dpa (the minimum) and 912 dpa. The upper limit was based on matching the jobs growth aspirations of the Sheffield City Region LEP (1,420 jobs per annum) over the period 2016 to 2026. The Council has adopted a figure slightly above this range.

• Lichfields has produced an alternative assessment of housing need as part of a planning appeal in Doncaster. This assumes a lower rate of jobs growth (741 to 1,182 jobs per annum) but arrives at a much higher level of housing need (1,370 dpa).

• We conclude that PBA has made unjustified and unrealistic assumptions for a number of factors which all suppress the level of housing required to support future employment growth. In particular, we disagree with their assumptions about commuting, double jobbing and household formation rates.

• We also disagree with a number of the assumptions made by Lichfields and conclude that they overestimate the housing needed to support the level of growth in their scenarios.

• We conclude that Doncaster would need to deliver between 1,000 and 1,100 dpa between 2015 and 2032 to support future economic growth. This is based on our review of the assumptions made in the two reports and our professional judgement but would need to be tested through a detailed modelling exercise.

• In summary, the housing target of 920 dpa meets the minimum level of housing required as set out in the standard method but would risk constraining the future economic growth of Doncaster. For this reason we strongly recommend that the Council considers making a further upward adjustment.

Evidence base for current housing policy 4.1 The housing target of 920 dpa is based on evidence produced by Peter Brett Associates

(PBA) in its report Economic Forecasts and Housing Needs Assessment (June 2018). This report presents a number of demographic and economy-led scenarios to estimate the housing required in Doncaster over the plan period. This assessment drew heavily on economic modelling and assumptions developed by Experian in their local economic forecasting model. We therefore refer to this assessment as the PBA/Experian report.

4.2 The report recommends housing need is presented as a range between 585 dpa and 912 dpa (the Council has adopted a figure slightly above this range). This is based on the following:

• 585 dpa is the minimum level of housing required in Doncaster based on the standard method. This is based on the 2014 household projections (using the 2016 based projections reduces this to 572).

• 912 dpa is the level of housing that PBA estimate is required to meet the jobs growth aspirations of the Sheffield City Region. This is based on the period 2016 to 2026,


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which is different to the plan period (2015 to 2035) but aligns with the time period used in the standard method.

Alternative assessments of housing need in Doncaster

4.3 We have also reviewed an alternative assessment of housing need in Doncaster. This was based on the Proof of Evidence of Fiona Braithwaite (Lichfields) for a planning appeal in Doncaster on behalf of Faith Homes3. We refer to this as the Lichfields report. This assessment was undertaken in line with the previous methodology for objective assessments of need (ie prior to the introduction of the standard method). However the scope of this assessment was similar to the PBA/Experian report in that it sought to determine the level of housing required to support economic growth in Doncaster.

4.4 The assessment tested a wide range of different demographic and economic scenarios to determine housing need. It concluded that a range of 1,200 dpa to 1,541 dpa “provides the most reliable indicator of future housing need within Doncaster” over the period 2015 to 2032. It therefore arrived at a range where the minimum level of need was some 288 dpa higher than the maximum identified by PBA over the same time period.

What explains the difference between the assessments of need?

4.5 We have critically reviewed both of the reports and their underpinning assumptions to understand the reasons why their estimates of housing need are so different. We use this analysis to reach conclusions on the level of housing required to support future jobs growth in Doncaster. This section looks at each of the key assumptions in turn.

Jobs growth assumptions

4.6 PBA/Experian run two jobs-led scenarios:

• Experian Baseline (Dec 2017): based on average growth of 830 jobs per annum

• Policy led: this assumes average growth of 1,420 jobs per annum and is based on the jobs growth targets in the emerging Strategic Economic Plan (SEP) for the Sheffield City Region (SCR).

4.7 PBA conclude that the policy-led scenario should not be used to calculate the objectively assessed need under the previous planning framework and guidance. This is because “the OAN should be based on a realistic expectation of future jobs rather than aspiration, and the Guidance specifies that the aspirations of Strategic Economic Plans should not be treated as part of the development plan”. It goes on to state that “the policy led scenario is recognised as ambitious and hence the jobs growth and housing demand that it predicts may not materialise” and recommends that the Council adopt a lower number, halfway between the baseline and policy-led scenarios.

4.8 Lichfields run a large number of jobs-led scenarios but the preferred scenarios (those used to identify the OAN) are:

• Experian Baseline (Jan 2017): based on average growth of 741 jobs per annum

3 Land off Westminster Drive, Dunsville, Doncaster. Prrof of Evidence of Fiona Braithwaite Planning Inspectorate No.

Appeal AAP/F4410/W/16/3158500


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• Policy led: this assumes average growth of 1,182 jobs per annum. This is also based on SCR’s jobs growth target, however it is based on an earlier target to PBA/Experian’s policy-led scenario.

4.9 This means that PBA/Experian assume a higher level of jobs growth than Lichfields but arrive at a lower housing need figure. Therefore the jobs growth assumptions do not explain the large difference in the conclusions about the level of housing need.

4.10 While we agree with PBA that the objectively assessed need for housing should not be based on unfounded policy aspirations, we disagree that jobs growth of 1,420 jobs per annum is an unrealistic level of growth. This level of growth is based on employment growing at a rate of 1% p.a. which is in line with the long term average growth rate in Doncaster (see Table 3.1).

4.11 Furthermore, this rate of growth is consistent with the Local Plan target of delivering 481 hectares of employment land over the plan period 2015 to 2035. This target is based on Doncaster achieving a jobs growth rate of 1% p.a. over the plan period and the Local Plan states that this is a realistic and evidence based target: “It is considered therefore that there is sufficient previous evidence of investment, land development and analysis on (sic) the Doncaster Employment Land Review (2018) (Colliers) that enough land should be allocated for a 1% jobs growth”.

4.12 We therefore conclude that a growth rate of 1,420 jobs per annum represents a sound basis for planning housing. This is consistent with past trends and would ensure a greater alignment with the Council’s employment land policies.

Economic activity rates

4.13 The key factor explaining the difference between PBA’s and Lichfields’ assessment of housing need is their assumptions about economic activity rates; the proportion of Doncaster’s population who are either in work (employed) or seeking work (unemployed). The level of housing need is highly sensitive to the assumed change in economic activity rates in a jobs-led scenario because it determines what proportion of future jobs growth could be taken by local Doncaster residents. If the proportion of people who are economically active is flat or falling, then it implies that a larger share of future jobs growth will need to be taken by in-migrants, which increases demand for housing.

4.14 Lichfields and PBA have used different sources for their assumptions on future change in economic activity rates:

• Lichfields align their assumptions with the Office for Budget Responsibility (OBR)’s 2017 projections of economic activity rates for the UK, which they then rebase to take in to account the current conditions in Doncaster. The same assumptions are applied in all of the jobs-led scenarios.

• PBA use the assumptions which are built in to Experian’s model for local economic forecasting. The assumptions made about economic activity are more dynamic in that they respond to changes in the economy (eg if demand for labour grows then economic activity rates increase in response)

4.15 When applied to the same 2014 based sub-national population projections, the two sets of assumptions result in two very different projections of future change in the labour supply. PBA/Experian forecast an increase of 5,000 resident workers, while Lichfields forecast a fall of 1,400. The difference between these two (6,400 workers) helps to explain why they arrive at such different conclusions about the need for housing. In Lichfields’ scenarios the shortfall of local workers means that Doncaster needs to attract in-migrants to support jobs growth.


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Table 4.1 Projected Change in Labour Supply in Doncaster based on 2014 Sub-national Population Projections 2015 to 2032

2015 2032 Change Peter Brett Associates 148,200 153,200 +5,000 Lichfields 148,700 147,300 -1,400 PBA numbers from Table 2.1 in Economic Forecasts and Housing Needs Assessment, July 2018. Lichfields numbers from Land off Westminster Drive, Dunsville, Doncaster, Appendices to the Proof of Evidence of Fiona Braithwaite, Appendix 7: Modelling Outputs, Scenario A1: 2014 Baseline

4.16 The main difference between the two assessments relates to the assumptions made about the economic activity rates of 16 to 64 year olds

• Lichfields use the evidence from OBR to apply assumed change in economic activity rates for five year age groups. The net effect of these changes is a slight increase in the economic activity rate from 74.6% to 75.5%4.

• In contrast, PBA/Experian assume the economic activity rate for 16 to 64 year olds increases at a much faster rate. The scale of the increase is different in each of the scenarios but ranges from a 5.3 percentage point increase in the baseline demographic scenario (based on SNPP 2014) to 5.6 percentage points in the jobs-led scenario.

4.17 The scale of the increase is enough to offset Doncaster’s declining working age population and increase the size of the workforce over the plan period.

4.18 While we would normally support the assumptions used by Lichfields, analysis of recent data on economic activity rates show that PBA/Experian’s assumptions are justified. Although economic activity rates have fluctuated over time, the long term trend shows that economic activity rates have been increasing by around 0.4 percentage points per annum which is consistent with PBA’s assumptions.

Workers with more than one job

4.19 Neither the Lichfields nor the PBA/Experian reports explain their assumptions about the proportion of workers with more than one job. However this can have a significant effect on the level of housing need. If it is assumed that the proportion of workers with more than one job increases over time, it implies a smaller number of workers are required to support jobs growth than if the rate remains constant. This reduces the level of in-migration which in turn supresses the demand for housing.

4.20 Although PBA/Experian do not address the issue of “double jobbing” in their report, they do implicitly assume that the rate will increase from 3.6% to around 6% in each of their scenarios based on the ratio of ‘Workplace Jobs’ to ‘Workplace based Employment’. This has a significant effect on the number of people required to fill jobs; if they assumed that the rate remains constant then Doncaster would need to find an additional 3,300 people in the baseline scenario and an additional 3,400 people in the policy-led scenario. Assuming that these additional people could not be attracted through increased in-commuting (since that would be depriving neighbouring areas of workers), the shortfall would need to be addressed by increased in-migration to Doncaster which would increase demand for housing.

4 This is approximate. The Lichfields assessment states that OBR 2017 rates have been used and rebased to Doncaster

using data from the Census and Annual Population Survey. However they do not present the calculations, the specific assumptions which have been applied for different age groups and genders in Doncaster or how this translates to an overall economic activity rate for 16 to 64 year olds. We have tried to recreate Lichfield’s calculations and arrived at a broadly similar result as them.


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Table 4.2 PBA/Experian assumptions for double-jobbing 2015 Baseline

Scenario 2032 Policy-led

scenario 2032 Workforce Jobs 134,000 147,800 160,600 Workplace based Employment 129,300 139,400 151,600 % of workers with more than one job

3.6% 6.0% 5.9%

4.21 The source of PBA/Experian’s assumption on double jobbing is not clear, nor is it justified. APS data shows that around 3% of people in employment in Doncaster in 2015 had more than one job. However there is no evidence that this is increasing over time. Figure 4.2 shows the change in the double-jobbing rate for Doncaster and Yorkshire and Humber (this is included because the margins of error are much lower at regional level). This shows that the rate has fluctuated over time but has only risen above 3% on a small number of occasions. The data for Yorkshire is more consistent but shows that the double jobbing rate has consistently been between 3% and 4%. At no point has it got close to 6%.

Figure 4.1 Percentage of residents with more than one job

Source APS

4.22 Lichfields do not state their assumptions about double-jobbing. However it appears from their modelling outputs in Appendix 7 that they assume each new job will require one worker; effectively assuming a double jobbing rate of zero. This is also incorrect as the evidence above shows. A more reasonable assumption would be that the double jobbing rate is set at around 3% and then held constant for the duration of the plan period.

Commuting

4.23 The assumptions made about commuting can also have a significant effect on the estimated population and housing required to support future jobs growth. For example, if it is assumed that the net balance of out-commuters and in-commuters declines (sometimes referred to as “reclaiming commuters”), it means a larger number of new jobs can be filled from the local labour market, which reduces the need to attract in-migrants.

4.24 The two assessments for Doncaster make the following assumptions:


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• Lichfields assume that the commuting ratio (the ratio of employed residents to workforce jobs located in Doncaster) remains constant throughout the plan period. They do not state what the ratio is, but based on the data sources used it appears they have assumed a ratio of 0.99. This would mean that Doncaster is a net importer of commuters although only by a very small margin.

• PBA/Experian use the assumptions built in to Experian’s local economic forecasting model. It is not explained how commuting is calculated, however we assume this is essentially a balancing item which goes up and down based on forecast demand and supply in Doncaster and neighbouring areas. Their model shows that Doncaster’s commuting balance is negative, indicating that more people commute out than commute in. This is the reverse of Lichfields’ assumption which is explained by the fact that Experian apply an additional assumption about double jobbing, which means the number of people working in Doncaster is lower than the number of jobs. In both of the scenarios it is assumed that the net outflow of commuters will fall, which means there are more workers available to fill jobs created in Doncaster.

4.25 These different assumptions provide another reason for the large differences between PBA’s and Lichfields’ housing need results. By making the assumption that Doncaster will reclaim commuters, the estimated number of additional people required to meet jobs growth is reduced. We estimate that if the commuting ratio was kept constant, Doncaster would need to find an additional 2,700 employed residents to fill jobs in the baseline scenario and an additional 3,200 employed residents in the policy led scenario.

4.26 PBA explain the change in commuting patterns by stating that “this results from the tightening labour market”. In other words local demand for labour increases relative to local supply. However, commuting patterns are not just dependent on labour market conditions in Doncaster. They also depend on conditions in neighbouring areas. The complex range of factors which could influence commuting patterns (eg demographic change, jobs growth etc in multiple areas) means it is very difficult to predict how they will change in future. By assuming that the net outflow from Doncaster reduces, the model is essentially depriving neighbouring areas of workers by reducing a source of labour supply.

4.27 Guidance issued by the Planning Advisory Service (drafted by PBA itself) warns against making these sorts of assumptions unless they have been agreed with the neighbouring authorities that it affects: ““Another risky approach is to plan for recalling commuters, so the ratio of workplace jobs to resident workers – and hence to population and number of dwellings – is assumed to rise over the plan period. Like increasing activity rates, this assumption means that more jobs can be accommodated for a given number of dwellings, or a given number of jobs needs fewer dwellings. But the expected shift in commuting should be believable, and acceptable to the other local authorities affected by it. Strategies of recalling commuters should not be adopted unilaterally; they require cross-boundary agreement in line with the Duty to Cooperate.”

4.28 PBA could argue that their assumptions about commuting are internally consistent with Experian’s local economic forecasting model and its calculations about the commuting balance between different authorities. However these assumptions have not been agreed with neighbouring authorities. In fact there is evidence that they are inconsistent with some neighbouring authorities’ assumptions about commuting in their own housing need assessments. For example in Barnsley, which shares strong commuting links with Doncaster5, the OAN assumed a reduction in out-commuting down to 2001 levels. PBA

5 The 2011 Census showed that around 3,100 residents of Barnsley commuted to work in Doncaster, making it the third

largest source of external labour for Doncaster (after Rotherham and Bassetlaw)


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was highly critical of this assumption stating “setting aside the practicality of recalling these workers that are likely to be in employment elsewhere in the region, the approach is based on the notion that another Council must increase its housing by an equal number to offset this return of commuters to Barnsley”.

4.29 This means that the housing need models in two neighbouring authorities are both based on the assumption that they will be able to reclaim commuters. If this pattern was repeated across South Yorkshire, it would result in housing policies which cause an undersupply of labour relative to the needs of the economy. For this reason we believe the assumptions are unjustified.

Household Formation Rates

4.30 A further factor explaining the difference in results is in the assumptions made for household formation (the probability that a person of a given age/gender will form a household). Both Lichfields and PBA apply the household formation rates underpinning the 2014 based household projections developed by CLG. However Lichfields apply an additional sensitivity test which assumes that household formation rates for 15 to 34 year olds partially catch up to earlier household formations forecasts produced in 2008. The justification for this is that there is some evidence that household formation among younger age groups have been suppressed by the economic downturn, stricter lending requirements and the poor affordability of housing in some parts of the country. This adjustment increases the average housing requirement by between 60 and 80 dwellings per annum in the two “preferred” scenarios.

4.31 We believe an upward adjustment to household formation rates for younger people in Doncaster is justified. However we disagree with the method used by Lichfields which assumes a partial catch up to household formation rates used in the 2008 projections (now ten years out of date). A more reasonable adjustment would be that they continue on the trajectory forecast in the 2014 household projections between 2015 and 2024 rather than falling again after this date. By the end of the plan period this would mean the household formation rate is around 46.7% rather than 45.2%. We estimate this would increase the number of households by around 40 per annum in PBA’s baseline demographic scenario and 60 per annum in the policy-led scenario.


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Figure 4.2 Household Formation Rates for 25 to 34 year olds

Source CLG 2014 Household Projections

Timescale

4.32 The final reason why we consider PBA’s housing need estimate to be too low to support economic growth is the time period used. Paragraph 4.29 of the report presents two estimates of housing need for the policy-led scenario based on different time periods:

• For the plan period 2015-32: 1,073 dpa

• For 2016-26, the assessment period used in the new standard method: 912 dpa. 4.33 They explain the main reason for the difference is that the gap between labour demand

(jobs growth) and labour supply (due to change in population and economic activity) gets larger over time. So the longer the forecast period the greater is the need to attract new workers to Doncaster.

4.34 PBA use the lower figure because it aligns with the ten year period used in the standard method. However there is no reason why these two should align. Given that the housing target will apply throughout the plan period adopting the lower figure risks labour supply becoming increasingly out of step with labour demand.

Conclusions 4.35 We have identified flaws in a number of assumptions used by PBA/Experian and Lichfields.

In the case of PBA/Experian, these have all suppressed the level of housing required to support future economic growth. We also disagree with a number of the assumptions made by Lichfields and conclude that they overestimate the housing needed to support the level of growth in their scenarios.

4.36 Based on the above, we conclude that Doncaster would need to deliver in the region of 1,100 dpa between 2015 and 2032 to support future economic growth. This lies between the two estimates made by PBA/Experian and Lichfields. This is based on our review of the assumptions made in the two reports and our professional judgement but would need to be tested through a detailed modelling exercise.


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4.37 In summary, the housing target of 920 dpa meets the minimum level of housing required as set out in the standard method but would risk constraining the future economic growth of Doncaster. For this reason we strongly recommend that the Council considers making a further upward adjustment.


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5. Summary of Key Points 5.1 Doncaster Borough Council is consulting on its Draft Local Plan which will shape

development in the borough between 2015 and 2032. Hatch Regeneris has been appointed by Spawforths, on behalf of a consortia of housebuilders, developers and landowners to review the available evidence and provide advice on whether this level of provision will be sufficient to meet the needs of the future population and economy of Doncaster.

Policy and methodological context

• The UK Government is committed to delivering more housing and delivering economic growth. This is made clear in NPPF and in numerous other policy statements.

• Rebalancing the UK economy is another central objective of government policy. Growing the economic prosperity of the North of England is a primary policy goal.

• The revised NPPF and PPG has set out a standard method for determining the minimum level of housing that local planning authorities need to deliver. This removes the requirement to align housing policies with the future economic growth of an area. LPAs can still make an upward adjustment to support growth although this will now be discretionary.

• Criticism of the new approach centres on the risk it will “lock” areas into a cycle of low inward migration and low housing delivery. There are also concerns that the standard method will work against the aim of narrowing the north-south divide by under-providing the housing required to support growth in northern economies.

• Applying the formula for the standard method in Doncaster would result in a housing requirement of 572 dpa.

The economic performance of Doncaster

• Doncaster has been one of the fastest growing economies in Yorkshire and Humber. The district has created around 24,000 jobs between 2000 and 2017, representing a growth rate of 1.1% p.a.

• Doncaster’s key asset is its connectivity by road, rail and air which has made it a highly attractive location for inward investment, particularly for industrial and logistics occupiers, with over 1.1m sq m of industrial/warehouse space taken up since 2010.

• The strong performance is also due to a significant improvement in key economic indicators, including skills and levels of enterprise. The business start-up rate has more than doubled since 2010 and is now in line with the national average. These improvements have removed a key barrier to growth and mean that Doncaster is well placed to continue its high rate of growth.

• The draft Local Plan has set a target of delivering 481 hectares of employment land between 2015 and 2035 and a number of ELRs shows there continues to be very strong market demand for industrial space in Doncaster. There is therefore strong potential for Doncaster to accommodate high levels of inward investment in future which would also drive jobs growth.


20

Our view of need in Doncaster

• The draft Local Plan sets a target of delivering 920 dpa between 2015 and 2032. The target delivers the minimum level of housing need for Doncaster based on the standard method (585 dpa) and makes an upward adjustment to support economic growth.

• The upward adjustment was based on evidence produced by PBA which recommended housing need is presented as a range between 585 dpa (the minimum) and 912 dpa. The upper limit was based on matching the jobs growth aspirations of the Sheffield City Region LEP (1,420 jobs per annum) over the period 2016 to 2026. The Council has adopted a figure slightly above this range.

• Lichfields has produced an alternative assessment of housing need as part of a planning appeal in Doncaster. This assumes a lower rate of jobs growth than PBA (741 to 1,182 jobs per annum) but arrives at a much higher level of housing need (1,370 dpa).

• We conclude that PBA has made unjustified and unrealistic assumptions for a number of factors which all suppress the level of housing required to support future employment growth. In particular, we disagree with their assumptions about commuting, double jobbing and household formation rates.

• We also disagree with a number of the assumptions made by Lichfields and conclude that they overestimate the housing needed to support the level of growth in their scenarios.

• We conclude that Doncaster would need to deliver between around 1,100 dpa between 2015 and 2032 to support future economic growth. This is based on our review of the assumptions made in the two reports and our professional judgement but would need to be tested through a detailed modelling exercise.

• In summary, the housing target of 920 dpa meets the minimum level of housing required as set out in the standard method but would risk constraining the future economic growth of Doncaster. For this reason we strongly recommend that the Council considers making a further upward adjustment.

www.hatchregeneris.com London: Manchester:

The Role and Growth of RossingtonSTRIPE ROAD, ROSSINGTON

Growth in RossingtonStrategic Location Plan

Doncaster

Thorne

M180

M18A1(M)

A19

A638

New Edlington Rossington

Braithwell

Tickhill

Finningley

Doncaster Sheffield Airport

Conisborough

Denaby Main

SprotboroughWalton

Armthorpe

EdenthorpeRive

r Don

Rive

r D

un N

aviga

tion

Bentley

Adwick le Street

Carcroft

Askern

Hatfield

N

IntroductionSpawforths have prepared a review of the Role and Function of Rossington on behalf of Firsure Ltd. Further housing growth is required in Rossington to support its continued growth and regeneration. The land at Stripe Road, Rossington presents a deliverable solution to meet this requirement.

This document has been produced for the site at Stripe Road, Rossington.

The site is being advocated to Doncaster Metropolitan Borough Council (DMBC) for inclusion within the Local Plan as a Housing Allocation. This document reviews the role and function of Rossington as a Sustainable Settlement and makes the case that further housing land should be allocated in this settlement.

The site is located to the south of Rossington in a triangle of land between existing housing areas and adjacent to the East Coast Mainline in an area currently designated as Green Belt. It is circa 18.5 Ha in area. The site is in an area on the southern edge of Rossington

Stripe Road is within 10 mins walk (800m) of the Gattison Lane Local Centres with good access to major bus routes.

The site is a protrusion of Green Belt within an existing residential area of Rossington.

The site is located 1 mile from the Great Yorkshire Way which provides access to the M18 (Junction 3) within approximately 10 minutes drive (3.8 miles).

The site is adjacent to existing housing to the north, east and west with the EastCoast Mainline separating the site from residential development to the east.

The site represents a highly sustainable development opportunity with access to existing facilities and services. It is a logical extension to the urban area of Rossington and supports the continued housing and economic growth of the Borough.

ObjectivesThe key objectives of the scheme are to:

Open up suitable Green Belt land for development

Support an attractive neighbourhood in Doncaster.

Provide new public open space and improve pedestrian and vehicular linkages.

Deliver in the region of 500 new homes to meet the needs of the Borough.

Support an attractive neighbourhood in Doncaster

ScopeThe scope of this document is to analyse the role and function of Rossington within the Borough in the context of significant local investment in infrastructure and strategic employment sites as well as the planned development of Doncaster Sheffield Airport. It will review the growth of Rossington and demonstrate that further land is required to support a growing population.

The document emphasises the opportunity presented by the land at Stripe Road, Rossington as a residential development and to seek its allocation as a housing site within the Local Plan. This is set in the context of the opportunity that the site provides to contribute towards delivering new housing for Doncaster and the economic growth aspirations for the wider Borough.

KEY

Flood Risk Zone

Proposed Development

Other Sites Considered

N500m0 1km

Stripe Road Sustainable

Development

Aerotropolis ‘Grand Plan’ residential

development relies on delivery of a

large scale projectProposed PGA Golf site will provide no

affordable homes

Allocated Parkland

879 - Allocated Employment

Colliery Scheme

Allocated Employment

70 dwellings is not large enough

J3

M18

Great Yorkshire Way

Growth in Rossington

A638

M18 Connection

Great Yorkshire Way

Rail Links

Yorkshire Wildlife ParkStrategic

Employment Site

Doncaster Park and Ride

Wider Context for Growth in Rossington

To achieve the growth that the Sheffield City Region (SCR) is seeking to achieve, and is securing Government funding for, the level of new housing needs to reflect the ambitions of the Strategic Economic Plan.

The Sheffield City Region Integrated Infrastructure Plan states: “A quality housing offer has a crucial role to play in the future economic growth of the City Region…It has been identified that between 70,000 and 100,000 additional homes are needed in SCR to support the proposed economic growth over the next 10 years. The new homes will have the dual benefit of providing accommodation that underpins the proposed increase in employment (70,000 jobs), as well as the wider economic benefits that housing investment brings.” The plan goes on to state that to prevent displacement: “The type and location of construction may be important in mitigating losses of households from the city region that might otherwise occur.”

Within this context it is important that Doncaster Council plans for new jobs and associated new homes in accordance with the Strategic Economic Plan growth aspirations.

The Local Plan should focus more growth and regeneration on the main towns. This growth should be of an appropriate type and scale to meet the economic needs and aspirations of the main towns.

Rossington should be identified as an area for growth, due to regionally

significant levels of inward investment in this location. A housing target for Rossington of between 385 – 950 dwellings over the plan period is clearly not sufficient to cater for the significant economic growth planned.

Spawforths previous representations in response to Draft Policies and Proposed sites consultation (October 2018) included a report by Regeneris who consider that: “Doncaster has been one of the fastest growing economies in Yorkshire and Humber. The district has created around 21,000 jobs between 2000 and 2016, representing a growth rate of 1% p.a.”

The Publication Local Plan has set a target of delivering 481 hectares of employment land between 2015 and 2035 .There is therefore strong potential for Doncaster to accommodate high levels of inward investment in the future which would also drive jobs growth.

The proposed housing requirement in the Publication Local Plan (920 p.a) does not represent an appropriate figure once consideration is given to the potential for economic growth and job formation. Regeneris consider that Doncaster’s housing target over the plan period should be between 1,100 and 1,300 dpa to support future economic growth.

Firsure Ltd welcome the amended plan period for the Publication Plan which is now 2015-2035. The PPG and the Framework (2019) are explicit that a plan needs to be in place for 15 years from adoption. It is however disappointing that the increased housing numbers have been allocated to

the Airport on the condition of the airport providing significant levels of new jobs. An opportunity is being missed to sustainably grow the existing settlement of Rossington, the growth of which would provide much needed improvements to services and provision of affordable and market housing.

The Stripe Road site provides a realistic proposition as a housing site.

Firsure Ltd welcome the inclusion of reserve development sites within the Publication version of the Local Plan. However, as these sites are either within a HS2 safeguarding area or fail against sequential flood risk testing then they do not provide a long term solution for future areas of development.

The Framework (2019) is clear that where necessary Local Plans should identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period’ and that local authorities should ‘be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period’.

Given that the proposed plan runs until 2035 it is considered that the safeguarded land requirement should seek to match this. This will not only provide a robust long-term Green Belt boundary but will also provide certainty for residents and developers alike in terms of likely growth locations beyond the end of the plan period.

Doncaster is an integral part of the Sheffield City Region and its ambitious growth aspirations. The Strategic Economic Plan sets out Sheffield City Region’s plans to transform the local economy over the next decade. At the heart of the plan is the creation of 70,000 new private sector jobs and 6,000 new businesses. It is critical therefore that the emerging Local Plan for Doncaster responds positively to this economic growth by providing sufficient housing allocations.

KEY

Sustainable Transport Travel Time

Schools

Medical Centres

Dentists

Proposed Development

Recreation and Green Space

500m0 1km

10 Min Walking Distance

Pharmacies

Other Sites

Local Centres

Supermarkets


N

I-PortAirport

Development

Amenity Location Map

M18

10 Min Cycle Distance

Great Yorkshire Way


Development

Growth in Rossington

Rossington is currently undergoing an exciting period of change. The colliery, closed in 2007, is now being redeveloped. In 2016 a new road link was completed between the A638 and M18 and then enhanced with a link directly to the nearby Doncaster Airport in 2018. The Airport has ambitious growth plans including a new railway connection to the East Coast Main line, 3 million sqft of logistics and advanced manufacturing space with an expected 73,000 jobs created. Immediately to the west of Rossington, Doncaster i-port a 337ha logistics park which will provide 6 million sqft of warehousing and is expected to provide up to 5,000 new jobs. Plans have been submitted for a European Tour Golf destination which will provide jobs, and raise the profile of Rossington.

The population of Rossington was estimated to be 13,536 in 2011(ONS) and had grown to 17,397 in 2017(ONS). A growth in population of 3,861. Parts of Rossington, in particular the southern and western parts of the town, are some of the most deprived parts of the country. An improved housing offer through new development can provide the homes required by a new workforce who are moving into the area.

Rossington is a sustainable settlement more “akin to a district centre” (DMBC Settlment Profiles, 2018) with good transport links and infrastructure already in place. The only measure which Rossington does not score highly upon in is the lack of a railway station.

However, there are plans for a new railway station at the airport which will be easily accessible from Rossington via sustainable means. The nearby South Doncaster Park and Ride already connects Rossington to the city centre and airport. Furthermore there are good bus connections which travel close to the Stripe Road site on Clay Flat Lane and Bond Street which provide regular services to Tickhill and Harworth. The excellent bus services within the area create opportunity for employment within urban Doncaster accessed by public transport.

Rossington is sustainable: economically, environmentally and socially. The town enjoys unparalleled inward investment in the form of the I-Port, the opening of the Great Yorkshire Way, investment at the airport and the potential PGA Golf course. The town benefits from a wealth of environmental assets including the nearby Yorkshire Wildlife Park, Potteric Carr Nature Reserve SS1, Great Holme Wood, Bawtry Forest and River Idle Washlands SSS1 are all in close proximity to the settlement. Social assets include a vibrant town centre, a swimming pool and community sports complex as well as numerous services as detailed below.

Rossington has three primary schools, one secondary school, two doctors surgeries and one clinic, two pharmacies, two dentists, a designated local centre and a number of neighbourhood shopping parades including 50+ units with a large supermarket as well as small independent shops.

St Joseph’s Catholic Primary School and Tornedale Infant School are within 10 minutes walk of the Stripe Road site and Rossington All Saints Academy provides secondary education within 5 minutes walk.

The Local Plan should be focusing more growth in Rossington. The Parish Council are currently preparing a Neighbourhood Plan which is seeking a greater mix of house types and tenures to suit the elderly as well as first time buyers, they are seeking more affordable homes and improvements to existing services. The aspirations outlined within the Neighbourhood Plan can only be provided through the delivery of more housing locally.

Rossington is demonstrably sustainable, however the level of housing planned as shown in the Publication Local Plan at between 385 – 950 dwellings up to 2035 does not match the expected levels of economic growth and investment in the vicinity.

There is an opportunity to build upon the assets which Rossington already has to rebalance the town by introducing new housing development to cater for the growing population. The site at Stripe Road presents an opportunity to ensure that Rossington has a housing offer which will be attractive to the incoming population, as well as the existing residents, which will continue the regeneration of Rossington to the benefit of the wider populace. This approach is aligned to the economic growth which the Publication version of the Local Plan is seeking to achieve.

Rossington is uniquely placed to take advantage of regenerative growth and become a truly sustainable modern settlement and focus for growth in the Borough. The plan, as drafted, focuses the vast majority of housing growth in Rossington at the Colliery site, this does not provide a robust platform for growth.

Harron Homes - 70 Homes Delivered

Residential Cell C. Reserved Matters - No Applications In.

Taylor Wimpey -Permission Granted for 190 Homes

Barrat Homes - Permission Granted for 184 Homes

Taylor Wimpey - 94 Homes, 21 Delivered

Housing Allocation with access from Residential Cell C.

KEY

Taylor Wimpey 94 Homes 21 Delivered

Barrat Homes Permission for 184 Homes

Allocated Housing with reserved matters

Allocated Housing

Harron Homes 70 Homes Delivered

Taylor Wimpey Permission for 190 Homes

N0 250m

Colliery SchemeDelivery Rates

125m

Housing Delivery in Rossington

That taken together with the draft allocation at the Former Torndale School field and other smaller permissions will only result in the delivery of approximately 700 units over the plan period (up to 2035) much less than the anticipated 1047 units from existing permissions and new allocations.

Unfortunately reliance upon one large residential development site will result in under delivery of housing.

The colliery site received outline planning permission for 1,200 houses and mixed uses in October 2013. Subsequently four reserved matters applications have been approved: Harron Homes in April 2015,

70 dwellings; Taylor Wimpey in April 2015, 94 dwellings; Barratt Homes in November 2018, 184 dwellings; and Taylor Wimpey in December 2018, 190 dwellings. According to the DMBC Residential Land Availability Report 2017/2018 (December 2018) and information gained directly from the developers actual delivery to date has only been 99 units.

The delivery rate in 17/18 (April to March) was 48 units. Due to the long lead in times, delivery rates since the grant of the first reserved matters application has only been c.33 dpa. Assuming similar delivery rates moving forward it is alarming to note that the colliery site will only deliver in the region of 600 units up to 2035. Annual average delivery rates shown (40 dpa) above

are above the delivery currently achieved. (33 dpa).

Therefore Firsure consider that to match the economic growth in Rossington the an appropriate housing target would be approximately 1,200 dwellings. There is therefore a shortfall of approximately 500 dwellings for Rossington.

A new housing allocation for approximately 500 units on the Stripe Road site can help to plug this gap by providing a housing site which can begin delivering in the short term. Lead in times and delivery rates will be much quicker due to the relatively straightforward nature of the site as demonstrated in our previously submitted representations.

Planned housing growth in Rossington does not match up with the economic growth planned in the area. The Rossington Colliery allocation will only deliver in the region of 600 dwellings over the plan period.

Parcel No. Dwellings Decision Date Net Completions 17/18 Total completions Total remaining

Taylor Wimpey Phase 1 94 Apr-15 21 21 73

Harron Homes Phase 70 Apr-15 27 70 0

Taylor Wimpey Phase 2 190 Dec-18 0 190 190

Barratt Homes Phase 184 Nov-18 0 184 184

Future Phase 1 ? ? ? ? ?

Future Phase 2 ? ? ? ? ?

Year 19/20 20/21 21/22 22/23 23/24 24/25 25/26 26/27 27/28 28/29 29/30 30/31 31/32 32/33 33/34 34/35 Total Delivery

Taylor Wimpey Phase 1

21 21 21 10 0 0 0 0 0 0 0 0 0 0 0 0 73

Harron Homes Phase

0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Taylor wimpey Phase 2

0 0 0 14 24 24 24 24 24 24 24 8 0 0 0 0 190

Barratt Homes Phase

22 24 24 24 24 24 24 18 0 0 0 0 0 0 0 0 184

Future Phase 1 0 0 0 0 0 0 0 0 0 0 0 15 24 24 24 24 111

Future Phase 2 0 0 0 0 0 0 0 0 0 0 0 0 15 24 24 24 87

Annual Delivery

43 45 45 48 48 48 48 42 24 24 24 23 39 48 48 48 645

PHASE 1

PHASE 2

N0

Urban Extension Phasing

125m 250m

The land at Stripe Road, Rossington provides a residential development opportunity in a sustainable location close to shops, services and community facilities to meet the needs of the District and support the continued regeneration of Rossington. The site is currently located within the Green Belt and is available, suitable and achievable in accordance with the Framework.

Stripe Road

AvailabilityThe land is being promoted by Firsure Ltd as landowner. The site is therefore available in accordance with the Framework and the National Planning Practice Guidance (PPG).

SuitabilityThe proposed site utilises a small part of the existing Green Belt which is surrounded by development. To the east of the East Coast Mainline railway line is countryside, not designated as Green Belt and where proposals for an international golf course are planned. The development of the site will be an efficient use of land to provide quality development and new market and affordable homes for Rossington.

The site is located in a highly sustainable location and has residential development to the north, east and west. The site is within easy walking distance to local centres with a range of facilities provided there as well as greater facilities within Doncaster Town Centre, a bus ride away. There are a large number of primary and a secondary schools in the vicinity of the site.

The site is well served by transport providing opportunities for sustainable travel to work in Doncaster and beyond with access to Doncaster Railway Station and a potential new railway at the airport. The development will provide additional

quality development that will benefit Rossington and the wider district with economic, environmental and social benefits. It is therefore considered that the development is suitable.

AchievableA range of technical work has been undertaken and briefly summarised below. The assessments indicate that there are no technical issues that would prevent development or are insurmountable. The site is therefore considered to be achievable.

The indicative masterplan shows how a mix of housing can be accommodated within the site, alongside connectivity, landscaping and drainage features.

The highway work has included initial modelling to confirm the suitability of the site access and highway network to accommodate the proposed development.

The drainage work has identified a drainage strategy for the site. It has confirmed the attenuation required on site and demonstrated the suitability of the site for development.

Ecological survey work has confirmed there are no ecological constraints to the development of the site and recommended

how habitats can be enhanced and created.Ground investigation has confirmed the suitability of the site to accommodate future development.

Economics The relationship between economic performance in an area and housing is complex, but having the right quantity, quality and balance of housing in an area is necessary for economic growth.

The development of the Stripe Road scheme can therefore support local economic growth, both through direct job creation through the construction phase of the scheme, but also through the increased population which will create sustainable local jobs from the increased demand for goods and services. This provides an important sustainable development opportunity in Rossington.

SummaryThe site at Stripe Road provides a development opportunity that is available, suitable and achievable and therefore it is considered that the site is deliverable, in accordance with national planning policy and guidance.

M18

Great Yorkshire Way


Development


Proposed PGA Golf site

Colliery Scheme

I-Port

Airport Development

879 - Allocated Employment

Conclusion

A638


10 Min Cycle Distance

KEY

M18 Connection

Great Yorkshire Way

Rail Links

Employment Site

Proposed and Existing Schemes

Existing Settlement

Site

500m0 1kmN

Doncaster Park and Ride

Conclusion

The Publication version of the Local Plan quite rightly places a strategic focus of growth in South Doncaster. However, this is primarily focused on the Aerotropolis development at the airport. It would make more sense to further develop the nearby sustainable settlement of Rossington by focussing more growth here.

The role and function of Rossington has fundamentally changed due to the investment in the locality.

The current housing growth in Rossington is focused at the former colliery site which is slowly delivering units (c.30 dpa). Whilst this is welcome, it does not make the most of the opportunities presented for regeneration and rebalancing in Rossington.

Firsure contend that the housing target for Rossington should be in the region of 1,200 dwellings over the plan period. The current allocations and permissions in Rossington will only deliver approximately 700 dwellings over the plan period and thus there is a short fall of 500 units.

A further housing allocation is required to build upon the assets which Rossington already has by improving the housing offer to the existing and incoming population attracted to the area by significant economic investments nearby.

Rossington has the opportunity to transform into a prosperous sustainable settlement, however to this the housing offer must be improved.

The site at Stripe Road presents an opportunity to develop approximately 500 dwellings. The site is located to the south of Rossington in a triangle of land between existing housing areas and adjacent to the East Coast Mainline in an area currently designated as Green Belt.

Stripe Road is within 10 mins walk (800m) of the Gattison Lane Local Centres with good access to major bus routes.

The site is a protrusion of Green Belt within an existing residential area of Rossington.

The site is adjacent to existing housing to the north, east and west with the East Coast Mainline separating the site from residential development to the east.

It has been demonstrated that the site is available, suitable and achievable and therefore deliverable in accordance with the NPPF.

The site represents a highly sustainable development opportunity with access to existing facilities and services. It is a logical extension to the urban area of Rossington and supports the continued housing and economic growth of the Borough.

Rossington needs to continue to grow to support and take advantage of the investment and economic growth in the settlement. Unparalleled levels of investment have taken place in Rossington and the population has grown, however planned housing growth needs to match this.

Key Benefits

Optimum location to assist in the continued growth and regeneration of Rossington

Gross Value Added of around £75 millionGVA

Circa £12 million Annual Household Expenditure

The delivery of circa 500 new homes in a range of house types, sizes and tenure

Circa 1,750 new jobs (direct and in-direct) from the construction of the residential scheme alone

At least £2.5 million of first occupation expenditure

from: spawforths on behalf of fisure homes sent: 30 september …€¦ · 2.5. this document...

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