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 Mr First Name Matthew Last Name Peter Kelly, Graham White, Paul Pennington, Stewart Oades Good Organisation (where relevant) Pegasus Group Address – line 1 The Pavilion Address – line 2 Green Lane Address – line 3 Garforth Postcode LS25 2AF E-mail Address Telephone Number
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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)
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
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.
This comment form should be read in conjunction with the associated report.
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).
This comment form should be read in conjunction with the associated report.
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:
To provide a full explanation of our points and address issues raised by the Council, Inspector or other
participants.
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:
• 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
Pegasus Group Pavilion Court | Green Lane | Garforth | Leeds | LS25 2AF
T | www.pegasusgroup.co.uk | @pegasusgroup
Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester
Pegasus Group is a trading name of Pegasus Planning Group Limited [07277000] registered in England and Wales Registered Office: Pegasus House, Querns Business Centre, Whitworth Road, Cirencester, Gloucestershire, GL7 1RT
Page | 1
002.MG/P18-2216EC
30th September 2019
Local Plan Team
Civic Office
Waterdale
Doncaster
South Yorkshire
DN1 3BU
By email only:
Dear Sir/Madam,
Re: Publication Draft Doncaster Local Plan: Consultation Representation on behalf
of Peter Kelly, Graham White, Paul Pennington and Stewart Oades
Please find enclosed a representation prepared by Pegasus Group on behalf of Peter Kelly,
Graham White, Paul Pennington and Stewart Oades in relation to Land at Paper Mill Fields,
Tickhill. The representation considers the content within the Publication Draft of the
Doncaster Local Plan.
The representation should be read in conjunction with the accompanying representation
produced by Pegasus Group to the draft policies and proposed site informal consultation in
September 2018.
I would be grateful if you could confirm receipt of these submissions.
Yours faithfully,
Matthew Good
Director
Email:
cc. Stewart Oades
Page | 2
DONCASTER LOCAL PLAN
PUBLICATION DRAFT CONSULTATION (AUGUST – SEPTEMBER 2019)
LAND AT PAPER MILL FIELDS, TICKHILL FOR PETER KELLY, GRAHAM
WHITE, PAUL PENNINGTON AND STEWART OADES
1.0 Introduction
1.1 This representation is prepared by Pegasus Group on behalf of Peter Kelly, Graham
White, Paul Pennington and Stewart Oades in relation to Land at Paper Mill Fields,
Tickhill. The representation considers the content within the Publication Draft of the
Doncaster Local Plan.
1.2 In compiling this representation Pegasus Group have applied the four elements of
soundness referred to in the National Planning Policy Framework, which are;
positively prepared, justified, effective and consistent with national policy.
1.3 This representation should be read in conjunction with the accompanying
representation produced by Pegasus Group to the draft policies and proposed site
informal consultation in September 2018. That document promotes the site and
illustrates why is should be allocated for residential development. The purpose of this
submission is to focus on the matters within the Publication Draft only, mainly the
overall requirement and distribution of housing.
2.0 Our Vision for the Future
2.1 Our client is supportive of the vision which has been informed by the ambitions of
the City Region, its Strategic Economic Plan as well the Northern Powerhouse.
2.4 The economic aspirations of the Borough must be matched by a clear commitment
to deliver the area’s future housing needs as a minimum. Objective 9 of the Local
Plan seeks to; “ensure housing provision meets the housing need and aspirations by
increasing the provision of new homes for all to meet current and future needs and
create mixed and balanced communities.”
2.5 Unfortunately, the proposed policies and strategy within the Local Plan do not meet
this challenge. This clearly has implications for the soundness of the plan.
3.0 Policy 2: Spatial Strategy and Settlement Hierarchy
3.1 This policy is considered unsound as it is not justified or effective.
3.2 The policy seeks to distribute the majority of new development to the most
sustainable locations, these being the Main Urban Area of Doncaster, the 7 Main
Towns and the 10 Service Towns and Villages. This general principal is considered
appropriate and is supported. It is, however, important that this is sustainable and
deliverable.
3.3 Tickhill is identified as in the ‘Service Towns and Villages’ category. The identification
of Tickhill within the Service Town and Village tier is supported. It is a high performing
settlement and provides many primary services. It is well served by a district centre
Page | 3
containing local services and amenities, two primary schools and health care
provision.
3.4 In terms of new homes the policy seeks to deliver at least 50% within the ‘Main
Urban Area’ of Doncaster and 40% within the 7 ‘Main Towns’ with just 10% allocated
to the ‘Service Towns and Villages’. The lack of housing allocated to Service Towns
and Villages is disproportionately low and takes no account of the sustainability,
deliverability, development opportunities or affordable housing need within these
settlements.
4.0 Policy 3: Level and Distribution of Growth
4.1 The policy is not sound as it is not positively prepared, justified, consistent with
national policy or effective.
4.2 Policy 3 of the Publication Draft of the Local Plan sets a target for at least 920 (net)
new homes each year over the plan period 2015-2035 (18,400 homes in total) with
sufficient land allocated to deliver the housing requirement.
4.3 The proposed level of housing growth remains unchanged since the draft policies
consultation in 2018. Therefore, Pegasus continue to question whether this approach
to meeting the needs for new homes demonstrates that the Plan is positively
prepared and justified. 4.4 The PPG states the Government will be supportive of
authorities who wish to plan for growth. In addition, the PPG identifies other factors
which need to be considered when determining the housing requirement. These
include growth strategies, planned infrastructure, previous levels of delivery and
recent assessments of need such as Strategic Housing Market Assessments (SHMA)
where this suggests a higher need (PPG ID 2a-010). These are all important
considerations in the context of Doncaster. It is not considered that the housing
requirement within Doncaster adequately meets the economic aspirations of the area.
4.4 It should also be noted that between 2004/5 and 2017/18 housing delivery averaged
in excess of 1,000 net additional dwellings. Since the start of the plan period (2015)
average delivery rates have been higher at 1,140 net additional dwellings. Setting
the housing requirement lower than average levels of delivery over the previous 14
years and 220dpa lower than the plan period average, would be contrary to the ethos
of the NPPF and the Government’s continued desire to boost significantly the supply
and delivery of housing.
5.0 Land at Paper Mill Fields, Tickhill (Ref. 824)
5.1 Policy 3 identifies that just 165 dwellings should be provided within Tickhill. Given
our comments upon the housing requirement and distribution, above, this is not
considered a sound approach. This is further compounded by the Local Plan
identifying just one allocation for 74 dwellings. The Local Plan identifies that;
“The remainder of the settlement’s housing requirement of 165 new
dwellings (91 units) has therefore been made good through allocated supply
at the Doncaster Main Urban Area and some of the Main Towns in line with
Policy 3, which adds any unmet local housing need from settlements to the
in part without the written consent of Pegasus Planning Group Limited.
DONCASTER LOCAL PLAN INFORMAL CONSULTATION: DRAFT POLICIES & PROPOSED SITES (SEPT 2018) REPRESENTATION APPENDIX: HOUSING NEED EVIDENCE APPRAISAL
Date: October 2018
CONTENTS 1. INTRODUCTION .................................................................................. i 2. EXISTING EVDIENCE ON HOUSING NEED IN DONCASTER .................. ii 3. NEW DEMOGRAPHIC AND HOUSING MARKET INDICATOR DATA ........ v 4. EMPLOYMENT TRENDS IN DONCASTER ............................................xiii 5. ECONOMIC GROWTH ASSUMPTIONS ............................................... xvii 6. CONCLUSIONS.................................................................................. xix
Pegasus Group Representations Doncaster’s Local Plan – Consultation Draft
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1. INTRODUCTION
1.1 This report considers demographic and economic factors relevant to responding to the
Consultation Draft of the Doncaster Local Plan. It focuses on the evidence behind the
housing growth targets and economic growth rates in the Local Plan. This report has been
prepared on behalf of a number of Pegasus Group clients.
1.2 The comments within this report serve to highlight a number of aspects of the Local Plan
and its supporting evidence base that require revision or additional analysis to be
considered suitably robust.
1.3 From the outset, it should be noted that the high-level vison set out in the ‘Local Plan –
Vision and Objectives’ consultation document is welcomed, which aims for Doncaster to
be "a thriving place to learn, work, live and care” and support the three objectives of the
Local Plan, which are for Doncaster to have:
• A strong economy supporting progressive, healthy, safe and vibrant communities.
• Full potential in employment, education and care.
• Prosperity and pride.
1.4 This report is structured as follows:
• Section 2 provides a review of existing evidence on housing need in Doncaster.
• Section 3 analyses the most recent data on demographic trends and housing
market indicators, both of which impact on the requirement for new homes.
• Section 4 reviews past employment trends in Doncaster, along with selected
benchmark areas.
• Section 5 provides views on future economic growth in Doncaster and the extent
to which the Consultation Draft of the Local Plan fully reflects the growth potential
of the District.
• Section 6 presents overall conclusions from the analysis.
Pegasus Group Representations Doncaster’s Local Plan – Consultation Draft
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2. EXISTING EVDIENCE ON HOUSING NEED IN DONCASTER
Adopted Core Strategy
2.1 The Core Strategy for Doncaster, adopted in May 2012, set out a requirement for 1,230
dwellings per annum over a 15-year period up to 2028. This dwelling requirement was taken
from the subsequently revoked Yorkshire and Humber Regional Strategy.
Emerging Local Plan
2.2 The Consultation Draft of the Local Plan identifies a need for 920 dwellings per annum in
Doncaster up to 2032. This figure is based on analysis undertaken by the Council in
August 20151. More recent analysis of housing requirements in the District was produced
on behalf of the LPA by Peter Brett Associates in June 20182, and this forms part of the
evidence base for the Local Pan consultation. It is therefore helpful to consider what PBA’s
work says regarding future housing need in Doncaster.
2.3 In summary, PBA identifies three housing need requirements, with a range of 562-1,073
homes per annum:
• Demographic starting point, from the 2014-based official household projections:
562 net new dwellings per annum (dpa)
• Adjusted need, to match business-as-usual job forecast: 579 dpa
• Job-led housing need, to match the job growth aspiration of Sheffield City Region:
1,073 dpa.
2.4 The third figure, relating to job-led housing need, is particularly interesting because it
looks at how many homes will be needed in Doncaster if it is to help support the wider
Sheffield City Region (SCR) achieve its long-term economic growth aspirations. PBA
reference work undertaken by Metro Dynamics, which provides a series of metrics for the
City Region as a whole up to 2040. One of these metrics is for the area to see 1.0% jobs
growth per annum over the next 20+ year. Modelling this for Doncaster leads to the
1,073 dpa target. However, PBA argue that this is extremely ambitious and suggest using
a figure that is halfway between the lowest of the three requirement estimates (562 dpa)
and the highest (1,073). This would lead to an annual need for around 820 new homes
per annum and while this is closer to the OAN of 920, it is still significantly below the job-
1 Housing Need Assessment 2015 – Doncaster. Doncaster MBC, August 2015. 2 Economic Forecasts and Housing Needs Assessment. Peter Brett Associates, June 2018.
Pegasus Group Representations Doncaster’s Local Plan – Consultation Draft
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led estimate of 1,073 and indeed the higher dwelling figures endorsed by the five-year
housing land supply Inspector, although as identified above this is subject to challenge.
‘Planning for the Right Homes in the Right Places’
2.5 This consultation document was published in September 2017 on the back of
commitments set out within the White Paper ‘Fixing our Broken Housing Market’, which
included proposals to tackle the housing challenge, specifically to build more houses of
the type people want to live in, in the places they want to live in. The consultation paper
considered that the previous system for determining dwelling requirements was too
complex and that it led to a costly and time-consuming process that lacked transparency.
In response to this a standard approach was identified, based on three key principles, to
be simple, based on publicly available data and realistic.
2.6 The approach taken, as part of the original Standard Methodology, is essentially a top
down method to achieving a total number of homes nationally per annum. The targeted
figure was initially 266,000 homes per annum, which was an average of three different
sources of evidence. More recently, however, a higher figure of 300,000 homes per
annum has been targeted by the Government. As referred to later in this report,
however, the total number of homes achieved by the Standard Methodology using the
most recent household projections is significantly short of 266,000 and 300,000 and
closer to 215,000 homes per annum.
2.7 The methodology, in essence, takes the latest household projections (the average
between the first ten year period from the current year (now 2018 to 2028, although the
original methodology was based on a timeframe of 2016 and 2026)) as a starting point
or Local Plan requirement (if it was adopted within the last five years) and on top of that
applies an uplift based on affordability, which is an arbitrary calculation to generate
figures that are capped at 40% of the household projections or the Local Plan figure
(depending on its status and age).
2.8 More recently, the Revised NPPF has been published following a consultation exercise,
which provides the policy framework that the Standard Methodology fits within. The
Methodology has remained unchanged, except for clarity over the starting point etc. In
light of this, it is pertinent to consider the implications arising from the Standard
Methodology for Doncaster. Taking into account the above, when it was published in
Pegasus Group Representations Doncaster’s Local Plan – Consultation Draft
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September 2017, the assessment of housing need in the Borough was 585 dwellings per
annum.
Summary
2.9 When comparing the chronology of figures presented above, the dwelling requirements
for Doncaster have varied significantly, going from 1,230 in the adopted Local Plan and
Yorkshire and Humber RS, to 562 to 1,073 as set out in the PBA report and 585 in the
September 2017 Standard Methodology. The Consultation Draft Local Plan goes with a
different figure, with an OAN of 920dpa. It is interesting to note that the figures in excess
of 1,000 are predicated on achieving economic growth aspirations and others merely seek
to provide for growth projected from short-term demographic projections, which, as set
out in the next section, can be volatile. As further evidenced in Section 5, it is advised
that economic aspirations are properly planned for within a land use plan, to facilitate the
aspiration becoming a reality.
Pegasus Group Representations Doncaster’s Local Plan – Consultation Draft
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3. NEW DEMOGRAPHIC AND HOUSING MARKET INDICATOR DATA
3.1 More recently, the 2016-based Subnational Household Projections have been published
as well as the 2017 affordability ratio data, both of which are considered in further detail
below – dealing with the latter first.
2017 Affordability Ratio Data
3.2 The more recent affordability ratio3 for Doncaster is 5.21, which is 0.14 higher than the
previous ratio and demonstrates that affordability in the Borough has worsened slightly.
In 2007 the ratio was 5.17, indicating that house prices in Doncaster over the last decade
have remained around five times the median local salary.
3.3 When comparing the affordability ratio data with other authorities in Yorkshire and the
Humber, Doncaster is one of the more affordable boroughs to live in the region. Harrogate
(10.36) and Hambleton (9.52) are the least affordable places. The average ratio for the
entire region is 5.90, which is closer to the figure for Doncaster. However, the fact that
the ratio in Doncaster has remained broadly the same over the last ten years means that
affordability still remains an issue for the area. Going back further, the affordability ratio
in the Borough has not been below 4 since 2003.
3.4 When comparing Yorkshire and the Humber to other regions, the most affordable region
to live is the North East, with an affordability ratio of 5.21. Unsurprisingly, London is the
least affordable and has a ratio of 12.36. Similar to Doncaster, Yorkshire and the
Humber’s ratio has stayed broadly the same over the last decade, indicating that housing
in the region has not become more affordable. The average price of a home is therefore
likely to remain unaffordable for many, especially for local employees on average
incomes.
2016-based Subnational Household Projections
3.5 The 2016-based Subnational Household Projections were published in September 2018.
This data is a key part of the Standard Methodology. When comparing the level of
projected growth with the earlier data set (2014 Based Subnational Household
Projections), which was 548 dwellings per annum between the period of 2016 and 2026,
3 Consistent with the original Standard Methodology consultation in 2017, the work-place based median affordability ratio has been used.
Pegasus Group Representations Doncaster’s Local Plan – Consultation Draft
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the more recent projection suggests that growth will be marginally lower at 531 dwellings
per annum for the same period. When looking at the period of 2018 to 2028, which is
the most up to date period that the Standard Methodology should be calculated from (as
set out in accompanying guidance to the Revised NPPF), the households per annum figure
is 532.
3.6 It should be noted that household projections are based on short-term past trends of
natural change and net migration (five years for internal migration and six years for
international migration). Further, it is acknowledged that there are additional
methodological changes, which may have impacted the change to the number of
households. Relevant factors are considered further below.
2016-based Subnational Population Projections
3.7 In order to further understand the differences between the different household projection
time series, it is necessary to consider the population projections, which are a key
component. Tables 3.1 and 3.2 show the population change in each of in the 2016 and
2014-based Subnational Household Projections respectively. Whilst the more recent
projections show a slower rate of household formation, the population projections show
the reverse. There is projected to be higher population growth in Doncaster, which is
contrary to what is happening in many other parts of the country. The slightly higher
rate of growth is projected in the more recent projections compared to the earlier data
set is quantified between 2016 and 2026, as a difference of around 900 people and,
between 2018 and 2028, as a difference of around 400 more people.
3.19 When examining the dwelling completions, it is clear that the economic downturn in
2009/09, has had an impact on housing delivery in the Borough with completions
significantly reducing. It is worthwhile noting, however, that whilst the dwelling
completions were reduced in this period, they remained at a reasonable level, which
shows resilience and continued market demand for homes. This is a further indicator
that there remains a strong need for homes, which should not be overlooked.
3.20 A further indicator of housing market pressure is whether there is a sufficient proportion
of vacant housing stock in the market to provide flexibility for renovations, transactions
etc. A rate of 3% has previously been identified as an appropriate level of vacancies to
maintain. The Government maintains a statistical data set of live tables recording such
data. The number of vacancies at October 2017 was 4,138, which represents 3.1% of
the total housing stock (135,250), meaning Doncaster is right on the threshold of what
is considered to be an appropriate level of vacant stock.
5 The 2011/12, 2012/13, 2013/14, 2014/15, 2015/16 and 2016/17 figures are provisional and subject to scheduled revisions pending the release of future census dwelling stock data. 6 Figures highlighted in red are imputed
Pegasus Group Representations Doncaster’s Local Plan – Consultation Draft
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Summary
3.21 Based on the data and commentary above, the low levels of housing delivery (possibly
as a consequence of the recession and other factors) in previous years has resulted in
increasing levels of negative net internal migration, which has then informed the
population and household projections. Such trends may not be desirable to repeat.
Indeed, as set out above in the analysis, there is concern that unsustainable and
unbalanced communities may result. Accordingly, it is important to consider other factors
such as affordability and economic aspirations (as explored in the following section),
when creating successful and sustainable communities.
Pegasus Group Representations Doncaster’s Local Plan – Consultation Draft
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4. EMPLOYMENT TRENDS IN DONCASTER
4.1 When considering the extent to which the current OAN provides a realistic level of new
housing provision, it is helpful to look at past employment trends in Doncaster, as housing
need will be driven to a large extent by changes in the labour market. This section
analyses the latest jobs data published by the Office for National Statistics (ONS). It
focuses on Doncaster, along with the benchmark areas of Sheffield City Region (SCR)
Local Enterprise Partnership, Yorkshire & the Humber and Great Britain7. Sheffield City
Region LEP covers the following local authority areas: Barnsley; Doncaster; Rotherham;
Sheffield; Bassetlaw; Bolsover; Chesterfield; Derbyshire Dales; and North East
Derbyshire.
Employment Trends
Total Employment
4.2 ONS data allow for long-term analysis of past trends in employment going back to 1998.
As a result of changes to the methodology used in producing the data, it is not possible
to look at trends over a continuous period. The following timeframes have been analysed
to allow for this fact:
• 1998-2008: Jobs data published as part of the Annual Business Inquiry (ABI) by
ONS).
• 2009-2015: Jobs data published as part of the Business Register & Employment
Survey (BRES) by ONS, which replaced the ABI.
• 2015-2017: Jobs data published by ONS as part of the BRES.
4.3 Table 4.1 shows jobs in Doncaster between 1998 and 2008, along with the benchmark
areas. The main points to note are:
• Doncaster saw total employment increase by around 10,000 from 1998-2008,
equating to annual growth of 0.9%. This was in line with the level of growth seen
in SCR, Yorkshire & the Humber and Great Britain.
• In absolute terms, the 10,000 new jobs in Doncaster between 1998 and 2008 was
the third highest figure at a district level in SCR – behind only Sheffield (24,000)
and Rotherham (18,000). Employment decreased in three of the nine districts in
7 Sheffield City Region LEP covers the following local authority areas: Barnsley; Doncaster; Rotherham; Sheffield; Bassetlaw; Bolsover; Chesterfield; Derbyshire Dales; and North East Derbyshire
Pegasus Group Representations Doncaster’s Local Plan – Consultation Draft
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SCR: Barnsley (which lost 3,000 jobs over the 10-year period at a rate of 0.4%
per annum); Bassetlaw (2,000 jobs – 0.5% per annum); and Chesterfield (2,000
jobs, 0.4% per annum).
Table 4.1: Jobs Change by District in Sheffield City Region, 1998-2008
Yorkshire and The Humber 2,415,000 2,463,000 255,000 1.0%
Great Britain 29,819,000 30,593,000 2,633,500 1.3% Source: Business Register & Employment Survey Note: Figures may not sum due to rounding
Pegasus Group Representations Doncaster’s Local Plan – Consultation Draft
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Summary
4.7 Employment in Doncaster has been on a positive trajectory since 1998, with job numbers
increasing over each of the three timeframes discussed in this section. Growth over the
period 2009-15 was particularly strong and while it fell back between 2015 and 2017,
Doncaster has still seen employment increase either at or above the levels experienced
by Sheffield City Region since 1998. The next section looks at why this is such an
important finding.
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5. ECONOMIC GROWTH ASSUMPTIONS
5.1 As noted in section two, one of the main documents underpinning the Consultation Draft
of the Doncaster Local Plan is PBA’s June 2018 report8, which looks at housing and
economic development needs for the period up to 2032. The analysis includes forecasts
of employment and this section reviews the forecasts to assess the extent to which they
fully reflect the economic growth potential of Doncaster.
Employment Growth Scenarios
5.2 The Employment Forecasts and Housing Needs Assessment uses local economic forecasts
produced by Experian to analyse two scenarios for future growth in Doncaster:
Baseline ‘business-as-usual’ Scenario
5.3 This scenario was calculated using the standard (or baseline) forecast from Experian
(December 2017). The forecasting model takes account of the macroeconomic context,
the area’s mix of industries and services (industrial structure) and its past performance
compared to the UK and the region. It also takes account of future population change,
which it assumes will be as shown in the latest official projection, which at the time of
analysis was the 2014-based Sub-National Population Projections (SNPP 2014).
5.4 The baseline scenario forecasts jobs growth of 13,800 in Doncaster between 2015-2032
(from 134,000 to 147,800), equating to 812 additional jobs per annum – an annual
growth rate of 0.6%.
Planned Growth Scenario
5.5 This scenario takes into account emerging targets associated with the latest refresh of
the Sheffield City Region (SCR) Strategic Economic Plan (SEP). The emerging SCR targets
are the work of the consultancy Metro Dynamics and have been provided in a ‘Target
Metrics’ report9, which forecasts employment growth over the plan period in SCR of
132,600 (7,800 jobs per annum) – an annual jobs growth of 1.0%.
5.6 The Planned Growth Scenario applies the same 1.0% annual growth rate to Doncaster in
and forecasts growth in the Borough of 24,200 jobs between 2015 and 2032, which
equates to 1,424 jobs per annum. The impact of this higher level of growth is that
housing requirements in Doncaster increase to 1,073 dwellings per annum according to
PBA.
8 Housing Forecasts and Housing Needs Assessment: Peter Brett Associates, June 2018. 9 Target Metrics Sheffield City Region: Metro Dynamics, June 2017.
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Jobs-Led Growth in Doncaster
5.7 Considering the fact that Doncaster has seen employment increase either at or above the
levels experienced by SCR since 1998, it is argued that the Planned Growth Scenario
better reflects the economic growth potential of the Borough. With the City Region aiming
for long-term annual jobs growth of 1.0%, Doncaster needs to show the same level of
ambition and be aiming for this level of growth in its labour market. As noted by Metro
Dynamics in its Target Metrics Report10:
“We believe these targets will push Sheffield City Region to further improve its economy…
they are attainable, yet challenging. They will ensure that SCR continues to move
forward, creating an economy that works for all its citizens. But they are targets, rather
than predictions. They require significant policy interventions and economic investments
to achieve them. All of them are set higher than what we believe would occur without
changes, and are meant to encourage action towards them”.
5.8 This would help build on the growth seen in the area since 1998 and would also better
reflect sub-regional objectives. Other areas have set considerably higher targets, such as
the West Midlands Combined Authority, which is aiming for 1.3% annual jobs growth up
to 2030 as part of its Strategic Economic Plan. This was pre-Brexit, however, and the
growth target may have been lowered since. An annual growth rate of 1.0% would ensure
that Doncaster isn’t left behind by other parts of the country. With increased jobs growth
comes a higher demand for homes and as noted by PBA, the Planned Growth Scenario
will see the annual requirement for housing increase to 1,073 – above the current OAN
of 920dpa.
10 Target Metrics Sheffield City Region: Metro Dynamics, June 2017.
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6. CONCLUSIONS
6.1 The analysis presented in this report raises a number of important points when
responding to the Consultation Draft of the Doncaster Local Plan. Firstly, the information
discussed in sections two and three shows that numerous housing targets have been
calculated for the Borough. The Consultation Draft of the Local Plan opts to continue with
the OAN figure of 920dpa. Doncaster has surpassed this target in the last two years and
seen more than 1,000 new homes built in both 2015/16 and 2016/17. Prior to this the
number of net completions on an annual basis was consistently below 900, but the two
most recent timeframes show that the Borough is able to deliver at least 1,000 dwellings
on annual basis.
6.2 Compared with other parts of the country, Doncaster is more affordable to live, however
affordability ratios have changed little over the past decade, suggesting that the housing
ladder remains out of reach for a substantial part of the local population. Build rates will
therefore need to remain high in the long-term to address this issue and it does not seem
unreasonable to expect Doncaster to see annual housing completions surpass 1,000 on
a consistent basis.
6.3 As set out earlier in the report, the household projections are self-fulfilling and heavily
influenced by recent changes to circumstances (such as the recent economic down turn
and recovery). It is, therefore, important that other factors and aspirations are
considered alongside the household projections and Standard Method calculations.
6.4 The Office for National Statistics has confirmed that they will be producing variant
projections, which are due to be published in early December 2018. These variant
projections will include higher formation rates for younger adults (those aged 25 to 44
years), as evidence suggests that such households were unable to form as freely as
previous generations (due to high house prices, less access to finance etc.). An increase
in housing numbers in Doncaster will help ensure that supply is able to meet demand –
especially from younger adult households that form and/ or may move into the area.
6.5 Secondly, the analysis presented in sections four and five raises the question of whether
Doncaster should be aiming for higher long-term growth in employment. Doncaster forms
a key part of Sheffield City Region and target metrics produced independently for SCR
LEP identify the need for jobs growth of 1.0% p.a. if the City Region is to improve its
performance relative to the UK. Given that Doncaster has seen employment increase
either at or above the levels experienced by SCR since 1998, it does not seem
unreasonable to therefore expect it to align with the City Region target and for jobs
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growth in the Borough to average 1.0% in the long-term. The impact of this would be to
increase requirements from the current OAN of 920dpa to 1,073dpa – an additional 153