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 the current year and older responses are available.
In 2023 – Durham County Council
Energy Efficiency, Renewables and the Historic Environment Supplementary Planning Document (SPD) Consultation
This draft document sets out guidance for property owners considering making energy efficiency or renewable energy improvements within the historic environment, for example buildings which are listed, non-designated heritage buildings and properties within conservation areas. This is the first consultation on this SPD. The Trust finds the whole document to be judicious and sensitive to the historic built environment. We particularly welcome the clearly presented tables of examples. Two areas of concern are replacement of historic windows and doors, and placement of solar panels on historic buildings.
Shopfront Design Guide Supplementary Planning Document (SPD) Consultation
This draft SPD sets out guidance to promote good shopfront design, restoration, and refurbishment especially for historic buildings and in conservation areas. This is the first consultation on this SPD. Generally, the Trust welcomes the guide and considers that it will be useful document when approved. The main thrust of the our comments is to reflect our concerns experienced when dealing with planning applications and the extensive experience of members and trustees. Principal areas are: (1) The retention and repair of traditional shopfronts, (2) The intrusion of contemporary (i.e. modern) additions or changes, particularly signage, lighting and for leisure uses, and (3) New leisure and shop frontages.
Design Code Supplementary Planning Document (SPD) Second Consultation
This draft SPD gives guidance to ensure that developents are well designed and well suited to their surrounding area. The SPD will be supported by Settlement Character Studies as they are developed, and an example is included in the draft document. This is the second consultation on this SPD. We responded to the earlier consultation (see the entry further down this page). The Trust reiterates points from our previous response that have not beeen incorporated into the new draft. In particular, failure to adequately deal with Durham City will be to miss an opportunity to pursue better quality design often lacking in the City. Over-merging the City into the detail of a County wide code is not working. Sustainability in all its aspects needs to be more of a thread through the code. Key characteristics from the National Design Guide are omitted from this draft with no rationale for what is included and what is omitted.
Trees, Woodlands and Hedges Supplementary Planning Document (SPD) Second Consultation
This draft SPD gives guidance to ensure trees, woodlands and hedges are fully considered as part of the planning process. This is the second consultation on this SPD. We responded to the earlier consultation (see the entry further down this page). The Trust again compliments the County Council on the production of this comprehensive, well-researched and informative draft. We still have points that we suggest could improve the draft. These include (but are not limited to): the need for an additional biodiversity SPD; using the identifiable economic value of trees when assessing development proposals; the value of the ‘ordinary’ as well as the exceptional; ensuring ongoing management of these green assets.
County Durham Housing Strategy
Durham County Council have held the first stage of their consultation on their Housing Strategy: views on Principles and Priorities. The new Housing Strategy is to be adopted in 2024. The current strategy is dated 2019. The Council’s vision is that County Durham will be a place that has good quality homes that meet the needs of existing and future residents and that they can afford. It aims to deliver quality housing that supports economic growth and contributes to improved health, and which creates and maintains sustainable, mixed, and balanced communities where people live long and independent lives. The City of Durham Trust supports this Vision and particularly welcomes the elements of affordability and of sustainable, mixed and balanced communities. We suggest that the Principles accompanying the Vision should ‘unpack’ the term “good quality” into net zero carbon footprint houses that are of the highest quality design internally and externally coupled with generous green spaces.
Rights of Way Improvement Plan (ROWIP) 4
Durham County Council is developing the fourth Rights of Way Improvement Plan (ROWIP4). The Plan covers investment in the PROW network of footpaths, bridleways, and byways, by enhancing the existing green network for the benefit of its users: walkers, cyclists, horse riders, and some off-road motor vehicles. The ROWIP4 is up for consultation and the Trust has written a response, offering suggestions for improving the draft document..
Solar Energy Supplementary Planning Document (SPD)
The Trust welcomes the fact that Durham County Council has produced this Supplementary Planning Document as a contribution to responding to the climate crisis, and we have responded to the consultation. We have, however, identified a number of weaknesses in the SPD, e.g. it lacks any specific short-term local targets, making it impossible to measure progress; and it does not do enough to promote and encourage solar energy. In particular, it contains no requirements to fit solar energy systems to new buildings; the focus is on fitting them to existing buildings.
Parking and Accessibility Supplementary Planning Document (SPD) 2023
The consultation on the final draft of this SPD has been carried out and we have responded at length. The Trust still has many concerns with this SPD and suggest improvements. Our previous responses in 2022 and 2021 can be seen further down this page.
Design Code Supplementary Planning Document (SPD) consultation
Consultation website SPD document The Trust is appreciative of this draft where it aims to fulfil the guidance offered by the National Design Code and its supporting documents. Given the lack of other county-wide examples and the early stages of Design Code development at this scale, any first draft is to some extent breaking new ground. The relationship of this SPD to the other SPDs need identifying. Referencing to neigbourhood plans is needed. Sustainability, including biodiversity, in all its aspects needs to be more of a thread through the code. The coverage of settlement categories is challenging because of the complexity of the task and the extensive range of settlements leading to a heavy burden of background research. The result, in the view of the Trust, is a failure to adequately outline Durham City’s characteristics even at a high level and to lead to code that will help in steering design codes for its future developments. The code will need to show how it will relate to the City’s Settlement Study and the Durham Conservation Area Management Plan (DCAMP).
Development Viability, Affordable Housing and Financial Contributions Supplementary Planning Document (SPD) (second stage) consultation
Consultation website SPD document We made comments on the previous draft in 2022. The Trust agrees with the contents on the whole, and suggests some additional details. However, the transport and traffic consequences of development are amongst the most unsatisfactorily addressed.
Housing Needs Supplementary Planning Document (SPD) consultation
Consultation website SPD document The Trust welcomes and is supportive of this SPD, and makes suggestions for improvements and clarity. In particular, proposals for additional PBSAs need to be assessed first by whether there is a quantitative need for the proposed type of PBSA in the proposed location. If there is an identified shortfall then consideration can be given to the quality aspects of the accommodation. More coverage of Neighbourhood Plans is needed.
Trees, Woodland and Hedges Supplementary Planning Document (SPD) consultation
Consultation website SPD document The Trust compliments the County Council on the production of this comprehensive, well researched and informative draft. However, there needs to be greater integration with other SPDs. The function of trees and woodland in green infrastructure and the importance that this is now assuming in planning and management considerations should be stressed more, including their wider role in sustainability, environmental issues, historic environments, and health and cultural benefits. Cross referencing to neighbourhood plans is needed. Should there also be a Biodiversity SPD, dealing with all green and blue infrastructure?
In 2023 – Other organisations
Permitted Development Rights
The Government’s consultation proposed changes to the Town and Country Planning (General Permitted Development) (England) Order 2015, as amended. The Trust responded to a question in the section on changes to certain permitted development rights that allow for the change of use to dwellinghouses.
Q.6 Do you think the prior approval that allows for the local consideration of the impacts of the change of use of the ground floor in conservation areas on the character or sustainability of the conservation is working well in practice?
a) Yes
The City of Durham Trust is a strongly supported amenity society in Durham City now in its 81st year. Trustees are concerned about the impact on Durham’s centre of some of the proposed changes to permitted developments. Any proposal that would allow retail establishments in a conservation area to switch at will to residential status could be extremely damaging to the historical centre of the city. It would have an economically damaging impact upon it as a visitor centre.
The Trust has generally supported the local authority, Durham County Council, in its encouraging the use of the often-empty upper floors of some central shops for student rent, while preserving the traditional function of the ground floor. However, loss of the ground floor in addition would exacerbate here an already advanced trend toward making the centre of Durham little more than a student ghetto.
The Trust has observed with dismay the damage inflicted on city centre retail over the years by the development of large out- of-town retail parks, designed wholly for the convenience of motorists, but with none of the communal life of a traditional town centre.
Short term lets
The Department of Culture, Media and Sport has conducted a consultation on a registration scheme for short-term lets in England. Additionally, The Department for Levelling Up, Housing and Communities has held a consultation on the introduction of a use class for short term lets and associated permitted development rights. The Trust responded by endorsing the response of the National HMO Lobby. The National HMO Lobby is an association of some fifty community groups in thirty towns in all parts of the UK, who are concerned to ameliorate the impact of concentrations of houses in multiple occupation (HMOs) on their communities.
North East Active Travel Strategy
The North East Active Travel Strategy aims for active travel to become the natural first choice for
short everyday travel and combine it with public transport for longer journeys. Consultation website. Strategy document.
The Trust is glad to see that the vast majority of the interventions are infrastructure-based, with a limited focus on promotion and training. Promotion and training, without infrastructure delivery, has an impact which is limited in effect and in duration. It is very disappointing to see that walking and cycling improvements in Durham City Centre appears to be planned only for 2029-2035, a full ten years after the authority consulted on its LCWIP for Durham City. The lack of cycle infrastructure, and the poor quality of the congested pedestrian routes in the city have been identified in one strategy after another for a quarter of a century. The urban areas must be prioritised, so people can walk or cycle from the edge of towns to the key destinations in the town centres. , that investment will be wasted. The Trust feels that the change which would most help people to travel actively in the North East is a change in the culture within highways authorities, planning, and the police. Those responsible for delivering improvements to active travel must be forward-thinking and show enthusiasm for change and the promotion of new priorities.
Consultation on proposed approach to updating the National Planning Policy Framework
The National Planning Policy Framework (NPPF) sets out the government’s planning policies for England and how these are expected to be applied. This NPPF consultation is about a limited number of immediate changes to the policy context and wording. The Trust’s overall view on the proposed approach and text changes to the NPPF is that they are welcome.
