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CPRE) - Darlington Group Comment. Consultee Gillan Gibson (1164350) Email Address Company / Organisation Campaign to Protect Rural England (CPRE) - Darlington Group Address Event Name Darlington Local Plan 2016-2036 (Regulation 19) Comment by Campaign to Protect Rural England (CPRE) - Darlington Group ( Gillan Gibson - 1164350) Comment ID DBLPPS82 Response Date 14/09/20 10:14 Consultation Point Policy IN 1 Delivering a Sustainable Transport Network (Strategic Policy) (View) Status Processed Submission Type Email Version 0.5 Question 1b Do you consider that the Local Plan sound? No Question 2 Do you consider that this part of the Local Plan is Effective unsound because it is not: (tick all that apply) Justified Question 3a Your Comments Please give details of why you consider that this part of the Local Plan is not legally compliant or unsound or fails to comply with the Duty to Cooperate. See: "2 - CPRE - Rep form - IN 1-Sec C-Para vii - Road - Key routes for new roads and public transport links- Extension Document - Word version" for a Word version of the contents of this Representation form. (A PDF version of that Extension Document is also submitted) CPRE Considers these roads are not justified as they will generate more traffic and CPRE has not identified any exploration or detailed justification for these roads by Darlington Borough Council. Powered by Objective Online 4.2 - page 1 CPRE also notes the lack of detail in the routes of these roads in the Policies Map. So far as CPRE is aware they are only indicated on Map 1 as “New Roads and Transport Links (IN 1)” without any further detail, or reference to where further detail can be found. • The costs of new roads are not just financial, they include environmental and other wider impacts• Research has persistently found new roads create more traffic• The new roads proposed will currently go through unspoilt countryside and significantly change the landscape in a negative way• Tranquility is an important concept for CPRE who have conducted studies into the topic. New roads will severely damage the tranquility of the countryside along their route.• No attempt has been made to address if any mitigation is proposed for the damage that will be caused, or indeed if any mitigation is possible The concerns of other organisations and individuals are noted, with particular reference to Darlington Green Party. Question 4 Changes Sought Please Note your representation should cover succinctly all the information, evidence and supporting information necessary to support/justify the representation and the suggested change, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage. There is the opportunity to attach Word or PDF files before submitting your comment. After this stage, further submissions will only be at the request of the Inspector, based on the matters and issues identified for examination. Please set out what change(s) to the Local Plan you consider necessary to make it legally compliant or sound.You will need to say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording for any policy or text. CPRE requests these roads be removed from the Plan Question 5 Attendance at Examination Hearings If your representation is seeking a change, do you Yes, I wish to participate at the examination hearings consider it necessary to participate in the examination hearings? Question 5a Participation at Examination Hearings Please note the inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the examination hearings. If you wish to participate at the examination hearings, please outline why you consider it to be necessary? CPRE with many other individuals and organisations has persistently argued for many years additional roads are not required, with particular reference to a Northern Bypass/Link/Relief Road. These other roads will also bring many negative issues. Our concerns on this are substantial and need consideration that may well go well go beyond making written comments Question 6 Powered by Objective Online 4.2 - page 2 Do you request to be notified that the Local Plan Yes, I request to be notified has been submitted to the Secretary of State for independent examination under section 22(3) of the regulations and to be notified of the adoption of the Local Plan? Powered by Objective Online 4.2 - page 3 Comment. Consultee Gillan Gibson (1164350) Email Address Company / Organisation Campaign to Protect Rural England (CPRE) - Darlington Group Address Event Name Darlington Local Plan 2016-2036 (Regulation 19) Comment by Campaign to Protect Rural England (CPRE) - Darlington Group ( Gillan Gibson - 1164350) Comment ID DBLPPS83 Response Date 14/09/20 10:14 Consultation Point Policy H 1 Housing Requirement (Strategic Policy) (View) Status Processed Submission Type Email Version 0.6 Files 3 - CPRE - Rep form - H 1 - Housing Requirement - Extension document - PDF version.pdf Question 1a Do you consider that the Local Plan is Legally No compliant? Question 1b Do you consider that the Local Plan sound? No Question 1c Do you consider that the Local Plan complies with No the Duty to Cooperate? Question 2 Do you consider that this part of the Local Plan is Effective unsound because it is not: (tick all that apply) Justified Powered by Objective Online 4.2 - page 1 Consistent with national policy Question 3a Your Comments Please give details of why you consider that this part of the Local Plan is not legally compliant or unsound or fails to comply with the Duty to Cooperate. 1. CPRE objects to the figures Darlington Borough Council is using, considering the locally calculated baseline OAN of 422 houses per annum far higher than required. This is compounded if the figure of 492 houses per annum mentioned in this Policy is the “target” figure. CPRE questions the use of two different figures, an OAN and a “target” figure. As para 6.1.3 says, the standard methodology put forward by the Government identifies an Objectively Assessed (housing) Need (OAN) baseline of 177 hpa 2016-26 (houses per annum). And since March 2018, Government guidance requires any Local Planning Authority (LPA) Plan that has not reached submission stage to adopt the standard methodology OAN (Objectively Assessed Need). Increased provision above the baseline OAN to support economic growth is actively encouraged by the Government, but the level of increase must be realistic and justified. CPRE considers the Council has not put forward any exceptional circumstances to justify this higher figure and is not convinced there will be the creation of an additional 7,000 full time equivalent jobs over the Plan period. So the locally calculated baseline OAN of 422 (or 492) hpa needs to be discarded and the Plan redrafted adopting a baseline OAN of 177 hpa. CPRE notes and supports the analysis of the Darlington Green Party with regard to the OAN. With regard to the Duty to Cooperate, CPRE also notes the comments of the Low Conisclilffe and Merrybent Parish Council on the lack of consideration of their Neighborhood Plan, which has been made, when considering the housing numbers and allocations for their Neighbourhood Plan area. The Neighbourhood Plan was informed by a specifically commissioned analysis which should, therefore, carry great weight. CPRE also represents this demonstrates a failing in the Duty to Cooperate. CPRE also draws attention to the following analysis of planning applications, commitments, and the figures in the Local Plan: Darlington Local Plan Submission Draft 2020Note regarding Housing Allocations. Local Plan Extract 6.2.2 There is the need to allocate sufficient land to accommodate a minimum of 8,440 dwellings and a target of 9,840 dwellings within the plan period. The allocations which will contribute to achieving this are set out in Policy H 2. In combination with existing commitments and taking into account housing delivery since the start of the plan period (2016) there is sufficient land to surpass the housing target. The allocations and existing commitments have the potential to deliver approximately 10,000 homes up to 2036. The build out of a number of the strategic sites will also extend beyond 2036. Taking this into consideration the plan has sufficient land for approximately 16,000 homes. CompletionsThe tables in the Housing Trajectory, Appendix A, give completions for the first four years of the plan and these total 1807 dwellings on both large and small sites. CommitmentsTable 6.4 lists housing commitments, totalling 2652 on sites of over 10 dwellings to be completed within the plan period. One of these sites, 68 West Park Garden Village, carries 360 completions after 2036. Small sitesThe third last line of the tables in the Housing Trajectory, Appendix A, estimates that 25 dwellings will be completed each year on small sites (under 10 dwellings), aggregating to 400 dwellings within the remainder of the plan period. Windfall sitesUnallocated sites of over 10 dwellings will come forward within the plan period and be approved where they conform with the plan policies, e.g. are within development boundaries or bring appropriate brownfield sites into sustainable development. The plan makes no estimate for windfall sites, without explanation. However the following examples already exist; Powered by Objective Online 4.2 - page 2 • Darlington Road Sadberge where outline permission was granted on 07/02/2020 for 46 dwellings on the former reservoir.• 182 Northgate where 24 apartments are recommended for approval on 2 September• 213-217 Haughton Road where 12 apartments were permitted on 04/05/2020. Thus windfalls already total 82 dwellings and on this basis the total for the remainder of the plan period could be significant.
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