APPENDIX 1

Sunderland City Council - Strategic Land Review, Green Belt Review (Stage 1) and Local Plan growth options

Policy Context

1. Sunderland City Council is consulting on growth and development options for the emerging Sunderland Local Plan Core Strategy. Three potential growth options have been presented for consultation, setting out the broad implications of for low, medium or higher growth for Sunderland. Consultation responses will be used alongside a range of evidence to inform decisions on an appropriate scale of housing and economic development needs.

2. As part of this process, Sunderland has also carried out a Strategic Land Review and Green Belt Review, which consider the development potential of sites across the borough.

3. The Council shares borders with Sunderland City Council and as such strategic growth priorities guiding future development have potential to affect Gateshead.

4. The current consultation gives the Council the opportunity to provide a formal response on the emerging priorities of the Sunderland Local Plan. The potential for relatively high levels of housing growth in Sunderland (compared to recent trends in household and population change), as set out in the medium and higher growth options could impact on demand for new housebuilding within Gateshead. However, it should be noted that Sunderland is at an early stage in the plan preparation process, therefore the scale of growth to be set out in the Local Plan, and the implications of this growth for other areas are yet to be established. A consultation response from Gateshead highlighting potential issues will be part of ongoing discourse between the Local Authority areas as Sunderland’s Local Plan takes shape.

5. Some evidence regarding economic and housing growth in Sunderland refers to impact analysis studies carried out for the proposed International Advanced Manufacturing Park, to be located on land within South Tyneside and Sunderland, in an area north of the Nissan car manufacturing plant. Gateshead Council has previously indicated that it considers the assessment of the potential impact of this development to underestimate the quantity of new housing that will be required to accommodate potential workers in the area. The need for further assessment of this issue is raised again within this draft consultation response.

6. In terms of potential locations for growth, Sunderland’s Strategic Land Review and Green Belt Review identifies potential locations within Sunderland that may be suitable for housing or economic development. A number of sites are identified in the Washington area, which fall within an inter-district wildlife corridor that is shared with Gateshead; the development of these sites could have a negative impact on ecological value and connectivity within this area, and our draft consultation response highlights this as an issue. A number of sites located within strategic Green Belt gaps are also identified. The development of these sites has potential to merge settlements, and our draft consultation response requests that these sites are omitted from further consideration.

7. The deadline for consultation responses is 1 July 2016. In order to meet this deadline, our comments have been forwarded to Sunderland City Council for information, with an accompanying covering letter stating that our formal consultation response is subject to Cabinet approval on 12 July 2016.

Implications of Recommended Option

8. Resources:

a) Financial Implications – No financial implications directly arise from this report

b) Human Resources Implications – No human resources implications.

c) Property Implications - No property implications.

9. Risk Management Implication - No risks associated with the consultation.

10. Equality and Diversity Implications – No equality and diversity implications

11. Crime and Disorder Implications – No crime implications.

12. Health Implications – No health implications.

13. Sustainability Implications – Draft Sustainability Appraisal and Strategic Environmental Assessments have been prepared for the documents that have been published. Further updates to these assessments will be produced as proposals are developed.

14. Human Rights Implications - No human rights implications.

15. Area and Ward Implications – The Sunderland Local Plan could potentially have implications for Gateshead, although close cooperation between Councils and adhering to the duty to co-operate should resolve any issues.

Annex Sunderland City Council growth options consultation response

As neighbouring local authorities, cooperation on strategic cross-boundary issues can positively influence sustainable patterns of development in Gateshead and Sunderland. The assessment of sites within Sunderland that may be able to accommodate development, and the identification of potential growth options for the city are of particular relevance to Gateshead Council, as we continue to implement the Gateshead and Newcastle Core Strategy and Urban Core Plan (CSUCP), and prepare other elements of our emerging Local Plan.

Growth Options Three potential options for Sunderland’s growth are presented for consultation. In terms of the implications for housing growth in the city, these scenarios set out potential for 515 new homes per year for the low growth scenario, 820 new homes per year for medium growth and 1,055 new homes per year for the higher growth scenario.

Sunderland City Council has considered economic (jobs growth) projections alongside demographic projections in identifying potential growth options. Sunderland has seen relatively strong economic growth over recent years, while Census data have revealed a decline in the city’s resident population over the ten years to 2011. Analyses carried out to support Sunderland’s emerging Local Plan suggests that if the city’s economic growth is to be supported into the future (without a significant increase in in-commuting), there is a need to increase the size of Sunderland’s working age population beyond the level that would be delivered through the continuation of current trends. This view is supported by Sunderland’s 2016 Objectively Assessed Need and Strategic Housing Market Assessment Update (SHMA), which recommends a housing requirement of 819 new homes per year, taking into account increased population growth to support economic growth in Sunderland.

We estimate that the low growth scenario is associated with population growth of roughly 350 residents per year. This scenario seems to be broadly consistent with recent ONS/DCLG population and household projections for Sunderland and can perhaps be considered to represent a ‘baseline’ level of growth. The medium growth scenario seems to be associated with population growth of around 1,000 residents per year. Delivery of the higher growth scenario appears to require population growth of roughly 1,500 residents per year.

If Sunderland’s Local Plan is to deliver housing and economic growth that is in line with the medium or higher growth scenarios, consideration needs to be given to how the increased levels of population growth could be delivered, and what impact this would have on other areas. A proportion of the required level of population growth could be achieved by reducing net out-migration from Sunderland to areas outside the North East of England. However, the component of migration that is most likely to be influenced by the Council’s policy interventions is the migration of residents between Sunderland and neighbouring or nearby local authority areas in the North East.

Demographic analysis carried out to support Sunderland’s emerging Local Plan reveals that the city experiences an average net loss of around 400 residents per year to County Durham. Although addressing current trends in migration between Sunderland and County Durham (subject to agreement between the two local authorities) may assist in delivering growth in Sunderland, change in migration trends between these two areas alone would not deliver population growth in Sunderland capable of delivering the medium or higher growth scenarios. It therefore seems likely that population growth which is significantly higher than that outlined in the low growth scenario would necessitate a change to recent trends in the migration of residents between Sunderland and more than one other local authority area.

ONS data reveals that migration between Gateshead and Sunderland currently results in relatively small net migration between the two local authorities: based on a ten year average up to 2014, net migration results in only around ten residents moving from Sunderland to Gateshead per year. However, the small numbers associated with net migration mask relatively large numbers of migrants each year moving from Sunderland to Gateshead, and vice-versa: a ten year average of ONS migration data indicates an ‘inflow’ of around 530 residents per year from Sunderland to Gateshead, and an ‘outflow’ of around 520 residents per year from Gateshead to Sunderland. Given the sizeable number of residents moving between our areas, and the considerable influence that delivery of the medium or higher growth scenarios would have on migration trends between Sunderland and other areas, it is reasonable to conclude that the pursuit of a policy objective of increasing Sunderland’s population beyond current trends (i.e. the selection of the medium, or higher growth option) has potential to affect net migration flows between Gateshead and Sunderland.

This issue is of relevance to Gateshead as we continue to implement the CSUCP, and prepare other elements of our emerging Local Plan. The scale of housing and economic growth in Gateshead’s emerging Local Plan, set out in the CSUCP (adopted March 2015), is predicated upon an assumption that the migration of residents between Gateshead and other local authority areas over the plan period will continue at a rate that is broadly in keeping with recent trends in migration. It is recognised that migration patterns cannot be ‘fixed’ at a specific level, and are liable to change over time due to a range of factors. In this respect, modest changes in migration flows between Gateshead and other local authorities are unlikely to have a significant impact on the implementation of the CSUCP. We believe that the CSUCP sets out a robust and credible plan for growth in sustainable locations, and accommodates an appropriate degree of flexibility to cope with change. However, where neighbouring or nearby local authorities specifically aim to deliver population growth through increased net in-migration from other areas there is potential for substantial alteration to current migration patterns, which could result in markedly lower levels of growth in some areas.

We are concerned that a significant change to the level of migration between Sunderland and Gateshead could mean that the CSUCP’s objectives around delivering sustainable economic growth are compromised. We are keen to minimise any potential negative implications for Gateshead, and accordingly we would welcome the opportunity to discuss the growth objectives of Sunderland’s emerging Local Plan as the document is prepared. In particular, we seek reassurance that the scale of growth to be set out in Sunderland’s Local Plan can be achieved without having an adverse impact on implementation of the CSUCP for Gateshead.

Sunderland’s exploration of the implications of the growth scenarios presented for consultation appears so far to focus on growth in housing and jobs within the City. However, population growth of the scale associated with the medium or higher growth scenarios is likely to have consequences for the amount of shops and services provided within Sunderland. As more detailed Local Plan policies relating to town centre uses in Sunderland emerge, Gateshead Council would be keen to be given the opportunity to consider any issues that may have implications for Gateshead’s communities, and for the vitality and viability of our centres.

International Advanced Manufacturing Park Our response to consultation on the International Advanced Manufacturing Park (IAMP) Green Belt and Site Selection Options (February 2016) highlighted Gateshead Council’s desire to work with South Tyneside Council and Sunderland City Council to develop our understanding of the implications of this project. Once established, an IAMP will be a large-scale development with potential to attract business growth from outside the region, and from outside the UK. If neighbouring areas are to benefit from, and support the delivery of this project, land use and economic development policies will need to appropriately take account of its potential impacts.

Sunderland’s 2016 Employment Land Review considers the potential economic uplift that development of an IAMP could have on Sunderland’s economy (excluding the jobs that will be accommodated directly within the IAMP site). The 2016 SHMA considers the potential impact that jobs growth could have on housing needs in Sunderland. The assessment considers the implications of projected economic growth in Sunderland, which is said to raise the city’s housing need figure by 305 dwellings per annum (as set out in paragraph 8.25). Although this assumed economic growth may incorporate assumptions of the secondary growth (eg. through supply chain and multiplier factors) that would be facilitated by the IAMP, we note that this scenario appears to exclude the housing need that will be associated with direct jobs provision within the IAMP site. Instead, the assessment applies findings published within the 2015 IAMP housing impact study which estimates that around 10% of jobs at the IAMP will be filled by employees migrating to the North East to work. Applying this assumption to housing needs is suggested to result in a requirement for only 523 additional homes across the region (of which 177 would be required in Sunderland) to accommodate workers benefitting from employment opportunities provided within the IAMP.

It seems unlikely that direct employment growth delivered by the IAMP will result in a need for so few additional homes, and our February 2016 response to consultation on the IAMP Green Belt and Site Selection Options sets out what we consider are flaws in the approach used so far to assess the housing impact of the project. Accordingly, we encourage a review of the IAMP’s impact on housing needs that appropriately considers the full demographic and labour force implications of the additional jobs growth that will be delivered by the project. This assessment would support the emerging Local Plans of South Tyneside and Sunderland City Councils, and, given the IAMP’s proximity to Gateshead, would also assist us in understanding the housing impacts of the development.

Green Belt The Growth Options consultation includes no specific proposals to alter the boundary or extent of the Green Belt, or site allocations (allocations in the South Sunderland area only are included in the South Sunderland Growth Area strategy document, which has been progressed by Sunderland City Council in advance of the emerging Core Strategy). However, the consultation indicates that a consequence of the higher growth option would be that “significant land would need to be released from Settlement Breaks and Green Belt”. The medium growth option is said to be very likely to require development of additional greenfield sites and land in Settlement Breaks, and could also require development of some Green Belt land. The consultation is accompanied by a Strategic Land Review (SLR) and Green Belt Review Stage 1, which will inform the Publication Plan stage of the Core Strategy.

Reference to the 2013 draft Core Strategy has been made in the Growth Options consultation, as part of a question asking whether a similar broad distribution should continue to be followed. The 2013 broad spatial plan referred to the majority of new housing in the city being located in South Sunderland, and to only a minor amount of new housing being developed at Washington, where no extension of the urban area, or loss of Green Belt, was envisaged. The Council would support this approach if this is consistent with a level of growth which delivers Sunderland’s growth aspirations on a basis agreed with the adjoining local authorities.

Gateshead Council has considered in detail the Green Belt Review Stage 1 for the three sub-areas that adjoin Gateshead: Nissan Area, Usworth Area and Springwell Village Area. Whilst across Sunderland as a whole the great majority of the existing Green Belt is identified by the Review as essential to its purposes and excluded from further consideration, this is not the case in any of the three specific areas considered.

The Nissan Area, which comprises Green Belt north of the Nissan plant extending to the boundary with South Tyneside, and as far west as the Leamside line, is identified in its entirety for further consideration for allocation for development at Stage 2, on the basis that there is “an exceptional strategic circumstance” – the proposed IAMP. Gateshead has previously commented on specific options for the location of this proposal, in both Sunderland and South Tyneside. The impact of the IAMP on Green Belt purposes will depend on its detailed location, design and layout. Gateshead anticipates that Sunderland and South Tyneside Councils would have due regard to the importance of continuing to fulfil Green Belt purposes as far as practicable and avoid bridging strategic Green Belt gaps, in particular between Gateshead (at Follingsby) and Sunderland, or severing strategic green infrastructure corridors.

The Usworth Area comprises the section of Green Belt between Washington and the Gateshead boundary, east of the A194 (M) and west of the Leamside line. The Green Belt Review finds only two relatively small and tenuously- connected parcels of land along the river Don to be essential for meeting the purposes of the Green Belt. The remainder of this area, which meets or very nearly meets the Gateshead boundary at three separate places, would join or very nearly join the built-up area of Washington to that of Follingsby (following the development of the South of Follingsby Lane employment site in Gateshead), and would sever the continuous east-west Green Belt corridor which currently separates Sunderland and Washington from South Tyneside and Gateshead.

Sunderland City Council acknowledges the importance of preventing Gateshead and Washington from merging, “the east-west Strategic Green Infrastructure Corridor from Nissan to Springwell”, that “the Green Belt development at Follingsby further strengthens the need to retain the City’s portion of Green Belt” and that the development of the fields would “prejudice the integrity of the Green Belt”. However, a combination of the method adopted and perhaps the boundaries of individual “fields” used for assessment has led to a conclusion at odds with all these important judgments. Gateshead does not believe that the Green Belt Review has reached a defensible conclusion with respect to this land, or one that is borne out by the judgments within the report itself.

The Springwell Village Area comprises all the Green Belt north-west of the A194 (M), surrounding Springwell Village. Again the greater part of the Green Belt land here is identified for further consideration at Stage 2. We believe that the same deficiencies in the method as have been identified above with regard to the Usworth Area, have also led to inappropriate conclusions with regard to land in the Springwell Village Area. Land which is identified for further consideration includes sites which would bridge the gap between Eighton Banks in Gateshead, and Springwell Village, and/or (to the north) almost bridge the gap between Springwell Village and Wrekenton in Gateshead. It is important to note that while the main part of Eighton Banks is part of the continuous built-up area of Gateshead and is excluded from the Green Belt, to the south of this and within the Green Belt is a further quite substantial section of the village, very narrowly detached from the main part. This should not be disregarded in considering the effect of Green Belt deletions on the merging of settlements.

Development on any significant scale of sites to the north and/or west of Springwell Village would thus risk joining the built up areas of Washington/Springwell with Gateshead, or narrowing the Green Belt in this vicinity to the extent of endangering its integrity. This adverse effect would not only be local, but would prejudice the long and important Green Belt gap extending from the coast to the west of Tyne and Wear, separating Tyneside on the north from Sunderland and Washington/Birtley/Chester-le-Street on the south.

Gateshead Council therefore believes that the Green Belt Review gives insufficient weight to the importance of maintaining clear, reasonably wide and inter-connected gaps between major urban areas, particularly between Tyneside on the one hand, and Sunderland and Washington on the other.

Environment A number of those sites considered as part of the SLR (Washington) occur within important inter-district Wildlife Corridors. Their development would adversely impact ecological connectivity between the local authority areas of Gateshead, Sunderland and South Tyneside. These sites are also known to support a broad range of priority habitats and species, and as such constitute an important sub-regional biodiversity resource.

Through separate cross-boundary discussions, held specifically in relation to proposals for an IAMP, we have highlighted the importance of acknowledging the ecological value of land to the north of Nissan and Washington Road (site 805). This site constitutes an extensive tract of land incorporating the inter- district River Don Wildlife Corridor, which supports high levels of ecological value in Sunderland, Gateshead and South Tyneside, including a broad range of priority habitats and species. Proposals for an IAMP (as set out in documents published for consultation in December 2015) incorporate a “Landscape and ecological mitigation zone”. As proposals for an IAMP are progressed, we are keen to work with South Tyneside Council and Sunderland City Council to ensure that the project, including this area for landscape and ecological mitigation, maintains and enhances the ecological value and function of this area.

Flood Risk and Water Management We are keen to work collaboratively with Sunderland City Council to make a positive contribution towards the catchment management of the River Don to improve flood management, water quality and ecological connectivity. This would support the North East Local Nature Partnership’s emerging work on the River Don Partnership Vision which involves other stakeholders such as Northumbrian Water, Environment Agency and South Tyneside Council. If they were to come forward for development, it would be beneficial if development sites located alongside the River Don within Sunderland such as the IAMP (Strategic Land Review Site 805) incorporate mitigation measures such as green buffers along the river corridor and SuDS similar to Gateshead’s strategic employment site South of Follingsby Lane.

Transport We understand that so far the consideration of potential development sites has not included detailed assessment of implications for the transport network. Given the potential scale of development that could take place in Sunderland over its plan period (in addition to development in Gateshead, and in South Tyneside), we are keen to work with Sunderland to gain a more detailed understanding of the potential impact of development for our transport network. Increased traffic flows to and from Gateshead and Newcastle flowing through the borough could have an adverse impact on our road network, particularly at known congestion hotspots like the A1, Heworth, Whitemare Pool and Oakwellgate. In this respect the development of IAMP, close to Gateshead’s boundary, has potential to impact on Gateshead’s transport network. As its Local Plan progresses, Sunderland City Council and developers will need to assess the impact of development on the transport network in Gateshead and make contributions towards improvements as appropriate.

We are keen to work with Sunderland City Council to better understand how the potential adverse impacts of development on our transport network can be avoided or mitigated. Measures that seek to reduce reliance on the private car as a mode of transport are likely to assist in this objective, and we would like to explore how collaborative work could support more sustainable modes of transport.

Given the potential scale of development that could take place nearby, Gateshead Council would support a proposal to re-open the Leamside line for freight or passenger access. We are keen to work with neighbouring local authorities to explore the potential for this.

Summary The future development of Sunderland, to be set out in the Council’s emerging Local Plan, is likely to be of significance to Gateshead in terms of potential impacts, and also opportunities to complement development activity within both local authority areas. We therefore value the opportunity to consider the findings of Local Plan evidence as it is prepared.

As Sunderland’s Core Strategy progresses, we would welcome further discussion on the potential economic and demographic impacts of growth in Sunderland. In particular, we would like to understand the scale of growth that is to be planned for within Sunderland’s emerging Core Strategy, and the potential implications that this growth may have on the implementation of the CSUCP for Gateshead. Through ongoing dialogue with both South Tyneside Council and Sunderland City Council, we also hope to develop a further understanding of the likely impact of an IAMP for housing and economic growth within Gateshead.

As set out in our detailed comments above, we consider that the development of a number of sites assessed within Sunderland’s SLR would have a detrimental impact on ecological value and connectivity within the area.

Locations considered appropriate for further consideration within Sunderland’s Green Belt Review include a number of areas which we consider, should they come forward for development, would compromise the gaps between major urban areas: particularly between Tyneside, and Sunderland and Washington. Our detailed comments highlight those locations where we think the method used for assessing sites, perhaps in combination with the boundaries identified for the “fields” assessed, results in the identification of some sites within the Green Belt as being suitable for further consideration within the Green Belt Review. We request that those sites are discounted from Sunderland’s Green Belt Review.