Durham at the Crossroads 51

Cover: The route of the County Council’s proposed Western Relief Road through the countryside of the Browney Valley in Durham’s Green Belt

CONTENTS ______Page

The case in summary for withdrawal of the County Durham Plan 5

Objection to consultation procedures 9

Population and household projections 13

Objection to Policy 1 17

Objection to Policy 2 19

Objection to Policy 3 21

Objection to Policy 4 23

Objection to Policy 5 25

Objection to Policy 6 27

Objection to Policy 7 31

Objection to Policies 8, 9 and 10 33

Objection to Policy 12 37

Objection to Policy 14 39

Objection to Policy 30 42

Objection to Policy 32 43

Objection to Policy 48 45

Appendices:

A.1 Friends of the Durham Green Belt pro-forma letter of objection 47

A.2 Newspaper report of meeting addressed by Jonathon Porritt, 4 July 2012 48

A.3 The Friends’ Green Belt leaflet 49

A.4 Other Key documents relevant to this submission 50

A.5 Durham at the Crossroads 51

3 4 THE CASE IN SUMMARY FOR WITHDRAWAL OF THE SUBMITTED COUNTY DURHAM LOCAL PLAN ______

The Friends of the Durham Green Belt are concerned about issues of procedural compliance and soundness of the County Durham Draft Local Plan and recommend that the Plan should be withdrawn at this stage in order that the weaknesses identified below can be remedied.

 A critical failure of the Plan is to be found in the population and housing forecasts. The trend in population changes in recent years has been relatively static or slightly growing. Despite this, the Plan’s trend projections have been inflated to suggest a much higher level of inevitable population increase. The Plan then aspires to increase it even further to meet a predetermined house-building target. This is a wholly unacceptable basis for the Plan.  Durham County Council’s vision for a successful local economy with high levels of employment, population and housing is expressed in a high growth strategy, the feasibility of which has remained untested. The Council’s alternatives are only variants on their preferred high growth strategy, leading to a dismissal of other possibilities. Our objection is that reasonable alternatives have not been considered (other than alternative distributions of the high growth strategy favoured by the Council). This led to our development of a ‘moderate growth’ alternative, which we submitted for assessment against the Plan proposals. Rather than assessing the two, the Council simply set our alternative aside. The Council’s high-level growth strategy is apparently unchallengeable.  Under the provisions of ‘The Duty to Cooperate’, local authorities within a region should agree reasonable strategic levels of growth. No such agreement is apparent, with the consequence that all local authorities are promoting economic growth and housing targets that are likely to prove collectively unachievable. This in turn will lead to wasteful competition between developers to provide housing sites. If the Durham City economy grows at a slower rate than that proposed in the Plan, then the attractive housing sites in the Green Belt are likely to become dormitories for commuters to Tyneside, Wearside and Teesside rather than an essential requirement generated by employment growth in the City. Under this scenario, it is difficult to understand where the benefits are for Durham City and the County as a whole.  In the absence of options based on more realistic growth, the consequences for the remainder of the County remain unexplored. One possibility is that areas outside Central Durham that continue to need regeneration will be starved of resources, a question that has been avoided in the optimistic ‘growth for all’ vision.  The impact on Durham City’s Green Belt remains the focus of our objection. The willingness of the County Council to accommodate 4,000 dwellings, a further exclusive executive housing site, a commercial development site and two relief roads in the Green Belt to achieve a ‘critical mass’ for the City is quite plainly contrary not only its own Green Belt policy but also national policy. There are no ‘very special circumstances’ that demand it. On the contrary, there is every reason to invest in Durham City’s future by exploiting its special strengths as a World Heritage Site and a city with a world-class University that spins out high technology and knowledge-based enterprises in the County such as at NetPark in Sedgefield.  The Plan contains exemplary policies based on sustainability principles but these are treated as discretionary rather than mandatory where proposals do not accord with them, such as housing and two relief roads in the Green Belt and executive housing in an historic landscape.

5  The Draft Plan fails to treat student accommodation as a strategic matter. The County Council and the University have not identified any new major site to accommodate planned increases in student numbers. Without a strategy for student accommodation, the conversion of houses into multi-occupation and the exploitation of brownfield sites in the City for new student accommodation will continue. For many people in Durham, this failure alone is sufficient to judge the Plan as unsound  In the round of consultation finishing on 9th December 2013 (which was presented by the Council as another chance to comment), it was not made clear that this was the one and only opportunity to object to any aspect of the Plan. Even if a member of the public understood that the opportunity existed, it is likely that the terminology in which a formal objection should be made would deter any potential objector. The Friends of the Durham Green Belt were so concerned at this lack of clarity that we published a letter in the Durham Advertiser on 20th November 2013. This was an invitation to members of the public to send it to the Council in its entirety or in a modified form to compensate for the Council’s failure to face up to the possibility that there might be considerable objection to its proposals.  There are many consequences resulting from the inflated population and housing forecasts and from the refusal to treat any contrary views seriously. We have listed in the schedule below our separate elements of objection, but we believe them to be in combination a devastating commentary on an unsound and potentially non-compliant Plan.

Policy or Policy Nature of the Objection Statement

Consultations Contrary to the NPPF requirement on ‘empowering local people to shape their surroundings’, the County Council has constructed elaborate and costly consultation exercises with little evidence of willingness to respond positively to contrary views or to simplify the process to encourage genuine public engagement. Paragraphs 4.22 to Elements of the forecasting process are extremely unconvincing. 4.27 – Population and There is a very strong case for new population and household housing forecasts forecasts being undertaken and agreed before consideration is given to any other aspects of the Plan.

Policy 1 – Sustainable Sustainability criteria are treated as discretionary to enable non- development conforming proposals to be judged to be sustainable development. Policy 2 – Spatial The hierarchy of settlements included in the Policy is approach accompanied by text that concedes that growth in Durham City is more likely to dominate. In the event that growth is lower than the target for the County set by the Plan, the allocations in the City will all be taken up, and the allocations in the remainder of the County will fail to develop. The Plan must examine this more probable lower growth scenario to protect the interests of the rest of the County and protect the City from over-development. This would require major consequential changes to Policies 4, 6 and 8 and their accompanying reasoning.

6 Policy 3 – Quantity of The Council has failed in its ‘Duty to Cooperate’ with new development neighbouring authorities to agree compatible strategic population and housing levels. In addition, unsound population forecasts have resulted in allocations of housing within the Durham City Green Belt. Competition for housing development will lead to Green Belt sites providing homes for commuters to Tyneside, Wearside and Teesside.

Policy 4 - Distribution The distribution of housing developed is unbalanced, with too of development much in Durham City, and with inadequate recognition of windfall, brownfield, empty homes and vacated student conversions in the City. Policy 5 – Developer We object to the use of developer contributions for the building of Contributions unsustainable relief roads.

Policy 6 – Durham City The willingness of the County Council to accommodate 4,000 dwellings, a commercial development site and two relief roads in the Green Belt to achieve a ‘critical mass’ for the City is quite plainly contrary not only its own Green Belt policy but also national policy. There are no ‘very special circumstances’ that demand it. On the contrary, there is every reason to invest in Durham City’s future by exploiting its special strengths as a World Heritage Site and a city with a world-class University that spins out high technology and knowledge-based enterprises in the County such as at NetPark in Sedgefield. Unrealistic targets for employment, population and housing growth in the County and lack of consideration of reasonable alternatives including a ‘moderate growth’ alternative put forward by the Friends of the Durham Green Belt. The Council’s ‘critical mass’ justification to enhance Durham City’s status is spurious in relation to its international reputation. Also the absence of an assessment of the impact on areas outside Central Durham of slower growth (no ‘Plan B’ to ensure that Durham City does not grow at the expense of all other areas). Policy 7 – Aykley To allocate 7.5 hectares of Green Belt for prestige office Heads development is contrary to Green Belt policy. The existing non- Green Belt land at Aykley Heads and on other sites in Central Durham provide agreed considerable potential for prestige office development. Policy 8, 9 & 10– The unnecessary housing requires the unsustainable roads, and Durham City Strategic the Council’s wish to build the unnecessary roads needs the Sites and Relief financial contribution from the housing developers. It is an Roads unsustainable package presented as sustainable development. The traffic model predictions about car traffic growth do not take into account future scenarios of likely lower car ownership and use, impact of climate change mitigation, damage to wildlife and scarcer resources including agricultural land. The model did not test a lower growth alternative and thereby concludes that the roads are necessary to serve the Green Belt housing. The NPPF Principles on the need for transport proposals to support the transition to a low carbon future and to make the fullest use of sustainable transport has not guided the Draft Plan.

Policy 12 – Executive The term ‘executive housing’ is undefined within the Plan and Housing Allocation inappropriate in terms of sustainable development, which seeks

7 to create balanced communities. In addition, the single chosen site is contrary to Green Belt Policy 14.

Policy 14 – Green Belt National policy is to retain Green Belts permanently. The Council has redrawn the boundaries of the Durham Green Belt. This fails the national requirement to assess the total impact of changes in respect of the five national criteria in designating and reviewing Green Belt boundaries. There are no ‘very exceptional circumstances’ that can justify these changes.

Policy 30 – Housing Sniperley Park, North of Arnison, Sherburn Road, Merryoaks, the Land Allocations ‘Durham Northern Quarter’ and the executive housing site at Lambton Park Estate, are all in the Durham Green Belt and should be rejected pending a full review of the Green Belt boundaries. Also, the schedules of housing land allocations should include allowance for sites smaller than 0.4 hectares and other potential sites e.g. windfall sites.

Policy 32 – Houses in The inclusion of at least one major new site for student Multiple Occupation accommodation is essential, and a commitment to introduce an and Student Article 4(2) Direction for Durham City to manage the percentage Accommodation of HMOs in each neighbourhood is required.

Policy 48 - Delivering The policy has been rendered in effect meaningless by the Sustainable Transport unsustainable and costly road proposals for Durham City, which encourage car ownership and car use. Proposals for the construction of relief roads within the Durham Green Belt should be replaced with a commitment to invest in a truly integrated transport infrastructure that provides a viable alternative to dependency on private car use. If the County Council reconsiders its strategy, then Policy 48 will be useful in identifying a pattern of growth that makes the fullest use of public transport, walking and cycling, and focuses development in locations, which are, or can made sustainable.

8 Objection to consultation procedures ______

The consultations carried out fail to meet the Government’s soundness tests in that they run contrary to the National Planning Policy Framework provisions on ‘empowering of local people to shape their surroundings’. Our objection is that the County Council has constructed elaborate and costly consultation exercises with little evidence of willingness to respond positively to contrary views or intention to simplify the process to encourage genuine public engagement.

Core Strategy, May/June 2010

The consultation on ‘Core Strategy Issues’ undertaken in May/June 2010 presented alternatives A and B for consideration. The choice presented was between (A) a Durham City-centred option and (B) a wider, regenerative distribution to other towns and villages. The problem is that this had already been pre-determined by the Sustainable Community Strategy (SCS), which has as an objective: "a thriving Durham City to exploit its potential as a major retail, business and residential centre, academic and cultural hub and visitor destination". However, since there had been no public consultation on the SCS, there were no means no means by which to challenge this over-arching objective. Hence, the apparently unstoppable strategic planning consequence that "Durham City will be the driving force of economic growth in County Durham" which in turn requires that Aykley Heads be cleared for headquarters offices, that large-scale housing development takes place in the Green Belt and that Northern and Western Relief roads are constructed. To oppose any of these consequences was, and is, to oppose the SCS objective for Durham City, which remains impossible.

Although the result of the 2010 consultation was not conclusive, there was a 60% preference for something other than the first option. Alternative A, unsurprisingly, was the unanimous preference of the development sector.

This was sufficient warning to the Council that more evidence, at least, was necessary if it was to continue with the high-level growth option based on Durham City. Indeed, this should have led to the consideration of a more moderate growth option, which, in all probability, would have been far more acceptable basis for the Pre-Submission Draft Plan. We therefore object that although the Council has carried out extensive consultations and invited comments, it has then rejected the results if they did not support the option the Council prefers.

Core Strategy Policy Directions, May/July 2011

The subsequent ‘Core Strategy Policy Directions’ consultation in May-July 2011 presented Option C which was claimed to be taking the best of Options A and B and discarding their respective weaknesses. A majority of representations other than from developers objected that the forcing of major new housing development on Durham City on a scale which "requires" most of this development going onto land that is designated to be permanently protected as Green Belt. In the absence of a public meeting arranged by the County Council, the Friends organised a public meeting in Durham Town Hall on 30 June 2011 addressed by the Council’s Head of Planning and by the chairperson of our Friends of the Durham Green Belt. The Town Hall was full to capacity, and the meeting was overwhelmingly in favour of reduced house-building targets for Durham City and for retaining the entirety of the existing Durham Green Belt.

9 Update for Durham City residents, October 2011

The County Council issued a public document in October 2011 entitled “Update for Durham City residents”. It provided some design details on the strategic housing site and relief road proposals in Durham City. This was not a consultation document, but it did give the assurance in its final paragraph that “By summer 2012, the Council will need to make its position clear on the major decisions which it will put before a Planning Inspector at an Examination in Public. There is still an opportunity at this stage to put alternatives before the Inspector before he decides whether the Council’s Plan is ‘sound’.” The Friends and others have been putting forward alternatives at every stage, but it would appear the Council has withdrawn that offer in the Pre- Submission document that it is minded to submit. There is no mention of putting forward alternatives.

On 4th July 2012, in anticipation of the County Council’s forthcoming next major consultation stage, we organised a public meeting in Durham Town Hall, addressed by the County Council’s Head of Planning and by Jonathon Porritt, former Chair of the Sustainable Development Commission. Once again, the Town Hall was full to capacity (see Appendix A.2 for the newspaper report), and the meeting was again overwhelmingly in favour of reduced house-building targets for Durham City and for retaining the entirety of the existing Durham Green Belt.

Friends formally placed follow-up questions to the County Council Cabinet meeting held on 24 July 2012 but the response from the relevant Portfolio holder was to dismiss Jonathon Porritt’s credentials and his views.

Preferred Options September/October 2012

Thus undeterred, the ‘Preferred Options’ consultation of September/October 2012 retained the proposals for major housing development and two relief roads in the Durham Green Belt. Objectors once again opposed these proposals. For our part, the Friends of the Durham Green Belt submitted a major case (Appendix A.5: ‘Durham at the Crossroads’) against these ‘preferred options’ and made alternative suggestions based upon more moderate growth aspirations for County Durham. The Council once again rejected the dispersed growth option favoured by a majority of consultees and favoured the ‘developers preference’. Both options were high growth options. No lower growth option was offered.

The County Council’s response at Cabinet on 20th March 2013 by the Portfolio holder to ‘Durham at the Crossroads’ was courteous and a meeting was offered with its Planning Officers. That meeting took place on 6 May 2013 but served only to reject every point that was raised.

As elections for all 126 seats on the County Council were held on 2nd May 2013, in April, Friends sent to all known candidates a briefing paper about the emerging County Plan’s issues around the Green Belt. This was followed up in May by a further briefing paper to all elected County Councillors. No acknowledgements were received.

In order to demonstrate that concern over the loss of parts of the Durham Green Belt was not just from a small handful of people, Friends established a public petition asking for “the protection of Durham City’s Green Belt so that the character of the City and setting of the World Heritage Site can be enjoyed by future generations”. This petition gained 1,138 signatures and should be included in the weighing-up of consultation views. A copy of the petition has been handed in to the County Council with the Friends’ present Objection document.

10 In summary, we have gone to considerable lengths to augment the County Council’s consultation arrangements at each stage. We object that although the Council has carried out extensive consultations and invited comments, it has then rejected the results if they did not support the option the Council prefers.

Pre-Submission Draft September/December 2013

The consultation on the Pre-Submission Draft has been seriously flawed, as this is the only opportunity to object to the Plan. The Council has already indicated that relatively few changes will be made at this stage as it considers that all major issues have been decided at previous stages. The fact that there remain huge unresolved matters appears not to be accepted by the Council. It has therefore emphasised this stage as another opportunity to comment on matters of detail rather than the last opportunity to object to major weaknesses in the Plan. We believe that the public remains largely unaware that objections after December 2013 to these substantive matters will not count.

It was for this reason that the Friends of the Durham Green Belt produced a leaflet ‘Which Future for Durham City’ to highlight the Councils reluctance to consider other options (See Appendix A.3) Friends then paid for and published a letter of objection in the Durham Advertiser. This letter (Appendix A.1) was in a form that invited members of the public to send as written or modified as appropriate to individual concerns raised by the Plan. We object to the Council’s failure to make clear that the Pre-Submission Draft stage was the opportunity to object and not just a further opportunity to comment.

A further difficulty is the manner in which objections were required to be expressed. Assuming that an individual did understand that the opportunity existed, the County Council’s form of objection was confusing and discouraging. The terminology in terms of unsoundness and procedural non-compliance and the four tests of Plan-making are for groups and organisations (although we have found it difficult to comply in the timetable allowed). We object because the objection form has discouraged participation by the public, which could have been facilitated by the availability of a simplified form.

Finally, several documents - most notably the important Evidence Base paper for the high forecasts of population increase - were not available until two weeks into the consultation period, and it should have been extended by two weeks to allow these to be absorbed.

Status as a ‘Local Plan’

We have a concern around the concept of a “local plan” for the whole of County Durham prepared in a single process rather than for the individual 250 towns and villages of County Durham. The Draft Plan’s proposals are not about the best shaping of a particular village in close consultation with its residents, businesses and other interests; on the contrary, they are top-down allocations of, for example, housing land dispositions across the County.

Among examples, the Preferred Options document proposed large-scale housing development sites in villages such as Langley Park. Local opposition was fierce, to no avail. The developer simply countered by pointing out that the County Council could not in principle resist something it had itself put forward. This is happening with other such proposed allocations (Browney is another example). The proposed allocations are already being converted into planning permissions - facts on the ground that render subsequent consultation meaningless. We doubt this is good local planning practice.

Conclusion

11 Contrary to the NPPF requirement on ‘empowering local people to shape their surroundings’, the County Council has constructed elaborate and costly consultation exercises with little evidence of willingness to respond positively to contrary views or to simplify the process to encourage genuine public engagement.

12 Paragraphs 4.22 to 4.27 - Population and Household Projections ______

The Friends’ fundamental objection to the Plan arises from the adopted population and household projections and targets. They are the platform upon which all the core policies are constructed, and Friends of the Durham Green Belt consider that it is a wholly unjustifiable basis for the key task of forecasting demographic trends.

Our case is set out below. It begins with the confusion at the heart of the Draft Plan where Paragraph 4.12 states "After 30 years of population decline and more recent population growth, latest projections forecast that the population is likely to remain fairly static over the next 20 years in the absence of a significant change in policy." By contrast, paragraph 4.23 states “The population and household projections show that the population of the County is due to increase by 47,700 over the Plan period”. These two conflicting statements describe the trends i.e. what will happen if past and present factors are projected into the future without any policy interventions. What cannot be understood is how ‘remaining fairly static’ can be reconciled with + 47,700 population growth in the trend projection. The problem may have resulted from the new population model used at a very late stage that is based on much higher net in-migration rates. This is an extraordinary lapse in consistency and discourages any confidence in the forecasts which should by now have been accepted by all parties as the basis for the Plan.

Population and household projections for County Durham

The Council for many years produced its own population estimates and projections for County Durham. The most recent are those contained in the Preferred Options Report of September 2012 (the document before the current Pre-Submission Draft). That Report acknowledged the long-term struggle for County Durham to stem net out-migration and to retain a stable population level in the face of significantly high death rates arising from an elderly population and severe health issues. A trend (i.e. no policy intervention) projection is displayed (496,000 in 2009 grows to 516,300 in 2030), and a Preferred Scenario is adopted which sets a target population level of 532,700 for the year 2030. Thus a target population growth of +36,700 (+7.4%) between 2009 and 2030 is adopted in the Preferred Options Report of September 2012.

However, the Council has now abandoned its own population projection model and has acquired a different model - ‘POPGROUP’ (developed by Bradford Council, the University of Manchester and Andelin Associates) just as the results of the 2011 Census have become available. The 2011 Census gives a significantly higher base population for County Durham than the estimate by Durham County Council previously used (513,000 in 2011 as compared to the County Council’s 496,000 in 2009). This is an uplift of 17,000 in the base figure.

Quite properly, the County Council accepts the new base figure. When used in the new projection model, the result is a much higher trend for 2030 of 560,700 and a much higher target for 2030 of 578,000, involving a population growth of +65,000 people. This is an uplift of +45,300 in the target, whereas the base only went up by +17,000. The new model clearly builds in a remarkable extra degree of potential population growth to the Plan. The Council has given no explanation as to why this is a better reflection of the demography of the County than the previous model. Any model that creates high net in-migration without intervention would appear to be wholly uncharacteristic of the County Durham experience. County Durham Local Plan Base year Trend Projection Target House- document population population population building

13 2030 2030 required by 2030 Preferred Options report, 496,000 516,300 532,700 +30,000 September 2012 (2009) Pre-Submission Draft Plan. 513,000 560,700 578,000 +31.400 October 2013 (2011)

The targets are constructed around a key aspiration of improving the Employment Rate from 66% currently to 73% by 2030. Before the 2008 recession, employment in County Durham was at the target now set by the Plan for 2030.

The Employment Rate in County Durham as recently as June 2007 was 72%. The document states that “In 2007, County Durham’s employment rate had steadily risen and achieved a level that was close to the national average. Since the 2008 recession, the County’s employment rate has fallen substantially so our principle (sic) aim is to achieve and maintain employment at around 73% of the economically active population by the end of the Plan period. This would return employment levels to those achieved in the mid 2000's and equates to the England & Wales average prior to the recession.” (Paragraph 2.8)

Several scenarios are explored to achieve these higher levels of employment. The conclusion is that, in addition to the high trend in-migration level predicted by the model (i.e. no policy intervention), there would need to be extra net in-migration of 15,000 people of working age. This is expressed in the Draft Plan as “attracting talented, skilled and educated people to the County” (paragraph 2.8).

The evidence that it will be possible to attract a specific population category is extremely doubtful. Indeed, there is no mechanism for ensuring that the in-migrants are of the desired working age. In addition, the Plan worsens the analysis in stating “A higher level of out- migration will occur if the population is too high relative to labour force or jobs targets.” (paragraph 4.25).

The Plan’s evidence on the relationship between employment rate aspirations and population growth are extremely unconvincing. Added to the doubts about the suitability of the large net in-migration basis of the population model, there is a very strong case for new population and household forecasts being undertaken and agreed before any consideration of other aspects of the Plan.

Housing and other development and infrastructure requirements

The development and infrastructure requirements resulting from the adopted population target appear to be excessive even by contrast with the forecast made a year ago. The Council predicted a trend growth of +20,300 people and adopted a target growth of +36,700 people, requiring +30,000 houses. Now, the County Council predicts a trend growth of +47,700 people and an adopted target of +65,000 people, requiring +31,400 houses.

This is a considerable upwards revision (+45,300) in the population growth. Surprisingly, however, roughly the same number of extra houses is required. Without this astonishing increase in the County Council’s population target, the number of extra houses required by 2030 would be about + 20,000 rather than +31,400.

This lower requirement is, as it happens, very close to the Friends of the Durham Green Belt’s submission last year in ‘Durham at the Crossroads’ that about 22,000 extra houses would be needed in County Durham by 2030 in a realistic, more moderate growth alternative

14 strategy. We continue to argue that about 20,000 extra houses for County Durham by the year 2030 is a better basis for planning than the County Council’s artificially inflated figure of 31,400.

The population and household targets for Durham City

We note that all five references in last year’s document to Durham City’s future role as being “the key driver of County Durham’s economy” have been removed. Now the references are to both Durham City and the other main towns in the County. However, the five references in last year’s document to Durham City becoming a “City of regional, national and international significance” are all retained in the current Pre-Submission Plan document.

This is of concern because the phrase is used specifically to justify increasing the scale of the City to achieve “critical mass”. This term “critical mass” is not defined, but appears to mean achieving the amounts and types of population, employment and tourism to enable Durham City to become a “City of regional, national and international significance”. On that basis, it seems that increasing the population of the City from 42,000 to about 55,000 is regarded as achieving ‘critical mass’ and therefore considered necessary as part of it becoming a “City of regional, national and international significance”. Hence the proposed addition of about 5,200 houses to the City.

The capacity of brownfield land in the City is estimated by the Council to be able to accommodate 1,200 dwellings. The Friends believe this is too low and there are more sites potentially available. The strategy adopted is to find 4,000 housing development sites in the countryside around the built-up area of the City and another 400 at Lambton Park Estate.

This surrounding countryside was formally designated with a permanent boundary in 2004 as statutory Green Belt where new housing development is not allowed except for genuine agricultural need. The County Council’s solution is to remove Green Belt protection from enough parts of the Green Belt to accommodate 4,000 houses.

We fundamentally disagree with that approach. We argue that Durham City is already of international significance, indeed of world significance with its World Class University and World Heritage Cathedral and Castle.

We further argue that enlarging Durham City from 42,000 people to about 55,000 people would achieve very little in improving its national and international significance. Cities such as London, Birmingham, Manchester, and Leeds certainly have that significance in terms of economic, commercial and political weight. The smallest of these, Leeds, has a population ten times that proposed for Durham City.

Certainly, Durham City’s unique assets should be used to enhance the quality, range and scale of employment opportunities for the whole of County Durham. However, in terms of population and housing it should grow within its natural limits, with no incursions into the Green Belt.

15 16 Objection to Policy 1: Sustainable development ______

Policy 1 fails to meet the government’s soundness tests as follows.

Positively prepared – Does the Plan meet development and infrastructure requirements and will it achieve sustainable development? Is the Plan the most appropriate strategy when considered against reasonable alternatives? Is it based on balanced evidence?

This Policy is Durham County Council’s most important policy in that it conforms in a comprehensive way to Government requirements on sustainability. If every part of the Plan and all its development proposals met, where relevant, the 18 criteria set out within it, then the Plan could be judged sustainable. This, however, is not the case, as most of the policies for development of housing and road building that appear in later policies in the Plan do not meet these criteria in full. The conclusion must be that many key development policies of the Plan fail the Council’s own sustainability criteria, or these criteria have been judged irrelevant, or more likely, inconvenient.

 Support the local economy and businesses. It is a key element of our objection that the Council’s intention to concentrate development opportunities on Durham City will deny opportunities to the local economies of other parts of the County. The Council has been unable to provide any evidence on the implications of a slower rate of growth of Durham’s economy. It, quite simply, refuses to consider the possibility, and therefore allows the possibility of unforeseen decline in the rest of the County.

 Protect the productive potential of the County’s agricultural land and forestry. The adopting of unnecessarily high housing needs forecasts has resulted in the identification of land on greenfield sites, which could have remained in agricultural use while brownfield sites are developed.

 Promote health, well-being and active lifestyles by protecting, maintaining, providing or enhancing green space and sport and recreation facilities, and protect, maintain and enhance the County’s biodiversity. The taking of Green Belt is just one aspect of the failure to recognise the importance of these criteria. The Friends of the Durham Green Belt made detailed proposals on these matters in the submission ‘Durham at the Crossroads’. These were in line with the NPPF on ‘the need to enhance the beneficial use of the Green Belt’ and centred on a proposal for a City Park which would further protect the openness of the Green Belt and assist in realising its potential to provide opportunities for the provision of community and visitor facilities and to protect wildlife. So far, the indications are that the Council’s overriding interest is in the potential of the Green Belt for development purposes rather than the purposes promoted here.

 Ensure that development takes into account the risks and opportunities associated with future changes to the climate, and minimise and reduce greenhouse gas emissions. There are fundamental differences between our proposals and those of the Council. We believe in moderate growth, the Council believes in a high level of growth. We believe in brownfield development and development in nearby towns and villages will be sufficient, the Council believes that greenfield sites are necessary. We believe in high density mixed housing within existing settlements, the Council believes in low-density peripheral housing developments for executives. We believe in serving developments with improved public transport, the Council believes that

17 relief roads are essential to successful housing development. We could not be further apart on the meaning of sustainable development.

Changes necessary to achieve soundness

 The policy as it stands is perfectly reasonable. The objection to it is that it appears to be a discretionary rather than a mandatory policy. It is clear from its application to various policies that different criteria can be set aside where they would rule out the County Council’s preferences for development. The change that is necessary is to that all policies must conform to Policy 1 if they are to be judged to be sustainable development. The policy is mandatory.

18 Objection to Policy 2: Spatial approach ______

Policy 2 fails to meet the government’s soundness tests as follows.

Policy 2 explains the concept of a ‘critical mass’ for Durham City. We have set out in the Population and Household Projections section of this report our reservations about this as a justification for this strategy.

At every previous stage in the preparation of the Plan, the County Council has put forward notional alternatives options of either A - Economic Growth or B - Regeneration. Alternative A sought to boost Durham City’s size to achieve ‘critical mass’. At every stage, the greatest support from developers and landowners has been for A, and from the public and amenity/heritage groups has been for B. The County Council has responded by favouring Alternative A. At the Preferred Options stage, when the County Council claims (paragraph 4.4 of the Preferred Options report) that the proposed spatial approach is a combination of the two options; it says, “Although the preferred spatial strategy more closely resembles Option A, it does incorporate important elements of Option B”. The Draft Plan continues to defend the building up of Durham City.

An important procedural weakness is that both alternatives offered are variants using the same high growth targets for population and house building in County Durham. No serious examination of reasonable alternatives, including Friends’ more moderate growth has been made.

Effective – Can the Plan be delivered in the period set out? Is it based on effective joint working between neighbouring local authorities to make sure regional strategic priorities are met?

The great risk in the proposed spatial approach is that overall population growth will be below the target sought in the Draft Plan, and that housing development will take place in the strongest market - Durham City. The resulting lower amount of house building in the rest of the County will fail to achieve the regeneration and renewal aspirations of the Plan for the County’s towns and villages.

Consistent – Is the Plan consistent with national policy? Will it enable sustainable development in accordance with the National Planning Framework?

The over-emphasis on building up Durham City results in major incursions into the Durham Green Belt, directly contrary to national policy.

Previous consideration of these issues These views have been expressed to the County Council at every stage and at every forum, including well-attended public meetings that we have arranged and lively correspondence in the newspapers. The County Council in Friends’ opinion has shown disregard to the concerns so widely and vigorously expressed.

19 Changes necessary to achieve soundness

To achieve soundness, lower growth population and housing projections should be included in the assessments. In any case, there should be a re-balancing of the distribution of new housing so that Durham City grows within its natural limits and, and that the other towns and villages can attract a reasonable share of new development in the uncertain times ahead.

Recommendations for Change to Policy

 The hierarchy of settlements included in the Policy is accompanied by text that concedes that growth in Durham City is more likely to dominate. In the event that growth is lower than the target for the County set by the Plan, the allocations in the City will all be taken up, and the allocations in the remainder of the County will fail to develop. The Plan must examine this more probable lower growth scenario to protect the interests of the rest of the County and protect the City from over-development. This would require major consequential changes to Policies 4, 6 and 8 and their accompanying reasoning.

20 Objection to Policy 3: Quantity of new development ______

Policy 3 fails to meet the government’s soundness tests as follows.

Policy 3 is based on un-realistic targets for in-migration and housing development. The evidence provided by the County Council for these targets appear selective and contradictory. The Council’s chosen growth targets result in wholly excessive amounts of house building for Durham City, thereby justifying major incursions into the Green Belt. The consequence of making such over-provision on Green Belt land will be the neglect of brownfield sites and the deprivation of the former colliery villages in the rest of the County where new housing development is essential to assist regeneration and the retention of their schools, shops, bus services etc.

Justified – Is the Plan the most appropriate strategy when considered against reasonable alternatives, based on appropriate evidence?

Policy 3 fails this test because it is not derived from an assessment of reasonable alternatives, including our moderate growth alternative contained in “Durham at the Crossroads”. Furthermore, it is not the most appropriate strategy based on appropriate evidence, given that the population trends, forecasts and targets are significantly over- stated.

Effective – Can the Plan be delivered in the period set out? Is it based on effective joint working between neighbouring local authorities to make sure regional strategic priorities are met?

Policy 3 fails this test because the evidence points clearly to moderate rather than high growth in population and therefore the strongest housing market areas, notably Durham City, will leave the rest of County Durham well short of the quantities of new housing development that the Plan seeks to deliver for them. On the question of effective joint working, the County Council’s evidence base paper on the Duty to Cooperate sets out what the Duty entails and how liaison meetings and protocols have been established. However, it is silent on whether there is agreement on the population and housing numbers and on regional strategic priorities; it merely lists individual County figures and county priorities.

The Plan envisages a minimum requirement of 31,400 extra houses being built in County Durham out of a total of between 107,500 and 126,600 for the seven local authorities in the North East. This is close to 25% of the higher total and more than 34% of the lower total. (Evidence Base Duty to Co-operate document, page 10). The accompanying text says, “in some instances it may be necessary to claw back economically active households from adjoining authorities”. This is competition rather than co-operation. The aim to accommodate between 25% and 34% of the region’s future house building is not commensurate with the 20% share of population that County Durham has at present.

Consistent – Is the Plan consistent with national policy? Will it enable sustainable

development in accordance with the National Planning Framework?

There is everything to be said in favour of reasonably ambitious targets, especially for County Durham, which has suffered the loss of virtually all of its basic industries and continues to display high levels of deprivation. It is right to seek to maximise the contribution that its great assets such as Durham City can make to giving hope and prosperity to the whole County. It is, however, unsound to attempt to achieve this by adopting unrealistic high population, employment and in-migration targets which ignore the actual prospects of growth in the region.

Previous consideration of these issues

The Friends of the Durham Green Belt raised these issues during previous consultation conducted in 2012 in relation to the Local Plan Preferred Options. However, there is no evidence that any consideration was given by the Council to representations made in support of a moderate growth option. In addition, the Pre-submission draft now presents revised and increased targets for house building and in-migration that further increase the amount of housing proposed in the Durham City Green Belt.

Changes necessary to achieve soundness

To achieve soundness, the population projection methodology, inputs and assumptions, particularly for net in-migration, should be assessed independently. As a result, replacement projections and targets should be agreed that correspond to the facts and the realities. It follows that the quantity of new house building should be re-calculated (taking into account the detailed critique of the City of Durham Trust). We suggest that the quantity of new homes should be closer to 20,000 rather than the 31,400 adopted in the Plan.

Recommendations for Change to Policy

 The number of new houses in Policy 3 should be revised downwards to around 20,000 to provide a better basis for planning.

22 Objection to Policy 4: Distribution of development ______

Policy 4 fails to meet the government’s soundness tests as follows.

For the reasons already presented, we consider that proposing 5,200 new houses in Durham City is the wrong strategy, and that reasonable alternatives should not have been dismissed, and that the evidence offered for the population and housing projections and targets is deficient.

The calculations of the quantity of housing sites in Durham City should include an allowance for ‘windfall’ sites and for bringing empty homes back into use. It should also allow for the release of former family homes back to the market as the existing properties converted to student accommodation become vacant. This will be the consequence of the University of Durham’s estates strategy (see Appendix A.4) of increasing significantly the proportion of students to be housed in purpose-built accommodation.

The material made available to the public does not evidence the treatment of brownfield land as potential housing sites; the Strategic Housing Land Assessment 2013 report only addresses sites that developers have put forward for consideration. As a result, many brownfied areas of land in Durham City have not been assessed.

Justified – Is the Plan the most appropriate strategy when considered against

reasonable alternatives, based on appropriate evidence?

As above under ‘Positively Prepared’,

Effective – Can the Plan be delivered in the period set out? Is it based on effective joint working between neighbouring local authorities to make sure regional strategic priorities are met?

As above under ‘Positively Prepared’

Consistent – Is the Plan consistent with national policy? Will it enable sustainable development in accordance with the National Planning Framework?

There is a failure to address brownfield land in the terms of the National Planning Policy Framework.

Previous consideration of these issues Raised explicitly in ‘Durham at the Crossroads and in correspondence with the County Council, but dismissed.

Changes necessary to achieve soundness

23 To achieve soundness, the table of housing sites should be amended to an allowance for smaller sites, brownfield sites, ‘windfall’ sites, re-use of empty homes, and family re- occupation of student conversions. The table should also be amended to reduce the quantity of housing sites required in Durham City.

Recommendations for Change to Policy

 The table in Policy 4 should be re-calculated following a comprehensive review of brownfield sites and allowances for ‘windfall’ sites, use of empty homes, and release of homes currently occupied as HMOs. If a more moderate growth target of 20.000 new houses for County Durham is used, then this will result in a considerably lower figure than the 5,220 calculated for Durham City and an appropriate adjustment to the provision in other towns and villages.

24 Objection to Policy 5: Developer contributions ______

Policy 5 fails to meet the government’s soundness tests as follows.

It is our contention that the Plan is unsustainable in respect of the housing and relief road package. It fails its own sustainability criteria in Policy 1 for development and Policy 48 for Delivering Sustainable Transport. Policy 5 has been used simply to provide evidence of the financial feasibility of the Council’s unsustainable vision.

Justified – Is the Plan the most appropriate strategy when considered against

reasonable alternatives, based on appropriate evidence?

The policy is perfectly reasonable. The obligation placed on developers to contribute to improvements in infrastructure capacity to cater for the additional needs they generate. These can be physical, such as roads, utilities and energy supply networks; or social, such as community buildings, education, health facilities, affordable housing, sport, recreation, employment or training opportunities. They can also be environmental, such as heritage assets, areas for wildlife and green infrastructure.

The source of our objection is the temptation put in the way of a Highway Authority that wishes to build roads. It is clearly stated in Policy 8 “the build out of Sniperley Park, North of Arnison and the housing allocation at Merryoaks is reliant on the delivery of the Western Relief Road. These three sites will be required to fund the Western Relief Road and associated highway improvements through the use of Section 106 and/or Section 278 Agreement”’. This statement is the origin of our belief that the unnecessary housing is dependent on the unsustainable roads, and the unsustainable roads are dependent on the finance from the unnecessary housing. The County’s own policies would suggest that higher density housing in areas already or capable of service by existing and improved public transport, possibly supported by developer contributions, would be preferable. It has never been considered.

Consistent – Is the Plan consistent with national policy? Will it enable sustainable development in accordance with the National Planning Framework?

The Plan is contrary to the NPPF guidance that requires plan should be community-driven. Instead, the attraction to a local authority of financing major infrastructure projects from developer contributions leads to the exclusion of community interests and preference for the views of major developers.

Our objection is that the Council is intending to harness developer contributions towards unsustainable ends.

25 26 Objection to Policy 6: Durham City ______

Policy 6 is where the County Council sets out the case for the requirement in Durham City for a critical mass of employment, to build on the opportunities and become a city of regional, national and international importance. It identifies approximately 23 hectares of employment land, 5,200 housing sites and 5,800 sq.m. of new convenience floor space and two relief roads. The Plan fails to meet the government’s soundness tests in every aspect of its assessment of the City’s past performance and potential.

The ‘Spatial Approach’ adopted by the Council for Durham City is based on a number of highly doubtful assumptions, predictions and assertions, the most contentious of which are:  the development and infrastructure requirements are based on aspirational growth targets for in-migration and housing development  the development package will be transformational and improve its status to become a city of regional, national and international importance  the City’s ‘competitive ranking’ with an over-reliance on public sector jobs, lies in the bottom half of national rankings because its development and growth has been limited as regeneration of the rest of the County has taken priority  two relief roads are necessary to ease congestion from natural traffic growth and to support the developments

These points reveal a narrow, property-investment driven interpretation of the City’s needs with serious consequences for the remainder of the County. Whilst growth of the economy and investment in improving infrastructure are one element of a possible future, they do not necessarily result in sustainable development as the policy claims.

An alternative vision is one that Friends put to the Council. It is based on an entirely different reading of the City’s future, based on the NPPF requirements and the Council’s own policies for sustainability:  more moderate employment and population forecasts would be a better basis for planning Durham City’s future  Durham City’s status as a city of regional, national and international status is already assured and development and infrastructure on the scale proposed will do little to improve it and is more likely to damage it  the City has not been deprived of employment growth resulting from a policy to regenerate other towns in the County. The most vital issue is that this initiative should continue and not be sacrificed to developer pressure for sites in and on the fringe of the City  the demand for wholly unnecessary housing sites and roads in the Green Belt are directly the result of artificially derived demand calculations

Justified – Is the Plan the most appropriate strategy when considered against reasonable alternatives, based on appropriate evidence? 27

The Friends of the Durham Green Belt argue that Policy 6 is not justified, as it has not been assessed against any alternative more moderate growth scenario. It also fails against the Council’s own policies for sustainability:

Policy 1 Sustainable Development appears to rule out the proposed package to facilitate development of some 4,400 new homes and the construction of two relief roads within Durham City Green Belt. The Council has a tightly written policy but an extremely loose interpretation of the sustainability principles set out within it.

Sustainability appraisals have been used to support the proposals rather than assess them independently. In Policy 6, it is admitted that the viability of Green Belt housing developments is dependent upon relief road construction, a combination that should and ought to fail any basic and independent test of sustainability. Furthermore, the package for Durham City can only result in a considerable increase in traffic generation and associated increase in carbon emissions which fails the sustainability test to be applied to new development ‘to minimise and reduce greenhouse gas emissions and other forms of pollution from new development’.

The moderate growth option of development within the City and surrounding towns and villages linked to sustainable forms of transport and travel can meet this criterion far more easily.

Policy 14 – the Green Belt has to accord with The National Planning Policy Framework (NPPF) paragraph 83 that, once established, Green Belt boundaries should only be altered in very exceptional circumstances, through the preparation or review of a Local Plan. The Council describes the ‘very exceptional circumstances’ in paragraph 1.5 of their paper entitled, ‘Durham City Green Belt Site Assessment Phase III’, September 2012, The exceptional circumstances in Durham’s case are stated to be the economic challenges which the County is currently experiencing and a requirement to meet housing need.

As demonstrated in the Friends’ response to Policy 3, the house-building targets set by the Council are aspirational and not based on projections of future housing need arising from natural population growth. It is clearly misleading to consider housing need as an ‘exceptional circumstance’ when such need might only exists if there is large-scale in- migration. In County Durham and in Durham City itself there is a need for affordable housing, and housing that suits the needs of older people, yet the policy for Durham City does not focus on these issues.

Durham County Council also presents ‘economic challenges’ as an exceptional circumstance for the County and a justification for development in the Green Belt. Newcastle, Sunderland, and Northumberland Councils have also sought to justify Green Belt development through a need to address exceptional economic circumstances. Economic challenges are clearly un-exceptional if faced by everyone and this justification appears to have been presented by numerous Councils in the North East and may herald a regional Green Belt grab, the cumulative/cross border impacts of which have been given no evident consideration.

‘Very exceptional circumstances’ prevailing within County Durham that justifies large- scale development within the Durham City Green Belt remains unproven. Policy 48 - Sustainable Transport is also unhelpful to the Council’s aspirations for the expanding of Durham City supported by roads investment. A sustainable travel future in any modern European city is one where public policy and investment is directed towards the shaping and support of public transport services essential to the quality of life of its residents

28 and experience of its visitors. A sustainable transport strategy requires the integration of public transport services in Central Durham into frequent, reliable and affordable services that are the transport of choice of the great majority. This is a challenge that will not be helped by the building of new relief roads. Building these roads to serve housing estates spatially separated from services such as shops, schools and most other amenities and this will simply increase car dependency and more car use, and does not maximise walking, cycling and other alternatives to private car ownership as required by the policy.

Effective – Can the Plan be delivered in the period set out? Is it based on effective joint working between neighbouring local authorities to make sure regional strategic priorities are met?

Policy 6 has been prepared without agreement with Neighbouring Councils to integrate their Development Frameworks. The authorities will therefore compete for in-migration. The Council, indeed, recognises that to achieve its targets for working age in-migration it may be necessary to claw back economically active households from adjoining households.

Competition for population growth will render all their Plans ineffective and wasteful. It requires intervention by Government to give credibility and effectiveness to the local plan preparation process.

Consistent – Is the Plan consistent with national policy? Will it enable sustainable development in accordance with the National Planning Framework?

Policy 6 is less consistent with national policy than the Moderate Growth alternative put forward by the Friends of the Durham Green Belt in respect of every principle as follows:

1. To empower local people to shape their surroundings and set out a positive vision. The Council has shown disregard to the Friends’ alternative and its attempts to open up a wider discussion on the future of the City. 2. To support sustainable development whilst protecting Green Belt and other heritage assets by using land of lesser environmental value including previously developed (brownfield) land. Policy 6 comprehensively fails this NPPF requirement whilst the alternative might well achieve it. 3. To drive and support positively sustainable development to deliver all types of development taking into account market signals etc. This one criterion most closely supports the Council’s strategy and the development industries’ preferences. 4. To take account of the different roles and character of different areas, promoting vitality of urban areas, protecting the Green Belts around them etc. The Council’s strategy again fails the test on Green Belt grounds and protection of the countryside. This is not the case in the moderate option, which seeks to give a positive role to the Green Belt by the designation of a City Park. 5. To support the transition to a low carbon future in a changing climate, reuse existing resources and renewable resources. This criterion is absolutely failed by the Council’s roads and Green Belt housing package compared with the Moderate growth option of brownfield higher density development served by integrated public transport. 6. To promote mixed-use developments and encourage multiple benefits in rural areas (such as for wildlife, recreation, flood risk mitigation, carbon storage, or food production). In addition, to conserve heritage assets so they can be enjoyed for their contribution to the quality of life of this and future generations. The Friends have taken this to be of prime importance in respect of the value of the Green Belt to provide these benefits and the setting of the World Heritage Site. The County’s

29 attitude has been to put ‘the very exceptional circumstances’ for breaking into the Green Belt before these requirements. 7. To manage patterns of growth to make fullest use of public transport, walking and cycling, and focus development in locations that are, or can be made sustainable. Our proposal for higher density housing in the City and for developments in the surrounding towns and villages meets this principle and furthers the cause of sustainable living in a far more comprehensive way than the car-based strategy of the Council. 8. To take account of and support strategies to improve health, social and cultural well- being for all, and deliver sufficient community and cultural facilities to meet local needs. The Moderate Growth alternative features a proposal for a City Park, which is intended to enhance the health, social and cultural value of the nearby countryside for both local people and visitors to the area.

These are two very different visions. The Council’s vision fails to accord with the NPPF criteria in nearly every respect whereas the Friends’ vision is designed with meeting the criteria in mind.

Previous consideration of these issues

These issues were raised during previous consultations conducted in 2012 in relation to the Local Plan Preferred Options by the Friends of the Durham Green Belt. However, there is no evidence that any serious consideration has been given by Durham County Council to representations made in support of a moderate growth option. In addition, the Pre- Submission Draft now presents revised and increased targets for house building and in- migration, which further increase the level of housing proposed in the Durham City Green Belt.

Changes necessary to achieve soundness

Policy 6 identifies the need to allocate space within the Durham Green belt for some 4,000 houses. To accommodate the traffic such house building will generate, the policy identifies the need for a Western and Northern Relief Road. To achieve soundness, this Policy must be overcome its incompatibility with the Plan’s key sustainability tests in Policies 1, 14 and 48.

Recommendations for Change to Policy  Policy 6 should be withdrawn to support a moderate growth option that prioritises the restoration and re-use of previously developed sites within existing settlements, rather than creating new car-dependent suburban estates in the Durham Green Belt.

 Proposals for the construction of relief roads within the Durham Green Belt should be replaced with a commitment to invest in a truly integrated transport infrastructure that provides a viable alternative to private car ownership.

Objection to Policy 7: Aykley Heads ______

Policy 7 fails to meet the government’s soundness tests as follows.

The proposed Strategic Employment Site covers both a group of existing major buildings, notably County Hall, and a large and very visible part of the Durham Green Belt. At the time that County Hall was built (50 years ago) and ever since, there has been a strict control over the development of the County Council’s Aykley Heads estate to ensure that key views to and from the Cathedral and Castle on the Durham Peninsula (now a World Heritage Site) were safeguarded. In particular, the paramount considerations have been that the historic core of Durham City with its magnificent Norman Cathedral rising above the town can be seen from all approaches to the city, and that the green countryside around the city is seen from every vantage point within the historic core.

It is for these reasons that the development briefs for office development on the County Council’s Aykley Heads Estate very carefully ensured that development sites were located beyond and below the skyline as viewed from the centre of the city. High quality, award- winning private sector offices have been developed there fully in accordance with the design briefs.

Equally, it is for those reasons that at Aykley Heads all of the open land that comprises the green backdrop to the city is statutory Green Belt under the Saved Policies of the City of Durham Local Plan 2004.

It is worth noting that proposals in earlier decades at Aykley Heads for private sector office developments on those open green areas that slope down to the railway line and the River Wear caused public resistance and the formation of the ‘Save Our City’ movement, which led to the proposals for office development being abandoned. The current Draft Plan is provoking the same public concern over its proposed office developments in the same Green Belt areas. The parts of the Aykley Heads Estate that are already earmarked for redevelopment provides the high quality strategic employment site envisaged by Policy 7.

Justified – Is the Plan the most appropriate strategy when considered against

reasonable alternatives, based on appropriate evidence?

There are several alternatives to developing the Green Belt part of the Aykley Heads estate for prestige office development. Mount Oswald golf course was designated for this very purpose in the City of Durham Local Plan 2004 although it now has outline planning permission for housing and student accommodation. Also within Durham City, there is the Belmont prestige offices site. Further, there is an approved strategic employment site at Durham Green at the Bowburn interchange on the A1(M) motorway, and the former Black & Decker European facility on the A167 at Thinford is being transformed with prestige office developments.

Effective – Can the Plan be delivered in the period set out? Is it based on effective joint working between neighbouring local authorities to make sure regional strategic priorities are met?

It is not yet clear whether the proposed 7.5 hectare site can be delivered and developed within the Plan period. The highway network could not cope in its present configuration. Proposals to build a new Centre for children with Special Needs on the main access road into to the upper part of the site bring into question whether heavy road traffic should come anywhere need that new school. In addition, there are issues over ecology and wildlife.

Consistent – Is the Plan consistent with national policy? Will it enable sustainable development in accordance with the National Planning Framework?

The proposal is for major office development in the Green Belt, directly contrary to national policy and repeated Government re-assurances that the Green Belt is safe.

Previous consideration of these issues We have made our views known to the County Council throughout the period of Plan preparation, to no avail.

Changes necessary to achieve soundness To achieve soundness, the Green Belt part should be removed from the proposed Aykley Heads Strategic Employment Site.

Recommendations for Change to Policy

 Amend Policy 7 and the Proposals Map such that the area of land designated as the Aykley Heads Strategic Employment Site excludes any part of the Durham Green Belt.

32 Objection to Policies 8, 9 and 10: Durham City strategic sites and relief roads ______

Policies 8, 9 and 10 fail to meet the government’s soundness tests as follows.

These policies to provide infrastructure for Green Belt housing are completely incompatible with Policy 1 on Sustainable Development. They will result in major impact on the existing Durham Green Belt, a significant increase in traffic generation and a consequent considerable increase in carbon emissions. It is therefore incompatible with Policies 14 (Green Belt) and 48 (Sustainable Transport). The policy directly threatens the achievement of sustainable development.

Although alternatives to building these roads have been tested against other infrastructure alternatives, the traffic model predictions adopted on car traffic growth do not take into account possible future scenarios of car ownership and use responding to increasing costs, or the impact of climate change mitigation, damage to wildlife and scarcer resources including agricultural land. In addition, the model did not test a lower growth alternative and thereby concludes that the roads are necessary to serve the Green Belt housing

The County Council traffic model uses assumptions and a methodology that tends to favour car-based solutions and cannot assist in the development of a sustainable transport strategy. This is evident in the conclusion in the Plan about the relief roads being more effective than investment in ‘softer’ transport’ proposals. The Plan sets out an integrated transport approach for Durham City which we support as far as it represents the beginning of a better approach to transport planning in Durham. However, these proposals are stated to be insufficient without the road proposals.

A small city such as Durham can and must turn away from building more road capacity and embrace sustainable travel solutions.

Justified – Is the Plan the most appropriate strategy when considered against reasonable alternatives, based on appropriate evidence?

A sustainable travel future in any modern European city is one where public policy and investment is directed towards the shaping and support of public transport services essential to the quality of life of its residents and experience of its visitors.

This is a challenge that will not be helped by the building of new relief roads. Building more roads simply encourages more car usage, Even more significantly, more road building is incapable of accommodating the officially predicted future growth in car usage and in road freight. So at some point it will be necessary to stop trying to accommodate more cars. Now is a good time to stop, before further damage is inflicted on Durham City and its surrounding landscape.

33 severed when it is becoming apparent that food shortages are a potential future threat to national security and well-being. The use of the network of footpaths that link the City to heritage sites such as Beaurepaire, Witton Gilbert Small Pilgrim Place, and to local villages, Bearpark and Ushaw Moor, is likely to be adversely affected.

The proposed Northern Relief Road is to be built at the end of the Plan period. Thus the County Plan is accepting that Durham City is going to have to manage without whatever relief the Northern Relief Road proposal might eventually bring. It is to be hoped that the County Council will drop its proposal irrespective of the fate of its proposals for large-scale exploitation of the Green Belt for housing. This proposal only serves to cast doubt over the County Council’s confidence in its own sustainable transport proposals to meet the City’s travel needs.

These road-building proposals will reinforce car dependency and damage the landscape character and potential of the Green Belt for recreation and leisure purposes.

The proposals for Relief Roads should be withdrawn from the Plan as unsustainable and unnecessary with future travel needs to be met by the Council’s own sustainable transport proposals. The Friends of the Durham Green Belt has proposed a reasonable alternative based on higher density housing on sites within the City and for development in the surrounding towns and villages in the cause of more sustainable living through investment in integrated public transport including the development of shuttle bus services, safe by-ways and cycleways, and the reopening of the Leamside to Ferryhill Branch Lines to Tyneside and Teesside. The County Council has not explored this alternative.

A moderate growth alternative has not been tested and the Plan should proceed no further without it.

Effective – Can the Plan be delivered in the period set out? Is it based on effective joint working between neighbouring local authorities to make sure regional strategic priorities are met?

To base the Plan on the construction of two relief roads to serve a small city the size of Durham during a period of severe restraint on public expenditure appears to be extremely risky, unless the full costs can be met by developer contributions, a possibility which again is at the limits of probability. Cooperation in future with neighbouring authorities is likely to prove that expenditure in the conurbations in public transport systems has a far higher priority than the construction of roads, which serve no higher purpose than to serve housing sites.

The road building proposals are a high-risk gamble, which could be avoided by incremental development of higher density housing in existing settlements linked to sustainable transport provision.

Consistent – Is the Plan consistent with national policy? Will it enable sustainable development in accordance with the National Planning Framework?

These policies are inconsistent with national policy as set out in NPPF Principle 6, which requires the Plan ‘to manage patterns of growth to make the fullest use of public transport, walking and cycling, and focus significant development in locations which are, or can be made sustainable. The road proposals are also contrary to Principle 4, which requires the Plan ‘to support the transition to a low carbon future in a changing climate, reuse existing resources and renewable resources’.

34 The pattern of growth preferred by the County Council creates a dependency on relief road provision. Thus, the unnecessary housing in the Green Belt requires the unsustainable roads, and the unnecessary roads need the financial contribution from the housing developers. It is an unsustainable package presented as sustainable development

The traffic model uses forecasts of increasing demand for travel using the private car, and therefore it is impossible to meet the transition to a low carbon future. A far more radical model based on the provision of sustainable transport is necessary to achieve this.

The Plan to build relief roads around Durham is completely inconsistent with national policy to manage development and transport to support the transition to a low carbon future

Previous consideration of these issues

The Friends of the Durham Green Belt presented a case against the inclusion of the relief roads in the earlier report ‘Durham at the Crossroads. At that time, we said ‘The relief road proposals are not presented as part of the Transport and Infrastructure chapter (where the sustainable transport proposals are set out). Thus, the unsustainable parts of the Plan are brought together and mutually reinforce each other; the unnecessary housing needs the roads and the unnecessary roads need the justification provided by the housing. It is our contention that such roads cannot be justified without employing the widely doubted DfT forecasts. These are based on looking backwards to periods of considerable traffic growth in the 1990s, and not forward to a more difficult economic future with greater scarcity and cost of fuel, and the stark realities of climate change. We invite the County Council to share our view that that the concentration of housing development within the City and its surrounding towns and villages will favour investment in its own sustainable transport proposals and render unnecessary the huge and damaging investment in the roads which serve to undermine the credibility of the sustainability of the County Plan’.

Changes necessary to achieve soundness

To achieve soundness, this Policy must be compatible with the Plan’s key sustainability tests in Policy 1 and Policy 24

Recommendations for Change to Policy

 A sustainable transport strategy requires the integration of public transport services in Central Durham into frequent, reliable and affordable services that are the transport of choice of the great majority. This is a challenge that will not be helped by the building of new relief roads

35 36 Objection to Policy 12: Executive housing allocation ______

Policy 12 fails to meet the government’s soundness tests as follows.

This policy provides for 400 housing units at Lambton Park Estate “to meet a need for executive housing and to encourage economic growth in the County”. This number is questionable given that the Plan states “There is no clear evidence to quantify the specific number of executive homes which should be provided over the Plan period” (paragraph 4.181).

The Council examined a number of sites put forward by landowners and potential developers. The single site chosen is in the Durham Green Belt and in an area which is recognised to have a historic parkland character. It is claimed that a justification is that the proposal will secure the restoration and maintenance of Lambton Park for future generations. The Plan provides no evidence of the impact of the development on the Green Belt in terms of the five purposes of the Green Belt. Furthermore, there is no evidence of the impact the new housing would have on the historic parkland landscape.

In Policy 31 – Addressing Housing Need - all new housing proposals will be required to provide a percentage of ‘Affordable Housing’. The Lambton Park Estate developers are to provide funding towards affordable housing elsewhere, as the site is not considered suitable for this type of development. This is clearly a failure to recognise that sustainable development has not only physical dimensions, but also economic and social qualities. To exclude social housing from the site may well be a simple preference by the developer not to cater for such developments rather than the unsuitability of the site itself. We believe that this policy is an unsound in its encouragement of a development, which refuses to embrace the benefits of creating balanced communities on land that should remain open in perpetuity.

Consistent – Is the Plan consistent with national policy? Will it enable sustainable development in accordance with the National Planning Framework?

In line with our objection to Policy 14, this policy is a further example of the Council’s willingness to set aside national policy on Green Belt in the cause of providing executive housing. The Glossary to the Plan gives a full definition of the nature of affordable housing but there is no definition of executive housing, or indeed what is an executive. As a significant part of the Council’s vision is that executive housing is necessary to attract economically active people to the County, then there should be such a definition in the document.

We object to Policy 12, as it sets aside other policies in the Plan to accommodate executive housing and specifically because the Green Belt is to be sacrificed. Even if that objection was overcome, it remains contrary to Policy 31 that requires that affordable housing should be provided on all suitable sites. The size of the site must be sufficient to accommodate affordable housing.

37 Justified – Is the Plan the most appropriate strategy when considered against reasonable alternatives, based on appropriate evidence?

There is no adequate justification in the Plan to support the selection of a single site of this scale in the Green Belt. Given the range and number of other possible sites to consider, it is probable that an acceptable site outside the Green Belt could have been selected.

Previous consideration of these issues

Friends of the Durham Green Belt before have not raised this specific issue.

Changes necessary to achieve soundness

To achieve soundness, there should be a reconsideration of the Council’s intentions to break national and its own policies on Green Belt, historic landscapes and affordable housing in order to provide for executive housing.

Recommendations for Change to Policy

 A site or sites outside the Green Belt should be chosen.

38 Objection to Policy 14: Green Belt ______

Policy 14 fails to meet the government’s soundness tests as follows.

The Review Process The Durham Green Belt boundaries were approved in 2004 and continue in force as part of the statutory ‘Saved Policies’ of the City of Durham Local Plan 2004. These boundaries were drawn up, examined at a Public Inquiry and confirmed by the Secretary of State in 2004 as satisfying the test of providing permanence in the long term.

The publication of a new local plan provides the opportunity to review the Green Belt boundary in the saved policies of the 2004 Plan. The County Council, instead of the recommended approach to reviewing the boundaries, has adopted a view that the boundaries must be changed to accommodate the development it deems necessary. Far from assessing the value of the Durham Green Belt, it has mounted a search for 4,000 new housing sites by identifying the ‘least worst’ strategic housing sites i.e. those which are thought to cause the least harm to the integrity of the Durham Green Belt.

Indeed, paragraph 4.198 openly states “The strategic sites within Durham City were identified following a detailed assessment of constraints including landscape to ensure that the impact on Durham City’s special character and the World Heritage Site was minimised (our emphasis).”

We consider that in adopting this approach, the Council has misapplied the procedures for reviewing the Green Belt boundaries in order circumvent a comprehensive assessment that might rule out boundary changes and the reasons given for such changes.

The Case for Changing the Boundaries

The case for change to the boundaries is found in the five references in last year’s Preferred Options document to Durham City becoming a “City of regional, national and international significance”. These are all retained in the Pre-Submission Plan. The term “critical mass” is not defined, although it is the reason given for the levels of population, employment and tourism to be accommodated to enable Durham City to become a “City of regional, national and international significance”. Increasing the population of the City from 42,000 to about 55,000 is said to be needed to achieve ‘critical mass’ and transforming Durham into a “City of regional, national and international significance”. This has a serious consequence of proposing the addition of about 5,200 houses to the City.

The Council assesses the existing housing site capacity of the built-up area of the City to be capable of accommodating about 1,200 dwellings (The Friends of Durham Green Belt believe this to be an underestimate). The overestimate of need and the under assessment of existing capacity leads to a strategy with 4,000 housing sites in the countryside around the built-up area of the City. The County Council’s solution is to remove Green Belt protection to accommodate 4,000 houses.

The Friends fundamentally disagree with that approach. Durham City, for many years has been of ‘regional, national and international significance’ by virtue of its world class

39 University and World Heritage Site Cathedral and Castle. The contention that by increasing population from 42,000 to about 55,000 would transform it to ‘national and international significance’ is not credible and must be challenged as being the fundamental reason for expansion of the City beyond its natural boundaries.

Certainly, Durham City’s unique assets should be used to enhance the quality, range and scale of employment opportunities for the whole of County Durham. However, there is no justification for the City to grow beyond its natural limits, and no case for changing the boundaries of the Green Belt to do it.

Justified – Is the Plan the most appropriate strategy when considered against reasonable alternatives, based on appropriate evidence?

The Draft Plan seeks to justify its proposals for strategic housing sites totalling 4,000 houses in the Green Belt by arguing that the economic circumstances when the Durham Green Belt was designated are different to the pressures currently being faced. This ‘justification’ set out in paragraphs 4.197 to 4.203 is that private development finance is needed which require sites that are the most attractive to private finance. Durham City is the County’s strongest market area for house-building and therefore strategic housing sites must be located in Durham City’s Green Belt.

The Friends consider that the housing market should serve the needs of the Local Plan rather than the reverse. Given the strength of the Durham City housing market as evidenced by the popularity of housing there and the significantly higher prices than the rest of County Durham, the Plan should emphasise the benefits of re-using land that has been previously developed (brownfield sites), Brownfield land is more expensive to develop; developers normally will avoid damaged or derelict land when there is much more easily developed land available. Making a plentiful supply of Green Belt land available will inevitably affect the regeneration prospects of other parts of the County, but also the prospects of redeveloping sites in Durham City.

The Friends have requested that the Council to undertake a review of all brownfield sites and to carefully explore if 2,000 or so extra houses rather than 5,200 will serve the needs of Durham and allow it to continue to develop and thrive within its natural boundaries. There has been no effective response.

Consistent – Is the Plan consistent with national policy? Will it enable sustainable development in accordance with the National Planning Framework?

The National Planning Policy Framework paragraph 84 states “When drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. They should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary.” Before volunteering the Durham City Strategic Sites and Non-Strategic sites in the Green Belt, the County Council should have evaluated the combined impact including the specific assessment against the five purposes of the Green Belt. The Durham City Green Belt Assessment Phase 2 fails to provide adequate evidence that the sites have been scrupulously assessed according the criteria in NPPF, and a thorough assessment of sites in urban areas inside the Green Belt boundary and beyond the Green Belt boundary.

40 Paragraph 4.200 of the Pre-Submission Plan says, “‘As a result new development will be directed to locations that are attractive to the development industry but will deliver regeneration and economic growth. Partnership working with the development industry has enabled the most deliverable sites and locations to be identified.” We believe that this approach is not consistent with the NPPF core principle of “…genuinely plan-led empowering local people to shape their surroundings…” Instead, the Plan places much greater weight on the views of developers than on the people of Durham City and County.

Insofar as national policy includes assurances from the Prime Minister and relevant Ministers, the Green Belt should be ‘sacrosanct’. For Durham County Council to be proposing significant expansion of Durham City into the Durham Green Belt suggests that it attaches a far lower value to it.

There has been no review of the Green Belt area and boundaries in their own right as specified by the National Planning Policy Framework. The National Planning Policy Framework (NPPF) specifies that such reviews should be carried out in Local Plans in terms of the five objects of a Green Belt: 1. Stopping urban sprawl 2. Preventing coalescence of settlements 3. Safeguarding the countryside from encroachment 4. Protecting the setting of historic towns 5. Encouraging urban regeneration Such reviews are required to have regard to the intended permanence of the boundaries in the long term, so that they should be capable of enduring beyond the plan period.

Instead of a review under these terms, the assessments carried in the Plan have been merely to identify strategic development sites which are least damaging to the integrity of the Green Belt. The dangers of this approach is that there will always be another site which can be argued to be a special case that breaks the Policy in a similar way to the currently proposed sites. Furthermore, there has been no such assessment of the non-strategic development sites; these were assessed on the basis simply of their impact on the openness of the existing Green Belt. Therefore, the County Council has created two different approaches to assessment, one for the strategic sites identified by the Council and one for the non-strategic sites identified by private landowners.

Previous consideration of these issues Our views have been expressed and disregarded at every stage of preparation of the Plan and notably in our ‘’Durham at the Crossroads’ report which is appended

Changes necessary to achieve soundness The Plan process should have included a comprehensive review of the Green Belt. Instead of this, a limited exercise to identify housing development sites with the least impact was carried out. The consequence is that the Plan is unsound without the full Green Belt and brownfield sites review process being undertaken. The Plan must therefore be withdrawn.

Recommendations for Change to Policy

 The Proposals Map needs to be re-drawn to retain the existing statutory boundaries pending a full review of the Green Belt as is required in national policy.

Objection to Policy 30: Housing land allocations ______

41 Policy 30 is a consequential policy that results from the housing requirements and distribution set out in Policy 3 (Quantity of Development) and Policy 4 (Distribution of Development). It fails to meet the government’s soundness tests as set out in the Friends’ objection to those policies.

This Policy provides the detailed description of all potential housing sites considered suitable for development. For the reasons already set out under Policies 3, 6 and 14, the major housing proposals within the Durham Green Belt are not considered to be justified, and alternatives such as a more moderate growth alternative have not been properly considered. In addition, the schedules of housing sites include existing housing commitments above a size of 0.4 hectares. Therefore, a sizeable and important component of potential sites has not been included and therefore Policy 30 gives a misleading impression of the total potential within the City.

Effective – Can the Plan be delivered in the period set out? Is it based on effective joint working between neighbouring local authorities to make sure regional strategic priorities are met?

If these sites in Central Durham that are relatively easy to develop and sell, i.e. the Green Belt sites, are used early in the Plan period then many sites in other towns and villages, together with brownfield sites within Durham City, are likely to remain undeveloped.

Previous consideration of these issues The Friends of the Durham Green Belt have commented on all the Green Belt sites except for the newly introduced ‘Durham Northern Quarter’ site H5 and the Merryoaks site H8 (the latter justified in the text as “contributing to the funding of the Western Relief Road”). Both of these areas were considered by the County Council up until the publication of the Pre- Submission Plan as essential to the integrity of the Durham Green Belt. This casts doubt over the reliability of the Council’s assessment of the suitability of Green Belt land for development. Evidently, new proposals from developers have been received and been given sympathetic consideration. This is an alarming consequence of the Council’s approach to Green Belt review in that there can always be another site which can meet the newly relaxed conditions that now allow exceptions to Green Belt policy.

Changes necessary and recommendations to achieve soundness

The changes to Policy 30 necessary to achieve soundness are:

 the rejection of the Green Belt allocations pending a full review of the Green Belt boundaries

 the schedules of housing land allocations should include allowance for sites smaller than 0.4 hectares and other potential sites e.g. windfall sites.

Objection to Policy 32: Houses in Multiple Occupation and student housing ______

42 Policy 32 fails to meet the government’s soundness tests as follows.

The Plan now includes a Policy on student accommodation, which is welcome, but this needs to be expanded to include at least one major site for purpose-built student accommodation. The policy will fail to achieve sustainable development unless additional measures are taken to control the creation and location of student accommodation in Durham City.

Justified – Is the Plan the most appropriate strategy when considered against reasonable alternatives, based on appropriate evidence?

This new Policy is welcome in principle and intention. However, it only relates to the standard definitions of HMOs requiring planning permission, whereas what is needed is an Article 4(2) Direction that enables the planning authority to determine all proposals for new build or conversions that increase the numbers of students in a locality. The County Council’s evidence base on the extent of HMOs is admitted to be incomplete and therefore the policy lacks an adequate baseline from which to monitor its effects.

Effective – Can the Plan be delivered in the period set out? Is it based on effective joint working between neighbouring local authorities to make sure regional strategic priorities are met?

In its current form, the Policy will not be effective and sufficient to achieve more balanced communities in Durham City during the Plan period. The policy and supporting text make no mention of the issuing of an Article 4(2) Direction. Where an Article 492) Direction is in effect, a planning application may be required for development that would otherwise have been classed as permitted development. Article 4(2) directions have been issued by numerous Councils across the country to require planning approval for conversion of properties into HMOs that house fewer than 5 occupants (necessitating adoption of a locally meaningful HMO definition).

Without issuing an Article 4(2) Direction, conversion of properties to HMOs with fewer than 5 occupants would remain permitted development and not require planning permission. These kinds of HMOs make up the large majority of HMOs in the City with an estimated 1,300 properties, against some 300 licensed HMOs.

Furthermore, the policy in its current form does not seek to influence physical location of college building and conversion of large existing buildings into student residences. This issue is of considerable concern to residents of Durham City, as there are currently a number of on-going planning applications that if successful would result in construction of new residential buildings on previously developed land within the city centre, and conversion of large buildings into student accommodation. In these cases, this further damages the balance of communities in the City as opportunities on brownfield sites to create homes for permanent residents are lost.

It should be noted that the Universities and large providers of student accommodation are exempt from HMO Licensing by virtue of paragraph 4 of Schedule 14 to the Housing Act

43 2004, and so Policy 32 in its current form would have no influence on the spatial distribution of such large-scale student accommodation applications.

Previous consideration of these issues These issues and many other related concerns were raised by Friends and others during previous consultations. The issue of student accommodation over many years has given rise to major concerns affecting the University’s brand as a collegiate institution, the role of landlords and the well-being of local residents. The issue has been documented in authoritative reports including those referenced in Appendix A.4. We are pleased that a policy on the issue has now been put forward, and it is to be hoped that the Council (and the University) will develop and strengthen the scope and effectiveness of these essential controls by accepting the comments being made on this Pre-Submission Draft Plan.

Changes necessary to achieve soundness

To achieve soundness, the Plan needs to be more specific about providing for student accommodation in Durham City within the framework of fostering balanced and sustainable communities. This can be achieved by an adjustment to the proposed Policy 32 as detailed below, together with associated measures and detail on how and where Policy 32 will be applied. The County Council’s proposed ‘Houses in Multiple Occupation and Student Accommodation Supplementary Planning Document’ will be the appropriate vehicle for this additional detail.

Recommendations for Change to Policy

 include specific proposals for at least one major site for purpose-built student accommodation;

 include a commitment to introduce an Article 4(2) Direction for Durham City to create a local definition of an HMO as housing 3 or more residents, with a map defining the area that the Article 4(2) Direction covers.

44 Objection to Policy 48: Delivering sustainable travel ______

Policy 48 fails to meet the government’s soundness tests because it has been rendered in effect meaningless by the unsustainable and costly road proposals for Durham City, which encourage car ownership and car use. Proposals for the construction of relief roads within the Durham Green Belt should be replaced with a commitment to invest in a truly integrated transport infrastructure that provides a viable alternative to dependency on private car use. If the County Council reconsiders its strategy, then Policy 48 will be useful in identifying a pattern of growth that makes the fullest use of public transport, walking and cycling, and focuses development in locations, which are, or can made sustainable.

This policy has been included as “it is crucial that the Council, developers and other stakeholders deliver sustainable transport choices as development sites come forward via the planning system” (paragraph 9.9 of the Draft Plan). This Policy requirement has already been subverted in earlier policies when road proposals have been made on the basis that they are necessary to unlock the major housing developments proposed in the Plan. This extraordinary state of affairs suggests that the Council has a sustainable transport policy but will only implement it in full if it does not conflict with its intentions to allow the development of the major sites in the Green Belt. This is a similar weakness to that seen in Policy 1 on Sustainability.

The ‘Travel Assessment’ along with a ‘Travel Plan’ (T.P.) which seeks to change travel behaviour will be required before approval will be given. The T.P. ‘should reflect the scale of development and the extent of the transport implications of the policy’. This would be a reasonable proposal if the Council had already assessed those implications and found them favourable before proposing the major housing developments in the Plan. Our concern is that any assessment of this kind would find that the construction of two major relief roads to assist peripheral development of a small urban area such as Durham City could not pass any significant test of sustainability.

The lack of an alternative to the County Council’s high growth strategy is once again the source of embarrassment of the Plan’s sustainability credentials. A more moderate growth option would much more easily meet any such test of sustainability by focussing housing development in existing urban areas where public transport is already provided and can be improved along with cycling and walking infrastructure.

Our objection is therefore that Policy 48 has already been rendered ineffective by the adoption of a development strategy where the most important proposals are car- dependent. The County Council’s major development proposals, therefore, cannot meet the tests of sustainability set out in Policy 48.

Consistent – Is the Plan consistent with national policy? Will it enable sustainable development in accordance with the National Planning Framework? 45

The NPPF requires that the Plan should manage patterns of growth to make the fullest use of public transport, walking and cycling, and focus development in locations, which are, or can made sustainable. The Green Belt sites selected fail to meet this requirement comprehensively whereas our proposal for higher density housing within the City and for development in the surrounding towns and villages meets this principle. Supporting public transport investment and integration should further the cause of sustainable living. We also propose investment in safe byways and cycle routes and the development of shuttle bus routes to villages. The reopening of the Leamside and the Ferryhill Branch Lines to Tyneside and Teesside respectively meet this principle meet this principle, unlike car-dependent development in the Green Belt.

Previous consideration of these issues

The Friends of the Durham Green Belt has already proposed a different model for travel in the City in our submission ‘Durham at the Crossroads’. We challenged the County Council’s procedures in that its assessment showed that ‘a congestion charge and bus subsidies were potentially the most effective in reducing traffic’ before dismissing these measures on grounds of cost and diverted trade. It was, and is our contention that if the £31.5 million for the Western Relief could be committed to sustainable transport initiatives, then such measures would become possible. We also proposed that Durham City and its surrounding villages should be treated as one travel zone with fully integrated travel services and new facilities such as Park, Walk and Ride sites. Our proposals for the exploitation of the Durham Green Belt as a City Park and landscape would fit in well to a new model for travel. Interconnected paths and trails for walking, cycling and riding would be used for journey to work and school, and for leisure and tourism. The County Council in considering our document did not feel it necessary to test any of our proposals.

Changes necessary to achieve soundness

We consider that the Plan is deficient in that it has not considered a new model for transport that reflects the need to develop sustainable transport policies in association with its development proposals. To achieve soundness, the road proposals have to be withdrawn and new proposals developed based on more moderate growth and an integrated transport plan for the City based on sustainable modes of transport.

Recommendations for Change to Policy

 Policy 48 can remain in the Plan only if its intentions are implemented in the development strategy. If the County Council reconsiders its strategy, then Policy 48 will be useful in identifying a pattern of growth that makes the fullest use of public transport, walking and cycling, and focuses development in locations, which are, or can made, sustainable.

46 APPENDICES ______

A. 1 Friends of the Durham Green Belt pro-forma letter of objection

A.2 Newspaper report of public meeting addressed by Jonathon Porritt, 4 July 2012

49 A.3 Friends’ leaflet about the Pre-Submission Draft Plan

A.4 Other key documents relevant to Friends’ submission

Durham Area Action Partnership Housing Task Group Report, July 2102.

Studentification as an Extended form of Gentrification; a Durham Case Study, Samantha Oakden, University of Durham, June 2008.

University 0f Durham Residential Accommodation Strategy, 2012 to 2020, July 2012.

51 A.5 Durham at the Crossroads

DURHAM AT THE CROSSROADS

A response by the Durham Green Belt Group

to the County Durham Plan

Preferred Options Report (September 2012)

Page A Response to the County Plan 4

The Case for the Green Belt 6

A positive vision for the future 6

Planning for moderate growth 9

Two contrasting visions 12

The Case in Detail - Fulfilling Durham’s Potential 14

The potential for a strong knowledge-based economy 14

The potential of housing policy to enhance the viability of communities 15

The potential for travel demands to be satisfactorily met 20

The potential for open access for recreation and healthier lifestyles 20

The potential of tourism 23

Appendices

Appendix A. Population and housing 25

Appendix B. Brownfield sites 28

Appendix C. Transport 29

Appendix D. Tourism potential - some facts and figures 30

Appendix E. A short history of the Durham Green Belt 31

Cover: The route of the County Council’s proposed Western Relief Road through the countryside of the Browney Valley in Durham’s Green Belt.

54 A Response to the County Plan ______

The Durham Green Belt Group welcomes the opportunity to respond to the Preferred Options report and congratulates the County Council on producing such a clear and well- presented suite of documents.

We are generally in agreement with the intentions of the County Plan and, in particular, support the need to greatly improve County Durham’s economic prospects and social well-being. We do, however, challenge the assumptions on which the high levels of employment and population growth, housing targets and traffic growth have been based. The resulting large land allocations and major road proposals within the Durham City Green Belt that the County Council believes to be essential to the County’s economic growth, has led us to offer an alternative which has been prepared with the latest advice in the National Planning Policy Framework (NPPF) 2012 in mind. This alternative, based on more moderate growth assumptions, seeks to bring the benefits of development in all its forms to existing communities in the City and its surrounding villages. In our view, this is more realistic and more sustainable and a better basis for planning.

We trust that the County Council will not brush aside this contribution on the future of Durham City. Support can be found in the NPPF, which states that it is important ‘to empower local people to shape their own surroundings’ and to set out ‘a positive vision for the future of the area’. Whilst the County Plan has high aspiration, it lacks a vision of how we might cope with living differently in a world where the climate is changing, resources are fewer and ‘business as usual’ is not an option.

The County Plan shows that Durham is ‘at the crossroads’. The Plan points confidently in one direction; we think that the County Council has read the signs incorrectly. There is another and better way. That way is to adopt a more moderate growth option.

The Moderate Growth Option is characterised by:

 Adopting a more realistic ambition for future population and employment levels at a more appropriate scale for Durham and its Green Belt but, nevertheless, more than sufficient to maintain future prosperity

 Making future housing allocations primarily on brownfield sites rather than in the Green Belt, and planning to remedy the serious distortion of the housing market and the deterioration of living conditions caused by student occupation

 Providing an achievable balance in Central Durham between the City (2,200 new dwellings) and other towns and villages (3,610 new dwellings) without breaking Green Belt policy

 Setting the framework for identifying the potential for high quality regeneration and development in the larger village groupings on Garden City and Garden Suburb principles as part of the neighbourhood planning process

 Maintaining the ban against developing the Mount Oswald site for general housing and thereby avoiding the consequence of allocating Green Belt land at Aykley Heads to compensate for the loss of a prime employment site allocation

 Avoiding the need for the construction of the Western and Northern Relief Roads by adopting more realistic traffic growth forecasts, the abandonment of suburban car-dependent housing development, the provision of infrastructure for new public transport, cycling and walking, and the full integration of and reorganisation of public transport services provision

 Protecting and developing the Green Belt as an informal City Park with paths and trails to link the City and the villages and the attractions by walking and cycling for journey to work and school, for leisure and sport, and to encourage wildlife conservation, tourism, local food production and small scale energy generation

 Declaring that the Green Belt, the most widely understood and popular of all planning policies, should remain intact and its value as a setting for the City and its World Heritage Site remain undisturbed

56 The Case for the Green Belt ______A positive vision for the future

The strategy set out in the Preferred Options Report is based on what may well prove to be an unrealistically high aspiration for economic growth and matched population growth. Indeed, in its optimism, the County Council has had to set aside its own projections for population and economic growth (see Appendix A on page 25). It has resulted in proposals to expand the City into its Green Belt in order to find land for large scale housing sites, employment and road building.

We question a vision that regards the Green Belt to be an impediment (and hence a necessary sacrifice), to growth and prosperity. Our view is that the Green Belt defines the natural boundary of the City. It is a precious area of countryside that acts as the lungs of the City. It should be protected and can be enhanced by adopting more moderate growth aspirations. We have been drawn to an alternative vision and invite comparison between the two: the Council’s Option D (which we describe as the High Growth option) and a Moderate Growth option, as presented by this Group.

The High Growth Option proposes a level of employment and population growth that is unprecedented, and probably unlikely to be realised, especially in a period of severe national economic uncertainty. The Green Belt Group argues that it is unnecessary and unwise to propose this level of demand for housing sites, coupled with road building.

We invite Durham County Council to respond to the following five questions.

Would a more moderate level of growth be a better context for future planning in Central Durham? The County Council should plan for a more realistic level of population growth. County Durham has done extremely well just to halt decades of population loss, and actually managed briefly to rise in population to 500,000 in 2007, before the recession tipped it back to decline to 496,000 in 2009. The County Council’s trend population projection to 516,300 in 2031 itself appears to be very questionable (see graph on facing page), a population increase of 20,000.

The County Plan’s Trend Projection requires net immigration of 24,000 to offset the predicted natural decrease (more deaths than births), A far more plausible figure for any population increase would be more like 10,000, giving a population of about 506,000 in 2031. We suggest that the credible range of population levels in 2031 in County Durham is between 506,000 and 516,000.

Clearly, the Plan should aim to provide sufficient numbers and types of housing to accommodate the likely range of future population levels. Our opinion, based on the evidence of the County Council’s own figures, is that a population of 506,000 can be accommodated readily within well- established planning principles, and a higher figure than this – perhaps as high as 516,000 – can be an aspiration without the need to break into Durham’s Green Belt.

We therefore regard the County Plan’s aspiration for the population to grow to 532,700 by 2031 as wholly excessive. We suggest an upper population figure of 516,000 in 2031. Whilst this would still

57 seem to be optimistic, it would scale down the demand for housing sites (and associated road needs to serve them) in Central Durham.

Would moderate growth be sufficient growth? Durham’s Green Belt has been very effective in containing the outward spread of the City. It has also ensured that previously used land is redeveloped, and for continuous regeneration of the outer towns and villages to take place. It has been a successful strategy and one which we would urge the County Council to examine again. A Moderate Growth option would require 2,200 new dwellings which could be accommodated, by our estimate, within the City. The remaining demand for 3,610 dwellings can and should be built on sites in the surrounding towns and villages in Central Durham.

Moderate Growth, nevertheless remains a growth option which should be sufficient to drive prosperity in the City and its surrounding towns and villages. It has the advantage of respecting the natural limits of the City and avoiding outward sprawl. It would continue the redevelopment of previously used sites in the City compared with less sustainable suburban housing.

How can two relief roads form part of a sustainable transport plan? The relief road proposals are not presented as part of the ‘Transport and Infrastructure’ chapter (where the sustainable transport proposals are set out) but are included within the ‘Strategy’ chapter of the County Plan. Thus the unsustainable parts of the Plan are brought together and mutually reinforce each other; the unnecessary housing needs the roads, and the unnecessary roads need the justification provided by the housing.

58 Evidence suggests that the case for road building has weakened, although the Government recently has seen it as an opportunity to stimulate the construction industry. Thus many so-called ‘zombie roads’ –‘they just keep coming back from the dead’ – have reappeared recently and, amongst them, are the two relief roads on a longer list of such roads published by the Local Government Association.

It is our contention that such roads cannot be justified without employing the widely doubted DfT forecasts (see page 18). These are based on looking backwards to periods of considerable traffic growth in the 1990s, and not forward to a more difficult economic future with greater scarcity and cost of fuel, and the stark realities of climate change.

We invite the County Council to share our view that the concentration of housing development within the City and its surrounding villages will favour investment in its own sustainable transport proposals and render unnecessary the huge and damaging investment in the roads which serve to undermine the credibility of the sustainability claims of the County Plan.

How does the County Council propose to protect the Green Belt? We ask the County Council to assess the environmental, social and cultural impacts which would result from the development on Green Belt land and its road proposals in respect of the five established purposes of the Green Belt:

 Stopping urban sprawl  Preventing coalescence (or joining together) of settlements  Safeguarding the countryside from encroachment  Protecting the setting of historic towns  Encouraging urban regeneration

The County Plan proposals appear to fail in respect of all five.

How does the County Council view an option based on the Core Planning Principles? The Green Belt Group wishes to make a positive contribution at this crucial stage before the Council finalises its Plan. We have set out an alternative vision in accordance with the Core Planning Principles of the National Planning Policy Framework (NPPF) and the five established purposes of the Green Belt. Our alternative vision is designed to avoid suburban sprawl, to decrease car dependency and to protect the Green Belt whilst improving the quality of life in both the City and its surrounding towns and villages.

The County Council’s proposals to meet its housing target for Durham City in the Green Belt do not accord with the Core Planning Principles. Despite the emphasis of the NPPF on the encouragement of economic and housing growth, it leaves established policy on Green Belts largely unchanged and expressly excludes Green Belt land from the presumption in favour of sustainable development. The ‘exceptional circumstances’ provision does, however, allow local authorities to alter boundaries in the preparation of local plans. If the County Council claims that there are ‘exceptional circumstances’ sufficient to break its own Green Belt policy, it has not provided convincing evidence to support this claim.

Planning for Moderate Growth

59 In comparing the County Council’s High Growth vision and our Moderate Growth vision we have combined the NPPF 12 Core Planning Principles into seven composite principles. This comparison leads us to believe in the benefits of moderate growth.

The County Plan’s High Growth option is based on a hugely optimistic ambition for population growth with a consequential over–estimate of the need for housing in the County. It sets aside past population trends and house building rates and fails to deal with the distortion of the housing market by increasing loss of family housing to student accommodation. It also seeks to develop land in locations that are less suitable than those we suggest.

Our Moderate Growth Option is described below in terms of the seven Core Planning Principles drawn from the NPPF.

Principle 1 To be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area. To support sustainable development whilst protecting Green Belt and other heritage assets by using land of lesser environmental value including previously developed (brownfield) land. Rather than appropriating Green Belt agricultural land to meet its own inflated predictions for housing and other needs, the County Plan should have considered the full potential of brownfield sites within the City and its villages against a more realistic level of demand.

Significantly, the Plan does not take account of sites of less than 1.5 hectares – there is a very considerable housing capacity within the City and the villages provided by such sites. Given the fine grain and traditional form of the urban fabric of Durham City, small sites can have a higher- than-average density (e.g. Byland Lodge and Highgate).

There is no transport vision, only the dubious DfT forecasts to fall back on to bolster the case for more road building to serve suburban estates. The sustainable option would be to invest in integrated public transport infrastructure and services to serve the City and its villages. The County Plan cannot meet the requirement of this principle other than to empower local people to shape their own surroundings, which suggests that it should take the Moderate Growth option seriously.

Principle 2 To drive and support positively sustainable development to deliver homes, business and industrial units, infrastructure and thriving local places that the County needs. Every effort should be made objectively to identify and then meet the housing needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development taking account of the residential and business communities. The Green Belt Group supports policies for sustainable development to improve the economic prospects of County Durham, as long as the development of strategy is balanced with other Core Planning Principles of the NPPF.

Principle 2 is the one that most closely supports the County Plan’s High Growth option and can be characterised as the ‘developers option’ and indeed the greatest support for the High Growth option has been received from the building industry. The opportunity to build in a conventional way

60 on sites free of constraints will militate against the redevelopment of brownfield sites. There is also a risk that these sites will simply widen the choice in the regional housing market rather than secure balanced population and employment growth in Central Durham. Furthermore, the County Plan’s preferred High Growth option of major releases of Green Belt land favours large-scale developers whilst small-scale initiatives by local community builders are turned down. Principle 2 cannot stand alone and is only relevant when applied with the other principles, most of which undermine the feasibility of the High Growth option.

Principle 3 To take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the green belts around them, recognising the intrinsic character and beauty of the countryside and supporting rural communities within it. The County Plan does not seek to protect the Green Belt although it has identified the ‘least bad’ sites for housing. It also threatens significant harm to a superb Green Belt agricultural landscape by the Western Relief Road proposal and the fine setting of the City by the Northern Relief Road proposal.

Support for our concern comes from the Draft Statement of Outstanding Universal Value, approved by the International Council on Monuments and Sites UK in its Protection and Management Requirements 2011, which recognises the crucial importance of the wooded River Wear valley in the understanding of the mediaeval form of the Castle and Cathedral and the surrounding City. It also states that there is a need ‘to ensure the protection of immediate and wider settings of the World Heritage Site in light of the highly significant profile of the Castle, Cathedral and City and its distinctive silhouette, visible day and night’.

In addition, there is scant recognition of the loss of good agricultural land at a time when the dependence of Britain on increasingly scarce and costly imported food is becoming an everyday matter of concern. The Moderate Growth option recognises the huge value and potential of the Green Belt to both the City and its villages and makes positive proposals to protect it and to use it in creating a more sustainable future.

Principle 4 To support the transition to a low carbon future in a changing climate, reuse existing resources and renewable resources. This is an extremely weak aspect of the County Plan. The inclusion of two relief roads in the Green Belt and the development of suburban-style estates is likely to increase car dependency and do little to encourage walking, cycling and public transport use.

The alternative, as set out in more detail later, is to consolidate development in the nearby towns and villages and support public transport infrastructure provision. We also recommend that the Master Plan for Aykley Heads should be revised to provide satisfactory alternatives to private vehicle use.

Principle 5 To promote mixed use developments and encourage multiple benefits from the use of land in rural areas, recognising that some open land can perform many functions (such as for wildlife, recreation, flood risk mitigation, carbon storage, or food production). Also to

61 conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations. Our proposal for the protection of Green Belt to avoid the outward sprawl of Durham City is an important aspect of conserving the setting of the World Heritage Site and maintaining important agricultural land. The realisation of the Green Belt as a City Park such as we are proposing embodies this principle fully.

Principle 6 To manage patterns of growth to make the fullest use of public transport, walking and cycling, and focus significant development in locations which are, or can be made sustainable. Our proposal for higher density housing on sites within the City and for development in the surrounding towns and villages meets this principle. Supporting public transport development and integration should further the cause of more sustainable living. Investment should be made in safe byways and cycle routes. The development of villages and the provision of shuttle bus services and the reopening of the Leamside and Ferryhill Branch lines to Tyneside and Teeside respectively meet this principle, unlike suburban, car-dependent development in the Green Belt.

Principle 7 To take account of and support strategies to improve health, social and cultural well-being for all, and deliver sufficient community and cultural facilities and services to meet local needs. It is important that the towns and villages in Central Durham continue to develop in order to maintain and improve their community facilities and our recommendation to accommodate 3,610 dwellings in these communities will assist in this. The ‘City Park’ proposal will be a resource available to all communities in improving health, social and cultural well-being.

The case for a Moderate Growth option that accords with these NPPF principles is presented on page 5.

The following two pages illustrate the contrasting visions. The County Plan’s Key Diagram for Durham City and its surrounding villages under the High Growth Option is compared with our equivalent Key Diagram under the Moderate Growth Option.

62 Two Contrasting Visions The County Plan Key Diagram for Durham City (extended to Coxhoe)

The High Growth Option The County Plan proposes:  Building 3,875 new houses in Durham’s Green Belt  Releasing Green Belt land at Aykley Heads for office development  Developing Mount Oswald for private and student housing  Constructing Western and Northern relief63 roads Durham Green Belt Group’s Alternative Key Diagram for Durham City and Area

Moderate Growth Option Our alternative proposes:  Protecting Durham’s Green Belt  Developing brownfield and derelict land  Re-balancing village and City communities  Restoring the policy for Mount Oswald to be for knowledge-based jobs  Supporting re-opening the Leamside Line and developing walk/cycle/park & ride centres  Deleting the proposed Western and Northern relief roads  Stimulating villages to grow and thrive 64 The Case in Detail - Fulfilling Durham’s Potential ______

The Council’s intention is that the County Plan will be an opportunity to set out the means by which Durham City can ‘fulfil its potential’. Our Group considers that developing the interrelationships between the five elements below is the key to correct strategic policies and land allocations.

 The potential for a strong knowledge-based economy.  The potential of housing policy to enhance the viability of communities while protecting the landscape setting of Durham City and its World Heritage Site, its Green Belt and its amenity open spaces.  The potential for travel demands to be satisfactorily met through the provision of better integrated public transport, cycling and walking before road building is considered.  The potential of a protected Green Belt to provide open access for recreation and healthier lifestyles.  The potential of tourism to expand to provide greater economic, social and environmental benefits.

The potential for a strong knowledge–based economy

The County Council’s analysis shows that County Durham traditionally has demonstrated a low level of growth in employment within a region that has performed poorly in national terms. The Plan rightly sets out to facilitate a better future. It proposes to create 30,000 net additional jobs, which is an exciting prospect for the local economy if it can be achieved.

We agree that Central Durham, together with Netpark in Sedgefield, is where the potential is greatest and particularly in respect of knowledge-based employment and, specifically University- related employment. The two sites in Durham City that are most important strategically are identified in the Plan as Mount Oswald and Aykley Heads.

The land at Mount Oswald is arguably one of the finest sites available for University related- science and technology development in the North East Region. It is a precious resource and crucial to County Durham’s potential to develop its knowledge-based economy. According to existing policy, 90% of this site is to remain open with 10% to be developed. For the Plan to now propose that a large part of this site should be given up for housing is contrary to the County Council’s own commitment to realising Durham City’s economic potential. Also, it seems that the consequence to make up for this loss is the relaxation of the Green Belt in the Aykley Heads area. The County Council is robbing the Green Belt to pay for yielding to developer pressure for housing at Mount Oswald. Recommendation: The Mount Oswald site should continue to be the prime site for knowledge-based employment and business. The site could provide for student accommodation but general housing development should be resisted and the allocation removed from the Plan.

65 Whilst it is reasonable that development on previously developed sites at Aykley Heads takes place, there are a number of newly proposed sites that are currently in the Green Belt. These proposals are contrary to Principles 1 and 3 in so far as the Green Belt is not protected and it is not a pattern of growth that is supported by public transport. Previous piecemeal developments in the Aykley Heads area have resulted in large scale car parking, no provision for public transport access and increased car dependency. Recommendation: Green Belt sites in the Aykley Heads area should be excluded from the Plan. No further development should be allowed until adequate provision for public transport access is made and the whole Aykley Heads area, including the County Council site, is brought within the City Car Parking Control Area.

The potential of housing policy to enhance the viability of communities while protecting the landscape setting of Durham City and its World Heritage Site, its Green Belt and amenity open spaces.

The County Plan assessment of housing needs appears to be vulnerable in that it flows from the generous employment growth assumptions and is therefore based on targets rather than forecasts. It is unfortunate that the County Council is planning for this unprecedented growth in a period of national economic uncertainty. The credibility of this ambition is dependent on the acceptance of four assertions, which are:

 The County Plan’s provision of infrastructure for market-led employment sites, housing and road building will support a population growth from 496,000 in 2009 to 532,700 in 2031 including net inward migration of 41,000 persons. This is at odds with County experience over many years of attracting thousands of new jobs through public sector incentives and yet only just about maintaining a stable population. We believe that a more realistic, but still optimistic, Plan should be based on population growth to between 506,000 and 516,000 by 2031 (i.e. still having very considerable net inward migration of between 14,000 and 24,000 people), with a need to accommodate up to an extra 22,000 households.

 The County Plan’s housing completions in the County will rise from the current levels of 800 per year to about 3,000 in 2016 before falling away. Even in the best of economic times, this level of housing completion has never been approached in the County. The total new houses of 30,000 must therefore be viewed with considerable scepticism. Our figure for planning purposes is pitched at about 1,000 per year, a lower but still optimistic level. We propose a figure over the whole period of up to 22,000 extra houses (which accords with the households figure above). Recommendation: The County Plan target to build 30,000 houses by 2031 is unrealistic and should be scaled down to about 22,000.

 The County Plan proposal for Durham City is to accommodate at least twice the proportionate level of housing for its population size (8.5%) as compared with the rest of the County. For 17% of the County’s new house building total to be in Durham City is arbitrary and unnecessarily high. Having set such a high target, the County Council has proposed that most of it will be in the Green Belt. This is contrary to Principles 1 and 3 which reject the use of Green Belt land and insist on using land of lesser environmental value. We believe that Durham’s attractiveness as a housing location would still be reflected at an intermediate level of 10% which

66 equates to a total of 2,200 housing sites. Our full reasoning for this is set out in detail in Appendix A (page 25).

 The County Plan cannot itself address the full effect of student housing needs. We say that the County Plan must address this issue. It is a serious omission not just in statistical terms but in terms of the working of Durham City’s housing market. For the past ten to fifteen years, the availability of homes for families has been continually eroded by the increase in students seeking accommodation in the City, which has the effect of forcing prices up beyond the means of first time buyers. The nature of student occupation means that houses are poorly maintained, and are vacant for as many as 26 weeks of the year. A predominance of students in a neighbourhood also harms the quality of life of residents. The University has expressed the intention to provide accommodation for between 50% and 70% of its students but should also commit to reducing the current number of 6,000 students living in private accommodation in the City. To return 500 houses to the general housing market by 2031 (about 25 per year) would improve the general housing market and reduce the demand for development in the Green Belt.

In publishing its Sustainable Development Indicators in July 2012, the Department for Environment, Food and Rural Affairs (Defra), states ‘social capital is essential for sustainable communities and a strong and cohesive society underpins our economic development and our current and long term well-being’. We believe this to be an essential measure. The reduction of students that ‘live out’ must be reduced. If reduced to around 30%, it would be possible to rebuild the ‘social capital’ of many housing areas. This is no less than the recovery of their vitality, their diversity, their peace and their cleanliness. This must be factored into any calculations for future housing needs.

The figure below summarises the differences between the two approaches.

Settlement County Plan County Plan Alternative Alternative Notes housing % housing % allocation distribution allocation distribution Durham City 5,120 17.1 2,200 10.0 See Appendix A.

Other towns and 2,790 9.3 3,610 16.4 villages

Total Central Durham 7,910 26.4 5,810 26.4

Rest of County 22,090 73.6 16,190 73.6 Durham Total County Durham 30,000 100 22,000 100

We do not challenge the distribution the County Council has adopted for Central Durham in relation to the remainder of the County. We do however have a view about the nature of that growth in relation to the regeneration needs of Central Durham. Starting from the accepted view that Green Belts encourage regeneration of cities, our survey of brownfield sites (see Appendix B on page 28) suggests that a large potential for renewal through housing that might otherwise not occur if developers can take the easy option of greenfield land. The brownfield sites within the City also offer access to existing centrally located, public transport orientated living.

The vision we set out for the villages around the Green Belt is part of the argument for spreading the benefits of regeneration as far as possible. The County Council and its partners have successfully regenerated many of the communities of County Durham through policies that have guided new development and investment into them. Land releases in the Green Belt would be the first choice for developers to turn to instead of village regeneration sites. Our suggested vision gives a continuing regeneration role to the communities around the Green Belt, benefiting from new housing and populations to support facilities including public transport. The proposal for Green Belt paths and trails is part of this regeneration effort to link village communities and the City to improve their quality of life, enjoyment of their surroundings and opportunities for employment.

Our analysis suggests that the City should be allowed to grow to its ‘natural level’ and not consume its own Green Belt. There are sites for at least 2,200 new dwellings on existing approved sites, sites previously developed (‘brownfield’ sites) and houses returned to the market from University policy to accommodate more of its students. Recommendation: Durham City should grow to its natural level in accommodating around 2,200 more dwellings without breaking into its valued Green Belt.

The County Council analysis shows that 2,790 dwelling units can be accommodated in the villages in Central Durham. We propose that a further 820 should be added to this number to assist the regeneration of villages in preference to building in the Green Belt. In past years, a similar approach in Lanchester, Great Lumley and High Shincliffe has helped to create thriving local communities, and increased choice and quality in the Durham City housing market.

In actively promoting development based on existing communities, the County Plan would become significantly more sustainable by making use of existing road and rail networks, strengthening community infrastructure, and boosting local economic, social and environmental regeneration. In setting criteria for development, the County Council could identify villages (or groups of villages as we suggest) through local consultation where such an approach would be feasible, beneficial and welcome.

Recent interest shown by government in the values of the Garden City movement has resulted in the publication of ‘Creating Garden Cities and Suburbs Today’ by the Town and Country Planning Association. This approach applied at a more local scale to several Durham villages could become a model of ecological and sustainable design in setting a standard for future development in the County. The County Council could then justifiably claim that its plans for housing development are significantly more sustainable both in terms of choice of location and quality of design.

Recommendation: Provision should be made for 3,610 dwellings in Durham City’s villages to create a model for sustainable living with developments based on the design principles of the Garden City movement.

68 The potential for travel demands to be satisfactorily met through the provision of better integrated public transport, smarter choices, cycling and walking.

The Plan contains many references to sustainability in relation to transport and it is therefore surprising to find that a city as small and fragile as Durham needs two new relief roads to function in future. The justification appears to based on predictions that traffic demands will continue to rise as in the 1990s and that travel habits and patterns will not respond to increasing costs and scarcity of fuel and necessary responses to combat climate change. The DfT forecasts of inevitable growth in traffic as revealed so clearly in the diagram are now widely challenged. The Times reported on 8 October 2012 that the DfT’s official forecasts of future traffic growth are “now so far from reality that an urgent review is called for”.

We believe that in using the DfT forecasts of inexorable traffic growth, the County Plan seriously misinterprets the new reality, with road building proposals damaging the prospects for sustainable travel options. A sustainable travel future in any modern European city is one where public policy and investment is directed towards the shaping and support of public transport services essential to the quality of life of its residents and experience of its visitors. Our proposal to consolidate housing in existing communities rather than create new car-dependent suburban estates is part of that support. A sustainable transport strategy requires the integration of public transport services in Central Durham into frequent, reliable and affordable services that are the transport of choice of the great majority.

69 some point it will be necessary to stop trying to accommodate more cars. Now is a good time to stop, before further damage is inflicted on Durham City and its surrounding landscape.

The proposed Western Relief Road runs from Sniperley to a southern junction at Broom Park picnic area. The route shears across the Browney Valley and would destroy the peace and tranquility of that superb and historic landscape. Productive farmland would be lost and severed when it is becoming apparent that food shortages are a potential future threat to national security and well-being. The use of the network of footpaths that link the City to heritage sites such as Beaurepaire, Witton Gilbert Small Pilgrim Place, and to local villages, Bearpark and Ushaw Moor, is likely to be adversely affected.

The proposed Northern Relief Road is an un-costed item to be built at the end of the Plan period. Thus the County Plan is accepting that Durham City is going to have to manage without whatever relief the Northern Relief Road proposal might eventually bring. It is to be hoped that the County Council will drop its proposal if it accepts that the large scale exploitation of the Green Belt for housing is unwise. We think that this proposal only serves to cast doubt over the County Council’s confidence in its own sustainable transport proposals to meet the City’s travel needs.

These road-building proposals will reinforce car dependency and damage the landscape character and potential of the Green Belt for recreation and leisure purposes. Recommendation: The proposals for Relief Roads should be withdrawn from the Plan as unsustainable and unnecessary with future travel needs to be met by the County Council’s own sustainable transport proposals.

Another model for travel in the City?

In Appendix C (page 29), we have presented the results of evidence of research into the case that new roads improve the local economy and alleviate congestion. It can be said that there is little evidence that investment in new roads is good value in either respect. There remains, however, a need to prove that other alternatives will work. There is some indication to this effect in the Plan where it states that “a congestion charge and bus subsidies were potentially the most effective in reducing traffic” before dismissing these measures on grounds of cost and diverted trade. It is our contention that if the £31.5 million for the Western Relief Road could be committed to sustainable transport initiatives, then such measures would become possible.

It is not possible for a small group such as we are, to develop a sustainable transport model for Central Durham. The County Plan should treat Durham City and its surrounding villages as one travel zone with fully integrated travel services and new facilities such as Park, Walk and Ride sites. Our proposals for the exploitation of the potential of the Durham Green Belt as a City Park and landscape could fit well into a new model for travel. Interconnected paths and trails for walking, cycling and riding would be used for journey to work and school, and for leisure and tourism. This appears later as the Durham Villages, City Park and Green Belt Paths and Trails proposal (see page 22). Recommendation: Sustainable transport proposals in the County Plan should include recognition of the need to increase public transport capacity, to make smarter choices including car share and car pooling, to provide better infrastructure for local journeys by foot or bicycle and to improve access to public transport interchanges. To this end, new

70 Park, Walk and Ride sites, e.g. at Bowburn and Langley Moor, should be considered. Integration of the regular bus services to and from all the surrounding villages, with new and existing park,walk and ride schemes and the cathedral bus should be made. Upgraded tracks and trails across and round the Green Belt linking the villages with the City are an important investment in promoting cycling and walking. The re-opening of the Leamside and Ferryhill Lines will be a major contribution to sustainable travel.

The potential of a protected Green Belt to provide open access for recreation and healthier lifestyles

The Green Belt and earlier landscape protection policies have for many years served to prevent the outward sprawl of the City and maintain the quality of its setting and of the World Heritage Site. There is now a serious threat to its openness and permanence. Our Group has come together to question the County Council’s assumptions, targets and land allocations to ensure that Green Belt policies remain intact. By strictly adhering to the advice contained in the NPPF, we hope to demonstrate that it is not only unwise, but also unnecessary for the City to grow beyond its natural limits as defined by the Green Belt. We believe the County Plan should give full consideration and evidence on the following issues.

The need to give continuing support to the protection of the Green Belt: one of the core planning principles in NPPF is ‘…promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic quality and beauty of the countryside and supporting rural communities within them’.

Despite the emphasis of the NPPF on the encouragement of economic and housing growth, it leaves established policy on Green Belts largely unchanged and expressly excludes Green Belt land from the presumption in favour of sustainable development. The ‘exceptional circumstances’ provision does, however, allow local authorities to alter boundaries in the preparation of local plans. We believe that “exceptional circumstances” do not exist. It is Durham County Council’s questionable ambition to transform the City into a regional economic powerhouse, rather than a genuine need, that has led it to propose breaking its own Green Belt policy.

The need to respect the purposes of the Green Belt in future planning: it is worth reiterating the five purposes of Green Belts; stopping urban sprawl; preventing coalescence (or joining together) of settlements; safeguarding the countryside from encroachment; protecting the setting of historic towns; and encouraging urban regeneration. The County Plan proposals fail in respect of all five. In the pursuit of its growth vision for the City, necessary consideration of the implications of the five purposes has been superseded by evaluation of the relative development merits and weaknesses of tracts of Green Belt land. The County Council betrays its own lack of respect for the principle and purposes in stating that the development proposals are ‘… only 3% of the Green Belt in total’. This is a statement of great carelessness. In the northern section of the Green Belt, it is our contention that the impact and loss is high and severe and unsuited to a percentage calculation. In our view, the County Council is, in effect, undertaking a review of its Green Belt whilst under pressure to allow more development. In such circumstances, it is vital that it takes into full account the original and continuing purposes of the Green Belt.

The absence of an overall assessment of the environmental, social and cultural impact caused by the loss of Green Belt sites: there is a serious omission in the Plan in that the

71 cumulative impact of the proposals has not been assessed. In publishing its Sustainable Development Indicators in July 2012, the Department for Environment, Food and Rural Affairs (Defra), states ‘social capital is essential for sustainable communities and a strong and cohesive society underpins our economic development and our current and long term well-being’.

The assessment that has been made is between sites, to choose the better sites, or possibly the ‘least bad’ sites. An overall assessment is the responsibility of the County Council in proposing such a radical change. If these proposals had arisen from a planning application rather than having its origin in the County Council itself, this assessment would have been carried out.

It is clear that the assessments of each site have been scrupulously undertaken to minimise such impacts. We question this approach in that it serves to support the proposals rather than highlight their impact. Development on this basis is incremental, with the next site being suitable on the grounds that the last one was allowed. Before volunteering these sites, the County Council should have evaluated the combined impact including the specific assessment against the five purposes of the Green Belt.

We accept that such an assessment is difficult in trying to place a value to local attachment to the Green Belt; the loss of the grand sweep of agricultural land on the City approach resulting from the intense narrowing of the gap between the City and Sacriston; the outward sprawl of Newton Hall into countryside that is their lungs and potentially their playground; the blighting of the beauty and tranquillity of the Browney Valley by the Western Relief Road, a road on its way from nowhere through somewhere well- loved by many; and the disregard for the setting of the World Heritage Site by the Northern Relief Road as it carves through the priceless landscape of the River Wear valley. These are the cultural losses to which there is no response in this Plan.

The need to enhance the beneficial use of Green Belt: in accordance with NPPF, ‘Local planning authorities should plan positively to enhance the beneficial use of Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity’.

This is exactly what we have in mind in examining the potential for a City Park shared and enjoyed by the residents and visitors to the City and its surrounding towns and villages. The provision of better footpaths and cycleways, development of park facilities including new health and fitness circuits, nature conservation and landscape improvement schemes, and sculpture and public art projects would be an opportunity for local engagement in an exemplary public investment over many years. The diagram on the facing page suggests the huge potential by simply linking the many attractions that already exist. Our proposal would make a major contribution to health and well-being. Recommendation: The potential for developing the Green Belt for beneficial uses should be established in the County Plan and principles set out whereby the provision of community and visitor facilities and services can be made as opportunities arise.

Our contribution on this recommendation is to set out here some principles in ‘Durham’s Villages, City Park, and Paths and Trails’ (see next page) that would assist in realising this potential.

Durham’s Villages, City Park and Green Belt Paths and Trails – Some Principles

KEY

Green Belt designation and area of informal City Park for leisure and recreation, tourism and visitor facilities and services,, agriculture, local food growing, education, landscape

improvement, wildlife habitat conservation, small scale energy generation schemes.

Villages and groups of villages where the development of housing, employment and

community facilities enable continuing regeneration and improvement on sustainable principles

Paths and trails to link Villages, the City and visitor attractions and amenities. Promoted and developed for general use including walking and cycling to school and work, and enjoyed for leisure, sports and amenity use.

City trail linking main visitor attractions and services including bus and rail stations, and links to the City Park

73 The potential of tourism to provide greater economic, social and environmental benefits

From the Green Belt Group’s standpoint we are totally in agreement with the County Council’s belief that the City and the County’s tourism assets are and will be a hugely significant resource for a wide range of development and employment opportunities. It is especially valuable to the fundamental priority of offering accessible employment opportunities – particularly for young people – consistent with safeguarding County Durham’s appeal. Tourism has long been of economic importance to the City because of the timeless appeal of the Cathedral and Castle. Durham remains a half day visit for the great majority of visitors and is certainly not fulfilling its potential to provide a richer experience and greater economic, social and environmental benefits.

The County Plan is important in two respects. Firstly, there should be no development proposals in it that would damage the County’s attractiveness to visitors. The proposals to build on Green Belt land fall into this category and are a further reason to oppose the Plan on the grounds that there will be damage to the setting of the World Heritage Site.

Secondly, and more positively, the County Plan has set out the development principles to realise its tourism potential. The County Plan recognises that in order to provide a richer visitor experience, much more could be made of the County’s heritage assets and attractive landscape. The Plan does not however, indicate how this would be achieved. We propose that the inclusion of a tourism development framework would be appropriate and influential in guiding how the City might develop and adapt to accommodate more tourist activity.

In the difficult financial conditions that may endure for several years, it is important to enhance what the City already possesses rather than to seek major new investments, although an exception to this would be to re-instate the City’s dedicated Tourist Information Centre. Finding new lower cost improvements is likely to be the way forward including overcoming the difficulties that visitors have in finding many of the attractions. A good example of this is seen at Durham Railway Station. The County Council’s DLI Museum and Durham Art Gallery is close by and yet isolated from it. The Cathedral Bus that waits in the station forecourt could easily provide visitors with direct access. Even more extraordinary is that for the want of some 300 metres of footpath, passengers could take a pleasant stroll to the DLI directly, and a continuous traffic-free cycle and walking route from Newton Hall to the Station would also be completed. Another case is that the long and superb walk from the City via Kepier Hospital northwards along the river which finishes in a dead-end less than a mile from Finchale Priory.

There are many more examples in and around the City where paths could be upgraded and improved into longer trails and local loops for walking and cycling to enable local people and visitors to better enjoy Durham City’s superb setting and many attractions within it. The entry points also might well be a starting point for way-marked trails in the City Park. A complementary strategy within the City linking entry points, attractions including the Peninsula, the riverbanks, Old Durham Garden, the Botanic Garden, the Oriental Museum, Crook Hall and the many churches and buildings of architectural importance, would capture the interest of visitors and help to support related visitor services and facilities. The provision of an integrated and flexible shuttle bus service around the City and its Villages would also be of great benefit to visitors by extending their range beyond the Peninsula.

74 Set out here are some of the ‘structural’ elements we believe to be important in a tourism development framework:

 A new visitor and interpretation centre, centrally-located for the City and wider County

 Better reception facilities at entry points including the rail and bus stations and Park. Walk and Ride sites

 The development management, promotion and signposting of a City walking trail linking the main tourist attractions and services

 The development, management, promotion and signposting of the Green Belt Paths and Trail

 The development of related tourist services and businesses

Recommendation: The County Council should prepare a Tourism Development Framework for Durham City and its Villages for inclusion in the County Plan.

If you want to comment to us and/or to the County Council about our document, the contact details are:

Durham Green Belt Group: [email protected]

Spatial Policy Team, Durham County Council: [email protected]

75 Appendix A – Population and Housing ______

Population County Durham’s population decline in past decades was caused primarily by the loss of its basic industries. High unemployment coupled with a disfigured environment, bad housing and poor prospects drove people to move elsewhere. It is to the great credit of the Local Authorities and their partners that thousands of new jobs, a transformed environment and major housing and educational improvements successfully stabilised the population at around 495,000 over the most recent decade. There was apparently a sudden leap in 2006/7 but subsequent estimates show a resumption of slight decline and then stability again. No doubt the expansion of Durham University from 4,000 students in the 1960s to 15,000 today has had a distorting effect on the overall picture of population trends.

Population projections are a complex matter, and many assumptions have to be made in constructing trends and scenarios. The graph below from the County Council’s report ‘Defining Economic Growth in the County Plan’ (March 2012) indicates that the projection of past trends (Scenario A - the red line) would take the County’s population surprisingly upwards to about 513,000 in 2031. (The County Plan text gives the trend scenario population figure as 516,300 in 2031 which is slightly higher. The reason for this difference is understood to be net commuting levels).

Given the history of County Durham, the huge public sector effort that has been required just to achieve population stability, the difficult economic circumstance now faced by the whole country, and the severe reductions in public sector resources until the year 2017 at the earliest, it is remarkable that the trend outlook appears to be so positive. It would seem to be based upon one year’s jump, and it relies on importing an extra 24,000 people by net inward migration to more than offset the ‘built-in’ natural decline of about 4,000 (i.e. 4,000 more deaths than births).

76 To achieve this “trend” degree of population growth with acceptable employment participation rates will take the creation and attraction of many thousands of new jobs. It is all the more odd therefore that the Plan sets out to increase the scale of the task. Instead of resolving to provide enough jobs to meet the need of a stable or modestly increasing population, it adopts a far higher target population figure for 2031. A series of scenarios beyond trend Scenario A are explored, and the fourth - Scenario D – the green line – (subsequently called Scenario 4) is chosen in the County Plan. This chosen scenario is that the population to be accommodated in the County in 2031 should be 532,700. We consider this to be over-ambitious and unsound.

Indeed, the County Plan states (para 4.28) explicitly that “Scenario 4 requires the provision of 30,000 additional jobs and will result in a population increase from 496,000 in 2009 to 532,700 by 2031. Due to the existing and forecast age profile of the County it will be very difficult to support this growth without an increase in in-migration. Scenario 4 therefore requires 12,600 people of working age to move into the County”.

The Plan thus acknowledges the circularity of an argument that requires attracting more people into the County to achieve a higher total population than can reasonably be expected and for whom the target for the amount of employment required is thereby so much higher. It was a severe lack of jobs that drove people away, and it will require more new jobs to draw people to County Durham. With record levels of long-term youth unemployment now being experienced in the North East Region, whatever success can be achieved in creating new jobs must be dedicated to catering for the County’s present level of labour force, not increasing the problem by an additional 12,600 people of working age.

For those reasons, we challenge the assumptions contained within the various scenarios – they are all very optimistic, whereas statutory development plans such as the County Plan have to be sound and realistic. We consider that a figure for population growth from 496,000 in 2009 to somewhere between 506,000 and 516,000 is consistent with the evidence and is realistic.

Housing – County Durham Adopting such a high aspirational target population brings with it a correspondingly high requirement for new housing. The County Plan estimates that 30,000 extra houses will be needed over the Plan period April 2010 to 2030 for a population of 532,700.

There were:  1,221 houses under construction at April 2010 expected to be completed by December 2012;  3,333 housing sites currently under construction;  5,276 sites with unimplemented planning permission.

Thus the ‘pipeline’ already provides 9,830 more houses, leaving 20,170 new housing sites to be identified in County Durham to make up the 30,000 required by the Plan.

Housing – Durham City – The Plan’s proposals Of the County total of 30,000 extra houses, the County Plan proposes that 5,120 i.e. 17.1% should be in Durham City. For Durham City the ‘pipeline’ figures are:  18 houses under construction at April 2010 expected to be completed by December 2012;  111 housing sites currently under construction;  321 sites with unimplemented planning permission.

So the Durham City ‘pipeline’ already provides 450 more houses, leaving 4,670 new housing sites to be identified to make up the 5,120 required by the Plan.

Policy 30 and Table 8 of the Plan list the proposed housing site allocations in Durham City (reproduced below for convenience). These have a total estimated capacity for 4,668 new houses. This is only 2 short

77 of the figure required, and there will be many smaller acceptable sites that come forward, known as ‘windfall’ sites, that will certainly make up more than this trivial deficit. Furthermore, the Plan makes no allowance for the re-use of empty homes, on the grounds that there is uncertainty about funding.

Within the 4,688 housing site allocations proposed in the Plan, a total of 490 are on sites within the City, 303 are at Mount Oswald and 3,875 are on proposed sites in the Durham Green Belt – Sniperley Park, North of Arnison and Sherburn Road.

The County Plan’s proposed housing land allocations for Durham City

Housing – Durham City – The Durham Green Belt Group’s proposals Our necessarily approximate estimate is that 22,000 new houses will be required for a County population of Allocation Site Site area Estimated Average gross density Phasing reference (hectares) yield (houses per hectare HA5 Sniperley Park 84.2 2,200 26.1 Medium HA8 Mount Oswald 30.8 303 9.8 Short HA9 Durham Johnson 2.6 77 29.6 Short School (Whinney Hill) HA10 Potters Bank 1.9 15 7.9 Short HA11 Former Dairy, Land at 1.8 64 35.6 Medium Stonebridge HA12 Aykley Heads 9.0 220 24.4 Short to Medium HA13 Sniperley Park and 1.7 45 26.5 Short Ride HA14 Willowtree Avenue 1.9 69 36.3 Medium HA15 North of Arnison 72.9 1,225 16.8 Medium HA16 Sherburn Road 23.4 450 19.2 Medium TOTALS 230.2 4,668 20.3 516,000 in 2031.

We suggest that allocating 17.5% of the County total of housing sites to Durham City, which has 8.5% of the County’s population, is disproportionate. Instead, our proposal is that about 10% is a reasonable amount, still representing growth. This gives a figure of 2,200 houses to be provided in Durham City.

We endorse the 450 new houses coming through the ‘pipeline’ already. We accept in principle the 490 proposed allocations (HA9 to HA14) within the City. We support the University of Durham’s new Accommodation Strategy that seeks to provide purpose-built housing for between 50% and 70% of its students. This should release existing houses currently occupied by groups of students – we make the very modest assumption that about 25 per year or 500 over the Plan period. These three elements will together provide a total 1,440 more houses. So we need to identify a further 760 more sites. More than sufficient potential sites are listed in Appendix B.

We therefore reject the proposed development of Mount Oswald (HA8) for housing instead of high-tech and knowledge-based employment. We reject the Green Belt sites (HA5, HA15, and HA16). Our proposal is that the many areas of brownfield land within the City should be developed. These are not as easy to develop as fresh greenfield land, but this is why one of the strong purposes of Green Belt designation is to steer developers towards tackling such wasted and unsightly parts of towns.

78 Appendix B - Brownfield and Acceptable Greenfield Sites ______Schedule of the County Council’s Deliverable SHLAA March 2010 sites and of other ‘brownfield’ sites in Durham City identified by the Durham Green Belt Group. We acknowledge that not all of these sites will prove to be suitable, deliverable or have the capacities indicated.

Site name Housing capacity County Council’s Deliverable SHLAA sites 1. Former County Hospital, North Road 52 2. Fire and Rescue Headquarters 71 3. Durham Johnston School Annexe 22 4. Kepier House 35 5. Former Ustinov College 25 6. Land at 6th Form Centre 14 7. Land off Claypath 18 8. Land at St Leonard’s School 118 9. Hollow Drift, Green Lane 35 10. Bede College 58 11. Palatine House 27 Sub-total 475

Green Belt Campaign’s additional potential sites 12. Former Carillion depôt, Gilesgate 20 13. Former Bernard Gilpin site, The Sands 40 14. Former Mono Containers site, Dragonville 90 15. Former Fred Henderson garage, Ainsley Street 30 16. Former bus depôt, Waddington Street 20 17. Former Elliott’s depôt, Ainsley Street 5 18. Passport Office, Framwelgate Peth 200 19. Nevilles Cross College 50 20. Elvet Waterside 60 21. John Street 20 22. Sidegate to brickworks 20 23. Shell garage on the A167 10 24. Top of The Avenue 10 25. Flass Street vacant land 5 26. School sites at Aykley Heads 10 27. Old Shire Hall 20 28. Site of ‘The Grange’ public house on the Sunderland Road 4 29. Paddock at north end of Southfield Way 10 30. Land and cleared site between Cuthbert Close and Benthouse Lane 30 31. Site released by suggested relocation of Gilesgate School to near the 6th 160 Form College Sub-total 814 TOTAL 1,289 In addition, many ‘windfall’ sites will appear over the period of the Plan, as well as some of the SHLAA’s 1,100 “currently unsuitable but could be revised” sites,

79 Appendix C – Transport ______

The County Council’s case for new roads The County Council appears to be justifying the two new relief roads on the basis of generating jobs and alleviating congestion. There are, however, contrary independent arguments form diverse sources that can be put. Below are views from Sustrans, Massachusetts University, and independent economic studies.

Sustrans criticised a CBI call for a new ‘Plan A Plus’ that urges the Government to build new roads as a way to ‘kick start’ economic growth: ‘The CBI’s proposed plan would fail its members, fail our economy and fail any simple mathematics test. New road schemes have been shown to lead to greater congestion, poorer air quality and contribute to sedentary lifestyles, all at a huge cost to our economy. It’s time for a plan that puts sustainable transport at its heart – and offers a better quality of life, increased efficiency in spending, more travel choices to people - and ticks the two government priority boxes of cutting carbon emissions and improving our economy.’

A study from Massachusetts University, published June 2011, found that investing in bicycle and pedestrian infrastructure produced more jobs than road building projects. The finding was that for each $1m spent, 11.4 jobs were created, road-only building projects created 7.8 jobs/$1m.

Two Canadian economists, Duranton and Turner concluded that “increased provision of major urban roads is unlikely to relieve congestion.” The study found that a one percent increase in roads leads to a one percent increase in traffic within less than ten years. In other words, if road infrastructure is doubled, car traffic also doubles within a few years.

The Transport Economic Evidence Study (TEES), found that a 5% reduction in car trips can be achieved by providing smarter choices and better public transport infrastructure. Sustainable Travel Towns (STT) have found that a package of measures to promote behavioural change by encouraging walking, cycling and smarter choices schemes could reduce traffic by at least 10%. Sustrans found that of parents driving their children to school, only 7% are continuing to their workplace.

There is also an increasing body of research and evidence indicating the massive value of the natural environment for the well-being of people. Policies to reduce car-dependency, encourage and promote walking and cycling not only reduce carbon emissions, but contribute to the overall health of communities regularly emerge from central government:

The groundbreaking UK National Ecosystem Assessment (UK NEA: 2011), funded by Defra 'reveals that nature is worth billions to the UK economy.' The report also states: 'The health benefits of living with a view of green space are worth £300 per year.'

Also in 2011, the Government published 'The Natural Environment' White Paper, 'The Natural Choice', responding to Professor John Lawton's independent review 'Making Space for Nature' (June 2011). In response to recommendation 1 in the review, the White Paper states: 'Government will ensure that the National Planning Policy Framework reflects the importance of planning in protecting and enhancing the natural environment and the Coalition agreement to maintain the Green Belt...'

80 Appendix D – Tourism potential – some facts and figures ______Tourism is an essential part of the economy and provides jobs for local residents accounting for the employment of 11,500 people in the County, 10% of the employment base. Cultural, social and environmental benefits contribute to the quality of life of local communities. County Durham’s rich heritage assets, including Hamsterley Forest, Durham Dales, Durham Heritage Coast and Magnesian limestone escarpment, provide a visitor experience that should be a key destination in the country. The Durham Visitor Survey (2010) established an increase of 16% overnight visitors to County Durham over the past seven years.

In Durham City, tourism is now worth £173,580,000 from 3,809,030 visitors. The timeless attraction of the World Heritage Site of Durham Cathedral draws over 600,000 people from all over the world. The increase in overnight stays is to be welcomed, but needs to be strengthened. The exciting development of attractions, such as continental markets, folk, brass, literature and food festivals, the Durham Miners’ Gala, and Lumière, will be enhanced by the programme celebrating the Journey of the Lindisfarne Gospels to Durham City from 1 July – 30 September 2013.

Durham City’s Cathedral and Castle is a defining icon of the North East. The City has the potential to become a thriving tourist hub with increasing numbers of jobs for local people, including entry for young people with practical skills and opportunities for development. There are many strategic assets which increase the tourism potential for the City:  Connections to East coast main railway line and AIM motorway.  Unique heritage and story  First-class university  Beautiful countryside  Dramatic topography  Practical knowledge of local people

There is potential for extending the visitor constituency by broadening the appeal:  Conferences and meetings  Visiting friends and relations  Niche Visitor Appeal: Gardens, Heritage & Architecture, Food, Walking and Cycling

The Government’s response to ‘Making Space for Nature’ review recommendation 7 states: ‘The National Planning Policy Framework will provide communities with the tools they need to deliver an improved and healthy natural environment.’ Not only has the City a remarkable heritage and townscape with dramatic topography, it is set in a green landscape bowl, surrounded by green belt which affords space for developing the natural environment for sport and recreation. The heritage assets and natural environment can be further developed in several ways:  shuttle-bus linking sites in the City e.g. WHS, DLI Museum, Botanic Gardens, Oriental Museum  minibus transport linked to hotels and B&Bs taking visitors to attractions in the region  development of coach park reception facilities and accessible tourist information  provision of short-term self-catering accommodation  development of Visitor Interpretation Centre highlighting the Story of Durham City: Charter to the Burgesses 1179; Medieval Guilds; Corpus Christi Processions; 800 Years of Markets; Industrial Heritage - carpet making and mining  development of signposted footpaths and cycle routes from the City to Durham’s Green Belt villages and sites: Beaurepaire, Battle of Nevilles Cross, Witton Dene  development of the riverside, retaining the integrity of the natural landscape, but providing good play areas for children and café at Elvet Waterside  development of a first-class mining museum in Miners’ Hall at Redhills, linked to sites such as Cockfield  proper assessment of problems for visitors caused by the ‘night-time’ economy, in order to create a safe inclusive environment.

81 Appendix E - A short history of the Durham Green Belt ______

Background to Green Belts

The first “Green Belt” appeared as the Metropolitan Green Belt around London in 1935. The Town & Country Planning Act 1947 allowed all planning authorities in England and Wales to include green belt proposals in their development plans.

In 1955 the Government published its Green Belt Circular 42/55 inviting planning authorities to submit proposals for Green Belts giving statutory and permanent protection to areas of primarily open land around cities and between towns.

Draft Green Belt Map under Circular 42/55

Immediately this Circular appeared, the County Council prepared a draft Green Belt Map which it submitted to the Minister at the end of 1955, including a Green Belt for Durham City. In his response in March 1957 the Minister agreed that a partial Green Belt for Durham City “to maintain its unique character” should be incorporated in the County Development Plan. Agreement was reached with the Minister that a partial Green Belt for Durham City to the east, south and west sides of the City could be adopted for the control of development pending the statutory vehicle of a formal Review of the first County Development Plan approved in 1954. Thus since 1957 the partial Green Belt was applied by the County Council to all development proposals within the defined area, and its decisions were upheld by Government Inspectors on appeals against refusals of permission.

The County Development Plan Amendment No 39 1969

After the statutory Approval in 1954 of the first County Development Plan, the County Council prepared Town Maps for many of the towns in the then County, each as a formal Amendment to the County Development Plan, but no Town Map was prepared for Durham City. In 1964 the County Council submitted a full review, update and revision of the County Development Plan, in the form of Amendment No 39. This was approved with amendments by the Minister of Housing & Local Government in 1969. It is essential to refer to the 1969 Approved document despite the fact that in Durham’s main library the 1964 document is presented. Only the 1969 Approved document has statutory force.

The 1964 Submitted Review proposed the designation of several Areas of Great Landscape Value, and for Durham City it proposed a Green Belt around the west, south and east sides of the city. The Minister in approving the Plan with amendments declined to approve a partial Green Belt for Durham City but after negotiations did agree instead to approve the same proposed area as an Area of Great Landscape Value but with the exact wording of the national green belt policy. This device proved successful, again with consistent support by Inspectors on appeals.

The boundary of the Durham ‘green belt’ that acquired statutory force with the approval of the County Development Plan Amendment No 39 is defined precisely in Diagram 15 of the 1969 Written Analysis. It does not include the north side of the city, nor does it include Aykley Heads.

The first Durham County Structure Plan

Structure Plans consisted of a broad framework of policies looking forward up to 20 years ahead, supported by a "key diagram" showing land use, transport and environmental proposals diagrammatically (that is, not on a locationally specific map base). Local Plans, usually prepared by district rather than county councils, were required to accord with the overall strategy set out in the structure plan. It is in local plans that precise boundaries are defined.

The first Durham County Structure Plan, approved in January 1981, had two strategic policies for protecting the unique setting of Durham City. Policy 98 declared an Area of Great Landscape Value around the west, south and east sides of the City; and Policy 126 required protection of the traditional setting by conserving the wooded slopes and horizons and views to and from the Cathedral and Castle.

County Structure Plan Review 1999

After a series of annual reports and formal Alterations to update certain policies and to extend the Plan period to 1996, a full review resulted in a new County Structure Plan approved in March 1999. Policy 5 of the 1999 County Durham Structure Plan makes provision for a Green Belt in North Durham which extends from Tyne and Wear and encompasses Durham City. The general extent of the Green Belt around Durham reaches south westwards from Chester-le-Street, east of Kimblesworth, south of Witton Gilbert, east of Bearpark, and southwards to Croxdale and then north-eastwards to Sherburn and West Rainton, to encircle Durham City.

The County Structure Plan 1999 makes clear that an all-encompassing Green Belt around Durham City is necessary to preserve its special character and setting which encompasses the high quality landscape and undulating topography of open land around the City along with strategic gaps between settlements. It highlights the importance of maintaining the strategic gap between Chester-le-Street and Durham City to prevent the linking up of these urban areas.

The City of Durham Local Plan 2004

Detailed application of the County Structure Plan strategic policies are set out in the City of Durham Local Plan started in 1996 and finally approved in 2004. The boundaries of the Durham City Green Belt include land which is vital to the character and setting of Durham City and is likely to be subject to development pressures which cannot be controlled by normal development control policies. It includes green fingers of land that penetrate the City at Aykley Heads and Flass Vale; substantial areas of high landscape value around the City, including parts of the Browney Valley and the Wear Valley; and the strategic gap to the north of the City, adjacent to the proposed Chester-le-Street Green Belt.

Saved Polices

The Planning and Compulsory Purchase Act 2004 abolished structure and local plans (just as Durham City’s Local Plan was approved). Instead, Local Development Frameworks had to be produced. In the interim, the Act allowed some local plan policies to be 'saved' until they are replaced by new policies in the County Durham Local Development Documents. For Durham City, the Secretary of State agreed to a set of saved policies in 2007.

So far as the Durham Green Belt is concerned, the following saved policy continues to be in statutory force until it is superseded by the County Durham Local Plan in 2014.

E1 Green Belt: Within the green belt defined on the proposals map the construction of new building is inappropriate and will not be permitted unless it is for the following purposes: 1. Agriculture or forestry; or 2. Essential facilities for outdoor sport and recreation, for cemeteries, and for other uses of land which preserve the openness of the green belt; or 3. Limited infilling in, or redevelopment of existing major developed sites consistent with policy E2; or 4. Replacement of an existing dwelling where this is consistent with policy H6; or 5. The re-use or conversion of an existing building where this is consistent with policy E8; or 6. Limited extensions or alterations to existing dwellings where this is consistent with policy Q9.