The Trust responds to local or national consultations as they affect the City of Durham. The consultation issue is briefly summarised below and the Trust’s full response is available for viewing and download. Responses in 2023 and older responses are available.
In 2024 – Durham County Council
Non-Designated Heritage Asset Supplementary Planning Document Consultation
This SPD covers all the appropriate aspects of the definition, identification and selection of non-designated heritage assets (NDHAs). However, the Trust feels that in places it lacks necessary detail and clarity. In particular, more definitions of landscape assets are required and these need better coverage in the criteria. The main problem is with the scoring process. A scoring process needs to be transparent and robust. Criteria, and quality and significance, are related but are not identical. The criteria identify the type of asset and its characteristics. However scoring an asset’s significance cannot be simply the number of criteria that it meets as the various types of assets differ in their nature. NDHA consultation.
Biodiversity SPD Consultation
The Trust welcomes the Council’s commitment to supporting nature recovery and applauds the aims of this SPD. The points made by the Trust aim to improve clarity and to increase emphasis. It is crucial that the BNG improvements are practically achievable and can be sustained for the 30 years required. It is important that the public are enabled to assess the developer’s BNG proposals at the planning application stage. The Trust also makes a number of suggestions for biodiversity improvements that lie outside the scope of the SPD and which could be addressed in the review of the Local Plan. Biodiversity SPD consultation.
Shopfront Design Guide Supplementary Planning Document Consultation (phase two)
The Trust previously responded to the consultation on the first draft in 2023. The Trust thinks the second draft SPD is an improvement over the first but needs fine tuning in some areas. Consultation on 2nd draft.
Energy Efficiency, Renewables and the Historic Environment SPD consultation (phase two)
The Trust previously responded to the consultation on the first draft in 2023. The Trust responded very positively to the first draft. The comments that we made then have been incorporated in this second version, with the exception of the point that heritage interior doors should be treated with the same care as exterior doors. Consultation on 2nd draft.
Air Quality Action Plan 2021-2026 Consultation
This Air Quality Action Plan (AQAP), currently undergoing consultation, presents a series of Actions that will be undertaken by the Council to reduce emissions and improve air quality across the County, and specifically within the Durham City Air Quality Management Area (AQMA). The AQMA was first declared in 2011 due to concentrations of nitrogen dioxide (NO2), predominantly from road vehicles, being above the national health-based objective for annual mean concentrations. The Trust has previously commented on this topic in 2015 and in December 2023. The Trust’s main points are:
- more measures placing additional costs on users of polluting vehicles must be included so
- that the polluter pays
- given the climate emergency, the ranking and prioritisation of actions should also reflect
- the likely impact on carbon emissions
- any actions to “investigate” or “study” possible interventions should rapidly be developed
- into firm proposals
- measures which tackle air quality but which are also visible to the public will help with
- awareness of the issues and potentially build public support
The AQAP does not state what the targets for air quality improvements are, nor over what timescales it is hoped they will be achieved. The targets and timescales should be clearly set out. Each year the Council should consider whether the plan is on track, and reallocate resources accordingly.
Durham City Conservation Area Management Plan Consultation
Part 2: Conservation Area Character Appraisals: Crossgate Conservation Area
This is a very welcome document and should help in sharing the understanding of the conservation area and in assessing new development proposals within the area. The draft is as informative as it will be useful. It is very well researched and illustrated, and the background work in putting the document together shows throughout. Where the Trust comments, it is more a matter of emphasis and suggestions of where there are points worth more attention. If there is a concern, it is that this quality and depth of reportage will not be easy to sustain, and a full city wide review will take time.
Local Nature Recovery Strategy Consultation
Durham County Council is developing a Local Nature Recovery Strategy (LNRS) which will identify the current priorities for nature in the County and help direct resources to those identified habitats and species. The consultation wants people’s views on their experiences of nature in County Durham, what the priorities for nature recovery should be, what are the most important ways to support nature recovery, which areas of the county are valuable for existing wildlife, and where are there the opportunities to enhance or create new wildlife spaces. The Trust welcomes the opportunity to provide a detailed response to this consultation. We warmly welcome the LNRS. We identify a number of initiatives and areas in the City that are of priority and would benefit from support. We also note two other issues: (i) the priority for BNG should be enhancement of biodiversity at the primary development site, with the enhancement of sites elsewhere being very much a fall-back option. The requirement for BNG in Durham should not become laxly exploited as enabling a convenient general pot of funds and “biodiversity units” for spending elsewhere, at the expense of the primary site. We also assume that the welcome LNRS scheme is in addition to BNG, given the advice from Natural England that a BNG rate at 10% will be insufficient to halt biodiversity decline; (ii) It seems understandable that the LNRS exercise stresses the links between the enhancement of biodiversity for life in general and human amenity in particular (such as beauty and psychic health). However, is this strategy in danger of downplaying what are actually strong areas of conflict between these evaluative categories, and even risking entrenchment of the destructive fallacy that the natural world is of value solely as a human resource of some sort?
Housing Needs Supplementary Planning Document Consultation (stage two)
The Trust has responded to Durham County Council’s 2nd consultation on the Housing Needs Supplementary Planning Document (SPD) and the Interim Policy Statement on First Homes, reaffirming our responses to the first consultation in 2023. In addition we have emphasised the need to use the Strategic Housing Market Assessment (SHMA) evidence in housing proposals, to strengthen the criteria for the quantitative and qualitative needs for PBSAs, and to improve the way the figure of average local income for defining affordability is calculated.
Solar Energy Supplementary Planning Document 2nd Consultation
We welcome the changes made to the Solar Energy Supplementary Planning Document (SPD)
which have addressed most of the issues we raised in our response to the previous consultation.
However, there are a few issues that still need to be covered in the SPD itself, plus other issues that
we would urge the Council to cover in other actions outside the Solar Energy SPD. E.g. guidance on how to design new buildings to facilitate and optimise energy generation, solar gain and energy-efficient ventilation; stronger requirements to require all new developments to incorporate solar energy, with targets for this and the monitoring of these targets. Solar Energy SPD 2nd consultation website.
Draft Council Plan 2024 to 2028 Consultation
In 2019, public, private and voluntary sector bodies that make up the County Durham Partnership jointly agreed a long-term Vision 2035. The Council Plan describes how this vision will be achieved. It is a high-level plan covering three years and is updated annually, following consultation. The Plan is structured around five themes: our economy; our environment; our people; our communities; our council. The Trust welcomes the Vision and the focus on Well Being and Equality and Inclusion. We note a number of aspects that should be included within the Plan.
In 2024 – Other organisations
Proposed reforms to the National Planning Policy Framework and other changes to the planning system
The National Planning Policy Framework sets out government’s planning policies for England and how these are expected to be applied. This consultation sets out a wide range of changes, with one of the key aims to increase the building of new homes. One controversial aspect is the identification of parts of the Green Belt which would be suitable for development, aka ‘the grey belt’. Another is the method of calculating housing need.
Redevelopment at East Durham College, Houghall Campus, Consultation
DPP Planning (an independent consultancy) is preparing to submit a Full Planning Application for improvement works at East Durham College – Houghall Campus. The proposal comprises the partial demolition of the existing college buildings, partial refurbishment and repurposing of existing buildings and construction of a new two-storey teaching block and agricultural buildings with associated external areas, landscaping and accesses. A leaflet explaining the proposed development is available. The Chair of the Trust attended the public consultation event. The Trust is pleased that the college has received funding from the DfE to improve its facilities. However, we have two major areas of concern. The first is that the new teaching block is to be located on a field in the Green Belt. The second is about the felling of trees.
An Accelerated Planning System Consultation
Over March to May 2024 the Government consulted on measures to speed up the planning system. The Trust considers that it is more important to achieve the right decision than a speedy decision. Consequently these proposals are misconceived. Given the length of time that it takes to complete a major project, the time taken in gaining planning permission is only a small part of the whole. Local people and the community will be affected by a wrong, rushed, decision for years and probably decades.
The Future Homes and Buildings Standards: 2023 Consultation
The government is committed to improving the energy efficiency and reducing the carbon emissions of new homes and non-domestic buildings. Energy efficiency requirements for new homes and non-domestic buildings are set by Part L (Conservation of Fuel and Power) and Part 6 of the Building Regulations 2010. This consultation sets out the government plans for achieving the Future Homes Standard and Future Buildings Standard. It sets out technical proposals for changes to the Building Regulations, the associated Approved Document guidance and calculation methods. The Trust’s response focusses on answering the questions in a way which would hasten the adoption of the highest standards for insulation and energy consumption. Building Regulations should be the minimum standards for buildings. These higher standards need to be supported by stronger design codes so that there is no lowering of design standards and of the aesthetic considerations of proposals. Regulation 25B aims for new buildings to be “nearly zero-energy”. It needs to be retained as the proposed Future Homes standard does not go far enough in reducing energy demand from buildings. The idea that buildings will be “zero carbon ready” principally because their services are entirely electric places a huge burden on the decarbonisation of the grid when there will be increased electricity demand for heating and transportation. Higher specifications for buildings are required, e.g. extent of glazing, provision of external shading, house orientation, opportunities for through flows of air, ventilation (balancing the need to prevent condensation and mould against heat loss) etc. etc. The interaction of Building Regulations with the planning system needs improvement, with testing of compliance at the planning application rather than the construction stages. Better and easier access for home owners to guidance and information is needed, particularly about the level of the standards achieved for their own home. Information about the functioning of the Future Home standards should not be withheld for reasons of commercial confidentiality. For example there should be mandatory performance testing via random sampling of new homes to ensure standards are improved. A government-endorsed Future Homes Standard brand would be a good idea but only if reserved for higher specification buildings which go significantly beyond the current proposals. The new requirements should be brought in as fast as possible. Developers have already had long enough to adapt, and we are in a climate emergency.
