Hellens Development Ltd Land at Coxhoe, Durham

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Central Square Forth Street Newcastle upon Tyne NE1 3PJ

Hellens Development Ltd

Land at Coxhoe, Durham

Representations to Durham Pre-Submission Draft Local Plan October 2013

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Hellens Development Ltd Reps to Durham Local Plan

CONTENTS

1. Introduction ...... 3 2. Background ...... 5 3. The Site – Land at Coxhoe ...... 7 4. Comments on the Local Plan ...... 9 5. Summary ...... 18

Appendices

Appendix 1 Representations Pro-forma

Appendix 2 Site location Plan

Hellens Development Ltd Reps to Durham Local Plan

1. Introduction

1.1 We are instructed by Hellens Development Ltd ("our client") to submit representations on their behalf to the Pre-Submission Draft Local Plan (October 2013)("the Local Plan"). On their behalf we have made submissions to each stage of the County Durham Plan and evidence base.

1.2 Notwithstanding previous detailed representations to each stage of the Local Plan, the pre-submission draft Local Plan has not increased the allocation of houses to the village of Coxhoe to a level commensurate with the size of the village or the availability of land, nor has it allocated our client’s land for housing. In our view the plan has identified insufficient housing development sites in Coxhoe and is over relying on the strategic Green Belt sites under Policy 8.

1.3 Our clients object to this position in the strongest possible terms and consider that the previous representations and evidence submitted to support increasing an allocation for Coxhoe and an allocation of our client’s land has not been properly considered by the Council.

1.4 We therefore consider that the following policies are not sound:

 Policy 4 – Distribution of Development

 Policy 8 - Durham City Strategic Sites

 Policy 30 – Housing Land Allocations

In addition to the above Policies, our client considers that the proposals map is not sound because it does not show an existing housing commitment at Commercial Road East, Coxhoe (“The Limes”) and incorrectly shows land as a local wildlife site which has now been developed or has planning consent for development that has lawfully commenced.

1.5 In summary, our client considers that Policies, 4, 8 and 30 and the proposals map for the Local Plan are not sound because they are not:

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Hellens Development Ltd Reps to Durham Local Plan

 Positively prepared (it is not the most appropriate strategy and it is not based on balanced evidence)

 Justified (it is not the most appropriate when considered against the evidence based and reasonable alternatives)

1.6 As required, we have completed the Council’s pro-forma response forms and answered the questions raised which are attached in Appendix 1.

1.7 Should you wish to discuss anything in relation to this matter then please contact:

David Brocklehurst Associate T 0191 269 0065 E [email protected]

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Hellens Development Ltd Reps to Durham Local Plan

2. Background

2.1 Our client is a major landowner in the north east and in Durham with interest in sites in Coxhoe, Ferryhill and Peterlee.

2.2 These representations refer only to our client's land at Coxhoe.

2.3 The land our client owns in Coxhoe is located at the northern edge of the village, to the north of Commercial Road East. It was historically a lime works. The remaining undeveloped/non consented extent of ownership is outlined in red on the plan in Appendix 2. The land which already benefits from planning consent is annotated on the same plan.

2.4 The entire area of our client's ownership has previously benefitted from outline planning consent granted by Durham City Council in the mid 1980's and renewed several times, lastly in the early 1990's. The outline consent granted (which included further land to the south outside our client's ownership) was for residential, commercial, retail and industrial uses. Our client’s land contained the retail, commercial and industrial uses. Only the housing element was ever constructed (the housing estate to the south known as Beechfield Rise) however the principle that our client’s land is suitable for development has been established in the recent past.

2.5 More recently our client obtained residential planning consent for the development of 80 houses on part of the land in 2009 and then later in 2011, obtained consent for a further 47 houses. That housing is currently well under construction by Barratt Homes (a development knows as "The Limes") and at the date of this letter have constructed 70 houses.

2.6 As part of the assessment of both of those applications, the Council (Durham City at that time) agreed that the land (being part of a former lime works) is previously developed as defined (at that time) in PPS3. The remainder of our client's land (outline in blue in Appendix 2), which also formed part of the same lime works, must also be recognised as being previously developed.

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Hellens Development Ltd Reps to Durham Local Plan

2.7 In total our client has permission to construct 127 houses on their land at Coxhoe under the following planning consents:

 4/07/00860/OUT and 4/09/00592/RM – 80 dwellings

 4/11/00166/FPA – 47 dwellings

2.8 The first two phases of development of the land has been very successful and since construction began in 2011, Barratt Homes has completed 70 dwellings (therefore approximately 35 per annum). They have also started on the next phase of 47 houses with the first houses programmed to complete by June 2014 and total completion of the site by the end of 2015. In the first two years of construction the site has out- performed other Barratt housing sites in Durham. This is a reflection of a combination of the following factors:

 The location of Coxhoe in very close proximity for access to the A1 and to Durham City;

 Coxhoe having a range of facilities within walking distance of the site;

 The edge of countryside location;

 The affordability of the homes on offer between £110,000 and £190,000;

 A range of house types, sizes and styles; and

 A lack of supply elsewhere in Coxhoe and in Durham City/Central Durham and the surrounding villages to Durham City due to Green Belt constraints and the lead in time to development of the proposed Strategic Sites around Durham City under Local Plan Policy 8.

2.9 Given the success of the sale of the existing houses constructed it is anticipated that the balance of the 127 homes (i.e. 57 dwellings) which have planning consent will be completed by Barratt Homes over the next two years (site completion at the end of year 2015).

2.10 Acknowledging the success of the existing permitted development on our client's land, they are seeking further development on part of the remainder of their land and it is that land (outlined in red in Appendix 2) to which the representations in this report relate.

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Hellens Development Ltd Reps to Durham Local Plan

3. The Site – Land at Coxhoe

3.1 The site which is the subject of these representations is outlined in red on the attached plan (“the site”) in Appendix 2 and equates to 2.8 hectares. The remainder of our clients land is outline in blue on the same plan.

3.2 The site was formerly part of a lime works and retains structures on site from that historic use. The land has not been in active use in recent years but is previously developed land. The Council has previously accepted in granting planning consent to our client on their land that it is previously developed as defined in planning policy guidance (PPS3/NPPF).

3.3 The land remains privately owned and is not publicly accessible and does not have any rights of way across it.

3.4 The site is in part a Local Wildlife Site ("Local Site") and other than the remaining structures associated with the former lime works comprises of self seeded magnesium limestone grassland and shrubs and some sporadic individual and groups of trees together with 3 ponds in the far north east corner of the site. The site is bound by a watercourse to the north but is not at risk of flooding.

3.5 The site is relatively flat in its western part but rises gently up to the east edge with the Crow Trees Nature Reserve.

3.6 The site is accessible directly from Commercial Road East which runs along the southern boundary.

3.7 The site borders open arable farmland to the north, the Crow Trees Nature Reserve to the east and land used for horse grazing to the south. The land borders a permitted housing site to the west which is now under construction.

3.8 The land sits at the northern edge of Coxhoe village but is within walking distance of its principle shops and services on Coronation Terrace and Station Road.

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Hellens Development Ltd Reps to Durham Local Plan

3.9 The proposal is for our client’s land outline in red on the plan (2.8 hectares) in Appendix 2, to be developed for in the region of 100 houses with the remainder of their land ownership (8.8 hectares) used as an extension to the Crow Trees Nature Reserve. Any development could also involve biodiversity off-setting either on our client’s retained land or at an alternative location. In terms of the latter option our client has identified some third party land to the north as shown on the plan in Appendix 2 as being a potentially suitable site for bio-diversity offsetting. This offsetting would bring a local wildlife site and area of great crested newt ponds into active ecological management.

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Hellens Development Ltd Reps to Durham Local Plan

4. Comments on the Local Plan

Policy 3 (Quantity of New Development)

4.1 Our client supports the construction of at least 31,400 new homes of mixed type, size and tenure, but as set out below (Policy 4), believe that in order to deliver that number in the plan period, which is already three years old, there is a need to redistribute the housing with less reliance on the Strategic Durham sites (Policy H8) that will take a number of years to begin (they are not included in the 5 year housing land supply) and are unlikely to be delivered at the levels proposed, in our view, by the year 2030.

Policy 4 (Distribution of Development)

Has Policy 14 been Positively Prepared?

4.2 We consider that Policy 4 is not currently sound because the distribution of housing has not been positively prepared. The plan has failed to provide sufficient housing in the village of Coxhoe and the plan over relies upon the delivery of Strategic Housing Sites around Durham City (Policy 8) to deliver the housing in Central Durham.

4.3 The plan is not currently sound because:

 There is an under supply of housing in Coxhoe for the early part of the plan period;

 There is an over-supply and reliance on the delivery of the strategic Durham City housing sites; and

 There is inconsistency in the allocation of housing to the small towns/ larger villages in the County.

There is an under supply of housing in Coxhoe for the early part of the plan period.

4.4 Policy 4 allocates 470 dwellings for Coxhoe (increased from 450 in the Preferred options Local Plan)

4.5 We understand the 470 for the plan period (2010-2030) to be made up of the following sites with planning permission plus the two proposed housing allocations

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Hellens Development Ltd Reps to Durham Local Plan

under Policy 30 (H11 – West of Grange Farm, 110 houses in the long term) and H12 (Bogma Hall Farm, 200 houses in short term).

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Hellens Development Ltd Reps to Durham Local Plan

Site Planning Yield in Plan Timescale (years Consent Period (2010 - from start of plan 2030) period at 2010) Land at Cosa Nostra Vicarage 11/00168/FPA Terrace 1 1-5

Land West Of Beech House 09/00679/FPA 1 1-5

Former Coxhoe Picture House 10/00221/FPA 5 1-5

1 Grove Cottages Coxhoe 07/00710/DOM 1 1-5

48 Garden Terrace 10/00154/FPA 1 1-5

Land rear of 15 & 16 Front Street 09/00991/FPA 1 1-5

West of Beech House, 10/00516/FPA Cooperative Road 1 1-5

Land At Sycamore Close 09/00278/FPA 1 1-5

Land at Coxhoe Industrial Estate 09/00592/RM 80 1-5

Land at Commercial Road 11/00166/FPA 47 1-5

The Pottery, Front Street 11/00805/OUT 24 1-5

Sub-total (sites with planning 163 consent)

West of Grange Farm N/A 110 11+

Bogma Hall Farm N/A 200 1-5, 6-10

Total 473 1-20

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4.6 As set out above, it is expected, based on current construction and sales rates (currently 35 units per annum) that the remaining dwellings on our client's land (57 units) will be completed before the end of year 2015.

4.7 Of the 36 consented units on other sites in Coxhoe we would expect some if not all of them to be completed in the next two years whilst some may not come forward at all. Therefore at the end of 2015, supply of new housing will rely on the allocated housing sites.

4.8 We consider that the two allocated sites, due to access and ownership constraints and the lead in time to delivering new houses from obtaining planning consent to construction, are unlikely to deliver any new housing until the middle to latter part of years 6-10 of the plan period (i.e. years 2016-2021). If this is the case it would mean that with the exception of one or two very small sites, there could be a gap in the delivery of new houses in Coxhoe after 2015.

4.9 We therefore consider that an additional allocation is needed in Coxhoe to fill the delivery gap before the allocated sites come forward.

There is an over-supply and reliance on the delivery of the strategic Durham City housing sites in Central Durham

4.10 We consider that as currently drafted there is a heavy reliance on the delivery of housing on the three strategic "Green Belt" housing sites in Durham City (under Policy 8).

4.11 Given the likely substantial lead in times to the development of those sites there is a need to ensure sufficient supply of housing sites elsewhere in the Central Durham sub- area in the short term to medium term. We consider it unlikely that the Durham City strategic sites will deliver the number of houses proposed (3,675 units in the Local Plan period). If the Local Plan is adopted in 2014 (at which point the sites in Policy 8 would be removed from the Green Belt) and notwithstanding any challenges to the adoption of the plan an application would in our view take 12-18 months before approval, even if an application is submitted shortly after adoption of the plan. Given the size of the sites in question our experience would suggest at least another 12-18 months before reserved matters were obtained (where necessary), conditions

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discharged, infrastructure put in place and the first houses being delivered. That would mean the first houses on those sites being delivered in about mid 2017 (at best). That would leave 13 years in which to construct 3,675 dwellings (spread across three sites). That would require completion of about 216 houses per annum from those three sites combined.

4.12 We consider this to be overly ambitious and would lead to a saturation of the Durham City housing market particularly acknowledging the close proximity of the two main strategic sites (Sniperley and Arniston) and fluctuations in the economy over the plan period. By way of comparison, Newcastle Great Park in Newcastle was allocated for housing (and removed from the Green Belt) in 1998. Despite planning consent being granted in August 2000 and the site being located on the edge of the Tyne and Wear Conurbation, the allocation of 2500 houses (spread over 4 areas) is still many years from completion. 15 years from the date of adoption of the Newcastle UDP and 13 years since outline consent was granted about half of the 2,500 houses have been constructed at a rate of about 100 per year. This period also coincided with the significant housing boom between 2000 and 2008.

4.13 Whilst we do not disagree with the proposed strategic housing sites in Policy 8 in principle or indeed the number of houses proposed on them, we think that the delivery of the number proposed in this current draft Local Plan is likely to spill over beyond the plan period. Therefore in order to deliver the same number of houses overall for Durham (Policy 3) and the Central Durham sub-area (Policy 4), we consider it would be a more realistic proposal and would ensure better choice and delivery, to redistribute some of the proposed houses on the Durham City strategic sites for this plan period, to a wider range of sustainable locations in the Central Durham sub-area and to safeguard some of land at the Strategic Sites for development beyond the plan period (i.e. beyond 2030). That way (if re-distributed within the Central Durham sub-area) the benefits in Central Durham would still be achieved in the plan period.

4.14 Looking at the Council’s 5 year housing land supply (October 2013), it is clear that in Central Durham there is a significant under supply of housing sites given the heavy reliance on the strategic sites. If any or all of the strategic sites are found to be unsound or reduced in scale, the Local Plan does not have sufficient sites elsewhere to meet the identified need for Central Durham. We consider therefore that the Local Plan should disperse the housing allocation more widely across Central Durham to

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some of the most sustainable villages (the tier down from the main towns in the settlement study 2012), not constrained by Green Belt such as Brandon, Coxhoe, Bowburn, Langley Park, Sherburn and Sacriston

4.15 In the context of our client’s land interests we therefore consider it appropriate to increase the allocation for Coxhoe that has proven already in the plan period, to deliver housing.

There is inconsistency in the allocation of housing to the small towns/ larger villages in the County

4.16 We note that other large village locations such as Bradon/Langley Moor/Meadowfield (550 units) and Sacriston (590 units) and Murton (530) have larger allocations than Coxhoe, despite being on equal terms in respect to sustainability in the 2012 settlement study. We consider that for consistency and in order to deliver sustainable development early in the plan period in Central Durham that the allocation for Coxhoe should be increased in line with other larger villages to at least 570 units. This would reflect our comments in respect to Policy 30 that our client's land at Coxhoe should be allocated in the Local Plan for 100 units.

Is Policy 4 Justified?

4.17 We do not consider Policy 4 is justified because we do not consider that the evidence presented by the Council for housing delivery and distribution in Central Durham is deliverable in the plan period.

What Changes would make Policy 4 Sound?

4.18 To make Policy 4 sound we suggest that the housing distribution should be amended so that other larger village in Central Durham not constrained by Green Belt have an increased allocation. In the case of Coxhoe it should be allocated 570 units to reflect its role as a larger village in Central Durham (and therefore in line with other large villages in Central Durham and elsewhere) which have already demonstrably delivered new housing. The total number of houses allocated on the strategic sites (under Policy 8) should be reduced proportionately.

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Policy 8 (Durham City Strategic Sites)

Has Policy 8 been positively prepared?

4.19 We do not consider that Policy 8 has set realistic and achievable housing numbers in the plan period on the strategic sites in Durham City.

4.20 We consider that the projections for the site are overly ambitious and will not deliver 3,675 new houses before 2030 given that the plan is yet to be adopted, there is no planning consent in place and the evidence of historic delivery in the City and elsewhere indicates that this volume of housing cannot be supported.

4.21 Whilst we do not object to the allocation of strategic housing sites in Durham City, we consider that a proportion of those sites should be removed from allocation and safeguarded for development beyond the plan period (i.e. beyond 2030).

4.22 None of the strategic sites are in the Council’s 5 year housing land supply and therefore at the current time Central Durham has a significant under supply of housing sites.

4.23 We consider (for the reasons set out in respect to Policy 4 of the Local Plan) that the distribution of housing should be changed to increase housing in the larger villages (outside Durham City Green Belt) in Central Durham to ensure more evenly distributed housing and prevent a delay to the delivery of housing in the next 5 years in those locations.

Is Policy 8 Justified?

4.24 We do not consider that Policy 8 has been justified or there is evidence that the three strategic sites can deliver the houses proposed in the plan period.

4.25 Acknowledging that the Local Plan period began in 2010, by the time of the adoption of the plan only 16 years will remain to construct 3,675 dwellings. We consider that this is not deliverable on three sites on the edge of Durham City. We therefore suggest redistribution and safeguarding land is a more justified approach.

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What changes would make policy 8 sound?

4.26 We consider that the number of houses on the strategic sites in Policy 8 should be reduced and redistributed to other large village locations in Central Durham which are free of Green Belt constraint and which have proven to deliver new housing such as Coxhoe.

4.27 We consider that at least 100 units should be re-allocated to Coxhoe.

Policy 30 (Housing Land Allocations)

Has Policy 30 been positively prepared?

4.28 Given our client’s responses to Policy 4 and 8 which they do not consider are sound, our clients consider that Policy 30 is not sound because it does not allocate their land (outline in red in Appendix 2) as a housing allocation for 100 dwellings.

4.29 Local Plan Policy 30 has failed to meet development and infrastructure requirements for Coxhoe by including insufficient housing allocations and over relying upon the strategic sites in Durham City to deliver the housing requirements for Central Durham.

Has Policy 30 been justified?

4.30 As set out in responses to Policy 4, Coxhoe is a large village but has been under allocated when compared to other large villages in Central Durham. This is not justified because the evidence presented by the Council in its 5 year housing land supply and SHLAA is that Central Durham has a shortage of housing sites and is relying upon the delivery of the large strategic sites in Durham City.

4.31 We do not consider that Policy 30 is justified because the evidence presented by the Council (SHLAA, 5 year housing land supply) suggests that there is an over reliance on strategic sites in Central Durham.

What changes would make Policy 30 sound?

4.32 We consider that Policy 30 would be sound if it allocated more housing to locations in Central Durham including at least 100 more in Coxhoe on our client’s land outlined in red on Appendix 2. The plan would be sound if the proposals map annotates an allocation on the land for housing.

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Proposals Map

4.33 We consider that the proposals map cannot be adopted in its current format because it is not accurate and does not reflect housing commitments in Coxhoe on our client’s former land now being developed for housing by Barratt Homes (“The Limes”).

4.34 The Plan attached in Appendix 2 illustrates that the land north of commercial road east in Coxhoe has planning consent for 127 dwellings of which approximately 70 have been constructed. A further 57 are being constructed and are due for completion by the end of year 2015.

4.35 The committed houses should be annotated on the proposals map, like sites elsewhere in the plan (for example the housing commitment at Browney Lane, Meadowfield). This is relevant in the context of our client’s land because part of the site that has been developed and is committed is shown in the current draft proposals map as a Local Wildlife Site.

4.36 Given the development that has taken place and is ongoing the boundaries of the Local Wildlife Site should be amended on the proposals map.

What change would make the Proposals Map Sound?

4.37 The proposals map should be amended to annotate the committed housing development at Commercial Road East, Coxhoe together with (for reasons set out in response to Policy 30) a housing allocation on our client’s land outlined in red on the plan attached in Appendix 2.

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5. Summary

5.1 We are instructed by Hellens Development Ltd ("our client") to submit representations on their behalf to the Pre-Submission Draft Local Plan (October 2013).

5.2 Our clients consider that the following policies are not sound:

 Policy 4 – Distribution of Development

 Policy 8 - Durham City Strategic Sites

 Policy 30 – Housing Land Allocations

5.3 In addition to the above Policies, our client considers that the proposals map is not sound because it does not show an existing housing commitment at Commercial Road East, Coxhoe (“The Limes”).

5.4 In summary, our client considers that Policies, 4, 8 and 30 and the proposals map for the Local Plan are not sound because they are not:

 Positively prepared (it is not the most appropriate strategy and it is not based on balanced evidence)

 Justified (it is not the most appropriate when considered against the evidence based and reasonable alternatives)

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Appendix 1

Representations Pro-Formas

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COUNTY DURHAM PLAN For Office Use Only

PRE-SUBMISSION DRAFT - Consultee ID: Consultation October 2013 Received: Acknowledged: Processed:

Please use a separate form for each representation.

NAME & ADDRESS (Block Capitals) NAME & ADDRESS (AGENT)(IF APPLICABLE) GVA Hellens Development Ltd LEVEL 4 Teal House CENTRAL SQUARE 10 Teal Farm Way FORTH STREET Pattinson NEWCASTLE UPON TYNE Washington NE1 3PJ NE38 8BG

Email Address [email protected]

Email Address

Preferred method of contact (please tick): Email x Letter 

To which part of the County Durham Plan does your representation relate? Site Ref

Chapter Paragraph Policy no 4 Proposals Map

Q1 - Do you consider that this policy/proposal of the Pre-Submission Draft Local Plan is to be Legally and Procedurally Compliant and Sound?

(Please note the considerations in relation to the Local Plan being ‘Legally and Procedurally Compliant’ and ‘Sound’ are explained in the National Planning Policy Framework in paragraph 182 (Please see guidance notes). (Please select one answer for each question)

Yes (Go to Q2) No (Go to Q3)

Legally and Procedurally Complaint x

Sound x

Q2 - If you consider that this policy/proposal of the Pre-Submission Draft Local Plan is Legally and Procedurally Compliant and Sound please use this box to explain why?

Please note your representation should cover all the information, evidence and supporting information necessary to support/justify the representation and the suggested change, as there is no opportunity to submit further representations unless requested to do so by the Inspector, based on the matters he/she identifies for examination.

(This box can be expanded) (Go to Q6) Q3 - Why do you consider that this Policy/Proposal of the Pre-Submission Draft Local Plan is not Legally and Procedurally Compliant or Sound? (Please select all that apply)

Positively Prepared x

Justified x

Effective

Consistent with national policy x

Q4 - If you do not consider this policy/proposal of the Pre-Submission Draft Local Plan to be Legally and Procedurally Compliant or Sound please use this box to explain why.

Please note your representation should cover all the information, evidence and supporting information necessary to support/justify the representation as there is no opportunity to submit further representations unless requested to do so by the Inspector, based on the matters he/she identifies for examination.

Has Policy 14 been Positively Prepared?

1.1 We consider that Policy 4 is not currently sound because the distribution of housing has not been positively prepared. The plan has failed to provide sufficient housing in the village of Coxhoe and the plan over relies upon the delivery of Strategic Housing Sites around Durham City (Policy 8) to deliver the housing in Central Durham.

1.2 The plan is not currently sound because:

 There is an under supply of housing in Coxhoe for the early part of the plan period;

 There is an over-supply and reliance on the delivery of the strategic Durham City housing sites; and

 There is inconsistency in the allocation of housing to the small towns/ larger villages in the County.

There is an under supply of housing in Coxhoe for the early part of the plan period.

1.3 Policy 4 allocates 470 dwellings for Coxhoe (increased from 450 in the Preferred options Local Plan)

1.4 We understand the 470 for the plan period (2010-2030) to be made up of sites with planning permission plus the two proposed housing allocations under Policy 30 (H11 – West of Grange Farm, 110 houses in the long term) and H12 (Bogma Hall Farm, 200 houses in short term).

1.5 As set out above, it is expected, based on current construction and sales rates (currently 35 units per annum) that the remaining dwellings on our client's land (57 units) will be completed before the end of year 2015.

1.6 Of the 36 consented units on other sites in Coxhoe we would expect some if not all of them to be completed in the next two years whilst some may not come forward at all. Therefore at the end of 2015, supply of new housing will rely on the allocated housing sites.

1.7 We consider that the two allocated sites, due to access and ownership constraints and the lead in time to delivering new houses from obtaining planning consent to construction, are unlikely to deliver any new housing until the middle to latter part of years 6-10 of the plan period (i.e. years 2016-2021). If this is the case it would mean that with the exception of one or two very small sites, there could be a gap in the delivery of new houses in Coxhoe after 2015.

1.8 We therefore consider that an additional allocation is needed in Coxhoe to fill the delivery gap before the allocated sites come forward.

There is an over-supply and reliance on the delivery of the strategic Durham City housing sites in Central Durham

1.9 We consider that as currently drafted there is a heavy reliance on the delivery of housing on the three strategic "Green Belt" housing sites in Durham City (under Policy 8).

1.10 Given the likely substantial lead in times to the development of those sites there is a need to ensure sufficient supply of housing sites elsewhere in the Central Durham sub-area in the short term to medium term. We consider it unlikely that the Durham City strategic sites will deliver the number of houses proposed (3,675 units in the Local Plan period). If the Local Plan is adopted in 2014 (at which point the sites in Policy 8 would be removed from the Green Belt) and notwithstanding any challenges to the adoption of the plan an application would in our view take 12-18 months before approval, even if an application is submitted shortly after adoption of the plan. Given the size of the sites in question our experience would suggest at least another 12-18 months before reserved matters were obtained (where necessary), conditions discharged, infrastructure put in place and the first houses being delivered. That would mean the first houses on those sites being delivered in about mid 2017 (at best). That would leave 13 years in which to construct 3,675 dwellings (spread across three sites). That would require completion of about 216 houses per annum from those three sites combined.

1.11 We consider this to be overly ambitious and would lead to a saturation of the Durham City housing market particularly acknowledging the close proximity of the two main strategic sites (Sniperley and Arniston) and fluctuations in the economy over the plan period. By way of comparison, Newcastle Great Park in Newcastle was allocated for housing (and removed from the Green Belt) in 1998. Despite planning consent being granted in August 2000 and the site being located on the edge of the Tyne and Wear Conurbation, the allocation of 2500 houses (spread over 4 areas) is still many years from completion. 15 years from the date of adoption of the Newcastle UDP and 13 years since outline consent was granted about half of the 2,500 houses have been constructed at a rate of about 100 per year. This period also coincided with the significant housing boom between 2000 and 2008.

1.12 Whilst we do not disagree with the proposed strategic housing sites in Policy 8 in principle or indeed the number of houses proposed on them, we think that the delivery of the number proposed in this current draft Local Plan is likely to spill over beyond the plan period. Therefore in order to deliver the same number of houses overall for Durham (Policy 3) and the Central Durham sub-area (Policy 4), we consider it would be a more realistic proposal and would ensure better choice and delivery, to redistribute some of the proposed houses on the Durham City strategic sites for this plan period, to a wider range of sustainable locations in the Central Durham sub-area and to safeguard some of land at the Strategic Sites for development beyond the plan period (i.e. beyond 2030). That way (if re-distributed within the Central Durham sub-area) the benefits in Central Durham would still be achieved in the plan period.

1.13 Looking at the Council’s 5 year housing land supply (October 2013), it is clear that in Central Durham there is a significant under supply of housing sites given the heavy reliance on the strategic sites. If any or all of the strategic sites are found to be unsound or reduced in scale, the Local Plan does not have sufficient sites elsewhere to meet the identified need for Central Durham. We consider therefore that the Local Plan should disperse the housing allocation more widely across Central Durham to some of the most sustainable villages (the tier down from the main towns in the settlement study 2012), not constrained by Green Belt such as Brandon, Coxhoe, Bowburn, Langley Park, Sherburn and Sacriston

1.14 In the context of our client’s land interests we therefore consider it appropriate to increase the allocation for Coxhoe that has proven already in the plan period, to deliver housing.

There is inconsistency in the allocation of housing to the small towns/ larger villages in the County

1.15 We note that other large village locations such as Bradon/Langley Moor/Meadowfield (550 units) and Sacriston (590 units) and Murton (530) have larger allocations than Coxhoe, despite being on equal terms in respect to sustainability in the 2012 settlement study. We consider that for consistency and in order to deliver sustainable development early in the plan period in Central Durham that the allocation for Coxhoe should be increased in line with other larger villages to at least 570 units. This would reflect our comments in respect to Policy 30 that our client's land at Coxhoe should be allocated in the Local Plan for 100 units.

Is Policy 4 Justified?

1.16 We do not consider Policy 4 is justified because we do not consider that the evidence presented by the Council for housing delivery and distribution in Central Durham is deliverable in the plan period.

(This box can be expanded)

Q5 - What change(s) do you consider necessary to make this policy/proposal of the Pre-Submission Draft Plan Legally and Procedurally Compliant and Sound?

1.17 To make Policy 4 sound we suggest that the housing distribution should be amended so that other larger village in Central Durham not constrained by Green Belt have an increased allocation. In the case of Coxhoe it should be allocated 570 units to reflect its role as a larger village in Central Durham (and therefore in line with other large villages in Central Durham and elsewhere) which have already demonstrably delivered new housing. The total number of houses allocated on the strategic sites (under Policy 8) should be reduced proportionately.

(This box can be expanded) Q6 - Do you wish to participate in the Examination in Public? (Please note that the Planning Inspector will make the final decision on who will be invited to attend individual sessions at the Examination)

Yes x No

Q7 - Do you want to be informed of the following:

 Submission of the Local Plan to the Secretary of State? Yes x No

 The publication of the Inspector’s report*? Yes x No

 The adoption of the County Durham Plan? Yes x No

(*Note an independent Government appointed Planning Inspector will examine the County Durham Plan and produce an Inspector’s report).

Please send the completed question response Responses can also be sent by email to: forms to: [email protected] However, we would prefer if you made your FREEPOST SPATIAL POLICY responses online, via our interactive website: http://durhamcc- consult.limehouse.co.uk/portal/planning/ In order to make responses online, you may need to register. This is quick and easy to do.

Closing date for responses – 6 December 2013 COUNTY DURHAM PLAN For Office Use Only

PRE-SUBMISSION DRAFT - Consultee ID: Consultation October 2013 Received: Acknowledged: Processed:

Please use a separate form for each representation.

Email Address [email protected]

Email Address

Preferred method of contact (please tick): Email x Letter 

To which part of the County Durham Plan does your representation relate? Site Ref

Chapter Paragraph Policy no 8 Proposals Map

Q1 - Do you consider that this policy/proposal of the Pre-Submission Draft Local Plan is to be Legally and Procedurally Compliant and Sound?

Yes (Go to Q2) No (Go to Q3)

Legally and Procedurally Complaint x

Sound x

Q2 - If you consider that this policy/proposal of the Pre-Submission Draft Local Plan is Legally and Procedurally Compliant and Sound please use this box to explain why?

Positively Prepared x

Justified x

Effective

Consistent with national policy

Q4 - If you do not consider this policy/proposal of the Pre-Submission Draft Local Plan to be Legally and Procedurally Compliant or Sound please use this box to explain why.

Has Policy 8 been positively prepared?

1.1 We do not consider that Policy 8 has set realistic and achievable housing numbers in the plan period on the strategic sites in Durham City.

1.2 We consider that the projections for the site are overly ambitious and will not deliver 3,675 new houses before 2030 given that the plan is yet to be adopted, there is no planning consent in place and the evidence of historic delivery in the City and elsewhere indicates that this volume of housing cannot be supported.

1.3 Whilst we do not object to the allocation of strategic housing sites in Durham City, we consider that a proportion of those sites should be removed from allocation and safeguarded for development beyond the plan period (i.e. beyond 2030).

1.4 None of the strategic sites are in the Council’s 5 year housing land supply and therefore at the current time Central Durham has a significant under supply of housing sites.

1.5 We consider (for the reasons set out in respect to Policy 4 of the Local Plan) that the distribution of housing should be changed to increase housing in the larger villages (outside Durham City Green Belt) in Central Durham to ensure more evenly distributed housing and prevent a delay to the delivery of housing in the next 5 years in those locations.

Is Policy 8 Justified?

1.6 We do not consider that Policy 8 has been justified or there is evidence that the three strategic sites can deliver the houses proposed in the plan period.

1.7 Acknowledging that the Local Plan period began in 2010, by the time of the adoption of the plan only 16 years will remain to construct 3,675 dwellings. We consider that this is not deliverable on three sites on the edge of Durham City. We therefore suggest redistribution and safeguarding land is a more justified approach.

(This box can be expanded)

Q5 - What change(s) do you consider necessary to make this policy/proposal of the Pre-Submission Draft Plan Legally and Procedurally Compliant and Sound?

1.8 We consider that the number of houses on the strategic sites in Policy 8 should be reduced and redistributed to other large village locations in Central Durham which are free of Green Belt constraint and which have proven to deliver new housing such as Coxhoe.

1.9 We consider that at least 100 units should be re-allocated to Coxhoe.

Yes x No

Q7 - Do you want to be informed of the following:

 Submission of the Local Plan to the Secretary of State? Yes x No

 The publication of the Inspector’s report*? Yes x No

 The adoption of the County Durham Plan? Yes x No

(*Note an independent Government appointed Planning Inspector will examine the County Durham Plan and produce an Inspector’s report).

Please send the completed question response forms to:

FREEPOST SPATIAL POLICY Responses can also be sent by email to: [email protected] However, we would prefer if you made your responses online, via our interactive website: http://durhamcc- consult.limehouse.co.uk/portal/planning/ In order to make responses online, you may need to register. This is quick and easy to do.

Closing date for responses – 6 December 2013 COUNTY DURHAM PLAN For Office Use Only

PRE-SUBMISSION DRAFT - Consultee ID: Consultation October 2013 Received: Acknowledged: Processed:

Please use a separate form for each representation.

Email Address [email protected]

Email Address

Preferred method of contact (please tick): Email x Letter 

To which part of the County Durham Plan does your representation relate? Site Ref

Chapter Paragraph Policy no 30 Proposals Map

Q1 - Do you consider that this policy/proposal of the Pre-Submission Draft Local Plan is to be Legally and Procedurally Compliant and Sound?

Yes (Go to Q2) No (Go to Q3)

Legally and Procedurally Complaint x

Sound x

Q2 - If you consider that this policy/proposal of the Pre-Submission Draft Local Plan is Legally and Procedurally Compliant and Sound please use this box to explain why?

Positively Prepared x

Justified x

Effective

Consistent with national policy

Q4 - If you do not consider this policy/proposal of the Pre-Submission Draft Local Plan to be Legally and Procedurally Compliant or Sound please use this box to explain why.

Has Policy 30 been positively prepared?

1.1 Given our client’s responses to Policy 4 and 8 which they do not consider are sound, our clients consider that Policy 30 is not sound because it does not allocate their land (outline in red in Appendix 2 of the main submissions) as a housing allocation for 100 dwellings.

1.2 Local Plan Policy 30 has failed to meet development and infrastructure requirements for Coxhoe by including insufficient housing allocations and over relying upon the strategic sites in Durham City to deliver the housing requirements for Central Durham.

Has Policy 30 been justified?

1.3 As set out in responses to Policy 4, Coxhoe is a large village but has been under allocated when compared to other large villages in Central Durham. This is not justified because the evidence presented by the Council in its 5 year housing land supply and SHLAA is that Central Durham has a shortage of housing sites and is relying upon the delivery of the large strategic sites in Durham City.

1.4 We do not consider that Policy 30 is justified because the evidence presented by the Council (SHLAA, 5 year housing land supply) suggests that there is an over reliance on strategic sites in Central Durham.

(This box can be expanded)

Q5 - What change(s) do you consider necessary to make this policy/proposal of the Pre-Submission Draft Plan Legally and Procedurally Compliant and Sound?

1.5 We consider that Policy 30 would be sound if it allocated more housing to locations in Central Durham including at least 100 more in Coxhoe on our client’s land (outlined in red on Appendix 2 of the main submissions). The plan would be sound if the proposals map annotates an allocation on the land for housing.

Yes x No

Q7 - Do you want to be informed of the following:

 Submission of the Local Plan to the Secretary of State? Yes x No

 The publication of the Inspector’s report*? Yes x No

 The adoption of the County Durham Plan? Yes x No

(*Note an independent Government appointed Planning Inspector will examine the County Durham Plan and produce an Inspector’s report).

Closing date for responses – 6 December 2013 COUNTY DURHAM PLAN For Office Use Only

PRE-SUBMISSION DRAFT - Consultee ID: Consultation October 2013 Received: Acknowledged: Processed:

Please use a separate form for each representation.

Email Address [email protected]

Email Address

Preferred method of contact (please tick): Email x Letter 

To which part of the County Durham Plan does your representation relate? Site Ref

Chapter Paragraph Policy no Proposals Map x

Q1 - Do you consider that this policy/proposal of the Pre-Submission Draft Local Plan is to be Legally and Procedurally Compliant and Sound?

Yes (Go to Q2) No (Go to Q3)

Legally and Procedurally Complaint x

Sound x

Q2 - If you consider that this policy/proposal of the Pre-Submission Draft Local Plan is Legally and Procedurally Compliant and Sound please use this box to explain why?

Positively Prepared

Justified x

Effective

Consistent with national policy

Q4 - If you do not consider this policy/proposal of the Pre-Submission Draft Local Plan to be Legally and Procedurally Compliant or Sound please use this box to explain why.

1.1 We consider that the proposals map cannot be adopted in its current format because it is not accurate and does not reflect housing commitments in Coxhoe on our client’s former land now being developed for housing by Barratt Homes (“The Limes”).

1.2 The Plan attached in Appendix 2 of our main submissions illustrates that the land north of commercial road east in Coxhoe has planning consent for 127 dwellings of which approximately 70 have been constructed. A further 57 are being constructed and are due for completion by the end of year 2015.

1.3 The committed houses should be annotated on the proposals map, like sites elsewhere in the plan (for example the housing commitment at Browney Lane, Meadowfield). This is relevant in the context of our client’s land because part of the site that has been developed and is committed is shown in the current draft proposals map as a Local Wildlife Site.

1.4 Given the development that has taken place and is ongoing the boundaries of the Local Wildlife Site should be amended on the proposals map.

(This box can be expanded)

Q5 - What change(s) do you consider necessary to make this policy/proposal of the Pre-Submission Draft Plan Legally and Procedurally Compliant and Sound?

1.5 The proposals map should be amended to annotate the committed housing development at Commercial Road East, Coxhoe together with (for reasons set out in response to Policy 30) a housing allocation on our client’s land outlined in red on the plan attached in Appendix 2 of the main submissions.

Yes x No

Q7 - Do you want to be informed of the following:

 Submission of the Local Plan to the Secretary of State? Yes x No

 The publication of the Inspector’s report*? Yes x No

 The adoption of the County Durham Plan? Yes x No

(*Note an independent Government appointed Planning Inspector will examine the County Durham Plan and produce an Inspector’s report).

Closing date for responses – 6 December 2013 Hellens Development Ltd Reps to Durham Local Plan

Appendix 2

Site Location Plan

November 2013 I gva.co.uk 20

KEY

Proposed housing area (2.8 ha approx)

Area for ecological mitigation (8.8 ha approx)

Area of 3 rd party ownership (2.8 ha approx)

Crowtrees Local Nature Reserve

Area of Hellens ownership (8.8 ha approx)

Client: Hellens Development Title : Overlay Plan

Rev: Land at Coxhoe Industrial Estate File: HEL016.16 5 Coxhoe

Co Durham

Sandgate House, 102 Quayside Newcastle upon Tyne Tel: 0191 2044000 Fax: 0191 2044110 Scale: 1:2500 @A3 Date 01/10/13 Drawn By: KS