The City of Durham Trust
Comments on the County Durham Plan Preferred Options
The future of County Durham – what gets built, where and when – is being decided by the County Durham Plan. Currently planning applications are decided by reference to Local Plans drawn up by the former District Councils. The City of Durham’s plan dates from 2004. Parts of this have been superseded by changes in national laws, rules, and guidance, most notably the National Planning Policy Framework or NPPF, published in March 2012.
Durham County Council is now preparing a County Durham Plan to replace the former District plans and in September they published their 350-page Preferred Options to which the City of Durham Trust has now responded with over 60 pages of detailed comments. This page summarises those comments and links to the introduction and the individual answers to 24 questions. As an alternative, here is a link to the complete 59 page document.
As the largest civic amenity society in the North East, which has spent seventy years championing Durham City and its surroundings, the City of Durham Trust feels it has a duty to submit the following comments. While we speak primarily for our members, we believe that the comments may represent the views of many other citizens of Durham who, since they have no town or parish council, have nobody else to sprak for them.
In our brief introduction, we agree with the underlying aim of improving the well-being of people who live in the County by improving the economy of the County. We accept that Durham City has an important role to play, but argue that the plan over-concentrates on the City to the detrement of the rest of the County.
The Plan seems to be reluctant to acknowledge the City’s position sandwiched between Tyneside, Wearside and Teesside. The frequent references to the importance for Durham City to achieve a “critical mass” are unrealistic, for the county town will never become a third metropolitan area or regional capital. The Authority has taken scant notice of the public’s feedback for a more balanced approach, expressed in earlier rounds of consultation.
Spatial Vision, Strategic Objectives and Sustainable Development
Here we elaborate on the excessive focus on Durham City, quoting the Inspector at the last local plan Inquiry. The small, tight-knit nature of the City, which is one of its defining qualities, will be lost through a deliberate policy of subjecting it to excessive and unsustainable growth. It’s fine to be aspirational, but not to have over-aspirational and consequently undeliverable objectives.
The vision has a circular set of assumptions – on the one hand, the proposed figures for new housing reflect an aspirational number of new jobs, even as, on the other, it is hoped that the new population will form a “critical mass” for creating those same jobs. It also fails to recognise the regional context properly, and does not recognise that what is proposed is inherently risky.
The strategic objectives should also have explicitly recognised the importance of the Green Belt and contained a specific objective on sustainable transport.
We found that Policy 1 (Sustainable Development) did not meet the criteria set out in the NPPF. Instead it is actually concentrating on economic development, often with scant reference to sustainability, and at the same time at the expense of the linked social and environmental dimensions.
Attack on the Green Belt
The Plan has a number of policies that would take land out of the very narrow Green Belt surrounding Durham City, disregarding the clear guidance in the NPPF that this should only be done as a last resort when all alternatives have been explored, since one of the two essential characteristics of a Green Belt is its permanence. But in its search for housing sites near Durham City, the Council restricted the search to a 5km radius from the City Centre. This methodology is misguided, it should have looked at all potential sites over a wider area, and given Green Belt locations extremely negative weightings. The reasons given for this policy are essentially the extremely serious economic situation. The Trust of course recognises the situation but the Council has not shown how building on the Green Belt will solve it in a way that the alternatives will not.
Consequently the Trust opposes Policy 7 (Durham City Strategic Housing Sites) because it is an attack on the Green Belt, which stems from its over-concentration on Durham City. It took a Freedom of Information request for the Trust to discover that the Council has a list of sites that could take 39,172 new houses, without needing to build on the Green Belt.
Policy 6 of the Plan proposes a major employment site at Aykley Heads, eating into the Green Belt, ignoring the site’s other environmental, transport and location disadvantages, as well as the comparative advantages of available sites elsewhere (Durham Gate, Amazon Park, Mountjoy, the former Ice Rink, County Hospital, etc.).
We would have supported the overarching Green Belt Policy 13 had it not proposed removing large areas from the Green Belt, because its policies regarding land remaining in the Green Belt are sound. As well as the large areas, the Trust opposes removing a number of other sites which, although they are relatively small, play a key role in maintaing the openness of the Green Belt.
Policy 14 (Major Developed Sites in the Green Belt) does not in fact list the sites it is talking about. An explanatory note envisages permitting peripheral housing development next to these sites, and the Trust opposes this.
Damaging proposals for two relief roads
Policy 8 proposes a Western Relief Road running from the Sniperley Park and Ride round to Broom Park, and Policy 9 a Northern Relief Road from the Arnison Centre across the Wear valley to a junction with the A690. The Trust opposes both. Our evidence shows that they will not only be immensely damaging environmentally, they are not needed.
Their effects would be contrary to the Council’s own transport policies and sustainability objectives, and the schemes would have very damaging effects on the environment and setting of the City, both by encouraging road traffic growth and through its direct impact on the Green Belt. They are contrary to Government advice: alternative options do not seem to have been properly considered. If the road is built it will increase traffic on a number of linking roads including the one through Bearpark.
Traffic numbers have risen only slowly in recent years and in some cases – including Milburngate Bridge – they have actually fallen. Consequently the Trust calls on the Council to abandon these damaging and unjustified proposals.
Proposals for New Development
This batch of policies were concerned with the quantity and distribution of new development. We found that Policy 3 (Quantity of New Development) showed no sign of recognising that there will be cross-border travel to work, in both directions. House construction and job creation need to go hand-in-hand or the houses will be sold to commuters and not be there for new workers. And to propose building on the Green Belt when there are over 10,000 empty houses and around 1300 sites with unimplemented planning permissions is not acceptable.
Policies 4 (Distribution of Development) and 5 (Durham City) again both focus too heavily on the City of Durham. Durham City is quintessentially a small city which it is not possible to transform into the key driver for the whole of the County economy. However, given how much of the area surrounding the City is within 15 minutes by bus or 10 minutes by car from the City Centre, it would be perfectly possible to site new housing outside the Green Belt while still achieving the objectives of the Plan.
The Plan proposes putting development in places which already have good facilities, but the County Durham Settlement Study which was used has a scoring matrix which is rigged to favour larger settlements. The Plan proposes 21,805 new houses in the 12 main towns and 5,470 in the smaller towns and larger villages. We argue that this needs to be rebalanced away from the main towns.
We say that Policy 10 (Student accommodation) underestimates the scale of the problem. A rising number of students (currently 7,800) live out and this causes problems particularly in the central wards of the City. This runs counter to the NPPF which says “there is a need to create sustainable, inclusive and mixed communities.” The University has outline plans for four more colleges and these need to be incorporated into the Plan.
The Trust opposes Policy 12 (Executive Housing) because it will entrench social divisiveness and run counter to the Council’s own sustainability objectives. On the more general Policy 30 (Housing Land Allocations) the Trust objects to a number of proposals including Mount Oswald and between Witton Grove and the Sniperley Park and Ride site.
Promoting sustainable travel and new transport infrastructure
If Policy 47 (Promoting sustainable travel) did what the title promises, the Trust would have welcomed it. However, the Council’s proposed approach is both contrary to the provisions of its current Local Transport Plan (LTP3) and to the guidance of NPPF, both of which rest on a positive interpretation of sustainable travel. Therefore the Trust cannot support this policy.
The Trust supports some aspects of Policy 48 (New transport infrastructure), but wishes to see additional safeguarding of current and potential public transport infrastructure. However it strongly opposes the broad presumption in favour of the approval of new highway schemes, which amounts to a complete departure from the priorities and approach expressed in LTP3.
The Trust feels that the former Ice Rink Site and Durham Science Park should be allocated for specific rather than general employment uses and consequently has objected to Policies 23 and 24.
The Trust opposes Policy 25 (Retail Allocations) and argues that the proposed superstore north of Arnison is not only an unwarranted incursion into Green Belt, but it is unsustainable and would attract car traffic from a wide area. The Council’s preferred strategy for North Road does nothing to address the fundamental issues, and its proposed developer-led strategy is unlikely to offer prospects of an early reversal of the area’s decline. The retail hierarchy proposed in Policy 26 is generally welcomed but feels it needs to be strengthened and clarified.
The Trust considers Policy 44 (Historic Environment)to be a comprehensive and positive statement. However Policy 45 (Durham Cathedral and Castle World Heritage Site) lacks a sufficiently strong preservation or conservation element.
More information: General Employment Sites, Specific Use Employment Sites, Retail Allocations, Retail hierarchy and development in commercial centres, Historic Environment, Durham Cathedral and Castle World Heritage Site
Community Infrastructure Levy
The development proposed for the Green Belt is to be progressed, or financed, by charging developers a Community Infrastructure Levy which is excessively high compared, not only with the rest of the county, but in the country as a whole. There is no guarantee that developers will pay the high figure of around £25,000 per house – or that the Levy will last for the length of the Plan, as the last Conservative manifesto proposed its abolition. The County’s domestic council tax payers are therefore at risk of ending up paying for the County Council’s unwanted and unsustainable ambitions, while developers reap profits at their expense.