Representations to the Darlington Borough Council Proposed Submission Local Plan - August 2020
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Representations to the Darlington Borough Council Proposed Submission Local Plan - August 2020 Prepared on Behalf of Bellway Homes Ltd September 2020 Representations to the Darlington Borough Council Proposed Submission Local Plan - August 2020 Prepared on Behalf of Bellway Homes Ltd. Status: Draft Final Issue/Rev: 01 02 Date: September 2020 September 2020 Prepared by: CB CB Checked by: JH JH Authorised by: JH JH Barton Willmore LLP 1st Floor 14 King Street Leeds LS1 2HL Tel: 0113 204 4777 Ref: 29109/A5/Reps/CB Email: [email protected] Date: September 2020 COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP. All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil-based inks. Contents Page 1.0 Introduction 1 2.0 Vision, Aims and Objectives 3 3.0 Sustainable Development 6 4.0 The Settlement Hierarchy 7 5.0 Design, Climate Change and Construction 9 6.0 Housing 12 7.0 Environment 21 8.0 Transport and Infrastructure 26 9.0 Conclusions 29 Figures 6.1 Policies Map Extract Appendices A Site Context Plans (Great Burdon and Burtree Lane) B Indicative Great Burdon Masterplan Introduction 1.0 INTRODUCTION Background 1.1 Barton Willmore is instructed by Bellway Homes Ltd. (hereafter referred to as our ‘Client’) to submit representations to the Darlington Borough Local Plan Proposed Submission currently subject to public consultation until 17 September 2020. 1.2 Our Client is one of the UK’s leading housebuilders, committed to the highest standards of design, construction and service. They have a large number of site interests across Darlington and are therefore keen to engage with the Council and assist in preparing a sound plan which is positively prepared, justified, effective and consistent. Land Interests 1.3 Our Client’s principle land interests in the Borough include the following: • Great Burdon (identified as Site 20 within the Proposed Submission) and; • Burtree Lane (identified as Site 109 within the Council’s Housing Employment Land Availability Assessment 2018). 1.4 Site Context Plans outlining these sites is found in Appendix A of this Report and site-specific representations are provided within separate documents. Consultation 1.5 The current consultation seeks comments on the Proposed Submission version of the Darlington Borough Local Plan. 1.6 The Plan sets out the broad spatial planning and policy framework for the Darlington Borough up to 2036. The current consultation runs for a period of six weeks from 6 August to 17 September 2020 and this is the final opportunity to comment on the legal compliance and soundness of the Local Plan before it is submitted for independent examination by the Planning Inspectorate. The National Planning Context 1.7 These representations set out our Client’s comments on the Proposed Submission Local Plan and highlight several issues in relation to the Local Plan that our Client believes should be addressed during the Examination stage. 1.8 Where appropriate, these representations refer to relevant paragraphs in the revised National Planning Policy Framework (2019) (the Framework), with which the Local Plan must be consistent. Paragraph 35 of the Framework sets out that the plan must be: 19015/A3/Reps/CB 1 September 2020 Introduction Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development; Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework. 1.9 We trust these representations will be afforded full consideration by Darlington Borough Council (the ‘Council’) and the Inspector in relation to the emerging Local Plan. Structure of this Report 1.10 These representations are set out as follows: • Vision, Aims and Objectives; • Sustainable Development; • The Settlement Hierarchy; • Design and Construction; • Housing; • Environment; • Transport and Infrastructure; • Site Specific Representations at Great Burdon and Burtree Lane; and • Conclusions. 19015/A3/Reps/CB 2 September 2020 Vision, Aims and Objectives 2.0 VISION, AIMS AND OBJECTIVES 2.1 Chapter 2 of the Local Plan sets outs the Council’s overarching vision, aims and objectives which sets out sets out what the Plan is seeking to achieve. The vision will set out what the Council believes the Borough will look like at the end of the Plan period (2036). In order for this vision to be realised, a number of overarching aims and objectives have been identified. Vision 2.2 The vision, as set out within the Proposed Submission, states: ‘In 2036, Darlington Borough will have maintained its identity as a cohesive historic market town situated amongst countryside and villages, whilst developing its reputation for ingenuity and its status as an economic driver in the Tees Valley. Its coherent community, natural and historic environment will be enhanced and continue to be cherished protected and celebrated. The opportunities available in Darlington and its links with other centres will make the Borough an attractive place for both residential and commercial investment, with the Borough’s needs for housing, jobs and other development being met, supported by new and improved built and green infrastructure and community facilities. Together with excellent national and regional connectivity and accessibility, these characteristics will mean Darlington continues to thrive and be a great place to live, work and invest.' 2.3 In general, our Client is supportive of the proposed vision; however, it is considered that further emphasis should be placed on the commitment to provide a variety of house types and sizes through the delivery of much needed new homes in sustainable locations to better reflect the emphasis on sustainable growth and boosting the supply of housing as highlighted in the Framework. This is particularly important given the past undersupply of housing that has been recorded in the Borough. 2.4 In light of this we advocate the following points being added to the vision which state: • The Local Plan will seek to boost significantly the supply of housing within the Borough; ensuring that housing need can be sufficiently met over the plan period and that an appropriate balance between jobs and new homes is achieved. • That growth is focussed on sustainable locations within the Borough including logical extensions to the existing urban area. 2.5 As set out within national policy, the Council must allocate sufficient sites for new housing to meet the social and economic needs of the area, as well as ensuring the right locations are chosen to accommodate sustainable growth. 2.6 Paragraph 59 of the Framework states that: 19015/A3/Reps/CB 3 September 2020 Vision, Aims and Objectives “to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay”. 2.7 For this to be achieved through the plan making process, it requires Local Planning Authorities (LPAs) to fully illustrate the expected rate of housing delivery and set out a strategy to describe how the required delivery will be maintained. 2.8 In order to meet the identified housing need within the Borough, the emerging Local Plan identifies that a minimum requirement of 422 net additional dwellings will be required per annum over the Plan period from 2016 to 2036. This results in a total net minimum requirement of 8,440 dwellings. The Council’s housing target (which makes allowance for economic growth) is; however, 492 net additional dwellings per annum over the same period, resulting in a total net target of 9,840 dwellings over the Plan period. 2.9 The aims and objectives set out within the ‘vision’ detail the Council’s overall ambitions and provide the link between the vision and the spatial strategy. 2.10 Our Client considers that a stronger emphasis should therefore be placed on housing delivery, which in turn will support economic growth. The Borough requires a demonstrable supply of residential development sites which are well located to key essential amenity including public transport links, education, healthcare and recreational facilities and which also have the potential to provide long term economic and infrastructure benefits. 2.11 It is considered that residential development at Great Burdon and Burtree Lane will provide all these benefits and help support the provision of a significant number of new dwellings to meet the Council’s identified housing need. Aims and Objectives 2.12 With regard to the overarching aims and objectives identified by the Council, it is noted that these do not specifically refer to the delivery of housing and as a result, these are considered to be unsound for being ineffective and not consistent with national policy. Housing delivery is vital for the growth of the Borough and this should therefore be recognised as a key overarching aim within the Plan. 2.13 A number of objectives are the set out. Our Client is generally supportive of these and, in particular, the specific aims of enabling the development of at least 10,000 new homes in order to meet the housing needs and aspirations of those living and working in the Borough.