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 Mrs

First Name Richard Raj

Last Name Mills Bains

Organisation (where relevant)

North Lincs Property Crestwood Environmental Ltd.

Address – line 1 Sandtoft Road 1 & 2 Nightingale Place

Address – line 2 Belton Pendeford Business Park

Address – line 3 Doncaster Wolverhampton

Postcode DN9 1PN WV9 5HF

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:

Raj Bains - Crestwood Environmental 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.: 170 Paragraph:

Policy Ref.: Policy 62, 63 and 64 Site Ref.: 1011

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.

In 2017, Land at Grange Farm, Finningley, Doncaster was submitted as a proposed mineral site for consideration to the

emerging local plan (see Doc 1 – Assessing Mineral Sites Representations). The emerging Doncaster Local Plan 2015-2035 supports the inclusion of Land at Grange Farm, as a proposed new mineral allocation Site - Reference 1011 (please refer to Table 12: New Mineral Allocation page 170 ). The Site offers approximately 1.55 million tonnes of sharp sand and gravel mineral reserve. With the inclusion of this site we consider that the Doncaster Local Plan has been positively prepared and is legally compliant with national policy.

Crestwood Environmental Ltd. has been appointed by North Lincs Property Holdings (our client) who wish to bring this site forward with the inclusion of land at Ninescores Farm, Finningley, Doncaster, DN93DY (land adjacent site to Grange Farm) as a composite planning application for the phased extraction of the sand and gravel mineral resource. Please see

attached Site Location Plan (DWG1) showing the proposed Site boundary. Ninescores Farm, which benefits from an Interim Development Order (IDO) offers approximately 400,000 to 600,000 tonnes of sand and gravel reserve. The composite application proposal, will enable mineral reserves to be blended on Site, ensuring that the locally and regionally scarce mineral reserves found at the Site (i.e. the sharp sand / concreting aggregates) can be maximised

further supporting the sustainability of the Site and reserve, whilst also regularising the situation in relation to a

registered IDO planning permission. A full planning application will be submitted and supported with an Environmental Statement in accordance with

Schedule 4 of the Environmental Impact Assessment (EIA) Regulations 2017. The total area of the proposed Site measures approximately 64ha of land of which Grange Farm totals 40ha. The existing land use of Ninescores and Grange Farm is agricultural land. The proposals would form a new proposed sand and gravel quarry operation on the eastern boundary of Doncaster and support the continuous provision of mineral reserve in Doncaster following the cessation of mineral extraction (exhaustion of reserves) at the nearby site at Bank End Farm Quarry (also owned by our client).. The current proposals being prepared will allow for a total estimated mineral reserve of circa 2.1 million tonnes of sand and gravel within Doncaster of which around 1.55 million tonnes relates to the Grange Farm site allocation. The proposals will allow for the continuous provision of a scarce commodity (i.e. sharp sand / concreting aggregate reserves found at Grange Farm) serving the existing market within and surroundings of Doncaster.

The need for sand and gravel is highlighted within the Core Strategy 2011-2028 and emerging Doncaster Local Plan 2015-2035. The most recent Local Aggregate Assessment (2018) for Doncaster and Rotherham paragraph 60 reads: “Based on ten year average sales of 0.31Mt the land bank for sand and gravel stands at 18.1 years for 2017, although this is down from the year before due to revised monitoring it is well above the NPPF advised 7 year landbank. Historic returns have confirmed that only a small proportion of the remaining permitted reserve in Doncaster is however suitable for use as concreting aggregate. We have received very few sand and gravel submissions for the Local Plan; these have been assessed and will be subject to informal consultation of draft policies and proposed sites in 2018. It is also essential that we also identify the best remaining resource options in Doncaster as ‘Areas of Search’ within the Local Plan. These ‘Areas of Search’ ‘allocations’ will also be identified in the Doncaster Local Plan for consideration and take up by industry. Please note, sand and gravel is also imported into ‘South Yorkshire’ from other areas such as Nottinghamshire,

the need for sand and gravel is increasingly becoming difficult to obtain in Doncaster where supply is sought and imported from neighbouring Mineral Planning Authorities”.

Grange Farm is one of two proposed mineral site allocations within the emerging Local Plan and is considered as Doncaster’s best options for contributing towards the landbank of permissions during the plan period. Given the proposals for new housing, employment and infrastructure in Doncaster over the Local Plan period and the lack of planned mineral sites, the proposals would contribute an important amount of sand and gravel mineral reserve in support of wider economic growth within and surrounding Doncaster.

Further to this, the existing landbank is predominantly made up of non-concreting aggregates and this is locally recognised via the Doncaster Core Strategy and LAA, where concreting aggregate supply is a scarce commodity. This further supports the allocation of Grange Farm (as also supported by the wider IDO is relation to Ninescores Farm) for mineral extraction as the reserve is proposed to be allocated to cater for concreting aggregates and replacing locally scarce resources that are or will shortly become exhausted.

The proposals offer multiple economic and environmental benefits including preserving approximately 75 local jobs (existing in relation to other nearby operations) and continuity of supply of an important local sand and gravel mineral resource during the early years of the proposed plan period, with direct accessibility via the existing strategic transport network. The restoration of the Site would be to a mixture of agriculture and nature conservation, including provision of

ponds/wetlands. The proposed restoration would be ‘low level’.

In light of the emerging local Plan Publication and consultation period, recent consultations have been undertaken with

officers at Doncaster Council. A composite planning application for both Grange Farm and Ninescores Farm will be progressed on the grounds that such proposals support the overall need for concreting aggregate resources, against current local planning policy and the LAA priorities for mineral provision.

In relation to national planning policy the proposals are considered to support and comply with the following paragraphs of the National Planning Policy Framework:

Paragraph 203 - “It is essential that there is a sufficient supply of minerals to provide the infrastructure, buildings, energy and goods that the country needs. Since minerals are a finite natural resource, and can only be worked where

they are found, best use needs to be made of them to secure their long-term conservation”.

Paragraph 205 – “ When determining planning applications, great weight should be given to the benefits of mineral extraction, including to the economy65. In considering proposals for mineral extraction, minerals planning authorities

should: a) as far as is practical, provide for the maintenance of landbanks of non-energy minerals from outside National Parks, the Broads, Areas of Outstanding Natural Beauty and World Heritage Sites, scheduled monuments and conservation areas; b) ensure that there are no unacceptable adverse impacts on the natural and historic environment, human health or aviation safety, and take into account the cumulative effect of multiple impacts from individual sites and/or from a number of sites in a locality; c) ensure that any unavoidable noise, dust and particle emissions and any blasting vibrations are controlled, mitigated or removed at source66, and establish appropriate noise limits for extraction in proximity to noise sensitive properties; d) not grant planning permission for peat extraction from new or extended sites; e) provide for restoration and aftercare at the earliest opportunity, to be carried out to high environmental standards, through the application of appropriate conditions. Bonds or other financial guarantees to underpin planning conditions should only be sought in exceptional circumstances; f) consider how to meet any demand for small-scale extraction of building stone at, or close to, relic quarries needed for the repair of heritage assets, taking account of the need to protect designated sites; and g) recognise the small-scale nature and impact of building and roofing stone quarries, and the need for a flexible approach to the duration of planning permissions reflecting the intermittent or low rate of working at many sites”.

The proposals are considered compliant with the existing Doncaster Core Strategy 2011-2028 - Policy CS20: Minerals and the following proposed policies set out in the emerging new Local Plan 2015-2035:

• Policy 62: Providing for and Safeguarding Mineral Resources (Strategic Policy),

• Policy 63: Mineral Development Proposals, Borrow Pits and Incidental Extraction and • Policy 64: Reclamation od Mineral Sites (Restoration and Aftercare).

The Proposed Development fulfils a number of strategic objectives including sustaining sand and gravel mineral production, retaining jobs and supporting wider economic development, which ultimately support and complement the

objectives of the emerging Doncaster Local Plan. The proposals are unlikely to result in any adverse environmental

effects that would be a constraint to development, with any planning application supported by an Environmental Statement and EIA technical assessments. As such the proposals are considered broadly positive, to which significant weight should be afforded. Overall, we support and commend the allocation of Grange Farm as a preferred minerals site. The Local Planning

Authority can also be assured that detailed proposals and an Environmental Impact Assessment is being progressed to bring forward the Site as quickly as possible, accounting for scarcity of concreting aggregate resources, under the current extant planning policy position. As such, it is not only considered Sound to allocate provision of mineral from the Site, it is also practical and Effective. i.e. the proposals have operator commitment, are currently being detailed up and would be considered deliverable over the early years of the plan period.

We would however request the Council to consider accounting for and recognising the existence of the Ninescores Farm IDO (registered planning permission) through its LAA process in support of the emerging Local Plan, for which it is

intended to bring forward and regularise the Ninescores permission as a composite part of the Grange Farm mineral

planning proposals on the basis of maximising the valuable resources at the Site, particularly in respect of sharp sand and concreting aggregates. This will be further justified on sustainable minerals recovery. Also enclosed are the following documents:

• CE - Doc 1 - Doncaster Local Plan – Local Plan evidence Base – Assessing Mineral Site Representations – Land at

Grange Farm Representation • CE - Doc 2 - Mineral Sites Map – Site Reference - 1011

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

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

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

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

☐ Yes, I wish to appear at the Examination.

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

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

Date 30/09/2019

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

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

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

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

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

or defamatory.

0

Doncaster Local Plan

Local Plan Evidence Base

Assessing Mineral Sites Representations

Version: Consultation Draft May 2018

37

Late Representation (received 03/11/2017)

Land at Grange Farm (1011) Grid Reference 469620 400469

Ward Finningley

Site Proposer

Agent Lichfields - Jonathan Standen

Representation New Quarry - Extraction of Sharp Sand and Gravel

Site Area 40.0Ha

Land Ownership Multiple private ownership

Estimated Output (tpa) 260,000 to 270,000 tpa

Estimated Reserve 1.55Mt

Proposed Life of Operations 6 years

Existing Land Use Agriculture

Access Bank End Road (via existing access serving Bank End Farm)

Estimated Traffic Movement 13,500 return movements per year

Site Location Plan

Assessment Criteria and Summary

Mineral Deposit

Sand, Gravel and bedrock Sherwood Sandstone. Southern section comprises of fine grained silty sand and glaciolacustrine deposits with silty clay. The northern section is overlain with Peat, Sutton sand and glaciolacustrine deposits in the southern half. River Terrace deposits are present below the surface. Extract from Doncaster Grange Farm – Aggregate Resource Assessment Letter

38

Planning History

Historic sand and gravel mineral extraction has taken place within the surrounding area

Economic Justification

The agent has provided excerpts from the 2014 and 2015 Local Aggregate Assessment (LAAs) as part of the economic justification for the project, stating the 2014 landbank equated to 7.6 years and the 2015 landbank equated to 14.5 years and also acknowledges that the landbank for sand and gravel should be 7 years or more. These LAAs identify a shortfall in sharp sand and gravel. The representation states the shortfall in sharp sand and gravel can be met in part by the Grange Farm prospect.

Proposed Operations

Not given

Proposed Restoration

Agriculture (but nature conservation is also mentioned within the representation)

Highways, Rights of Way, Traffic Issues (and proposals) (SA objective 3)

The site is within 0.5km of the strategic road network Proposed access Bank End Road (via existing access serving Bank End Farm) 13,500 return movements per year? (as identified in the representation)

Mineral can be routed directly on to Bank End Road and to the A614

Navigable waterways- The site is over 0.5km of the navigable waterway with wharf access

Housing, Employment and other Options (SA objectives 1 and 5)

Farm and residence immediately adjacent the representation - no buffer. No detail on impact on local amenity. No other residences within the immediate area.

Housing representation 153 Land of Bank End Quarry (Site 1) is located immediately south west of the representation – not proposed for allocation in Local Plan.

39

No employment Representations within the vicinity of the Grange Farm Representation.

Landscape Character (SA objective 12b)

The Landscape Character and Capacity Assessment identifies the area as sand land heath and farmland. The site is in a ‘minerals moderate capacity area’. A more detailed landscape character and visual impact assessment would be required in support this site.

Natural Environment (National and Local Biodiversity, Ecology, Geodiversity) (SA objective 12)

National and internationally important sites- Hatfield Moor is 3km from the representation

Nightjar foraging habitat – within 3km of Hatfield Moor (SPA, SAC, SSSI)

Local – the representation is immediately adjacent Whin covert local wildlife site and Ash Holt LWS is approximately 120m from the representation Site within the buffer of a designated site or would trigger a NE consultation

Impact on (or the setting of historic and cultural heritage). Listed Building, Conservation Area, Parks and Gardens of Historic Value and Special Interest, Scheduled Monuments, Archaeology (SA objective 13)

There are no above ground heritage assets within the area of search. No heritage assets in the wider area would be affected by mineral extraction. Archaeology will be considered through the Doncaster Minerals and Archaeology (EH project number 6497) due for completion in summer 2018

Best and Most Versatile Land (SA objective 14a)

The agricultural land map identifies the representation area as grade 2 and 3 agricultural land. (roughly about 50% each)

Air Quality Management Areas (SA objective 14c)

Site located outside of an AQMA or National Exceedence Area

Groundwater Source Protection Zone (SA objective 14b)

SPZ 3

Pollution to surface water bodies

Flood zones (SA objective 11a) Flood zones are not considered relevant to the assessment of sites however flood zone information is provided for information

Flood Zone 3a - 99.93% Coal Authority Land Stability

Not within a known area with land stability issues

Conflict with incompatible Uses (including residential properties)

No immediate issues apart from impact on the highways network

Opportunities (including biodiversity opportunity mapping BOM)

Part in the Finningley cover sands BOM area

Airport Consultation Zone

The representation is within the 13km consultation zone for the Doncaster Sheffield Robin Hood International Airport, representation will require statutory consultation with the airport. Cumulative Impacts

Existing quarries in the vicinity of the representation with progressive extraction and restoration around the immediate area.

Main Potential Adverse Impact (if any) / Development Management Issues

Temporary impacts on highway, impacts of noise from extraction and machinery / plant, dust, monitoring ground water levels, protecting groundwater, specifying landscaping / restoration, soil retention and handling, protected species? Proximity to adjacent property

Appropriate Assessment Screening Requirement (Under the EU Habitats Directive)

All Local Plan mineral site proposals within the planned 3km nightjar consultation buffer zone around Hatfield Moor will automatically require screening to see if an appropriate assessment is required. Other proposals not immediately within the 3km buffer zone may still require screening but for different reasons such as impacts on the water table so on.

Summary

The representation is in an area of known sand and gravel extraction and has an estimated reserve of 1.55Mt. It appears adverse impacts can be mitigated through the use of planning condition, however I am concerned about the amenity impacts on the farm and detached house immediately adjacent to the representation. A detailed breakdown of the sand and gravel resource would be beneficial to assess whether the representation can provide much needed sharp sand and gravel in the desired quantity

40

Decision It is proposed to bring forward this representation as a proposal for minerals development as it has potential to provide 1.55Mt of sand and gravel to contribute toward the landbank of permissions.

42

Appendix One - Mineral Sites - SA Scores Summary Table

Site Ref Site Name

Source of Site

08d Unstable

Land Score

12a Biodiversity

Score Landscape -

Minerals

13a Heritage Impact Score

14b Agricultural Land Score

14c Groundwater

Source Protection

Score

14d Pollution

to Surface Water Bodies Score

14e Air Quality Score

Road Network

Score Waterways

Score

023

Johnsons Field, off Holmewood Lane, Armthorpe

Call for Sites 0 -- 0 0 ? 0 -- 0 - -

035

Finningley Quarry Extension

Call for Sites 0 -- 0 0 ? 0 -- 0 + -

044

Paddock at South View, Austerfield

Call for Sites 0 - 0 0 ? 0 -- 0 + -

066

Land at Old Mill Field, off Epworth Road East, Hatfield

Call for Sites 0 - 0 - ? 0 0 0 + -

080

Hazel Lane Quarry, Hampole

Call for Sites 0 - - 0 - 0 0 0 + -

102

Holme Hall Quarry, Stainton Lane

Call for Sites -- -- 0 0 - 0 -- 0 + -

235

Warmsworth Quarry Extension,

Call for Sites 0 -- 0 - - 0 0 0 + +

43

Sheffield Road, Warsmworth

238 Land East of Kirk Lane

Call for Sites 0 - - 0 0 0 -- 0 + +

420

Austerfield Quarry, Land North of Highfield Lane

Call for Sites 0 - 0 0 + -- 0 0 + -

780 Land at Thorne Road

Additional Call for Sites 0 - 0 0 0 0 0 0 + -

1011

Land at Grange Farm, Finningley

Additional Call for

Sites (2017) 0 - 0 0 - 0 -- 0 + -

57

Land at Grange Farm, Finningley (1011)

1

1

1

UV035

UV1011

Scale :

Date :

Reference :Minerals(LDF).mxd

1:24,000

23/05/2018

Helen McCluskieCompleted By :

(c) Crown copyright. License Number 100019782. 2015. (c) Copyright GeoInformation Group 1997, 2002, 2005 and 2007.

0 0.4 0.80.2 Miles

¯

Derived from 1:100,000 BGS digital data under licence 2008/113British Geological Survey (c) NERC

BGS - MineralResources

Mineral SafeguardingAreas

Legendsafeguarded stone siteMinerals Processing InfrastructureLocal Plan proposals_mineralsQuarries_Update_2017Mineral Areas of Search

Land at Grange Farm (1011)Late Rep.Estimated Reserve - 1.55MtIt is proposed to bringforward this representationas a proposal for mineralsdevelopment as it haspotential to provide 1.55Mtof sand and gravel tocontribute toward thelandbank of permissions.