Doncaster

Local Plan

Publication Draft 2019

Ref: (For Official Use Only)

COMMENTS (REPRESENTATION) FORM

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

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

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

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

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

Title Mr

First Name Jeremy

Last Name Williams

Organisation (where relevant)

Tanks & Vessels Industries Ltd ID Planning

Address – line 1 c/o Agent 7th Floor, The Balance

Address – line 2 2 Pinfold Street

Address – line 3 Sheffield

Postcode S1 2GU

E-mail Address

Telephone Number

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

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

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

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

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

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

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

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

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

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

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

or

Name / Organisation Name:

Tanks & Vessels Industries Ltd

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

Doncaster Local Plan Publication Draft ☒ Policies Map ☐

Sustainability Appraisal ☐ Habitats Regulations Assessment ☐

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

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

Page No.: Paragraph:

Policy Ref.: 4 Site Ref.: 1032

Policies Map:

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

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

Positively prepared ☒ Justified ☒

Effective ☒ Consistent with National Policy ☒

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

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

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

Our full response is provided by supporting letter dated 26th September 2019 (L017) and associated Plan 1. The response should therefore be read in the wider context of that letter.

Policy 4 – Employment Allocations (Strategic Policy)

Policy 4 ‘Employment Allocations (Strategic Policy)’ allocates land for employment uses in accordance with those sites identified by Table 4 of the Publication Draft Plan and the accompanying Proposals Map. On those sites allocated for employment uses, emerging Policy 4 sets out that:

a) Only business (B1 b/c), general industry (B2) and storage and distribution (B8) uses will be permitted on

these sites unless the proposal is ancillary to the employment use.

b) The employment sites will be developed in accordance with the development requirements set out in Appendix 2 and other relevant Local Plan policies.

c) For employment or other developments that propose 20+ direct jobs, the Council will seek to enter into a local labour agreement with the developer/ applicant to provide an agreed percentage target for local labour, a training and recruitment plan and a commitment to an agreed target for the proportion of local

procurement of services and supplies.

Whilst TVI support identification of their land for employment uses (Site Ref: 1032) it is considered that in order for

emerging Policy 4 to be considered fully effective, justified, in line with national policy and therefore “sound”, a degree

of flexibility should be afforded in the policy for consideration of other uses that are not ancillary. This would allow the plan to adapt to any changes in the market.

The National Planning Policy Framework (2019) makes clear at paragraph 11 a) that “plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change”.

Again, at paragraph 81, planning policies should “be flexible enough to accommodate needs not anticipated in the plan,

allow for new and flexible working practices [..] and to enable a rapid response to changes in economic circumstances”. Flexibility should be built into the wording of Policy 4 to enable other uses to be considered should circumstances change

and to allow the plan to be able to provide a rapid response to changes in economic circumstances or other rapid change in an area not envisaged in the plan.

Policy 4 (A)

On this basis, the inclusion of a criteria-based approach in Policy 4, such as that proposed for Employment Policy Areas under emerging Policy 5, would be supported. It is noted that in ‘employment policy areas’ other uses are ‘supported’ provided a number of criteria are met.

Policy 4 (A) allocates the employment sites ‘only’ for B1(b/c), B2 and B8. Other uses are allowed but ‘only’ where they are ancillary.

In order to accord with national policy and provide some flexibility in approach, we consider Policy 4 (A) could be re-worded as follows with proposed new policy wording underlined. “A) Only business (B1 b/c), general industry (B2) and storage and distribution (B8) uses will be permitted on these sites unless the proposal is ancillary to the employment uses or where an alternative use would accord with the Policy 5

criteria and other relevant policies in the Plan.”

This would ensure the emphasis is on such sites being brought forward for B1(b/c), B2/B8 uses but allows consideration of other non ancillary uses in particular circumstances in line with national planning policy. Policy 4 (C)

Policy 4 (C) seeks to enter into local labour agreements to agree target percentages for use of local labour, establish a training and recruitment plan and provide a commitment for an agreed target for local procurement of services and supplies.

Whilst our client supports use of local businesses and suppliers in new developments, such a policy requirement could

prevent a full and proper competitive tendering process for new developments and limit the use of certain contractors resulting in them not being able to tender for projects related to the site. This could have adverse consequences on the

ability of our client to deliver economic investment on the site in the most cost effective manner. This relates to both the construction and operation phase of any development brought forward. Consequently, we consider such a policy should not be included within the development plan and whilst discussions can

take place on individual sites, inclusion of the Policy 4(C ) criteria could hamper delivery of some projects in a very competitive market and the uncertain economic climate.

On this basis we request that Criteria (C) in Policy 4 be deleted from the policy wording.

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

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

Policy 4 (A) On this basis of comments made under Question 6, we consider inclusion of a criteria-based approach in Policy 4, such as that proposed for Employment Policy Areas under emerging Policy 5, is required to make Policy 4 and the Plan “sound”. As noted above, in ‘employment policy areas’ other uses are ‘supported’ provided a number of criteria are met. Policy 4 (A) allocates the employment sites ‘only’ for B1(b/c), B2 and B8. Other uses are allowed but ‘only’ where they are ancillary. In order to accord with national policy and provide some flexibility in approach, we consider Policy 4 (A) could be re-worded as follows with proposed new policy wording underlined. “A) Only business (B1 b/c), general industry (B2) and storage and distribution (B8) uses will be permitted on these sites unless the proposal is ancillary to the employment uses or where an alternative use would accord with the Policy 5 criteria and other relevant policies in the Plan.” This would ensure the emphasis is on such sites being brought forward for B1(b/c), B2/B8 uses but allows consideration of other non ancillary uses in particular circumstances in line with national planning policy. Policy 4 (C) Policy 4 (C) seeks to enter into local labour agreements to agree target percentages for use of local labour, establish a training and recruitment plan and provide a commitment for an agreed target for local procurement of services and supplies. For reasons set out in our response to Question 6, we consider Policy 4(C) should not be included within the development plan and whilst discussions can take place on individual sites, inclusion of the Policy 4(C) criteria could hamper delivery of some projects in a very competitive market and the uncertain economic climate. On this basis we request that Criteria (C) in Policy 4 be deleted from the policy wording.

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

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

☐ Yes, I wish to appear at the Examination.

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

N/A

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

Your Signature

Date

26/09/2019

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

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

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

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

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

or defamatory.

a: 9 York Place, Leeds LS1 2DS t: f:

a: 7th Floor, The Balance, 2 Pinfold Street, Sheffield, South Yorkshire, S1 2GU t: w: www.idplanning.co.uk

Registered in ENGLAND No: 05271142

Our Ref: JWID2853/L017 26th September 2019 Local Plans Team, Planning Regeneration and Environment Services Doncaster Council, Civic Office, Waterdale, Doncaster, DN1 3BU

By email Dear Sir/Madam, DONCASTER PUBLICATION DRAFT POLICIES & PROPOSED SITES CONSULTATION (2019) REPRESENTATIONS ON BEHALF OF TANKS & VESSELS INDUSTRIES LTD IN RELATION TO LAND AT BANKWOOD LANE INDUSTRIAL ESTATE, ROSSINGTON As you will be aware, we act on behalf of Tanks & Vessels Industries (TVI) who currently own significant areas of land on the eastern / northern side of the Bankwood Lane Industrial Estate in Rossington and are considering future redevelopment proposals for their land. A plan showing the location of the site is attached (see Plan 1). INTRODUCTION ID Planning are instructed by TVI to make representations to the Doncaster Publication Draft Policies & Proposed Sites Consultation (August 2019) in relation to their land interests at Bankwood Lane Industrial Estate, Rossington. Land at Bankwood Lane Industrial Estate is largely occupied for employment and industrial uses. Our client controls an extensive area of land in the northern part of the industrial estate. With rationalisation of the business in recent years a substantial part of the main TVI site in the eastern part of the industrial estate is becoming surplus to requirements and the potential exists for further employment and/or residential development on this land. The adopted Doncaster Unitary Development Plan (1998) allocated part of the Bankwood Lane Industrial Estate as an ‘Employment Site’ with the wider industrial estate identified as an ‘Employment Policy Area’.

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The following representations relate to the continued use of our client’s land at the industrial estate for employment purposes. A review of the Publication Draft Policies & Proposed Sites Consultation documents has been undertaken, following which we wish to make comments in respect of:

• Policies 2, 4 and 5 of the Doncaster Publication Draft Policies & Proposed Sites Draft Policies (August 2019); and

• Submission Policies Map. SITE DESCRIPTION The following representation relates to land in our client’s ownership, the extent of which is shown on the attached plan (Plan 1). Two areas are shown including Area A to the east of Bankwood Lane and Area B at the northern end of Bankwood Lane. The site forms part of the wider Bankwood Lane Industrial Estate. Bankwood Lane forms the western edge of Area A whilst Area B is located at the northern end of Bankwood Lane. Allotment land is to the north west of Area A, while the Rossington Drain forms the northern boundary of both areas. The Great Yorkshire Way, which opened in 2016, runs approximately 590m north of the site area and the industrial estate, providing access to the M18 and providing a gateway to the wider Sheffield City Region. Land to the north of the site is within the Green Belt. The site is bound to the east by woodland and to the south by further allotments and existing residential development. The site is currently in use by TVI for existing operations including employment and distribution uses. Part of the employment area is intended for future redevelopment with the potential for further provision of jobs, economic investment and housing in this location. An outline permission (12/01107/OUTA) was granted in October 2013 for 1,200 residential dwellings and associated development on colliery land to the west of Bankwood Lane Industrial Estate. It is estimated that approximately 300 dwellings associated with the development have been delivered at present. In the vicinity of the TVI land there have been two planning applications submitted that relate to proposals for a Link Road which would connect the West End Lane Roundabout to the west with Bankwood Lane and the wider industrial estate Full application 18/00548/FULM was submitted on behalf of Attero Developments and relates to Phase 1 of the Link Road along with proposals seeking to expand their existing on-site waste recycling operations at the industrial estate. The application was approved in November 2018. The second application (18/02114/FULM) was submitted by ID Planning on behalf of TVI and relates to the full extent of the Link Road from the West End Lane Roundabout up to the western edge of Attero’s land and the wider industrial estate. The application is pending consideration and if approved, will result in improved vehicular access to Bankwood Lane Industrial Estate from the Great Yorkshire Way and the strategic road network beyond, whilst also resulting in residential amenity benefits as it would provide

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an alternate route for HGV traffic which currently passes through residential development to the south and west of the industrial estate and along the southern end of Bankwood Lane. The proposal would therefore support the continued use of Bankwood Lane Industrial Estate for employment purposes while also protecting existing and future residential amenity. EMERGING DONCASTER PUBLICATION DRAFT POLICIES & PROPOSED SITES (AUGUST 2019) Doncaster Publication Draft Policies & Proposed Sites Draft Policies Policy 2 - Spatial Strategy and Settlement Hierarchy (Strategic Policy) Policy 2 indicates that decisions on the location and scale of development should be informed by Doncaster’s Settlement Hierarchy and in accordance with Policy 3. Policy 2 states that Main Towns such as Rossington should be maintained and enhanced and should be the focus for substantial housing growth supported by appropriate levels of employment and retail growth. TVI support the identification of Rossington as a Main Town and as an appropriate location for housing and employment growth. We therefore find emerging Policy 2 to be sound. Policy 4 – Employment Allocations (Strategic Policy) Policy 4 ‘Employment Allocations (Strategic Policy)’ allocates land for employment uses in accordance with those sites identified by Table 4 of the Publication Draft Plan and the accompanying Proposals Map. On those sites allocated for employment uses, emerging Policy 4 sets out that:

a) Only business (B1 b/c), general industry (B2) and storage and distribution (B8) uses will be permitted on these sites unless the proposal is ancillary to the employment use.

b) The employment sites will be developed in accordance with the development requirements set out in Appendix 2 and other relevant Local Plan policies.

c) For employment or other developments that propose 20+ direct jobs, the Council will seek to enter into a local labour agreement with the developer/ applicant to provide an agreed percentage target for local labour, a training and recruitment plan and a commitment to an agreed target for the proportion of local procurement of services and supplies.

Under Table 4, sites to be allocated for employment uses include:

• Site Ref. 1032 – Bankwood Lane, Rossington Table 4 confirms that the allocated site at Bankwood Lane comprises a gross site area of 17.84ha which is identified as available for employment uses and is to be developed in the plan period. The Policies Map further confirms the allocation of land at Bankwood Lane, Rossington as an ‘Employment Allocation’ identified below as Site Ref. 1032.

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TVI support the identification of land within their ownership at Bankwood Lane, Rossington as an employment site for B1(b/c), B2 and B8 uses under emerging Policy 4 of the Local Plan Publication Draft. The allocation of Site Ref. 1032 will contribute towards the employment development needs of TVI and the Doncaster Borough, with Rossington identified under emerging Policy 2 as a Main Town where appropriate levels of employment growth are to be located. The site is considered to be suitable for employment uses given its location within the existing Bankwood Lane Industrial Estate and that it benefits from excellent connectivity with the strategic road network (SRN) including the recently completed Great Yorkshire Way to the north. Further connectivity between the site and the SRN would be supported by the Link Road proposed under applications 18/00548/FULM & 18/02114/FULM which would connect the industrial estate to the West End Lane Roundabout to the west and the SRN beyond, boosting the productivity and efficiency of the industrial estate However, in line with representations submitted to the Local Plan Draft Policies consultation in October 2018, while TVI support the identification of their land for employment uses (Site Ref: 1032) it is considered that in order for emerging Policy 4 to be considered fully effective, in line with national policy and therefore ‘sound’, a degree of flexibility should be afforded in the policy for consideration of other uses that are not ancillary. This would allow the plan to adapt to any changes in the market.

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The National Planning Policy Framework (2019) makes clear at paragraph 11 a) that “plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change”. Again, at paragraph 81, planning policies should “be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices [..] and to enable a rapid response to changes in economic circumstances”. Flexibility should be built into the wording of Policy 4 to enable other uses to be considered should circumstances change and to allow the plan to be able to provide a rapid response to changes in economic circumstances or other rapid change in an area not envisaged in the plan. On this basis, the inclusion of a criteria-based approach in Policy 4, such as that proposed for Employment Policy Areas under emerging Policy 5, would be supported. It is noted that in ‘employment policy areas’ other uses are ‘supported’ provided a number of criteria are met. Policy 4 (A) allocates the employment sites ‘only’ only for B1(b/c), B2 and B8. Other uses are allowed but ‘only’ where they are ancillary. In order to accord with national policy and provide some flexibility in approach, we consider Policy 4 (A) could be re-worded as follows with proposed new policy wording underlined. “A) Only business (B1 b/c), general industry (B2) and storage and distribution (B8) uses will be permitted on these sites unless the proposal is ancillary to the employment uses or where an alternative use would accord with the Policy 5 criteria and other relevant policies in the Plan.” This would ensure the emphasis is on such sites being brought forward for B1(b/c), B2/B8 uses but does allow consideration of other non ancillary uses in particular circumstances in line with national planning policy. Policy 4 (C) seeks to enter into local labour agreements to agree target percentages for use of local labour, establish a training and recruitment plan and provide a commitment for an agreed target for local procurement of services and supplies. Whilst our client supports use of local businesses and suppliers in new developments, such a policy requirement could prevent a full and proper competitive tendering process for new developments and limit the use of certain contractors resulting in them not being able to tender for projects related to the site. This could have adverse consequences on the ability of our client to deliver economic investment on the site in the most cost effective manner. This relates to both the construction and operation phase of any development brought forward. Consequently, we consider such a policy should not be included within the development plan and whilst discussions can take place on individual sites, inclusion of the Policy 4(C ) criteria could hamper delivery of some projects in a very competitive market and the uncertain economic climate. On this basis we request that Criteria (C) in Policy 4 be deleted from the policy wording. Policy 5 – Employment Policy Areas (Strategic Policy) Emerging Policy 5 ‘Employment Policy Areas (Strategic Policy)’ indicates that Employment Policy Areas, as defined on the Proposals Map, will continued to be supported primarily for

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employment uses. However, other uses will be supported provided that they meet a number of criteria set out by Policy 5. TVI support the criteria-based approach contained within Policy 5 which allows for some flexibility in uses on sites identified as ‘Employment Policy Areas’ in addition to employment. Area B of the land identified in Plan 1 is identified as an Employment Policy Area. TVI consider the identification of their land identified as ‘Area B’ as an Employment Policy Area to be sound, with Policy 5 allowing for suitable flexibility in the type of uses which could be accommodated on the site. CONCLUSION The identification of land at Bankwood Lane shown as ‘Area A’ on Plan 1 for employment uses in the emerging Policy 4 of the Local Publication Draft is supported and the site is considered to comprise a sustainable employment location within an existing employment area which benefits from excellent connectivity with the wider road network. However, in order for Policy 4 to be considered sound, it is TVIs view that an element of flexibility should be afforded in Policy 4 to account for alternate uses and allow the policy to adapt to rapid change or needs not anticipated in the plan, as required by the NPPF (2019). Therefore, the Policy 4 allocation is supported subject to the proposed policy wording changes set out in our representations. This would ensure that Policy 4 is both effective and consistent with national policy and would therefore be ‘sound’. TVI consider the identification of their land identified as ‘Area B’ on the Proposals Map as an Employment Policy Area to be sound, with Policy 5 allowing for suitable flexibility in the type of uses which could be accommodated on the site. This is considered to be in line with the general thrust of the Publication Draft Policies & Site Allocations Plan and emerging Policy 2 which seeks to focus substantial housing and employment growth in Main Towns such as Rossington. We trust the above representations will be taken on board. In the meantime, should you require any further information at this stage, please do not hesitate to contact me. Yours sincerely

Jeremy Williams BA (Hons) MA MRTPI Director Enc - As detailed above