APPENDIX 6 PREFERRED OPTIONS CONSULTATION FEEDBACK REPORT County Durham Plan
Prefereed Options Consultation Feedback Report
Contents
1 Introduction to the Feedback Report 2 2 Vision and Objectives 2 3 How Much Development and Where 6 4 Building a strong competitive economy 13 5 Ensuring the vitality of town centres 14 6 Supporting a prosperous rural economy 15 7 Delivering a wide choice of high quality homes 17 8 Protecting Green Belt land 22 9 Promoting sustainable transport 23 10 Supporting high quality infrastructure 26 11 Requiring good design 30 12 Promoting healthy communities 31 13 Meeting the challenge of climate change, flooding and coastal change 32 14 Conserving and enhancing the natural and historic environment 36 15 Minerals and Waste 46
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1 The purpose of the Preferred Options consultation feedback report is to provide a summary of the representations made in response to the County Durham Plan Preferred Options (June 2018). The council’s response to every representation made is set out in the Preferred Options Statement of Consultation.
2 Consultation on the Preferred Options was undertaken between 22 June 2018 and the 3 August 2018. A total of 3,990 responses were received from 1130 respondents. In addition, social media played a large part of the consultation process with social media messages viewed 603,454 times and generating a total of over 1000 comments, albeit these were not submitted via the formal process. All duly made representations submitted in response to the Preferred Options have been considered and where possible changes have been made when preparing the County Durham Pre-Submission Local Plan. The details of the consultation and the council’s response to every representation made is set out in the Preferred Options Statement of Consultation.
Question 1 - Vision
Summary of main issues raised by representations
General support for the Spatial Vision. More should be added to the Vision supporting the regeneration of those areas within the county with the highest levels of deprivation. There should be more focus on the rest of the county and less on Durham City and Aykley Heads and building in the Green Belt. It should not be assumed that there will be population growth in the future. The Vision should be more positive about mineral working and acknowledge that minerals can only be worked where they are found. The emphasis on a strong economy is welcomed. The Vision needs more emphasis on how it relates to specific areas. The Vision requires more recognition of the importance of the historic environment. It is not just about the protection of assets its also about how they are managed. The importance of the role of smaller towns and larger villages should be recognised. The housing element of the vision is important for County Durham because of the lack of choice and quality within the current stock. There should be more reference to the county's cultural and leisure offer. Welcome the recognition of the importance of green infrastructure, natural environment and climate change. New housing needs to be supported by more infrastructure. The Vision is too aspirational and is too vague about how it will be achieved. There should be more emphasis on energy efficiency and the environment. Welcome the recognition of the link between economic growth and strong communities. The Vision is not ambitious enough particularly in relation to sustainable transport which should be less focused on road links. What is meant by more and better jobs.
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Question 2 - Objectives
Summary of main issues raised by representations
General support for many of the objectives. The objectives need to be prioritised. The housing objective should include reference to a range of types and tenures. It needs to be stated that the objectives will only be effective when considered jointly. The objectives are too focused on Durham City and Aykley Heads and building in the Green Belt. The objectives are too aspirational and is too vague about how they will be achieved. The protection of the environment objective is undermined by parts of the Plan particularly the proposed relief roads. Not enough focus on delivering affordable housing with too much emphasis on high value housing. Not enough detail on how the decline of town centres will be reversed. The design policy need to be reworded to better reflect the updated NPPF. More emphasis needed on the re-use of previously developed land and bringing empty properties back into use. Education should feature more in the objectives. An objective relating to noise pollution and air quality should be added. The Built and Historic Environment objective needs recognise the importance of 'significance'. The objectives need to recognise the importance of food systems. There should be a specific objective addressing the needs of older people. Some objectives contradict each other, for example Climate Change and the Supply of Minerals. A specific objective is required to recognise the importance of sustainable transport. There should be more recognition of the importance of mineral working. Welcome the recognition of the importance of rural areas. The Natural Environment objective should make reference to net gains and natural capital. There should be more reference to the county's cultural and leisure offer. What is meant by more and better jobs. Natural resources objective needs to include reference to the protection of best and most versatile agricultural land. The economic ambition objective should be made clearer to show that it is the economy of the whole county that is being improved. There should be recognition that some people have no option but to use the private car. The economic ambition objective should not just focus on GVA and should also referring to improving its resilience. Housing needs of specialist groups should also include reference to young people. The objective relating to low carbon should be clearer in its support for renewable energy. There should also be no reference to coal.
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Question 3 - Delivering Sustainable Development
Summary of main issues raised by representations
General support for the Sustainable Development Statement.
The Statement is so vague as to be virtually meaningless.
It is too Durham City focused to the detriment of the rest of the county.
Support making effective use of previously developed land although that needs to followed through in policy.
Support for the presumption in favour of minerals related development.
Needs to be clearer recognition of the need for new development in smaller settlements to ensure their resilience and sustainability.
It should be renamed 'Location of Development'.
There needs to be more recognition of viability in relation to the re-use of previously developed land.
Needs to include more reference to the natural environment.
Development should not be allowed until infrastructure is improved not the other way around.
Reference to safe cycling routes should be added.
There is too much reference to economic growth, this is not sustainability.
The reference to the Settlement Study should also differentiate between different settlement groupings.
The methodology used in the Settlement Study is unsound.
The wording needs to be amended to more closely reflect the wording of National Planning Policy Framework (NPPF).
The needs to more recognition of the contribution made by Project Genesis in Consett.
Welcome the commitment to work pro-actively with applicants jointly to find solutions which mean that proposals can be approved wherever possible.
The Statement reads more like a policy.
It is right that development is directed to the county's most sustainable settlements.
Should be more recognition of the benefit effects of new development.
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Question 4 - General Development Principles
Summary of main issues raised by representations
The policy is a catchall policy which underpins all policies in the Plan. A concern with catchall policies is their interrelationship with more detailed specific policies.
Should reference the importance of high speed broadband in reducing the need to travel.
Bland and obvious statements needs to be more focused.
The use of brownfield land must recognise the ecological value of some sites that have regenerated.
Need to recognise the needs of those with disabilities and dementia.
Need to include reference to pollution, flooding and air quality.
There is a total lack of information to support the principles cited.
Needs more emphasis on renewable energy.
The development of Aykley Heads, the new council HQ and the relief roads are in conflict with this policy.
The contribution of quarries to biodiversity should be recognised.
Policy should be clear that new development must deliver net gains to biodiversity.
New houses should be required to be larger and have more storage.
Support for good quality design.
Some criteria are unachievable without government intervention.
There should be recognition that some people have no option but to use the private car.
Unclear how some of the criteria in the policy will be achieved.
Needs to be more recognition of viability particularly in relation to the space standards and the renewable energy requirements for new buildings.
Needs more emphasis on climate change.
Some criteria are negatively worded and should be more positive.
Should be more emphasis on walking and cycling.
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Question 4 - General Development Principles
Summary of main issues raised by representations
Space standards should not be a requirement of the Plan.
Needs to include more reference to the need to have regard to the conservation, enhancement and enjoyment of the historic environment.
Should be more recognition of the needs of older persons.
Question 5 - Policy 2 - Quantity of Development - Employment
Summary of main issues raised by representations
General support for the policy.
Employment land allocations should be concentrated around the county.
The amount of employment land and its location should be based on realistic projections of what is happening on the ground.
Plan should make clear the employment sites that have been de-allocated.
Further land should be allocated in the A19 corridor, particularly around Wingate.
Question 6 - Policy 2 - Quantity of Development - Housing
Summary of main issues raised by representations
General agreement that County Durham can be considered as a self contained housing market area (HMA). Need should be determined on a community by community basis not as a target for County Durham. Seems unlikely that the HMA has been based on an impartial appraisal / summary. Change in needs figure between Preferred Options (which uses official figures) and Issues and Options shows this stage was not robust. Whilst DCC have accepted the Government's standard methodology they are working on ways to increase it with a lapse rate of applications being approved but not developed. The Plan should focus on houses for people not builders. The Plan should encourage types of accommodation that people need. Querying the need for 6,272 additional homes. Unconvinced that there is a need for new housing. Agree with 1,368 as developed through the New Standard Method. The New Standard Method is the minimum starting point. Need to state that the OAN is a minimum figure.
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Question 6 - Policy 2 - Quantity of Development - Housing
Summary of main issues raised by representations
OAN should be a ceiling - to have no limit is irresponsible. Break down 1,368 to reflect the number of homes required for affordable needs. Consideration should be given to stalled sites with planning approval where development is unlikely. Preferred option figure for the number of houses needed is too low. Consider NELEP /Northern Powerhouse and aspirations and regional context. Justify a higher figure on the basis of economic growth and potential for job formation. The aspiration for an Economic Activity Rate of 73% requires 1,629 homes. Consider scenarios presented at Issues and Options Stage - the Preferred Options figure is lower than these scenarios. The Preferred Option figure is insufficient to support jobs growth. There is a mismatch between employment strategy and housing strategy of the plan. Labour Supply scenario of ELR would lead to 86ha of employment land whereas plan providing for 305ha. Support aspiration for 73% economic activity rate. Economic aspirations qualify as a reason to increase housing need. The Preferred Option figure will not significantly boost the supply of housing. The OAN figure should be uplifted. Without an uplift it will project forward past trends (impacted by the recession) and would result in an ageing workforce which is unable to support existing and planned jobs growth. Appeal decisions in recent years give weight to a future housing need above that identified by the Government's standard method. DCC have used the base figure set out in the government's draft methodology and consideration has not been given to the need to adjust this to take account of economic ambition and economic growth. A shortage of housing will hinder the economic growth ambitions of the plan, stifle employment creation and potentially lead to unsustainable commuting patterns across the county. The housing figure should be amended (upwards) accordingly. Improve existing homes and putting money into loft conversions. Bring back more empty homes back into use or consider demolitions. Starting point should be bringing empty homes back into use - new homes create more empty homes. No study on the impact of Brexit on housing needs. Planning for more homes would present opportunities to meet the need for affordable homes and to deliver infrastructure. 2016 SHMA is dated - an up to date SHMA is required. Clarify this is a strategic policy. Review the figure at 2016. Most councils in Tyne and Wear and Teesside have adopted plans with figures higher than the government method. If these authorities find they have over-provided this will impact on County Durham's needs 2014 based projections are out of date - the 2016 based figures should be used. This will result in a lower need for County Durham.
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Question 6 - Policy 2 - Quantity of Development - Housing
Summary of main issues raised by representations
Housing should be built for older people - existing commitments are not what is needed. Make use of 2016 data in full over whole plan period (no extrapolation of 10 year period average figure). Make use of most up to date information. Some agreement that providing an allowance for large windfall may undermine the purpose of the Local Plan. Do not accept it is appropriate to ignore contribution of large windfalls. Criteria based policy needed to enable small windfall sites to come forward. Reduced rate for small windfalls or remove this altogether. 10% lapse rate too low - by the council's own evidence it has been 17% in the past. Factors as to why a site may lapse have not been fully considered. A 15% -20% lapse rate would be more appropriate. Undertake detailed assessment of all sites rather than have an assumption. Lack of evidence empty homes will be brought back into use therefore assumption is questionable. Demolition allowance should be higher (75 per year). Disagree with no allowance for HMOs returning to housing market. More needs to be done to return student housing to homes for long term non student residents. Do not ignore contribution of student housing returning dwellings to the open market. Consider implications of allocations and university ambitions. Demolitions should be 100 per annum. Empty property assumptions should be 100 per annum. High proportion of commitments as part of OAN is a risk of not meeting OAN. Make good use of empty stock.
Question 7 - Policy 3 - Employment Land
Summary of main issues raised by representations
General support for the policy.
Employment land allocations should be concentrated around the county.
Sites which are accessible by public transport should be favoured.
Support for further growth around Newton Aycliffe (Forrest Park).
Objection to the amount of time a site should be marketed for before being considered for alternative uses.
Further land should be allocated in the north of the county, particularly around Stanley.
Further land should be allocated in the A19 corridor, particularly around Wingate.
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Question 7 - Policy 3 - Employment Land
Summary of main issues raised by representations
Support for further growth at NETPark.
Further land should be allocated in Teesdale.
Objection to the protection of individual sites (Romanway, Abbey Road, Salters Lane).
Objection to how the Plan deals with Project Genesis.
Further consideration should be given to the impact of allocations on designated heritage assets.
Question 8 - Policy 4 - Aykley Heads
Summary of main issues raised by representations
General support for the redevelopment of the site.
Concern over the potential levels of traffic generated by the proposed redevelopment of the site and the impact on the existing road network.
The policy needs to clearer on how the new city park will be delivered.
Office space should be considered in other locations across the county.
New county council offices should be located on the Aykley Heads site.
Concern over the levels of car parking on the site and the potential for this to encourage car use resulting in congestion.
Concern over the potential loss of Green Belt through the redevelopment of the site.
Concern over the potential impacts on the Conservation Area and World Heritage Site.
Objection to ancillary uses being suitable on the site, with the potential to create a 'night time economy'.
Proposals are unrealistic. Which businesses will occupy the site, is there demand for the site?
Opportunities should be provided on the site for existing local businesses.
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Question 8 - Policy 4 - Aykley Heads
Summary of main issues raised by representations
Design of the site is of great importance and should be exemplar.
Objection to the loss of playing fields.
Question 9 - Distribution of Housing
Summary of main issues raised by representations
Some general support for the Sustainable Communities distribution.
A number of settlements such as Consett, Spennymoor and Crook should have less development.
A number of settlements such as Consett, Chilton, Coxhoe, Coundon, Lanchester, Middridge, Gainford, Seaham, Ferryhill, West Cornforth, Barnard Castle, Sedgefield, West Rainton, Stanley and Bishop Auckland should have more development.
There should be more housing in West Durham to replace the ageing stock.
The wider dispersal option should have been chosen rather than the sustainable communities option as more respondents preferred it at the Issues and Options stage.
There is too much development in Durham City and in the Green Belt.
There should be more use of brownfield land and bringing empty properties back into use.
More housing should be directed to East Durham to support regeneration.
More housing should be allocated to Newton Aycliffe and Sedgefield where new jobs are proposed.
New housing should be used to balance the tenure of the existing stock.
There should be more housing in the villages surrounding Durham City.
The county needs the right homes in the right places to continue its economic progress.
People should be able to live near where they work.
The council is confusing accessibility with sustainability.
Appropriate levels of housing should be proposed in high value areas.
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Question 9 - Distribution of Housing
Summary of main issues raised by representations
Too much housing on large sites could lead to failing the Housing Delivery Test.
Exceptional Circumstances have not been demonstrated to justify Green Belt releases.
Question 10 - Policy 5 - Housing Allocations
Summary of main issues raised by representations
Please see Appendix A - Preferred Options Statement of Consultation Site Allocations
Question 11 - Policy 5 - Housing Allocations – Alternative Sites
Summary of main issues raised by representations
A range of alternative sites spread across various settlements were submitted as alternatives, or in addition to the schedule of housing allocations identified.
Question 12 - Policy 6 - Durham City's Sustainable Urban Extensions
Summary of main issues raised by representations
Sniperley Park is valuable Green Belt land providing a valuable community resource.
Outlying settlements have been dismissed from consideration as alternatives to releasing Green Belt land.
Querying the purpose of structural planting along the A167.
Both Sniperley Park and Sherburn Road benefit from excellent transport links therefore the major road infrastructure projects are not required.
The Green Belt should be protected to prevent urban sprawl.
Sniperley Park and Sherburn Road will increase traffic levels in the locality.
There are insufficient services and infrastructure to support a development of this scale.
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Question 12 - Policy 6 - Durham City's Sustainable Urban Extensions
Summary of main issues raised by representations
There are no exceptional circumstances to justify the proposals and release of Green Belt.
Concern over the loss of the household waste recycling centre.
Question 13 - Policy 7 - Development on Unallocated Sites in the Built Up Area
Summary of main issues raised by representations
The aims of the policy are generally supported.
The policy should apply equally to urban neighbourhoods within larger settlements. The policy criteria (e) should be reworded so that it accords with paragraph 109 of the NPPF (regarding residual cumulative highway impacts). The policy criteria (f) should be reworded so that it accords with Paragraph 84 of NPPF (regarding opportunities to access sustainable transport. There should be opportunities identified on the edge of more sustainable settlements, or a recognition that some modest housing growth will be permissible on the edge of and adjacent to the built -up area of villages where it is well related to it and where it respects the scale and rural character of the settlement and its setting. Actions need to be taken to prevent the coalescence between Peterlee and Easington. The council should ensure that such developments are designed so as to maximise their “walkability”. Dispute that sites which come forward in ‘built up’ areas need to have good access by sustainable modes of transport. It is suggested that the opening paragraph of Policy 7 (a) is amended to ensure compliance with the section 38(6) of the Planning & Compulsory Purchase Act 2004. There should be explicit exclusion of retail development. The definition of what constitutes built up area should be explicitly included in the policy itself to aid clarity and public understanding. All rural settlements need to be allowed to grow and evolve in order to maintain their long-term vitality and viability. This should not be prevented by an overly restrictive local plan policy where such developments are necessary and sustainable, and do not cause harm to interests of acknowledged importance. It is vital that monitoring takes place of development in the built up areas. The current definition of a built-up area is considered too restrictive and inflexible in its current form. Greater flexibility is needed to allow development to come forward that is contained by physical features. The policy needs to reflect the approach to development within the countryside as set out in NPPF. The policy needs to include the necessary assessment and balancing of development proposals on a case by case basis as per the NPPF. The necessity for the inclusion of part b of this policy is questioned.
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Question 13 - Policy 7 - Development on Unallocated Sites in the Built Up Area
Summary of main issues raised by representations
The policy should be more flexible to enable a pro-active response should there be a shortfall in the five-year housing land supply or more up to date evidence indicating increased housing needs across the county. The NPPF also stipulates that local planning authorities should support the development of Rural Exception Sites and Entry Level Exception Sites. This should be reflected in the policies of the Plan to ensure that sufficient flexibility is available. The policy should be revised to remove reference to previously developed land as it runs contrary to NPPF.
Question 14 - Policy 8 - Visitor Attractions
Summary of main issues raised by representations
General support for the policy.
Concern about the expansion of student accommodation, and the impact of the student population on Durham City.
The Plan should do more to promote development of visitor attractions, either in Durham City or in the wider county.
Durham City's Tourist Information Centre should be reintroduced.
There should be more focus within the policy on tourist development around the county as a whole, not just on Durham City.
The RSPB expressed concern that the policy did not do enough to protect biodiversity.
The wording of the policy should be amended to strengthen the policy, or to bring out specific points more clearly.
Question 15 - Policy 9 - Visitor Accommodation
Summary of main issues raised by representations
General support.
More should be done to improve the visitor experience in Durham City.
Some consultees requested that their site be considered for allocation for visitor accommodation development.
The approach to proposals for visitor accommodation development should be the same for sites in and out of the Green Belt.
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Question 15 - Policy 9 - Visitor Accommodation
Summary of main issues raised by representations
The policy should include provision for noise amenity and tranquillity of residents.
The policy should include a reference to protections for biodiversity.
Visitor accommodation should not result in change of use to permanent residential accommodation.
The policy places too much emphasis on the evening economy in Durham City.
Durham City's Tourist Information Centre should be reintroduced.
Amendment to wording were suggested, to comply with NPPF 2018.
Question 16 - Policy 10 - Retail Hierarchy and Town Centre Development
Summary of main issues raised by representations
Support for the town centre first approach.
Further support required for Durham city centre.
Need to reduce the levels of licenced premises within Durham city centre.
More flexibility should be allowed within town centres including considering the potential for residential uses.
Community and cultural facilities should be protected further.
Policy should address the need to improve North Road in Durham city centre.
Concern over the impact that development at the district centres is having on the city centre.
District centre boundaries at Sherburn Road should be extended to incorporate the former Mono-Containers site.
Improvements required in Stanley town centre.
The impact thresholds are too high and should be uniformly applied across the County.
The town centre boundaries in Chester-le-Street should be extended.
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Question 17 - Policy 11 - Development in the Countryside
Summary of main issues raised by representations
The Plan does not tackle inequalities of rural areas. The policy is not clear how the dispersed settlement pattern of the county will be managed. The policy does not sufficiently support the recycling of land. The application of the policy needs to be more rigorous. The scope of infrastructure needs to be defined. The policy is considered to be sufficiently flexible. Support is given to the policy and the fact that it has been subject to rural proofing. The term hobby farming should be defined. The policy should set targets for rural businesses. More support should be given through the policy to redevelopment of previously developed sites. There is a need for the policy to recognises the need to safeguard mineral resources. The policy should define what level of adverse harm will be unacceptable. No definition of countryside is provided. This should be included within the policy itself. Changes should be made to criterion (h), (l) and (o) to ensure consistency with NPPF. The text should be more explicit regarding residential conversions. Concerns about cumulative impacts of development in the countryside and its impact on coalescence. Criteria should be included relating to suitability of the access and its location in relation to services such as water, electricity and mains drainage. It is considered that the policy comes from the standpoint that the majority of development in the countryside is unsustainable and concern is expressed that the scope of development permitted through this policy is too limited. The policy should include a mechanism to enable housing growth outside the built -up area where a 5 -year housing land supply/ delivery shortfall exists. The policy needs to include the necessary assessment and balancing of development proposals on a case by case basis as required by NPPF. Further consideration should be given to the specific local circumstances across the settlement hierarchy and responsive to the need for regeneration, economic development and the maintenance and creation of services in rural areas
Question 18 - Policy 12 - Rural Housing and Employment Exception Sites
Summary of main issues raised by representations
General support for the policy.
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Question 18 - Policy 12 - Rural Housing and Employment Exception Sites
Summary of main issues raised by representations
Requirement for the provision of a secure supply of affordable housing could be strengthened especially with regard to local need.
Rural infrastructure such as NHS, A & E, education and transport needs to be supported.
Specific employment sites to be included as opposed to the term ‘vicinity’.
Market housing to only be included when robustly demonstrated essential to deliver viability.
Request more allocations in rural Durham.
Question 19 - Policy 13 - Permanent Rural Workers’ Dwellings
Summary of main issues raised by representations
General support for the policy.
Developers should give priority to rural workers when housing is available.
County has an increasingly ageing population and there is a shortage of appropriate housing accommodation for older people and also for those with special needs.
Question 20 - Policy 14 - Equestrian Development
Summary of main issues raised by representations
General support for the policy.
Concern raised around groundwater run off and the impact on water quality.
Question 21 - Policy 15 - Best and Most Versatile Agricultural Land and Soil Resources
Summary of main issues raised by representations
General concern with regard to potential loss of agricultural land
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Question 22 - Policy 16 - Addressing Housing Need
Summary of main issues raised by representations
General agreement that provision of affordable housing, older persons housing and specialist housing are key issues. Both in the social and private housing markets.
Housing associations are the best people to supply better housing, not councils.
County Durham does not have a lack of affordable homes - distribution is the issue.
Evidence base for viability areas is not robust and no review of these areas is proposed during the lifetime of the Plan.
Affordable housing requirements should be a minimum and should be strictly adhered to.
Developers should not use viability as a justification for non-delivery.
Off-site provision of affordable housing must be built locally, particularly in high value areas.
Affordable college and PBSA should also be considered.
The 10% requirement for older persons housing is not high enough.
Land owned by the council should be used to provide affordable housing for the elderly.
More bungalows should be built, for older people and those with disabilities. Including bungalows for families.
Need to make sure that the needs of disabled people are met, including dropped kerbs and safe crossing places.
More should be done to bring empty homes into use as well as dealing with issues around poor quality housing and absentee landlords.
Social housing providers should be engaged at pre-application stage to ensure an appropriate product is brought forward for the application area.
Standard space requirements should be improved/increased.
There should be a self contained village for older people which offers a range of services and facilities.
New affordable and older person housing should be integrated into new developments to encourage community cohesion.
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Question 22 - Policy 16 - Addressing Housing Need
Summary of main issues raised by representations
Where off site contributions are made, timescales should be put in place to ensure delivery. Safeguards needs to put in place to ensure the contributions are only used for that purpose and to prevent the developer being able to reclaim it if the council has not used it.
All new housing should be built to M4(2) standards.
The tenure split identified in the Plan is too prescriptive. A more flexible approach should be adopted.
The requirements for affordable and older persons housing (particularly additional standards) are too inflexible and may mean sites don't come forward on viability grounds. There should be clearly evidenced need to justify these requirements.
Individual sites proposed, specifically to meet demand for affordable or older persons housing.
Concern that the requirement for some sites to contribute to the northern and western relief roads will mean that the requirement for affordable and older persons will be lost on viability grounds.
Percentage of affordable housing required in lower value areas is too low. Former threshold of 20% should be maintained.
Help to buy scheme should not be classed as affordable housing.
Discounted market housing should be included in the definition of affordable housing.
All new build properties should be freehold not leasehold.
More one and two bedroom properties should be built for the social sector as people are being penalised through the bedroom tax.
Small starter homes should be restricted to owner occupiers only. Second/holiday homes are also having an impact on the availability of homes for local people.
Question 23 - Policy 17 - Durham University Development, Purpose Built Student Accommodation and Houses in Multiple Occupation
Summary of main issues raised by representations
Too much of the housing in the city is for students, not residents. The city is overrun with Houses in Multiple Occupation (HMOs) and cannot cope with further students.
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Question 23 - Policy 17 - Durham University Development, Purpose Built Student Accommodation and Houses in Multiple Occupation
Summary of main issues raised by representations
No reason why the University should be increasing its numbers. The city cannot accommodate the increased growth. University expansion will have a negative impact upon tourism The University commissioned Biggar Report which provided an economic impact assessment of the University should be reflected in the Plan The University's Masterplan should be published as part of the evidence base for the Preferred Options. The University's proposals should be subject to sustainability and environmental impact assessments (these should be subject to consultation). The Policy should be split into three - it is currently very large and unwieldly. The Policy is correctly identified as a strategic policy. DCC should determine the future size of the University and an absolute ceiling should be imposed on the number of students living outside of university managed accommodation (6,000 students). Welcome inclusion of sites for allocation for Purpose Built Student Accommodation (PBSA). Accommodation for students should be built on university land only. Areas outside of the City of Durham Parish Council should be designated as the preferred location for student accommodation. PBSA3 would be a better site for permanent residents and older people. PBSA3 needs to recognise the heritage significance of this sites where archaeological and architectural remains may be preserved. PBSA4 concern over the loss of car parking facilities PBSA should be subject to a 10% threshold test. PBSA should be flexibly designed so it can be re-purposed to other types of residential accommodation / tourist accommodation. Resist PBSA on City centre sites bar for exceptional circumstances. Policy should refer to WHS Outstanding universal value and heritage aspects should be strengthened in the policy. Heritage considerations should reflect the whether the harm is outweighed by public benefit. There should be a requirement for cycle parking / this should include electric cycles. Affordable housing should be provided for students. Criterion a: include reference to respecting the requirements of the local community. Criterion c: removed reference to 'as a major developed site'. Criterion g relating to cumulative effects should be included within criteria d, e, f and h. Criterion g sequential texting should not be limited to sites under the university control. Further HMOs should be stopped / Banned. The spread of HMOs should be limited. City centre homes should be brought back in family ownership. PBSA should be included as part of the assessment of the 10% tipping point for change of use to a HMOs.
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Question 23 - Policy 17 - Durham University Development, Purpose Built Student Accommodation and Houses in Multiple Occupation
Summary of main issues raised by representations
'Residential units' should be referred to in the policy rather than 'properties'. The 'exemption' clause to resist a new HMO where a high proportion of existing properties within the 100m radius are already HMOs is not supported. The 10% limit should be on approvals not just usage. Tax exempt status alone is not an acceptable metric. The percentage of HMO/PBSA occupants should be limited to 20% of the population within 100m. The Exceptions clause should also include new build HMOs. HMOs and PBSA should pay council tax and business rates.
Question 24 - Policy 17 - Durham University Development, Purpose Built Student Accommodation Allocations
Summary of main issues raised by representations
Site allocations for PBSA welcomed, but the quantum of development for each sites (as provided) should be included. PBSA1 and PBSA2 should not be restricted to limited infill. Pleased to see university accommodation identified on university land. PBSA3 better for permanent residents and is particularly suitable for older people. PBSA4 before permission is given the impact of the loss of the car parking should be considered with mitigation measures adopted. Too much new housing in the city is for students not residents. Support for the allocations. Allocations could exacerbate current problems associated with student occupation of the city but may be beneficial in confining University Development within the confines of or adjacent to University sites. The council hasn’t identified capacity associate with sites or quantified the requirement for bed spaces needed over the plan period. There is doubt that the sites can accommodate any significant element of the universities growth. The constraints identified in the notes are likely to significantly limit the developability of the allocations. The site assessment is not clear in noting how some sites have been taken forward ahead of others. The focus has been to identify sites within the university control - concern about a lack of competition. 'Readily accessible' is not clear. A site at Frankland Lane has safe and convenient walking and cycling routes. Adjoining undeveloped land to the west of PBSA2 Howlands should be allocated (as part of PBSA2). This site is 1 mile to the to the South West of the City Centre and linked via a footpath with pedestrian crossings. Whilst the site is in Green Belt, it does
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Question 24 - Policy 17 - Durham University Development, Purpose Built Student Accommodation Allocations
Summary of main issues raised by representations
not perform well when considered against any of the 5 purposes. Its development would represent infill development.
Question 25 - Policy 17 - Durham University Development, Purpose Built Student Accommodation - Alternative Sites
Summary of main issues raised by representations
Suitability of Frankland Lane for PBSA Allocation: Despite falling within the Green Belt, the developable area of the site defined within the capacity study is brownfield and of low environmental value. Move student accommodation out of the city and provide busses for them. Ushaw college use the old farm close to it as accommodation. New build student accommodation in smaller villages that would benefit from revitalisation Welcome development at Ushaw College Allocate the University's proposed site at Green Lane.
Question 26 - Policy 18 - Sites for Travellers
Summary of main issues raised by representations
Concern over possible damage to watercourse.
Support for temporary stopover sites
Question 27 - Policy 19 - Children's Homes
Summary of main issues raised by representations
Support for the policy
Children's homes should only be for children from the local area.
Suggestion that with every new development all developers are asked what they can do for our children in care in terms of supported apartments for care leavers and develop
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Question 27 - Policy 19 - Children's Homes
Summary of main issues raised by representations
Children should be placed closed to their school and have a level of permanence, no school moves if a placement breaks down.
Children's homes should be located in our best and strongest communities not in those areas with antisocial problems or high levels of unemployment.
Question 28 - Policy 20 - Type and Mix of Housing
Summary of main issues raised by representations
Majority of comments in general support of the policy.
The policy needs to focus on the general mix of housing within the locality.
Developments should only be allowed if they increase the diversity of housing type in the village to promote a distinct community and identity.
A need to ensure an appropriate choice and mix to meet the requirements of a range of household sizes, ages and incomes.
Low demand needs to be addressed by effective regeneration of areas and by attracting viable and sustainable employment to them.
The Plan does not recognise the value of terraced houses or town-houses.
Far more affordable housing is needed.
More doctors/dentists/play parks will be needed to support the new homes.
An indicative type and mix of housing would be welcomed that the council will seek to apply across the county.
A new policy should be added to the Plan that relates to the renewal of planning permissions which presumes in favour of granting planning permission to replace an extant permission for a residential development provided that there have been no significant changes in planning policy or material considerations following the grant of the earlier permission.
Question 29 - Policy 21 - Green Belt
Summary of main issues raised by representations
Green Belt should be greater protection.
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Question 29 - Policy 21 - Green Belt
Summary of main issues raised by representations
Removing sites from the Green Belt undermines the permanence of the Green Belt.
Clarification around criteria b regarding the provision of development for outdoor sport and recreation i.e. does it include floodlights.
A stricter approach is required against development in the Green Belt.
Gateshead Council support the position that the North West Durham Green Belt is not required.
Additional land should be safeguarded to ensure future needs can be met without reviewing the Green Belt boundaries beyond the plan period.
Question 30 - Policy 22 - Non-Strategic Green Belt Amendments
Summary of main issues raised by representations
In principle objections to Fernhill and the Skid Pan and some support for the removal of Lumley Boys School from the Green Belt.
Green Belt losses needs to be minimised to allow for future food production.
Additional amendments should be made to the Green Belt including: South of Station Road, West Rainton; High Shincliffe; Relley Cottage; Plawsworth Reservoir; Bearpark Reservoir; Aldridge Court, Ushaw Moor; Sidegate House; Hillcrest; Flass Vale; Hermitage; Picktree Lane; Ash Meadows; Lambton Park and Sherburn village.
Question 31 - Policy 23 - Delivering Sustainable Transport
Summary of main issues raised by representations
General support for the criteria of Policy 23.
Welcome the establishment of a sustainable transport hierarchy and the recognition of the transport implications of development.
Need major modal shift to cycling.
Removal of minimum standards in parking and accessibility standards was supported.
An inter-modal freight terminal which would be best placed at Newton Aycliffe Forrest Park.
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Question 31 - Policy 23 - Delivering Sustainable Transport
Summary of main issues raised by representations
The policy should reference specific cycling provision design guides such as the Active Travel (Wales) Design Guide.
The council needs to consider freight more in its transport polices.
The policy should reference the need to integrate bus services with other modes.
Need lots of electric charging places.
Specific cycle routes should be safeguarded in the Plan.
There should be more reference to the national Transport Assessments and Travel Plan guidance, the councils Strategic Cycling and Walking Delivery Plan and the council Parking and Accessibility Standards.
Good bus services are essential for many people, young and old and people with disabilities.
Network Rail would like to see more reference to level crossings to be considered in the Policy.
Question 32 - Policy 24 - Durham City Sustainable Transport
Summary of main issues raised by representations
A number of respondents queried the need for housing in Durham City, on the basis that new homes should be built elsewhere, where new major roads would not be needed to support the developments.
Others raised concerns about the proposed location of a new council headquarters in Durham city centre due to its perceived likely impact on traffic issues in Durham.
Some made general comments questioning the need and/or justification for the roads.
The roads should include provision for pedestrians and cyclists.
Building the roads would cause environmental damage, and damage to ecology, heritage, and the landscape in the affected areas.
The impact of the roads on the local road network should be fully considered.
The council should invest in sustainable transport options instead of in new roads.
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Question 32 - Policy 24 - Durham City Sustainable Transport
Summary of main issues raised by representations
There are only congestion issues at school times.
Concern about how the roads will be funded.
Concern about the proposed route, and suggestions of alternative routes for the roads.
Question 33 - Policy 25 - Allocating and Safeguarding Transport Routes and Facilities
Summary of main issues raised by representations
Support a dual carriageway to Consett.
Support the provision has been made in the Plan for a 'Corridor of Interest' to help facilitate any future relief road development in Barnard Castle.
Objection to the Barnard Castle corridor of interest.
General support for the reinstatement of the Leamside Line
Ferryhill would welcome a new station as part of the Leamside Line development.
The cost of the Leamside Line is underestimated at £300 million.
Etherley Parish Council strongly support a Toft Hill by-pass.
Support for Horden Rail Station allocation.
Objections to the allocation of the Sherburn Retail Link Road.
Support for the allocation of the Sherburn Retail Link Road.
Support for the recognition of the Darlington Northern Relief Road.
Support for the Bowburn industrial access road.
Need better road links between Seaham and the A19.
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Question 34 - Policy 26 - Provision of Transport Infrastructure
Summary of main issues raised by representations
The policy should include specific reference to Newcastle International Airport. The policy fails to give sufficient emphasis to promotion of sustainable transport use. More road infrastructure is required in Consett. Part (e) of Policy 26, and the supporting text should make explicit reference to the historic environment.
Question 35 - Policy 27 - Developer Contributions
Summary of main issues raised by representations
Concern that when developing new housing the existing infrastructure cannot cope with the additional development - new services and facilities are therefore necessary.
Important that Section 106 Agreement requirements do not threaten the viability of development.
Concern that the tests for planning conditions and planning obligations vary slightly from the tests provided in the NPPF and Regulation 122 of CIL Regulations 2010.
Concerns about how review mechanisms / overage payment clauses would be factored into s106 agreements and work in practice.
Review mechanisms should take account of both improvements and downturns in market conditions.
Question 36 - Policy 28 - Green Infrastructure
Summary of main issues raised by representations
More clarity needed on circumstances where 'the benefits of the development clearly outweigh the harm'.
Most proposed developments are on greenfield sites and this should be reviewed.
Residents in Aycliffe and Aycliffe Town Council would like to see all opportunities to invest/improve and retain green infrastructure being explored (sites suggested).
The line of the Stockton and Darlington Railway, whether in railway use or not, presents an important element in the green infrastructure of the county and forms part of the green corridor network.
Ensure good quality open space on each residential estate.
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Question 36 - Policy 28 - Green Infrastructure
Summary of main issues raised by representations
Appropriate green space should be included on site or adjacent to a residential / employment development site in Durham City.
Strengthen the policy wording by deleting 'where appropriate'.
Some housing allocations contravene the policy.
The policy provide no provision for Natural Capital.
Monitoring could also include the amount of new Green Infrastructure created.
When a Green Belt site, such as Sniperley is proposed for housing and other development purposes the loss will not be fully compensated.
No commitment or consideration to preserving green open spaces in Ferryhill.
Quantitative shortfall in the provision of allotments and amenity green space in the Central Durham assessment area identified. It is unclear what the expected triggers, methodology and contribution calculator will be applied to each site. Clarity requested for each allocation.
A commitment that new provision of green infrastructure should also contribute to the management and/or targeting of priority species and habitats needs to be shown in the policy.
Greater protection of green spaces needed.
Only green infrastructure assets identified in the Open Space Needs Assessment and Green infrastructure Framework should be protected.
The potential impact on viability of affordable schemes should be considered.
The policy needs to take into account more than just open spaces and verges.
Future favourable management of Green Infrastructure sites should be safe guarded.
Reference should be made to the design of sustainable natural environment within the built environment.
Concerns of the upkeep of new estates.
Long term green goals a concern.
Stronger emphasis on the need for space for food growing.
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Question 36 - Policy 28 - Green Infrastructure
Summary of main issues raised by representations
Concerns raised over the lack of a specific Green Infrastructure policy for Durham City.
Concerns over insufficient protection from over development and the protection for town and village identities and green spaces.
Question 37 - Policy 29 - Utilities, Telecommunications and Other Broadcast Infrastructure
Summary of main issues raised by representations
Very little reference to super fast broad band and it's possible use for business development and reducing our carbon foot print.
Availability of good broadband access is important for all areas of the county. In the long run the limitations of bandwidth on wireless frequencies will make it essential to provide good fibre networks. Given the likely increases in data traffic, this will probably mean that fibre connections will be needed even in remote areas.
Providing fibre connections to all the premises likely to need it will take years. Wireless connections will probably work as a stopgap measure. Identifying these broadband network requirements now is essential. It would be wise to include passive provisions of, ducting, for example, in places where it would avoid the future need for disruptive works.
In order to make this policy effective, Northumbrian Water Ltd suggest the following amendment to the wording of this criterion "It is located at an existing mast or transmission site, where it is technically and operationally feasible and does not result in is designed to minimise visual clutter".
Where a new site is required applicants must demonstrate to the council's satisfaction that the use of existing sites in the area have been fully explored and are not feasible. Equipment must be sympathetically designed and camouflaged and not result in order to reduce visual clutter.
The policy requires developers to ensure that all new build developments are served by a high speed and reliable broadband connection. This is not an appropriate planning policy.
It is not considered appropriate for Durham to seek additional local technical standards over and above this requirement.
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Question 37 - Policy 29 - Utilities, Telecommunications and Other Broadcast Infrastructure
Summary of main issues raised by representations
Paragraph 43-46 of the NPPF establishes that council's should seek to support the expansion of electronic communication networks, however it does not seek to prevent development that does not have access to such networks.
Policy 29 which requires all new build developments to be served by a high speed and reliable broadband connection is considered to be too prescriptive and onerous for developers, particularly as this is not within the direct control of the development industry and as such is likely to pose deliverability issues for development and developers.
To achieve this and have the required impact on the rural economy, whether for tourism, farmers or home workers or new high-tech businesses we recommend that the key infrastructure requirement to achieve the aimed progress and growth, within Teesdale, is broadband that matches that of major cities.
National Grid prefers that buildings are not built directly beneath its overhead lines. Land beneath and adjacent to the overhead line route should be used to make a positive contribution to the development of the site and can for example be used for nature conservation, open space, landscaping areas or used as a parking court.
Question 38 - Policy 30 - Safeguarded Areas
Summary of main issues raised by representations
Concern about the regulation of nesting or flight and flying patterns of wild birds in locations which are adjacent to aircraft and/or air fields.
There is a conflict between this use of the term "safeguarded" and use of the term to refer to reserving land for development after the Plan period.
Any further development within the areas identified should also be carefully monitored to ensure that the quality of life and quiet enjoyment of their properties of residents living within those areas is safeguarded.
The policy is not be robust in its requirements and requests the following amends - the policy as worded does not require mitigation to reduce or remove the potential impact.
Wind farms which can impact on radar and other navigational systems, as well as potentially presenting a collision hazard A small portion of the 15km zone falls within County Durham and a significant area is covered by the 30km wind farm zone.
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Question 38 - Policy 30 - Safeguarded Areas
Summary of main issues raised by representations
The policy also only requires consultation with the relevant safeguarding authority and should be strengthened.
The supporting text offers little detail on the types of development which are subject to aerodrome safeguarding.
Question 39 - Policy 31 - Sustainable Design in the Built Environment
Summary of main issues raised by representations
Overall support for a design policy.
New developments must have adequate parking provision.
General concerns about lack of internal space and storage. Support for adopting Nationally Described Space Standards (NDSS).
Some concern from the development industry that NDSS will impact upon viability.
Plan needs to support innovation and creative design.
The Policy should set higher standards in relation to energy efficiency.
Support for requiring the prioritisation of non-motorised transport, however this should be made more specific.
Support for minimum densities.
Development for older persons, especially bungalows, will not achieve the density requirements of 30dph. However it is essential for this type of accommodation to be built within developments to help meet housing need.
Depending upon their size schemes should include services and facilities.
Some support for the use of Building for Life assessments.
Concern that reference to requiring development of the 'highest standards' does not reflect national policy wording.
The Policy should refer to the use of locally relevant designs and materials to maintain local character.
General concerns about the lack of quality of new dwellings, including poor sound insulation.
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Question 39 - Policy 31 - Sustainable Design in the Built Environment
Summary of main issues raised by representations
Support for including some green infrastructure/food growing areas. Sufficient open space especially for children.
The Policy should reflect that sustainable design in the built environment is far more diverse than carbon emissions and is not limited to any one particular consideration including health and well-being, air quality, materials sourcing and use, site-wide ecology and biodiversity and procurement.
More certainty needed in respect to extensions and alterations.
General support for renewable energy generation within new houses.
Question 40 - Policy 32 - Hot Food Takeaways
Summary of main issues raised by representations
General support for the Policy in terms of the threshold for town centres and the exclusion zones around schools.
Consideration should be given to obesity levels in the county.
Consideration should also be given to the rubbish that are associated with hot food takeaways.
Opening hours of hot food takeaways should be considered in the Policy.
Lack of evidence to justify 400m exclusion zone.
A more granular approach should be taken to dealing with the issue in Durham City.
Question 41 - Policy 33 - Amenity and Pollution
Summary of main issues raised by representations
General support for the policy.
The policy should take into account the Agent of Change Principle set out in NPPF.
The Relief Road proposals will have an adverse affect on pollution levels in Durham.
The policy should set out what measures the Council are taking to reduce air pollution within the Air Quality Management Area.
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Question 41 - Policy 33 - Amenity and Pollution
Summary of main issues raised by representations
Concern was expressed about open cast mining.
The issue of light pollution affecting the World Heritage Site was raised.
Water quality should be included in the policy.
The policy should require consideration of cumulative impacts of air pollution.
Question 42 - Policy 34 - Despoiled, Degraded, Derelict, Contaminated and Unstable Land
Summary of main issues raised by representations
Some of the types of land referred to in this section, including unstable land are also important wildlife habitats. This section therefore needs to be considered together with parts of the Plan dealing with Woodland and species diversity.
This take a very narrow view on how healthy communities are created. Hot food takeaways, amenity and pollution and contaminated land are not the only factors effecting whether a community is healthy.
Greenspace and green infrastructure, particular everyday passive exposure to nature (such as street trees) has a considerable impact on physical and mental health and should be referenced within this section. There is scope to encourage truly naturally healthy communities, which also enable an improvement in levels of deprivation across the board.
Question 43 - Policy 35 - Renewable and Low Carbon Energy
Summary of main issues raised by representations
General support.
Clarification sought regarding what the baseline figure for energy generated by renewable sources was.
Concerns were raised that visible solar panels should not be permitted in conservation areas.
The policy should require solar and other low carbon techniques to be used as part of all new builds.
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Question 43 - Policy 35 - Renewable and Low Carbon Energy
Summary of main issues raised by representations
The Plan should do more to address climate change and to make the most of the options available, e.g geothermals at Spennymoor
The impact of climate change on biodiversity should be mentioned in the policy.
Question 44 - Policy 36 - Wind Turbine Development
Summary of main issues raised by representations
General support for the protection of heritage assets through the policy.
The policy as drafted does too much to encourage wind turbines in a county which already has a significant number of wind farms.
Concerns were raised about the identification of parts of the AONB as suitable for wind turbine development.
The policy should not allow for larger turbines to replace existing ones.
The policy does not go far enough in encouraging onshore wind turbines and addressing climate change.
A number of areas have been identified as suitable for small or medium turbines, but in many cases 'small' turbines of up to 25m high would have an unacceptable impact in these areas.
The policy should clarify whether height is measured to hub or to blade tip.
Question 45 - Policy 37 - Water Management and Policy 38 - Water Infrastructure
Summary of main issues raised by representations
General support for the policy.
Request to reference the Catchment Partnerships within the supporting text of the policy.
Request to amend Indicator 1 to make clear how watercourse improvement will be measured.
Concern that foul wastewater infrastructure is reaching, at or above capacity.
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Question 45 - Policy 37 - Water Management and Policy 38 - Water Infrastructure
Summary of main issues raised by representations
Site specific flood incidences and/or concerns.
The policy should set out that "all new development sites will be required to incorporate SuDS. SuDS should only be excluded in exceptional circumstances, and that there should be a requirement to provide robust evidence to demonstrate the reasons why SuDS cannot be incorporated.
Reference should be made to the future adoption of SuDS by the LLFA or regulatory Water and Sewerage Companies when the Sewers for Adoption 8 comes into effect in 2019.
Request for additional wording to be included in the policy to acknowledge that groundwater levels in some areas will increase and that this may affect the suitability of some SuDS in areas where there is a risk of groundwater flooding or where the ground may be unable to absorb any excess water from the propose scheme both now and in the future.
Request that the policy goes further to support water quality enhancements, in particular when trying to support Water Framework Directive objectives.
Request that any development proposing to discharge trade effluent should provide a water management plan.
The policy should consider drought risks as well as flood risks.
The SFRA sequential test should be updated to consider the crossings of the River Wear and River Browney.
Request that Reed Bed filtration is included within the policy as an additional 'non-mains' option.
Clause e) 4 Discharge into a combined sewer should not be permitted under any circumstances.
Sea level is currently rising which will require changes to water supply and drainage infrastructure. They may need to be moved or rebuilt. Upstream sites may need to be identified.
Part e. of the policy should take the opportunity to take viability into consideration.
Policy wording should be amended to extend this policy support to water treatment works, in order to ensure that drinking water supply can meet increasing demand.
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Question 45 - Policy 37 - Water Management and Policy 38 - Water Infrastructure
Summary of main issues raised by representations
Concern that Part f. of Policy 37 requires developers to solve existing flood risk issues in the wider area.
Within the policy there should be a much stronger steer given on the possibilities that SuDS can provide for biodiversity, the impact of climate change on biodiversity and how natural process can be utilised to help achieve climate resilience.
Question 46 - Policy 39 - Durham Coast and Heritage Coast
Summary of main issues raised by representations
General support.
Reference should be made to the Coastal Streams Partnership, which is a sub-group of the Wear Catchment Partnership.
Request to incorporate references to the Marine Management organisation licencing requirements, relevant marine plans as well as online resources.
Request for the definition of seascape to be included in the glossary.
The policy does not make it clear that biodiversity and wildlife in this area is very important.
The policy does not refer to a Coastal Change Management Area.
Access to the coast from Horden Railway Station should be supported.
Sea Level is currently rising, this will demand changes to water supply and drainage. This will also affect many properties near sea level in river valleys.
Question whether there is any difference between Heritage Coast and the Coastal Zone for planning purposes.
The policy should explicitly refer to natural and historic heritage features.
It should be made clear that the tests of the Habitat Regulations will apply for any development likely to adversley effect coastal Natura 2000 sites.
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Question 46 - Policy 39 - Durham Coast and Heritage Coast
Summary of main issues raised by representations
Request that criteria d. of the policy be amended to read 'protection, conservation and enhancement of its natural assets', in line with the defined purposes of the Heritage Coast.
Reference should be made to the developing North East Marine Plan.
Question 47 - Policy 40 - North Pennines Area of Outstanding Natural Beauty
Summary of main issues raised by representations
General support.
Definitions should be provided for 'public interest', 'natural beauty' and 'special qualities'. Need to be confident that the 'special qualities' of the AONB are clearly articulated in the AONB Management Plan if they are not articulated in the policy.
The policy should recognise that the landscape is not all 'natural', that many features are man-made, and that development may be important in the future.
The policy should refer to the protection of biodiversity and the natural capital value of the environmental resource.
Mineral extraction in the AONB should be recognised as a vital and valued activity. Particularly support for the expansion of Heights Quarry.
Question 48 - Policy 41 - Landscape Character
Summary of main issues raised by representations
General support for the policy.
Clarification sought on the definition of 'unacceptable harm'.
Request to include 'flora and fauna' in the policy.
The Magnesian Limestone Escarpment forms a significant and important feature in the area of the Partnership and is visible from a number of locations, including in both directions from the motorway. It is considered vital that our important landscape and features are protected and in particular views of the Escarpment.
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Question 48 - Policy 41 - Landscape Character
Summary of main issues raised by representations
Attention should be paid to the Great Aycliffe Neighbourhood Plan for proposed development within that area.
Concerns over flexibility of the policy. To ensure this flexibility the following change to Policy 41 is suggested: 'Proposals for new development will not be permitted where they would cause unacceptable harm to the character, quality or distinctiveness of the landscape, or to important features or views, unless appropriate mitigation or compensation is provided'.
Additional wording proposed to include 'unless appropriate mitigation or compensation is provided'.
No mention of natural capital value of the environmental resource.
All development in Lanchester should take full account of the important Landscape Character.
There is a threat that the development taking place on the former steelworks site is now encroaching into areas which have become part of the Derwent Valley countryside and risks damaging the character & ecosystem of this area as well as reducing the diversity of wildlife.
Policy 41 is not consistent with national policy. The NPPF calls for policies and decisions to ensure developments are sympathetic to local character and history.
Reference should be made to the County Durham and Darlington Historic Landscape Characterisation (HLC).
The Plan has no evidence of a protective wedge and Middridge Parish Council requests that it be replaced in a newer version of the plan which also should classify the whole of the Parish as countryside.
Suggested amending to the supporting text 'Parts of the county are covered by long term landscape scale partnerships covering specific places (the North Pennines AONB, the Durham Heritage Coast), short term thematic partnerships (e.g. for large HLF programmes) or those on a thematic basis (e.g. the County Durham Hedgerow Partnership), together with a number of shorter term or more localised partnership projects'.
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Question 49 - Policy 42 - Trees, Woodlands and Hedges
Summary of main issues raised by representations
Should aim for greater tree planting. If there is a local control of the Common Agricultural Policy it should be incorporated into these plans how Local Authorities would direct the spend of subsidies currently paid for unproductive farming.
Increase the amount of trees/woodland. Target of 'no not less' is poor.
Policy wording is subjective and undefined, and more detail should be given to quantify both the benefits and harm.
Wording should be amended as the loss of any features identified would not be acceptable.
Riparian (riverside) trees should be referenced as a distinct category along with woodlands and hedges
Tees Banks Woods on the north bank of the river at Barnard Castle should be incorporated in the conservation area.
Confirmation requested that in the future DCC will take actions based on a belief in the value of the protection of ecology and tree protection rather than only imposing such protections on third parties via the planning process.
Policy is negative in its approach.
The policy should go further. Not only protecting loss but areas should be protected that link up the smaller patches of woodland or new hedgerows should be included in developments to link up woodlands.
Veteran trees are considered irreplaceable habitat, which is acknowledged in the supporting text, but not the policy.
Concerns raised over the employment site at Bowburn
The policy could be enhanced by actively encouraging the planting of street trees and trees in urban settings instead of just minimising loss of urban trees.
Concerns raised over what is 'appropriate compensation' (as mentioned in this Policy) given that it is not possible to replace ancient woodland.
Hedges should be retained in their present state, including height.
Concerns raised by Sedgefield Borough Plan that previous 'green wedges' surrounding the Village of Middridge are no longer in the plan.
Concerns raised over mitigation against the loss of Ancient Semi-Natural Woodland and whether or not it is achievable.
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Question 49 - Policy 42 - Trees, Woodlands and Hedges
Summary of main issues raised by representations
The policy should stipulate the need for professional advice and services the council officers can offer.
No mention of the natural capital value
The policy does not consider Long term green goals.
Site near Spout Lane, Middridge Vale and associated community woodland and grassland area not shown on map
The policy should be monitored as per the criteria.
The plan should recognise the limited green space in the built environment of Durham City.
A target for tree planting should be incorporated to bring a percentage of each area of Durham to similar to that of Surrey.
Question 50 - Policy 43 - Biodiversity and Geodiversity
Summary of main issues raised by representations
General support.
Definitions should be provided for 'significant harm' and the cost calculations for determining net gain.
Previously developed land, even where is does have ecological interest and local wildlife designations, should be reviewed in order to identify opportunities for development.
The positive contribution of the quarrying industry should be referenced.
The policy should be amended to remove the dilution of biodiversity net gain - 'where possible'. The policy should seek net gain for biodiversity in all development in line with 25 year Environmental Plan. Net gain for geodiversity is problematic but could refer to access to, increased enjoyment and understanding of geodiversity.
The policy should be amended to allow more flexibility in cases where there are good reasons why net gains are not possible.
The policy should make reference to the management of biodiversity and geodiversity areas.
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Question 50 - Policy 43 - Biodiversity and Geodiversity
Summary of main issues raised by representations
There should be a section in the policy that refers specifically to irreplaceable habitats.
Lack of reference to the importance of species rich grassland and the need to protect it.
Policy wording should be amended to plan positively.
All new development should have the responsibility to ensure that there is no spread of non-native species.
Developments that incorporate substantial net ecological gains or habitat creation should be actively supported where possible.
Where mitigation or compensation is required it must be a site that is likely to attract species of the same kind that are being displaced.
No development should be permitted which will have a detrimental impact on peatlands.
Site specific requests for sites to be designated or de-designated as specifically protected sites or as more general open/green space.
Request to recognise that due to site constraints, ecological enhancements need to be considered on a site by site basis.
Better reference should be made to the habitats and species that characterise County Durham.
Suggested change to policy wording to make clear that biodiversity data does not necessarily have to be from the most up-to-date season as long as the data publicly available is still relevant.
Concern that changes in watercourse flows upstream may dramatically increase water temperature locally effecting local fish populations and wildlife. This can include outflows from sewage works and rising mine water levels.
The policy does not mention the natural capital value of the environmental resource.
There is no specific mention of the impact of climate change on biodiversity, or how natural processes can be utilised to help achieve climate resilience.
The carbon storage potential derived for habitats such as peatlands, woodlands and urban 'smart' soils should also be recognised as these will have an increasing contribution in climate change mitigation.
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Question 50 - Policy 43 - Biodiversity and Geodiversity
Summary of main issues raised by representations
New housing and commercial development has a great opportunity to provide nesting sites for some of our declining bird species.
Policy does not align with paragraph 170 of the NPPF 2018.
Question 51 - Policy 44 - Internationally Designated Sites
Summary of main issues raised by representations
General support.
Request for clarification of what is meant by 'imperative reasons of overriding interest', 'significant effects' and 'appropriate compensation'.
Policy should rewritten as it doesn't meet the requirement of the NPPF to plan positively.
References to the Conservation of Habitats and Species Regulations 2010 (as amended) should be updated to 2017 version, including the updated paragraph numbers.
Following the People over Wind ruling, the policy needs to be amended so that when determining whether or not a plan or project in likely to have a significant effect on a site at the screening stage, it should not take into account of measures intended to avoid or reduce the harmful effects of the proposal on that site.
Consultation on the extension to Teesmouth and Cleveland Coast Special Protection Area (SPA) has commenced. This are should be be included in the HRA and the proposal map with the buffer for likely significant effects.
Not clear how the Heritage Coast Management Plan and the HRA: Developer Guidance and Requirements in County Durham can specifically mitigate the impacts of the Plan.
Not clear why the policy specifically distinguishes between the 0.4km and the 6km buffer.
Monitoring of the policy should be made more specific and should not be based on the number of applications approved.
The appropriate assessment should also include RAMSAR sites, potential SPAs , possible SACs and sites identified or required as compensatory measures for adverse effects on European Sites as these should be treated as having equivalent status to Natura 2000 sites.
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Question 51 - Policy 44 - Internationally Designated Sites
Summary of main issues raised by representations
Concern that the wording around the 0.4km buffer was too restrictive and that some small scale development within this buffer could be acceptable.
There is no mention in the policy of the natural capital value of the environmental resource.
Question 52 - Policy 45 - Protected Species and Nationally and Locally Protected Sites
Summary of main issues raised by representations
General support.
Request for clarification of what is meant by 'significant', 'demonstrably outweigh the adverse impact', adequate management', 'significant contribution'.
Request that policy should be reworded as development of land within local wildlife sites and local nature reserves is not automatically incompatible with these allocations.
Concern that the Plan, allocations and evidence base (specifically the SHLAA) have too easily discounted sites, which have any of the 4 designations referred to in Policy 45, from further consideration.
Where provision is made for bird or bat boxes provision should also be required for their cleaning, maintenance and replacement.
Bee bricks should be included in the list of built features which can support the natural environment.
It should be reflected in the policy that developers have a responsibility to address the the fragmentation of habitats and species by incorporating landscape connectivity of both designated and non-designated sites in their development scheme.
Compensation must be suitable for the species likely to be displaced.
The policy does not accord with paragraph 171 and 174 of the NPPF 2018, which requires a clear distinction between nationally and locally designated sites.
The policy needs to reflect the NPPF principles of mitigation and compensation.
The NPPF refers to 'Priority' not 'Protected' species.
The policy should be reworded to plan positively.
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Question 52 - Policy 45 - Protected Species and Nationally and Locally Protected Sites
Summary of main issues raised by representations
The policy should be reworded to remove 'where possible', where it requires the enhancement of biodiversity.
Requests for specific sites to be designated or de-designated.
Requests to make the policy more flexible by adding 'wherever possible' in relation to avoiding sensitive habitats and species through careful site selection.
The policy should be considering zero harm approach to these sites.
There is no mention in the policy of the natural capital value of the environmental resource.
Mitigation and/or compensation should be fair and proportionate.
It should be noted that not all sites of valuable natural environment or of nature conservation value are designated.
Question 53 - Policy 46 - Historic Environment
Summary of main issues raised by representations
General support for the Policy.
An additional policy should be included in the Plan in respect of Belmont Viaduct.
The Policy should recognise the importance of 'time layering' of heritage assets and historic places.
Heritage Statements should always be produced by a heritage specialist.
The protection of non-designated heritage assets should be enhanced.
DCC should as a matter of urgency for Durham City apply for listed status for all the non-designated heritage assets identified in the character assessment of the Durham City Conservation Area.
Additional wording proposed to the first sentence of this Policy, to ensure consistency with national guidance.
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Question 53 - Policy 46 - Historic Environment
Summary of main issues raised by representations
Reword first paragraph of the Policy to make it clear that there is no implied suggestion that a heritage asset can be destroyed and then a subsequent planning application granted because the heritage asset has been partially or totally destroyed and is no longer worth protecting. It should also be clear that where full or partial loss is permitted that full and proper recording of the asset must be undertaken prior to its loss.
References to 'preservation' need to be changed to 'conservation' to ensure consistency with NPPF terminology.
The policy could also be monitored by the number of successful enforcement actions taken against developers in breach of listed building consents or planning conditions covering the historic environment.
Amendments proposed in respect of archaeological evaluations, which should be less onerous than currently required.
While the general policy to protect the historic environment is welcome, there is a lack of detail relating to Durham within the Plan.
A number of minor amendments were recommended by Historic England.
Question 54 - Policy 47 - Durham Cathedral and Castle World Heritage Site
Summary of main issues raised by representations
The Policy is too generic and does not emphasise the particular qualities and setting of the Durham WHS.
Reference should be included to the WHS Management Plan and the ICOMOS HIAs.
The Policy should mention the intention to extend the extent of the WHS.
The Policy should include reference to the Act.
The reference to setting needs clarifying. References to 'inner and outer bowl' are confusing – the bowl description was dropped in the 2017 WHS Management Plan as misleading and changed to inner and wider setting.
The Conservation Area Character Appraisal needs to be fully considered when development is proposed.
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Question 54 - Policy 47 - Durham Cathedral and Castle World Heritage Site
Summary of main issues raised by representations
Historic England recommended a minor tweak to the second sentence of the policy, which was considered to potentially be misinterpreted and read as only referring to development within or affecting the setting of the WHS, rather than the site itself.
Additional monitoring indicators could be included to measure more positive outcomes.
Question 55 - Policy 48 - Stockton and Darlington Railway
Summary of main issues raised by representations
Support for including a Policy on the S&DR in the Plan.
It should be made clearer that the policy safeguards and enhances the route itself and its assets and setting and not just access to them. The policy should include a requirement that development on or adjacent to the line and branches should reinstate a legible route where those remains no longer exist.
The supporting text should be amended, including to explain that those assets that remain along the 1825 line and which are significant to its heritage, public understanding and enjoyment should be protected and enhanced in relation to their significance.
The protection and enhancement of the S&DR and its setting by Policy 48 will impact on some development sites next to the line. Clear guidance should be set out for each affected allocated site so that developers are aware of the requirements of the Plan.
The chapter as a whole should make reference to the ECML Route Study, setting out the potential improvements which could be made to meet the challenges of increased growth.
Historic England welcome the inclusion of a unique policy for the S&DR. However they recommended including a number of additional requirements, for example in relation to conserving and enhancing elements of the asset which contribute to the significance of the S&DR and its setting, including its trackbed and branch lines, ensuring development proposals do not prejudice the development of the S&DR as a visitor attractions, as well as outlining the information required to accompany any applications affecting this asset. The Policy should include reference to the Heritage Action Zone.
The 1825 line and the branches should be fully and explicitly designated on the Policies Map.
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Question 56 - Policy 49 - Sustainable Minerals and Waste Resource Management
Summary of main issues raised by representations
North Yorkshire County Council have no strategic minerals or waste concerns with the approach being taken at this stage.
It would be helpful to indicate when the Minerals and Waste Policy and Allocations document will be published with the anticipated period for adoption stated.
Reference is made to the saved policies in the County Durham Minerals and County Durham Waste Local Plan. Many of these policies will be almost 20 years old and their relevance somewhat limited. It is questionable whether or not these policies are up to date and it is believed Para 11 c&d of the NPPF is applicable.
Paragraph 5.474 recognises the national and regional importance of certain minerals. It is not clear what evidence the Council has used to determine which minerals are of regional importance. This should be clarified.
Para 5.476 introduces the waste hierarchy. The Plan should discuss waste more in relation to Circular Economy and Sustainable waste management rather than the Waste Hierarchy. There is a mention of Industrial Symbiosis which has a huge potential. The council should work with business in the county to look to and adopt such innovative approaches and so the Plan could explore these a bit more.
Minerals and Waste Management are dealt with together, reflecting historical association between mineral extraction and landfill. Consideration should be given to separating minerals and waste policy to provide greater clarity recognising that although minerals and waste are related, increasingly the two are separate resources and should be addressed as such in policy terms.
An additional policy requirement could be added to provide for a steady and adequate supply of minerals to meet both local and wider needs.
A reference to the Marine Policy Statement in regards to the consideration of aggregate extraction, re-use and disposal should be included.
If the proposal to extend Heights Quarry to the North West is permitted it will take out large areas of wetland, removing an important habitat for waders and for flood water storage, contrary to the aims of the Weardale NFM National Pilot project.
The plan's provisions for the surface mining of coal should be removed. Coal should be considered a stranded asset and left in the ground.
This section refers to shale gas and underground coal gasification, the council should make a commitment to banning fracking in County Durham.
The council should work with Durham University and the energy industry to explore the possibility of promoting the 'gasification' of the extensive coal reserves in County Durham.
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Question 56 - Policy 49 - Sustainable Minerals and Waste Resource Management
Summary of main issues raised by representations
There is no reference to Liaison committees in this Policy.
Where is the consideration of resources, renewables and creating local waste a recycling systems?
Policy 49a and b should be re-written to allow for the re-use of inert waste in the restoration of mineral workings.
Policy 49c requires all proposal's to minimise waste. Whilst the principle behind this subsection are understood, the aggregates levy provided an imbalance to the use of minerals waste. Quarry scalpings, in many instances cannot be sold, due to the competition from recycled aggregates. It is unclear how this policy can be applied or enforced. Further clarity is sought on the implementation of this policy and its value.
Policy 49e)1 refers to "permanent waste management facilities" for a temporary period. The policy would appear to present conflicting considerations. Further clarity is sought on the implementation of this policy.
The policy fails to recognise inert waste is a valuable resource for use in the restoration of mineral workings to beneficial end uses and/or new habitats and enhanced biodiversity.
By law waste is not allowed to be disposed of in landfill resource if it is capable of being recycled or re-used.
Aggregate recycling facilities (i.e. Policy 49 (e)) should be addressed under a separate policy.
It is essential that there is a sufficient supply of minerals to provide the infrastructure, buildings, energy and goods the county needs, particularly to deliver the aims and objectives of the Plan.
The text should recognise that minerals are not only a finite resource but they can only be worked where they are found.
Magnesian limestone is also worked in its own right to specifically produce agricultural lime significant quantities of which are exported to continental Europe.
Overall, the minerals policies in the Plan need to have some flexibility for dealing with non-allocated sites.
Additional wording is needed to take into account of development below the water table. Risk assessment to groundwater should be assessed and managed in order to protect its quantity and quality.
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Question 56 - Policy 49 - Sustainable Minerals and Waste Resource Management
Summary of main issues raised by representations
The Council's indicator is only to monitor the capacity at waste management facilities. It is not clear how the indicator would assess the sustainable management of minerals
Question 57 - Policy 50 - Safeguarding Minerals Sites, Minerals Related Infrastructure and Waste Management Sites
Summary of main issues raised by representations
Northumberland County Council support the approach set out in Policy 50. The sites to be safeguarded are clearly listed in Appendix C, as well as being shown on the Policies Map, and this is welcomed.
Aggregate Industries will assist Durham County Council in defining mineral safeguarding areas in the vicinity of Hulands and Heights Quarries.
Support for the allocation of the following quarries as safeguarded minerals sites as shown on the Policies Map: Thrislington Quarries (Inset 29);· Cornforth Quarries (inset 29); Old Quarrington and Cold Knuckles Quarry (Inset 22); and Hawthorn Quarry (Inset 16).
Support the identification of minerals safeguarding zones around mineral sites of 250m (and 500m where blasting is likely to take place) and 100m around all mineral processing infrastructure as set out in paragraph 5.492.
With regards to Hawthorn Quarry, Tarmac would like to see the mineral safeguarding zone extended to the west slightly to include the company's lease area as per the enclosed plan. Tarmac questions the sense of extending the 500m safeguarding zone around the quarry into the sea to the east of the quarry. It is suggested therefore that the mineral safeguarding zone around Hawthorn Quarry is redrawn slightly to include the company's lease area to the west whilst removing the inclusion into the sea to the east.
Consideration should be given to separating minerals and waste to provide greater clarity and recognition that each are valuable resources in their own right.
Overall, the minerals policies in the Plan need to have some flexibility for dealing with non-allocated sites.
Page 25 Paragraph 4.15 refers to the number of houses to be provided over the Plan period noting that it is a "target not a ceiling". This approach should be adopted for the provision of minerals i.e. landbanks should not be seen as a ceiling.
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Question 57 - Policy 50 - Safeguarding Minerals Sites, Minerals Related Infrastructure and Waste Management Sites
Summary of main issues raised by representations
The supporting text should make reference to the agent of change principle referred to in the NPPF (2018).
The final paragraph of the policy states that planning permission will not be granted for non-minerals or non-waste related development adjacent to a safeguarded mineral processing facility etc. This would benefit from greater clarity as to what constitutes "adjacent"
It would be logical to have the Minerals Safeguarding Policy (56) and Minerals Infrastructure Policy (50), consecutively in the plan.
Policy 50 should acknowledge that any proposal for non-mineral related development within a safeguarded zone must not give rise to unacceptable impacts, for example upon the environment, heritage assets or other designations such as Heritage Coast.
The Merrington Lane safeguarded waste site should be removed from the proposals map and the text of draft Policy 50.
Cornforth village is shown in the plan as an area for mineral extraction and waste disposal. The plan should be amended to exclude this community from that notation.
The safeguarding zone for Old Quarrington Quarry should be reassessed.
The safeguarding zone and the safeguarded area in respect of Hawthorn Quarry should be reassessed.
A number of safeguarded sites are near to National Grid Infrastructure.
The definition of "exempt development" set out in Appendix C should also permit proposals for coastal management and related activities so that these are not constrained by the designation.
If the proposal to extend Heights Quarry to the North West is permitted it will take out large areas of wetland, removing an important habitat for waders and for flood water storage, contrary to the aims of the Weardale NFM National Pilot project.
Where is the consideration of resources, renewables and creating local waste a recycling systems?
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Question 58 - Policy 51 - Meeting the Need for Primary Aggregates
Summary of main issues raised by representations
This policy recognises the importance of Durham's aggregates to the north east economy. No economic assessment appears to have been made to support this statement.
In terms of the wording and layout of the policy, it is considered this could be clearer, particularly in respect the level of provision that is being planned for in respect to both crushed rock and sand and gravel and in respect to the cross referencing of the locational criteria for each of the resources.
This policy fails the requirement of being succinct. The Policy is almost two pages long and appears to incorporate, strategic, locational and development management matters. It is unwieldy, difficult to interpret, is overly restrictive, lacks flexibility and is not planned positively. The Policy also presents competition issues in terms of requiring the submission of sales information.
The Policy relies heavily on the LAA and highlights projections based upon 10-year and 3-year sales averages. However, the local plan brings forward housing targets for Durham (circa 26,000 new homes) which is clearly relevant and in accordance with the NPPF 2018 paragraph 207 constitutes other relevant local information.
This policy is extensive and as such is difficult to interpret. It should be separated into two or possibly three individual Policies to provide greater clarity.
The third bullet point refers to preventing over provision. This phrase would appear to be at odds with para 4.15 of the plan which refers to housing targets not being a ceiling.
Support for the importance of full recovery of permitted reserves.
Magnesian Limestone - It is not clear if the landbank figures and production figures quoted include aggregate use and industrial use. Greater clarity is needed over sales and landbanks for minerals which supply both aggregates and industrial applications.
The National Trust would not support proposals for further mineral extraction within the safeguarded zone around Hawthorn Quarry shown in map C of the proposals map document as it would be inconsistent with the heritage coast designation.
The minerals and waste policies need to make clear that there may be unacceptable impacts which would not support additional extraction in sensitive locations, such as along the Durham Heritage Coast and its setting.
New water abstraction licensing requirements may limit reserves at depth at existing quarries. The Council's policy on Basal Permian sands is for the deepening of quarries.
Ggroundwater abstraction and the impact this may have on the extraction of sand from the floor of magnesian limestone quarry requirement.
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Question 58 - Policy 51 - Meeting the Need for Primary Aggregates
Summary of main issues raised by representations
The policy is supported in relation to the proposed support for the extension of Hulands Quarry. However the Heights Quarry extension is strategically important as a source of Carboniferous limestone and asphalt and is vital to the Weardale economy as acknowledged in the previous County Durham Plan Submission Draft Policy 61 (2014)
It is considered that there are a number of existing sites, covered by IDO or dormant permissions under the Environment Act 1995. It is considered that a paragraph needs to be included into this policy, or supporting text, which acknowledges the potential for them to be worked and if they come forward, the need for the Authority to be flexible in the view that they take.
Any existing, extended or new mineral site and particularly hard rock or sand and gravel sites will need to be restored.
Question 59 - Policy 52 - Brickmaking Raw Materials
Summary of main issues raised by representations
Northumberland County Council support the approach of the policy.
Gateshead Council supports the approach to clay provision in respect of the Union Brickworks (located in Birtley, Gateshead). The council will continue to work positively with County Durham in addressing the longer-term needs of the brickworks.
Support for the future supply, 25 years, of raw materials for brick manufacture in the county.
Additional wording is needed to take into account of: Mineral and waste developments, in particular those below the water table. Risk assessment to groundwater be assessed and managed in order to protect its quantity and quality.
The text should be clear on the level of adverse impact that is "unacceptable" and consistent with the hierarchical approach to the protection of nature conservation designations as detailed in Policies 43 to 45.
The policy and its accompanying description make no reference to the very energy intensive nature of brick manufacturing. The process involves considerable carbon emission.
Policy 52 Footnote (189) refers to maintaining a stock of permitted reserves of 25 years This footnote should be incorporated in to the policy to accord with the NPPF2018.
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Question 59 - Policy 52 - Brickmaking Raw Materials
Summary of main issues raised by representations
The text should be clearer on the level of adverse impact that is "unacceptable" and consistent with the hierarchical approach to the protection of nature conservation designations as detailed in Policies 43 to 45.
Question 60 - Policy 53 - Surface Mined Coal and Fire clay
Summary of main issues raised by representations
Northumberland County Council supports the approach of the policy.
The Coal Authority has no objection to this policy which sets out the criteria against which proposals for extraction of coal will be considered.
The draft Plan does not identify any areas in the county where the MPA consider coal extraction may be acceptable. In such circumstances i.e. a failure to carry out an assessment aimed at identifying areas suitable for future coal extraction as envisaged by paragraph 209(d), a criteria policy based approach is the next best thing. In the event that an approach which sought to identify areas where surface mining may be suitable was undertaken, Banks Mining would wish to see the approach recognise the importance of the coal reserves in the north west of the Durham coalfield as essential raw materials for industries in the UK.
The plan is therefore correct to acknowledge that it is for individual operators to determine the level of output they wish to aim for in light of market conditions. In such circumstances, it is therefore imperative that the MPA makes itself aware of and understands the particular requirements of the market(s) the operators are seeking to serve in order that it can give due weight as appropriate in the application of policy.
The future scale of working being should be linked to future demand for coal from key industrial sectors in the UK reflecting the particular suitability of coal from the Durham Coalfield for use as a raw material by these industries
Coal will continue to be used for generation and play an important role in the energy mix until 2025.
Government has laid out new rules that will force all the remaining 8 coal fired power plants to close by 2025, in an effort to meet UK carbon reduction obligations. This will result in disappearance of the UK market for coal by 2025. Beyond this date, there will be no place for coal mining in the UK, and this will be just a few years into the life of the County Durham Plan.
Support for the recognition in the plan of the key role surface mining of coal plays in securing the supply of brick making materials, in particular, fireclays, for use by local brickworks.
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Question 60 - Policy 53 - Surface Mined Coal and Fire clay
Summary of main issues raised by representations
This policy does not seem to reflect the Highthorn (Druridge Bay) appeal decision on the relevance of national climate change regulations to coal extraction.
Opencast coal extraction will tribute to climate change.
Reference to surface mined coal, such that it cannot be mined in County Durham should be removed
Leave coal in the ground and not to extract or burn this most dirty and damaging of all fossil fuels is in the national interest
There should be a requirement to ensure overall net environmental gains through high quality restoration and after use of all sites.
No amount of restoration following surface coal mining can replace the natural habitats which currently exist
Our countryside is of much more worth left in tact as a health, leisure and tourism resource. In fact, double the benefit can be gained from leaving coal in the ground and this rules out the harmful immediate effects of dust and pollutants as well as protecting local landscapes which are invaluable amenities for health promotional activities.
Experiences with County Durham's most recent open cast operation demonstrates that mining companies can, and do, ignore Section 106 contracts, which are signed agreements between developers and DCC with the intention of setting conditions or obligations to make operations acceptable.
Opencast coal extraction does not provide sustainable employment and should not be supported within the Durham Plan preferred options.
It is clearly in the "national interest" to leave coal in the ground and not to extract or burn this most dirty and damaging of all fossil fuels.
The financial compensatory benefits offered to local communities do not warrant the permanent damage caused to landscape, protected habitats, amenity and heritage.
The distinction between derelict and untouched or unimproved land is important. The later provides valuable habitats which encourage species diversity. It is questionable whether any opencast planning applications in County Durham have relied on or been approved on the strength of reclamation of derelict land.
Recent years have seen many coal companies go into liquidation. UK Coal in 2015 for example, just after they acquired planning permission to opencast in the Pont Valley.
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Question 60 - Policy 53 - Surface Mined Coal and Fire clay
Summary of main issues raised by representations
5.544 requires much stronger wording to reassure local communities that DCC will not be complicit in allowing mining companies to expand beyond any permitted remit
Clean renewables are the way forward not coal which should be left in the past and in the ground.
Overall this preferred option offers no support for the environment and does not address the rightly held concerns of local people. It is bias in favour of developers to an extent which leads me to question the motives behind the preferred option.
Question 61 - Policy 54 - Natural Building and Roofing Stone
Summary of main issues raised by representations
Northumberland County Council supports the proposed policy in principle.
Support the policy and note the predominance of locally quarried stone in the buildings of Barnard Castle within the context of this policy.
The policy states that "great weight being given in decisions to the conservation of natural beauty". In order to be consistent, the policy should also reflect the NPPF 2018 para 205 and recognise that great weight should be given to the benefits of mineral extraction. Insert additional bullet point to reflect the NPPF.
Within the AONB are many sites where extraction of stone materials may be required. The location of the materials is within the AONB and not elsewhere within the county.
Wording within paragraph 5.551 commits to guiding any new proposals to locations which lie outside of, and do not impact internationally and nationally important nature conservation sites.
The text should be clear on the level of adverse impact that is "unacceptable" and consistent with the hierarchical approach to the protection of nature conservation designations as detailed in Policies 43 to 45.
A target should be "to maintain a steady, adequate and diverse supply of natural building and roofing stone" to accord with the proposed policy. Insert the text within the target.
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Question 62 - Policy 55 - Reopening of Relic Natural Building and Roofing Stone Quarries
Summary of main issues raised by representations
Northumberland County Council supports the proposed policy in principle and it is considered to be consistent with the NPPF.
The text should be clear on the level of adverse impact that is "unacceptable" and consistent with the hierarchical approach to the protection of nature conservation designations as detailed in Policies 43 to 45.
Question 63 - Policy 56 - Safeguarding Mineral Resources
Summary of main issues raised by representations
Northumberland County Council supports the proposed policy and have no detailed comments to make on the extent of the areas identified.
The Coal Authority supports the inclusion of this policy which sets out criteria against which proposals within the defined Mineral Safeguarding Area will be considered. The Coal Authority is pleased to see that the information provide to the LPA has been used to assist in the identification of the Mineral safeguarding Area.
Support for the requirement for a Mineral Assessment to accompany all planning applications for non-mineral development within a Minerals Safeguarding Area unless exempt development or temporary in nature.
It is recommended that the Policies Map, in particular the inset maps, include the relevant Minerals Safeguarding Areas to provide a greater degree of clarity.
It is important to ensure that the mineral resources are not sterilised by development located adjacent to MSAs. It would therefore be appropriate to provide stand-off distances around the safeguarded resources
It would be logical to locate this policy consecutive to Policy 50. Map C is not clear enough to identify the "Exact extent of the safeguarded areas."
With regard to criteria c non-minerals "development of a temporary nature", care Should be taken regarding wind turbines as whilst they are considered temporary development their lifespan can be extensive i.e. 25 years or more and which may not be compatible the timescale for considering mineral working in the safeguarded area.
It is essential that the area of known potential reserves of high grade dolomite and magnesium limestone around Hawthorn Quarry are identified and safeguarded to ensure future development does not affect the reserves and potential future extraction in this location, mainly to the north and west of the existing site.
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Question 64 - Policy 57 - The Conservation and Use of High Grade Mineral Resources
Summary of main issues raised by representations
Support for the plan recognising the importance of the high grade mineral resources and specifically high grade dolomite mineral resources and reserves at Thrislington Quarry. The recognition in paragraph 5.560 of high grade deposits of magnesian limestone at Hawthorn Quarry is supported.
It is unclear if this is a general policy for High Grade Mineral Resources or a site specific mineral policy for Thrislington Quarry. Clarification sought as to what the council consider "High Grade Mineral Resources".
The text should be clearer on the level of adverse impact that is "unacceptable" and consistent with the hierarchical approach to the protection of nature conservation designations as detailed in Policies 43 to 45.
A quality restoration scheme is essential in determining new licencing and works. Restoration should focus on enhancing/restoring threatened/rare habitats and communities. Reference to be made to restoration across all items relation to mineral extraction.
The policy only makes reference to Thrislington Quarry East as the supplier of high grade dolomite throughout the Plan period. Preference to one high grade dolomite quarry over another (Hawthorn Quarry) which also has an extant planning permission is not sound, it is not justified, and does not provide an effective planning policy. Hawthorn Quarry is a latent supplier of a high grade mineral of national and local significance and should be included within Policy 57.
Question 65 - Policy 58 - Preferred Area for Future Carboniferous Limestone Working
Summary of main issues raised by representations
Northumberland County Council supports the proposed policy.
There are various references in the plan to Carboniferous Limestone, in Policy 51, on page 225 and in Policy 58. This is a rather disjointed approach and it is unclear what the overall policy for Carboniferous limestone is.
The proposed extension of Heights Quarry utilises the extraction and sale of Carboniferous limestone and sandstone .The policy should support the storage and recycling of road planings at sites with asphalt plants.
The Policy needs to include the Heights Quarry western extension as previously supported by the County Durham Plan Submission Draft 2014 ,Policy 61.
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Question 65 - Policy 58 - Preferred Area for Future Carboniferous Limestone Working
Summary of main issues raised by representations
If the proposal to extend Heights Quarry to the North West it will take out large areas of wetland, removing an important habitat for waders and for flood water storage, contrary to the aims of the Weardale NFM National Pilot project. It would also further undermine the hydraulic function of Park Burn, which flows directly west of the quarry and whose wetland headwaters will be destroyed.
The RSPB is disappointed in the lack over-arching policy wording which sets out requirements for the restoration and aftercare of minerals proposals. This would be consistent with Objective 16 of the Plan. However, note this may be addressed in the Minerals and Waste Policies and Allocations Document. High quality restoration, secured by appropriate planning obligations would ensure longer term management and aftercare, deliver multiple benefits including the protection, strengthening and enhancing ecological networks
A quality restoration scheme is essential in determining new licencing and works. Restoration should focus on enhancing/restoring threatened/rare habitats and communities. Reference to be made to restoration across all items relation to mineral extraction.
Question 66 - Policy 59 - Strategic Area of Search to the South of Todhills Brickworks
Summary of main issues raised by representations
Northumberland County Council supports the proposed policy.
Restructure the Minerals section to put like matters together.
Environmental issues must be addressed.
Paragraph 5.568 provides further guidance on phasing and restoration, which seems to suggest a return to agricultural use which nevertheless provides environmental benefits. The RSPB considers that restoration plans should not automatically assume restoration to agriculture. In many cases it should be possible to restore a mineral site for nature conservation whilst still safeguarding the long term potential of the best and most versatile agricultural land and conserving soil resources.
The proposed sites is crossed or in close proximity to National Grid infrastructure.
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Question 67 - Policy 60 - Waste Management Provision
Summary of main issues raised by representations
Northumberland County Council supports the proposed policy.
Waste is an issue where potential strategic cross boundary planning issues between County Durham and Northumberland have been identified. There has been, and continues to be, ongoing cooperation between the two authorities on this issue.
Highways England supports this policy which continues to seek to minimise the effects of transporting waste including by locating proposals in close proximity to arisings where possible.
Waste management policies and the supporting text should be separated out from minerals policies.
Innovative ways of using waste should be supported and encouraged particularly energy generation.
Where is the consideration of resources, renewables and creating local waste a recycling systems?
The trend in general for many years has been for residents to recycle, for businesses to use waste products as raw materials for other business activities etc rather than just dump waste, building up future problems, incurring cost etc. There is no acknowledgement of this in the plan.
Despite the public being alerted to "plastic problem" worldwide, there is no mention of this at all and precious little on consumer waste at all.
What is the current status on household and local recycling centres performance trend with targets.
What is the DCC target each year, what are the plans to improve, what will success look like, what will be expected of residents?
Somewhere in the plan monitoring and targets should be clearly identified. They should inform on performance and guide residents on better practice to reduce and re-cycle waste.
Proposals which involve the use of inert waste for the restoration of mineral workings can only accept material which is not capable of being recycled or re-used.
The deposit of inert waste in mineral workings for the purposes of restoration should be considered a re-use of that material and therefore be viewed positively.
58 County Durham Plan Preferred Options Consultation Feedback Report Preferred Options Consultation Feedback Report
Question 67 - Policy 60 - Waste Management Provision
Summary of main issues raised by representations
It should be remembered that only waste which is not capable of being recycled or re-used can deposited in a landfill. Given the type of inert material currently received at landfill sites, it is difficult to envisage rates of recovery increasingly significantly if at all.
Question 68 - Policy 61 - Location of New Waste Facilities
Summary of main issues raised by representations
Northumberland County Council supports the proposed policy.
Priority should be to seek alternative technology that is available for recycling, not just find another landfill site.
Where is the consideration of resources, renewable' s and creating local waste a recycling systems?
Preferred Options Consultation Feedback Report County Durham Plan 59 Appendix A- Preferred Options Statement of Consultation Site Allocations Contents
Representations made on sites allocated in the County Durham Plan Preferred Options and Council responses 1 H1 Gilesgate School 4
2 H2 North of Hawthorn House 8
3 H3 South of Potterhouse Terrace 11
4 H4 Former Skid Pan, Aykley Heads 14
5 H5 Sniperley Park 17
6 H6 Sherburn Road 26
7 H7 Cook Avenue 32
8 H8 Cook Avenue North 35
9 H9 Land Adjacent to Woodlands 38
10 H10 Arizona Chemicals 41
11 H11 Former Roseberry 43
12 H12 Brackenbeds Lane 46
13 H13 Former Harelaw School 48
14 H14 Former Annfield Plain Community Centre 50
15 H15 Former Swimming Baths 52
16 H16 Former Blackfyne School 55
17 H17 East of Muirfield Close 60
18 H18 Laurel Drive 65
19 H19 South of Knitsley Lane 70
20 H20 Rosedale Avenue 81
21 H21 Chaytor Road 85
Appendix A- Preferred Options Statement of Consultation Site Allocations Contents
22 H22 High West Road 87
23 H23 Former Spennymoor Day Centre 99
24 H24 Former Tudhoe Grange Lower School, Durham Road 103
25 H25 Former Tudhoe Grange Upper School, St Charles Road 107
26 H26 Land to East of Ash Drive 111
27 H27 Former Etherley Lane Depot 114
28 H28 Former Chamberlain Phipps 117
29 H29 Bracks Road 120
30 H30 Copelaw 123
31 H31 Eldon Whins 126
32 H32 Land at Woodham College 128
33 H33 Cobblers Hall 131
34 H34 Land at Eldon Bank Top 134
35 H35 Adjacent Hunwick Primary School 136
36 H36 North Blunts 139
37 H37 Seaham Colliery 141
38 H38 Former Seaham School 144
39 H39 Camden Square 147
40 H40 Murton Colliery 150
41 H41 Dunelm Stables 153
42 H42 Grove Works 155
43 H43 Land off Leazes Lane 158
Appendix A- Preferred Options Statement of Consultation Site Allocations H1 Gilesgate School 1
Appendix A- Preferred Options Statement of Consultation Site Allocations 3 1 H1 Gilesgate School
H1 Gilesgate School
Level of support 1 representation supported the allocation.
Reasons for support A good use of derelict land.
Level of objection 6 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response
Greenfield Sites Too many greenfield sites in the plan. Supporting The Rationale for Housing Allocations document developers not the public. sets out the methodology used to select housing allocations.
The document sets out the approach which was taken which was briefly:
Using the list of settlements in the order identified in the Settlement Study we identified SHLAA Brownfield sites in each monitoring area that were suitable, deliverable and viable. Viability is determined in the Local Plan Viability Study If the list of brownfield sites was insufficient to meet the residual for allocation for that
4 Appendix A- Preferred Options Statement of Consultation Site Allocations H1 Gilesgate School 1
area the exercise was repeated but this time suitable, deliverable, viable greenfield sites were identified; If this was still insufficient the remaining houses were allocated to other monitoring areas where there were additional suitable, deliverable sites. It was only once these additional suitable deliverable sites were exhausted that the Green Belt was considered.
Empty Homes How many empty homes there are currently that theBringing empty homes back in to use is a key council could invest in. priority for the council. We also recognise the issues experienced in some areas as a result of concentrations of vacant, underused properties and will continue to work with all relevant agencies and in particular Homes England to pursue funding that will allow as many properties as possible to be brought back into use.
Infrastructure Community centre should be a requirement to Through the associated Infrastructure Delivery replace the one that was demolished. Plan the Plan recognises the need to ensure that all new development is supported by More residents yet less facilities as loss of school, appropriate infrastructure provision and community centre and playing fields. mechanisms are embedded within the policy framework to require this of developers where applicable. Healthy Communities The site is considered to be a playing field or wouldA new Playing Pitch Strategy (PPS) for County prejudice the use of a playing field. Durham is in preparation and will update and Loss of all-weather tennis courts, football pitch andreplace the PPS and associated Playing Pitch basket ball courts. Action Plans from 2013. The PPS will assess the current and projected supply and demand for pitches, including a technical analysis of pitch quality and usage levels. The findings of these
Appendix A- Preferred Options Statement of Consultation Site Allocations 5 1 H1 Gilesgate School
assessments will provide the evidence of where provision needs further consideration and/or to be protected/enhanced and inform the development of both strategic and sport specific recommendations. The strategy will set out site by site recommendations based on pre-determined areas aligned to the County Durham Plan (5 delivery areas).
The issue regarding this site concerns the loss of playing fields, in lieu of evidence which shows that there is a surplus of playing pitches across the respective areas. In this case the playing pitch will be retained.
Amenity Design of new housing means estates are crampedThe Plan sets down policy requirements to and properties overlooked. ensure development is well-designed and includes sufficient amenity and privacy for new and existing residents. A new Supplementary Planning Document is being prepared to set down adequate and consistent privacy/amenity distances throughout the County.
6 Appendix A- Preferred Options Statement of Consultation Site Allocations H2 North of Hawthorn House 2
Appendix A- Preferred Options Statement of Consultation Site Allocations 7 2 H2 North of Hawthorn House
H2 North of Hawthorn House
Level of support 1 representation neither objected to or supported the allocation.
Reasons for Stated that the site is best suited to bungalows. representations
Level of objection 3 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response
Highways Queries over where the access will be. Concerns The site has been assessed by Highways as over increased traffic to the Arnison centre and part of the site selection process, no issues Framwellgate Moor. Vehicles parking on the have been identified. Highways access is footpaths and mounting the pavement raising obtainable from St Godrics Close. concerns over pedestrian safety. Concerns about the junctions on Lanchester Road and at the bottom of Pity Me adjoining the A167. Greenfield Land There should be no use of greenfield land. The Rationale for Housing Allocations document sets out the methodology used to select housing allocations.
The document sets out the approach which was taken which was briefly:
8 Appendix A- Preferred Options Statement of Consultation Site Allocations H2 North of Hawthorn House 2
Using the list of settlements in the order identified in the Settlement Study we identified SHLAA Brownfield sites in each monitoring area that were suitable, deliverable and viable. Viability is determined in the Local Plan Viability Study If the list of brownfield sites was insufficient to meet the residual for allocation for that area the exercise was repeated but this time suitable, deliverable, viable greenfield sites were identified; If this was still insufficient the remaining houses were allocated to other monitoring areas where there were additional suitable, deliverable sites. It was only once these additional suitable deliverable sites were exhausted that the Green Belt was considered.
Appendix A- Preferred Options Statement of Consultation Site Allocations 9 H3 South of Potterhouse Terrace 3
Appendix A- Preferred Options Statement of Consultation Site Allocations 10 H3 South of Potterhouse Terrace 3
H3 South of Potterhouse Terrace
Level of support 1 representations supported the allocation.
Reasons for support Agree with the allocation.
Level of objection 3 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response
Highways Parking and access is already an issue on the site. The site has been assessed by Highways as Concerns over increased traffic to the Arnison centrepart of the site selection process, no issues have and Framwellgate Moor. Vehicles parking on the been identified. Highways access is obtainable footpaths and mounting the pavement raising from St Godrics Close. Access is possible concerns over pedestrian safety. Concerns about through realignment of the cul de sac head at the junctions on Lanchester Road and at the bottomThe Forge to continue the carriageway into the of Pity Me adjoining the A167. development site.
Infrastructure Ongoing problems with the sewage on the estate atThrough the associated Infrastructure Delivery present. Plan the Plan (IDP) recognises the need to ensure that all new development is supported by appropriate infrastructure provision and mechanisms are embedded within the policy framework to require this of developers where applicable. Sewage and Water Management
Appendix A- Preferred Options Statement of Consultation Site Allocations 11 3 H3 South of Potterhouse Terrace
are recognised in the IDP as critical components of the infrastructure required to support new development.
12 Appendix A- Preferred Options Statement of Consultation Site Allocations H4 Former Skid Pan, Aykley Heads 4
Appendix A- Preferred Options Statement of Consultation Site Allocations 13 4 H4 Former Skid Pan, Aykley Heads
H4 Skid Pan
Level of support 3 representations supported the allocation.
Reasons for support It was commented that the site should have been approved as part of the former Policy Headquarters site. The site promoter is seeking a larger area than that identified in the Plan. The three additional parcels have been assessed through the Strategic Housing Land Availability Assessment (SHLAA).
Level of objection 9 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response
Impact on the Green Belt The site promoter is seeking three additional parcelsThe sites have been deemed unsuitable for to the site allocation. housing development owing to the unacceptable impact on Hoppers Wood. Open, recreational uses should be proposed insteadThe former skid pan is an area of previously given its Green Belt status. developed land within the built up area of Durham City. Whilst the site is within the Green Wider distribution of small, brownfield sites would Belt, the skid pan area s a derelict, redundant be more sustainable as well as allowing the growthsite which until recently was used by Durham and regeneration of local economies. Constabulary as a skid pan and car park. As such would form an exception for decision There is no evidence of exceptional circumstancesmaking under the National Planning Policy and no record of anti social behaviour having beenFramework which would allow limited infilling or reported to the police. the partial or complete redevelopment of previously developed land, whether redundant or in continuing use which would not have a greater impact on the openness of the Green
14 Appendix A- Preferred Options Statement of Consultation Site Allocations H4 Former Skid Pan, Aykley Heads 4
Belt or would not cause substantial harm to the openness, where the development would re-use previously developed land and contribute to meeting an identified affordable housing need. The Green Belt assessment concluded that the site did not perform strongly against the Green Belt and its removal would allow a comprehensive design solution to prevent it becoming an unsightly area of redundant urban land which could attract future anti-social behaviour.
Environment Avoid visual impact on the nearby nature reserve. Any possible visual or landscape impacts will be need to minimised through appropriate mitigation and the avoidance of encroachment into Hoppers Wood. Ensure that any building work does not impact on the Aykley Heads nature reserve.
The Skid Pan site is a popular recreation route for dog walkers and the site is undergoing "re-wilding".
Appendix A- Preferred Options Statement of Consultation Site Allocations 15 H5 Sniperley Park 5
Appendix A- Preferred Options Statement of Consultation Site Allocations 16 H5 Sniperley Park 5
H5 Sniperley Park
Level of support 3 representation supported the allocation.
Reasons for support In addition to the site promoters, support was given to the site as being the best site to accommodate housing in and around Durham City.
Level of objection 82 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response
Impact on the Green Belt The site is unsuitable in the Strategic Housing LandA comprehensive Green Belt assessment has Availability Assessment owing to Green Belt. been undertaken which seeks to determine the role the Green belt plays against each of the five Wish to retain the special character of Durham as purposes including: checking the unrestricted far as possible. sprawl of built up areas and preserving the The Green Belt seeks to prevent sprawl. setting and special character of historic towns.
The northern boundary of the site along Potterhouse and Trout's Lane will preclude any sprawl further north than this boundary. Masterplanning of the site will ensure that the layout and design is in a manner which will reduce any perceived sprawl. This site has been identified as having the greatest benefits and also retain the special character of the city.
Appendix A- Preferred Options Statement of Consultation Site Allocations 17 5 H5 Sniperley Park
Exceptional No demonstration of a genuine need and is too The housing need figure is not determined on Circumstances large and in the wrong location. employment projections. The housing need is The scale of this development is based on identified for county Durham and the Exceptional aspirational and flawed employment projections forCircumstances paper sets out the range of Durham City. alternatives that have been considered in light Houses would be unneeded owing to the length ofof the preferred chosen spatial strategy for the time it takes to sell properties on Newton Hall and Sustainable Communities option. The spatial Framwellgate Moor. distribution already considers the location of Rather than deleting Green Belt, the County existing planning permissions. In line with Durham Plan should be reviewed in year 2024 / 25National Planning Policy Framework, sustainable to determine whether or not allocations and sites patterns of development have been taken into with planning permission are being delivered. account. Consideration has been given to Sniperley Park should be safeguarded for release channelling development towards the urban area beyond 2025. of Durham City (within the inner Green Belt The positioning of 1900 homes is disproportionateboundary), towards towns and villages inset at 40% of the total across the whole of the county. within the Green Belt and towards locations beyond the Green Belt. Completion rates around Durham City give an indication that sales for properties are buoyant indicating a demand for properties int he Durham City locality.
The chosen spatial strategy has had regard to the level of planning permissions which currently exist within settlements of Bearpark, Consett, Crook, Peterlee (Horden), Seaham, West Durham and Thornley. All these settlements included site allocations. Chester-le-Street is also constrained by Green Belt and other environmental designations but does not offer the same employment opportunities as Durham City.
Infrastructure Sniperley Park would cause gridlock on local roadsThe Infrastructure Delivery Plan sets out the and exacerbate congestion. infrastructure requirements associated with development proposed within the County
18 Appendix A- Preferred Options Statement of Consultation Site Allocations H5 Sniperley Park 5
Sniperley Park would put unreasonable pressure Durham Plan. As a result, the policy sets a on schools and nurseries. requirement for a new local centre which will act as a focus for community activity including retail Housing is only being proposed to fund the relief convenience and an allowance for A2, A3 and roads. A4 units to facilitate a viable and vibrant community. This should also include a building Concern about the impact on local services / which is suitable for the use of a health centre. amenities including at the doctor's surgery, accidentA primary school will be required together with and emergency hospital. suitable playing and open space facilities. A GP surgery should be developed on site. Concern about the capacity for primary and Traffic modelling demonstrates that the build out secondary education. of Sniperley Park will exacerbate existing traffic Community buildings including a community centre,issues on the A167 therefore the development leisure facilities and a church building would be of the site will require additional capacity required. introduced to the highway network by the For a playing pitch strategy (PPS) to be consideredWestern Relief Road. Detailed transport up-to-date, it should have been undertaken within assessments will be required to show how the the last three years. County Durham's overarching build out of the site will relate to the completion PPS was adopted in 2014, then the 14 Playing Pitchof the Western Relief Road. Action Plans which sit beneath it were completed during 2015. The PPS coverage for County Durham The masterplan developed for Sniperley Park will become out of date as the Plan progresses to demonstrates where additional road adoption. Where a PPS is out of date Sport Englandimprovements will be made to ensure the considers that it is not possible for a Plan to be ableupgrading of the Pity Me roundabout and an to justify allocations which seek the development ofalternative route to the Blacky Boy roundabout. playing field sites, unless it is proposed that the This will ensure that the junctions and playing field be replaced as part of the plan. Formerassociated roads will be able to accommodate Roseberry Comprehensive School allocation wouldadditional demand. The expansion of the Park prejudice the use of a playing field in lieu of evidenceand Ride and safe and attractive cycleways and which shows that there is a surplus of playing footpaths will be also required as part of the pitches across the respective areas, which is not development. The Park and Ride is already considered to accord with paragraph 74 of the NPPFsubsidised to ensure lower charges to users. or Sport England's Playing Field policy. The policy includes reference to the need to
Appendix A- Preferred Options Statement of Consultation Site Allocations 19 5 H5 Sniperley Park
Public transport will be required including the Parkensure Sniperley Park is able to achieve and Ride. sustainable and cohesive communities enabling Sniperley Park cannot be the justification for the connections to the east of the A167. Western Relief Road. Sniperley Park should not be developed until both A new Playing Pitch Strategy (PPS) for County the Western Relief Road and the Northern Relief Durham is in preparation and will update and Road are operational. replace the PPS and associated Playing Pitch Sniperley Park should not be developed until the Action Plans from 2013. The PPS will assess Northern Relief Road is operational. the current and projected supply and demand The road infrastructure along the B6532 Sacristonfor pitches, including a technical analysis of pitch Road is inadequate and this is the only exit for quality and usage levels. The findings of these Westcott Drive along to the Blacky Boy roundabout.assessments will provide the evidence of where Potterhouse Lane and Trout's Lane would be provision needs further consideration and/or to inadequate and would not allow for free flowing be protected/enhanced and inform the traffic. development of both strategic and sport specific There should be lower charges for the Park and recommendations. The strategy will set out site Ride to encourage its wider use. by site recommendations based on predetermined areas aligned to the County The speed limit along the A167 should be reduced Durham Plan (five delivery areas). The current to ensure that people can cross the road safely. Durham City Playing Pitch Action Plan indicates Fyndoune School has recently closed. that there is an adequate supply of senior football pitches in the Durham City area even after considering the loss of pitches at Sniperley Park. There is however a requirement to provide additional mini soccer pitches to meet latent demand from teams based within the area should their existing central league venues in Sunderland cease, or change to home and away format. Whilst the PPAP recommends mitigating latent demand by the conversion of surplus senior pitches on specified sites, on a 1:4 ratio, it will be necessary to incorporate some additional mini pitches at the new primary
20 Appendix A- Preferred Options Statement of Consultation Site Allocations H5 Sniperley Park 5
school/s which can be used both by the school and by community teams via a formal community use agreement.
There are currently no proposals to close the Fyndoune School.
Environment Avoid visual impact on the nearby nature reserve. The northern boundary of the site is existing roads at Potterhouse and Trouts Lane which will prevent further encroachment towards Sacriston. Mitigation and compensatory improvements will Green Spaces should be retained and protected. be required on Sniperley Park. A detailed This site is of natural beauty and needs to alleviatemasterplan has been developed to ensure that the impact on the wildlife and nature reserve. the need for mitigation is identified. The extent Deer, buzzards, owls, bats and woodpeckers are of the linear park has been identified to ensure some of the species found on the site. that opportunities to enhance the nature reserve, There are a number of ancient trees on the site. woodland and non-designated heritage asset Concern about encroachment towards Sacriston. are identified. The impact on the setting of Sniperley Hall and Farm will be detrimental which will be difficult to The policy itself also sets out the requirement mitigate when the development wraps around muchto design development in the vicinity of of of the western and southern boundary of the HistoricSniperley Hall and Farm will have regard to their Park and Garden of local interest. character and setting owing to the recognition Sniperley Park is on good agricultural land. of the area as an Historic Park and Garden of local interest. This could include through the provision of open space and lower housing densities.
An assessment of agricultural land has been undertaken on Sniperley Park which confirms that the site is on Grade 3 agricultural land. However it is considered that the benefits of allocating Sniperley Park outweigh this.
Appendix A- Preferred Options Statement of Consultation Site Allocations 21 5 H5 Sniperley Park
Employment Insufficient jobs to support new development Business Register and Employment Survey meaning people will commute to other cities and Data, 2016, evidences that Durham City cause pollution and create a ghost town. contains over 20% of total workplace employment within the county. Furthermore, there are proposals to create further employment opportunities around Aykley Heads.
Site Layout Houses should be 1 bedroom rather than executive A detailed masterplan has been developed to homes with 2 / 3 cars. provide details regarding landscaping along the Further land should be identified within the site A167 and along Potterhouse Lane in the vicinity allocation boundary. of the household waste recycling centre and the Landscaping along the A167 should be retained topoultry farm. The extent of the linear park has reduce any noise and dust which could impact on also been identified to ensure that opportunities existing properties. to enhance the nature reserve, woodland and Need to consider amenity issues resulting from thenon-designated heritage asset are identified. poultry farm. The location of the country park needs to be The development will be expected to provide for defined. a mix of house types which will meet need Older persons homes should first give first refusal including affordable housing and older persons to developers of specialist housing for elderly, housing. disabled and vulnerable people. Additional land within the vicinity of Sniperley Strongly urge that 4/DU/73 to the north of Witton Park has been considered but no Exceptional Grove is not included within the site allocation. Circumstances have been identified.
There are no proposals to remove land to the north of Witton Grove from the Green Belt.
Residential Amenity Concern about the construction phase and the A Health Impact Assessment has been impact of construction vehicles on residential undertaken for the County Durham Plan which amenity and health. has considered issues arising from the Residential amenity resulting from additional trafficconsultation on the impact on human health. flows. The process has included recommendations to Amenity issues for existing residents owing to the ensure that operational hours for construction Park and Ride expansion. are in place as part of the determination of any
22 Appendix A- Preferred Options Statement of Consultation Site Allocations H5 Sniperley Park 5
Deletion of the Green Belt will change the characterfuture planning application. The process has of the Witton Grove including through noise, air andalso endorsed the requirement to ensure there light pollution. is sustainable transport measures including cycling, parking and walking provision.
There are no proposals to remove land to the north of Witton Grove from the Green Belt.
Alternatives Brasside Stores, previously developed site in close proximity to Durham City, which can be built in a manner which safeguards the ecological interest of The Exceptional Circumstances paper sets out the site and delivers mitigation and enhancement. the range of alternatives that have been considered in light of the preferred chosen Previously developed sites in Sherburn Road, spatial strategy for the Sustainable Communities Bearpark, Consett, Crook and Thornley should be option. In line with National Planning Policy considered instead Framework, sustainable patterns of development have been taken into account. Consideration has been given to channelling development towards the urban area of Durham City (within There is a brownfield in Esh Winning which shouldthe inner Green Belt boundary), towards towns be considered. and villages inset within the Green Belt and towards locations beyond the Green Belt. Sniperley Park should include a retirement village which would result in less traffic and would benefit The chosen spatial strategy has had regard to from the local amenities and the park and ride. the level of planning permissions which currently exist within settlements of Bearpark, Consett, Development instead should be identified around Crook, Peterlee (Horden), Seaham, West Horden because of the rail station. Durham and Thornley. Chester-le-Street is also constrained by Green Belt and other Alternative sites in West Durham. environmental designations but does not offer Wider dispersal option is preferable. the same employment opportunities as Durham Alternative sites should be identified at Crook, City. Chester-le-Street or Seaham.
Appendix A- Preferred Options Statement of Consultation Site Allocations 23 5 H5 Sniperley Park
Brasside Stores has been considered as part of this process, however has not been deemed a suitable alternative given the ecological and heritage constraints which exist on the site. In addition, given the site's detachment from the settlement to the north of Frankland prison, there are less opportunities for sustainable movements into the city.
24 Appendix A- Preferred Options Statement of Consultation Site Allocations H6 Sherburn Road 6
Appendix A- Preferred Options Statement of Consultation Site Allocations 25 6 H6 Sherburn Road
H6 Sherburn Road
Level of support 4 Representation supported the allocation.
Reasons for support The site promoter supports the identification of the site allocation. In addition, support is given to the development of agricultural land which is of low amenity and wildlife value and given the site's proximity to employment uses.
Level of objection 22 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response
Impact on the Green BeltThe Green Belt was established around Durham A comprehensive Green Belt assessment has City in order to protect its historic setting and been undertaken which seeks to determine the character. role the Green belt plays against each of the five purposes including: checking the unrestricted The Green Belt seeks to prevent sprawl. sprawl of built up areas and preserving the setting and special character of historic towns. The exceptional circumstances have not been demonstrated. Masterplanning of the site will ensure that the layout and design is in a manner which will reduce any perceived sprawl. This site has been identified as having the greatest benefits and also retain the special character of the city.
26 Appendix A- Preferred Options Statement of Consultation Site Allocations H6 Sherburn Road 6
It was established on the full knowledge that it wouldThe development of Sherburn Road will ensure in due course constrain the future development andthat there is sufficient recreational provision outward sprawl of the City. included and will also seek to ensure beneficial The site should be used for recreational uses. enhancements providing opportunities for green infrastructure beyond the site boundary.
Site Layout The site promoter is seeking a range of between 420 and 480 dwellings. The yield of 420 is considered to be appropriate The site will become an area for student housing. number of dwellings for the site, having taken into account the need for open space, landscaping and the design and layout of the site.
The County Durham Plan includes a policy specifically for Durham University Development, Purpose Built Student Accommodation and Houses in Multiple Occupation. The council monitors the spatial concentrations of student properties across Durham City as one of the areas we consider as part of our ‘Annual Monitoring Report’ (AMR). This is monitored through the use of use of council tax data and note the concentrations of such properties by postcode area. It is through this process where we would consider whether the evidence would support the creation of an additional Article 4 Direction.
Infrastructure The highways infrastructure is already under considerable pressure and will be made worse by the additional traffic. Whilst this site would have good pedestrian, cycle and public transport links, the traffic signals Concern that highway access will not be achievableat the junction with Dragon Lane would not have regarding two highways junctions. capacity for extra traffic from this direction.
Appendix A- Preferred Options Statement of Consultation Site Allocations 27 6 H6 Sherburn Road
There is the potential for a bottleneck being created.However following a meeting between the The current volume of traffic is heavy on the A181 Highways Authority and the proposed developer, and improvements at Gilesgate roundabout there iswhich the proposed access onto the A181 and often queuing down Gilesgate Bank along to through the existing Sherburn Road estate is Sherburn Road and Sunderland Road. not the council's preferred access route it was Traffic will increase further increase at the traffic agreed that the proposal is a workable solution. light junction into Dragon Lane. Residential Amenity Impact of additional traffic on residential amenity. A Health Impact Assessment has been undertaken for the County Durham Plan which has considered issues arising from the consultation on the impact on human health. The process has included recommendations to ensure that operational hours for construction are in place as part of the determination of any future planning application. The process has also endorsed the requirement to ensure there is sustainable transport measures including cycling, parking and walking provision.
Environment Green spaces are important and encouraging Sherburn Road will be subject to a wildlife and providing an enhanced quality of life. masterplanning exercise which will ensure there are opportunities for compensatory improvements to the remaining Green Belt including the improvement of ecosystems including Old Durham Beck and access linking through to Pelaw Woods and the city centre.
Concern for the wildlife including the rabbits. In terms of protected species, surveys and a detailed desk study have determined that: The majority of the site is considered as having low potential for supporting breeding birds as the dominant habitat is arable land, which is considered poor for many species of breeding bird. The field margins around the arable land may be suitable, however, for some species of
28 Appendix A- Preferred Options Statement of Consultation Site Allocations H6 Sherburn Road 6
ground nesting birds. There is one tree on site that has features suitable for roosting bats. No other habitats or features are considered to be suitable for roosting bats, although the hedgerows across the site and around the boundaries of the site may provide suitable habitat for foraging bats or commuting bats and due to the overall balance of the habitat types and previous and current land use it is considered that reptiles are unlikely to be present on site.
Sniperley Park is on good agricultural land. An assessment of agricultural land has been undertaken on Sniperley Park which confirms that the site is on Grade 3 agricultural land. However it is considered that the benefits of allocating Sniperley Park outweigh this. Alternative Sites Wider dispersal option is preferable. The housing need figure is not determined on Brasside Stores employment projections. The housing need is The positioning of 1900 homes is disproportionateidentified for county Durham and the Exceptional at 40% of the total across the whole of the county. Circumstances paper sets out the range of Development instead should be identified around alternatives that have been considered in light Horden because of the rail station. of the preferred chosen spatial strategy for the Alternative sites in West Durham. Sustainable Communities option. The spatial distribution already considers the location of existing planning permissions. In line with National Planning Policy Framework, sustainable patterns of development have been taken into account. Consideration has been given to channelling development towards the urban area of Durham City (within the inner Green Belt boundary), towards towns and villages inset within the Green Belt and towards locations beyond the Green Belt. Completion rates around
Appendix A- Preferred Options Statement of Consultation Site Allocations 29 6 H6 Sherburn Road
Durham City give an indication that sales for properties are buoyant indicating a demand for properties in the Durham City locality.
The chosen spatial strategy has had regard to the level of planning permissions which currently exist within settlements of Bearpark, Consett, Crook, Peterlee (Horden), Seaham, West Durham and Thornley. Chester-le-Street is also constrained by Green Belt and other environmental designations but does not offer the same employment opportunities as Durham City.
Brasside Stores has been considered as part of this process, however has not been deemed a suitable alternative given the ecological and heritage constraints which exist on the site. In addition, given the site's detachment from the settlement to the north of Frankland prison, there are less opportunities for sustainable movements into the city.
30 Appendix A- Preferred Options Statement of Consultation Site Allocations H7 Cook Avenue 7
Appendix A- Preferred Options Statement of Consultation Site Allocations 31 7 H7 Cook Avenue
H7 Cook Avenue
Level of support 3 representations supported the allocation.
Reasons for support It was commented that the development of 200 houses in Bearpark was agreed with. Partially agreed that Bearpark needs more affordable housing.
Level of objection 5 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response Infrastructure Section 106 money from the site should be Through the associated Infrastructure Delivery Plan spent within the parish not towards the the Plan recognises the need to ensure that all new western relief road as this will not benefit thedevelopment is supported by appropriate parish. infrastructure provision and mechanisms are Section 106 money from the site towards theembedded within the policy framework to require this western relief road and widening of Colliery of developers where applicable. Road is not justified. Western Relief Road not supported therefore the housing is not supported as this is part of the road proposals. Employment Concern over the loss of employment land, Given the level of vacancies on the site, it was and would like to see this relocated within theconsidered that the employment site was no longer village/parish. performing its function and therefore in accordance with the evidence within the Employment Land Review, the Plan no longer protects the site.
32 Appendix A- Preferred Options Statement of Consultation Site Allocations H7 Cook Avenue 7
Highways Traffic problems at the junction of Colliery The site has been assessed by Highways as part of Road should be adequately dealt with. the site selection process, highway improvements would be required on Colliery Road, which would be dealt with at the planning application stage. Distribution of Housing Although it is agreed Bearpark needs more The Rationale for Housing Allocations document sets affordable housing, there are non greenfield out the methodology used to select housing sites in the area that could be developed. allocations. Sites should be allocated in Lanchester rather than Bearpark and Langley Park, as LangleyThe document sets out the approach which was taken Park scores higher in the settlement study. which was briefly: Using the list of settlements in the order identified in the Settlement Study we identified SHLAA Brownfield sites in each monitoring area that were suitable, deliverable and viable. Viability is determined in the Local Plan Viability Study If the list of brownfield sites was insufficient to meet the residual for allocation for that area the exercise was repeated but this time suitable, deliverable, viable greenfield sites were identified; If this was still insufficient the remaining houses were allocated to other monitoring areas where there were additional suitable, deliverable sites. It was only once these additional suitable deliverable sites were exhausted that the Green Belt was considered.
Appendix A- Preferred Options Statement of Consultation Site Allocations 33 H8 Cook Avenue North 8
Appendix A- Preferred Options Statement of Consultation Site Allocations 34 H8 Cook Avenue North 8
H8 Cook Avenue North
Level of support 2 representations supported the allocation.
Reasons for support It was commented that the development of houses in Bearpark was agreed with. Partially agreed that Bearpark needs more affordable housing.
Level of objection 2 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response Infrastructure Section 106 money from the site should be Through the associated Infrastructure Delivery spent within the parish not towards the Plan the Plan recognises the need to ensure western relief road as this will not benefit thethat all new development is supported by parish. appropriate infrastructure provision and Seek assurance that there will be mechanisms are embedded within the policy contributions to the local road network framework to require this of developers where improvements. applicable. Western Relief Road not supported therefore the housing is not supported as this is part of the road proposals. Housing Distribution Although it is agreed Bearpark needs more The Rationale for Housing Allocations affordable housing, there are non greenfielddocument sets out the methodology used to sites in the area that could be developed. select housing allocations. Sites should be allocated in Lanchester rather than Bearpark and Langley Park, as LangleyThe document sets out the approach which Park scores higher in the settlement study. was taken which was briefly: Using the list of settlements in the order identified in the Settlement Study we identified SHLAA Brownfield sites in each monitoring area that were suitable, deliverable and viable. Viability is determined in the Local Plan Viability Study
Appendix A- Preferred Options Statement of Consultation Site Allocations 35 8 H8 Cook Avenue North
If the list of brownfield sites was insufficient to meet the residual for allocation for that area the exercise was repeated but this time suitable, deliverable, viable greenfield sites were identified; If this was still insufficient the remaining houses were allocated to other monitoring areas where there were additional suitable, deliverable sites. It was only once these additional suitable deliverable sites were exhausted that the Green Belt was considered.
36 Appendix A- Preferred Options Statement of Consultation Site Allocations H9 Land Adjacent to Woodlands 9
Appendix A- Preferred Options Statement of Consultation Site Allocations 37 9 H9 Land Adjacent to Woodlands
H9 Land Adjacent to Woodlands
Level of support 0 representations supported the allocation.
Reasons for support
Level of objection 4 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response
Housing Distribution The site is thought to be in an The Rationale for Housing Allocations document sets out the unsustainable location. Small dispersedmethodology used to select housing allocations. sites are favoured rather than large estates. The document sets out the approach which was taken which was briefly: Sites should be allocated in Lanchester rather than Bearpark and Langley Park, Using the list of settlements in the order identified in the as Langley Park scores higher in the Settlement Study we identified SHLAA Brownfield sites settlement study. in each monitoring area that were suitable, deliverable Wide spread local developments on and viable. Viability is determined in the Local Plan brownfield sites would be more Viability Study sustainable. If the list of brownfield sites was insufficient to meet the residual for allocation for that area the exercise was
38 Appendix A- Preferred Options Statement of Consultation Site Allocations H9 Land Adjacent to Woodlands 9
repeated but this time suitable, deliverable, viable greenfield sites were identified; If this was still insufficient the remaining houses were allocated to other monitoring areas where there were additional suitable, deliverable sites. It was only once these additional suitable deliverable sites were exhausted that the Green Belt was considered.
Highways Concerns over access to the site, and The site has been assessed by Highways as part of the site acting as a secondary access in relationselection process, and Highways state that the site could be to the larger site subject to planning accessed from the approved access road to site 4/LP/01 to the consent. north of the site.
Appendix A- Preferred Options Statement of Consultation Site Allocations 39 H10 Arizona Chemicals 10
Appendix A- Preferred Options Statement of Consultation Site Allocations 40 H10 Arizona Chemicals 10
H10 Arizona Chemicals
Level of support 1 representation supported the allocation.
Reasons for support Agree with the allocation and would support an extension if possible.
Level of objection No objections to the allocation.
Appendix A- Preferred Options Statement of Consultation Site Allocations 41 H11 Former Roseberry 11
Appendix A- Preferred Options Statement of Consultation Site Allocations 42 H11 Former Roseberry 11
H11 Former Roseberry Comprehensive School
Level of support 2 representations supported the allocation.
Reasons for support Private developer is in negotiations to the purchase the site - they confer that the site can deliver 98 dwellings (CDP identifies yield of 65 dwellings).
Level of objection 1 representation did not support the allocation.
Reasons for Objection Theme Issue Our Response
Infrastructure For a playing pitch strategy (PPS) to be consideredA new Playing Pitch Strategy (PPS) for County up-to-date, it should have been undertaken within Durham is in preparation and will update and the last three years. County Durham's overarching replace the PPS and associated Playing Pitch PPS was adopted in 2014, then the 14 Playing PitchAction Plans from 2013. The PPS will assess Action Plans which sit beneath it were completed the current and projected supply and demand during 2015. The PPS coverage for County Durhamfor pitches, including a technical analysis of pitch will become out of date as the Plan progresses to quality and usage levels. The findings of these adoption. Where a PPS is out of date Sport Englandassessments will provide the evidence of where considers that it is not possible for a Plan to be ableprovision needs further consideration and/or to to justify allocations which seek the development ofbe protected/enhanced and inform the playing field sites, unless it is proposed that the development of both strategic and sport specific playing field be replaced as part of the plan. Formerrecommendations. The strategy will set out site Roseberry Comprehensive School allocation wouldby site recommendations based on prejudice the use of a playing field in lieu of evidencepredetermined areas aligned to the County which shows that there is a surplus of playing Durham Plan (five delivery areas). It is noted that the development site will not impact upon
Appendix A- Preferred Options Statement of Consultation Site Allocations 43 11 H11 Former Roseberry
pitches across the respective areas, which is not playing pitches and any development on the site considered to accord with paragraph 74 of the NPPFof the former school buildings will be required or Sport England's Playing Field policy. to maintain an access to the adjacent playing pitches.
44 Appendix A- Preferred Options Statement of Consultation Site Allocations H12 Brackenbeds Lane 12
Appendix A- Preferred Options Statement of Consultation Site Allocations 45 12 H12 Brackenbeds Lane
H12 Brackenbeds Lane
Level of support No representations supported the allocation.
Reasons for support
Level of objection 1 representation did not support the allocation.
Reasons for Objection Theme Issue Our Response The site is greenfield land so should not be Housing allocations give priority to suitable, developed. deliverable previously developed land in the first instance, as set down in the Rationale for Housing Allocations document which forms part of the CDP evidence base. The council promotes brownfield sites for development through the Brownfield Land Register. Suitable, deliverable green field sites are chosen where there are no previously developed sites available.
46 Appendix A- Preferred Options Statement of Consultation Site Allocations H13 Former Harelaw School 13
Appendix A- Preferred Options Statement of Consultation Site Allocations 47 13 H13 Former Harelaw School
H13 Former Harelaw School
Level of support 3 representations supported the allocation.
Reasons for support 1 representation of support was in principle only, owing to environmental constraints on land to the south of the site.
Level of objection 1 representation raised concerns with the allocation.
Reasons for Objection Theme Issue Our Response
Infrastructure The whole site cannot be built upon to the North ofFlood risk and surface water issues relating to the site as there is an underground Culvert, the site have been considered. Previous accommodating Carmyers Burn. Houses adjacentblockages in the culvert near the church have to the site have been subject to flooding 5 years agobeen solved with head walls and better due the fact that in part the Culvert and entrances maintenance. The culvert will have to be taken had been subject to neglect. This situation has nowinto account of within the layout of the houses been resolved but the area around and above the in the northern part of the site. The Plan places Culvert cannot be disturbed or built upon. a requirement on developers to address any such issues for a scheme to be granted planning permission.
Environment There are some environmental constraints The council are not aware of any specific particularly on land to the south. environmental sensitivities on this site which would prevent development.
48 Appendix A- Preferred Options Statement of Consultation Site Allocations H14 Former Annfield Plain Community Centre 14
Appendix A- Preferred Options Statement of Consultation Site Allocations 49 14 H14 Former Annfield Plain Community Centre
H14 Former Annfield Plain Community Centre
Level of support 2 representations supported the allocation.
Reasons for support No further comment.
Level of objection No objections to the allocation.
50 Appendix A- Preferred Options Statement of Consultation Site Allocations H15 Former Swimming Baths 15
Appendix A- Preferred Options Statement of Consultation Site Allocations 51 15 H15 Former Swimming Baths
H15 Former Swimming Baths
Level of support 1 representation supported the allocation.
Reasons for support No further comment.
Level of objection 2 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response
Existing housing stock Consett does not need additional housing - should Consett and Stanley are considered suitable be directed to Stanley instead. locations for further residential development. The council have assessed all the suitable and deliverable sites in both towns and identified where development opportunities exist through the allocations in the Plan.
Concern selling off land assets without any local Development will provide many local benefits benefit. including through employment creation (construction phase) and increased support for local services and facilities. Development is also required to offset the environmental impacts of development. The Plan includes policies which require a proportion of specialist housing
52 Appendix A- Preferred Options Statement of Consultation Site Allocations H15 Former Swimming Baths 15
(affordable, accessible housing) within new residential schemes, ensuring social benefits as well.
Appendix A- Preferred Options Statement of Consultation Site Allocations 53 H16 Former Blackfyne School 16
Appendix A- Preferred Options Statement of Consultation Site Allocations 54 H16 Former Blackfyne School 16
H16 Former Blackfyne School
Level of support 1 representation supported the allocation.
Reasons for support No further comment.
Level of objection 8 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response
Infrastructure For a playing pitch strategy (PPS) to be A new Playing Pitch Strategy (PPS) for County Durham considered up-to-date, it should have been is in preparation and will update and replace the PPS undertaken within the last three years. Countyand associated Playing Pitch Action Plans from 2013. Durham's overarching PPS was adopted in The PPS will assess the current and projected supply 2014, then the 14 Playing Pitch Action Plans and demand for pitches, including a technical analysis which sit beneath it were completed during of pitch quality and usage levels. The findings of these 2015. The PPS coverage for County Durham assessments will provide the evidence of where will become out of date as the Plan progressesprovision needs further consideration and/or to be to adoption. Where a PPS is out of date Sportprotected/enhanced and inform the development of England considers that it is not possible for a both strategic and sport specific recommendations. The Plan to be able to justify allocations which seekstrategy will set out site by site recommendations based the development of playing field sites, unless on predetermined areas aligned to the County Durham it is proposed that the playing field be replacedPlan (five delivery areas). Compensation will be as part of the plan. Former Blackfyne School provided for the loss of facilities on the former school allocation would prejudice the use of a playingsite in the form of a replacement sports changing room
Appendix A- Preferred Options Statement of Consultation Site Allocations 55 16 H16 Former Blackfyne School
field in lieu of evidence which shows that thereand financial contribution towards the improvement of is a surplus of playing pitches across the the existing playing fields immediately to the west of respective areas, which is not considered to the site. accord with paragraph 74 of the NPPF or Sport England's Playing Field policy.
The land could be used to improve the facilitiesThe site has been identified as a suitable housing site, for sport and recreation and a car park to taking into account playing pitch and sports and alleviate parking problems. recreation requirements in the local area. The site may support some open space on site, driven by the landscape and green infrastructure requirements, however existing sports pitches adjacent to the site will be retained, while the site is well located in relation to existing open space (including parks and gardens).
More infrastructure needed (school places, The Plan includes a requirement for developers to dentists, etc.). mitigate any such impacts over and above the existing situation which arise from new development.
Existing housing stock Consett does not need additional housing - Consett and Stanley are considered suitable locations should be directed to Stanley instead. for further residential development. The council have assessed all the suitable and deliverable sites in both towns and identified where development opportunities exist through the allocations in the Plan. Concern selling off land assets without any Development will provide many local benefits including local benefit. through employment creation (construction phase) and increased support for local services and facilities. Development is also required to offset the environmental impacts of development. The Plan includes policies which require a proportion of specialist housing (affordable, accessible housing) within new residential schemes, ensuring social benefits as well. Environment This site provides important habitat for wildlifeExtended Phase 1 Habitat Assessment, a Badger which would be displaced. Survey and a Great Crested Newt Survey have been completed for this site. There is no significant protected
56 Appendix A- Preferred Options Statement of Consultation Site Allocations H16 Former Blackfyne School 16
species presence on the site. Suitable mitigation, in the form of integrated bat roosting provisions for crevice dwelling species, would be appropriate when re-developing the site. There is a small area of semi-improved neutral grassland along the eastern edge which is understood to aid water logging in this location. This is a priority BAP habitat which will need to be retained or, if lost, mitigated for during any development of the site, however it would be just as valid to replace with a different green space option to suit the housing design layout subject to addressing the water issues. Mature trees on site should be retained for their biodiversity and landscape values, or if lost then replacement planting should take place. Concern about the quality and materials usedDevelopment is required to respond to local character for new development elsewhere in Consett and the surrounding area in relation to design and which would be harmful to the character of materials. The Plan sets down policy requirements to Blackhill. ensure development is well-designed.
Highways Vehicular congestion worsening in Consett. No adverse highway impacts have been identified in respect to this site as evidenced in the Strategic Housing Land Availability Study 2019 (SHLAA). Vehicular access to this site is problematic andAccess is available, however minor localised highway hazardous, especially in the winter. improvements are likely to be required to ensure a safe access. Parking problems will be exacerbated as the Development would need to provide sufficient parking majority of the local houses do not have in accordance with the council's standards for residential garages and therefore have to park on the development. It is not considered that new access road. Double yellow lines just as the road arrangements for the development would impinge upon straightens after the bend will further create aexisting parking and access arrangements in the vicinity problem for parking and access. of the site. Social/Amenity New development has negative impact on There is no evidence to suggest that existing housing existing house values. sales suffer as a result of new house building. The Plan strategy seeks to balance delivery throughout the
Appendix A- Preferred Options Statement of Consultation Site Allocations 57 16 H16 Former Blackfyne School
county, to ensure that it occurs in locations with good demand. Any impacts on existing house values cannot be regarded as a material consideration for strategic planning purposes.
58 Appendix A- Preferred Options Statement of Consultation Site Allocations H17 East of Muirfield Close 17
Appendix A- Preferred Options Statement of Consultation Site Allocations 59 17 H17 East of Muirfield Close
H17 East of Muirfield Close
Level of support No representations supported the allocation.
Reasons for support
Level of objection 24 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response
Infrastructure Development will exacerbate infrastructure The Plan includes a requirement for developers to deficiencies - money would be better spentmitigate any such impacts over and above the existing on our hospital, GP surgeries and schoolssituation which arise from new development. rather than more houses.
Environment Development will result in the loss of Extended Phase 1 Habitat Assessment, a Badger wildlife habitat, including associated flora. Survey and a Great Crested Newt Survey have been completed for this site. The site is predominately species poor neutral grassland but is bordered by ancient woodland. There is a badger sett on the golf course. While there is no evidence that badgers access the Muirfield site, there is evidence of humans accessing the badger sett for nefarious reasons. A mitigation plan will be provided for habitat retention along the border with the golf course and a security fence preventing access to the golf course – both
60 Appendix A- Preferred Options Statement of Consultation Site Allocations H17 East of Muirfield Close 17
essential elements for this site in order to protect the ancient woodland and badger sett. A sustainable urban drainage scheme would be recommended for the site and if the topography allows this system should link to the existing stream to the east of the site.
The proposed buffer adjoining ancient A mitigation plan for habitat retention along the border woodland would be a dumping ground forwith the golf course and a security fence preventing garden waste, something which has beenaccess to the golf course will be required in order to happening around the edges of the Links protect the ancient woodland. Estate ever since it was built. Development would adversely impact uponIt is not considered that development on this site would the Derwent Walk and a nearby nursery result in harm to the Derwent Walk or the nursery which owing to increased traffic both during the is opposite the entrance to the Links estate. The site building phase and thereafter. would deliver a relatively small number of units which would mean a short period of construction, while construction traffic would be required to adhere to normal safety standards and hours of operation to minimise impacts.
The estate suffers from serious flooding The overland flows in the area are not directly linked to issues and there have been various this site. Nevertheless, further investigation would be attempts to fix the problem without required by the proposer to determine the requirement success. Development would only add to for mitigation measures, for example incorporating this problem as additional tarmac would sustainable drainage techniques to ensure the effective add to run-off, making the problem worsemanagement of drainage from the site. for the existing houses of the estate. This problem would likely increase as the gardens, especially front gardens, of the proposed dwellings would be paved over to provide the extra parking wanted by residents but not provided by the developer as witnessed on every single new estate built in Consett for the last 30 years or more.
Appendix A- Preferred Options Statement of Consultation Site Allocations 61 17 H17 East of Muirfield Close
Any disturbance of the land on this site willFurther site investigations would be required based destabilise the ground and cause further upon a detailed plan for the site. This would ensure instances of slippage and landslides that adequate foundations are provided and creating a threat to properties that border development occurred without adverse impacts upon it and even to lives. ground stability. Brownfield land should be developed Housing allocations give priority to suitable, deliverable before greenfield sites – there are plenty previously developed land in the first instance. Suitable, of opportunities nearby and elsewhere in deliverable green field sites are chosen where there Consett and Stanley (which should receiveare no previously developed sites available. Consett a greater portion of new development). and Stanley are considered suitable locations for further residential development. The council have assessed all the suitable and deliverable sites in both towns and identified where development opportunities exist through the allocations in the Plan. The construction phase would introduce It is accepted that during any construction phase there difficulties and dangers to residents, will be a degree of disturbance which is unavoidable. especially children, as well as noise, dirt However, conditions are normally attached to a planning and disruption. consent to safeguard residential amenity, for example through considerate construction practices and controlling operating hours. Highways Existing roads are inadequate for It is accepted that during any construction phase there construction traffic. will be a degree of disturbance which is unavoidable. However, conditions are normally attached to a planning consent to safeguard residential amenity. Construction traffic would be required to adhere to normal safety standards and hours of operation to minimise impacts. Development would exacerbate parking Development would need to provide sufficient parking problems. in accordance with the council's standards for residential development. It is not considered that new access arrangements for the development would impinge upon existing parking and access arrangements in the vicinity of the site.
62 Appendix A- Preferred Options Statement of Consultation Site Allocations H17 East of Muirfield Close 17
Existing housing stock Concern selling off land assets without anyDevelopment will provide many local benefits including local benefit. through employment creation (construction phase) and increased support for local services and facilities. Development is also required to offset the environmental impacts of development. The Plan includes policies which require a proportion of specialist housing (affordable, accessible housing) within new residential schemes, ensuring social benefits as well. Social/Amenity The adjacent golf course poses risks to Given the configuration of the golf course (and factoring amenity and safety. in 'industry standard' safety margins) it is considered that the site would not be adversely impacted upon by the existing golf use. There would be a negative impact on There is no evidence to suggest that existing housing property prices. sales suffer as a result of new house building. The Plan strategy seeks to balance delivery throughout the county, to ensure that it occurs in locations with good demand. Any impacts on existing house values cannot be regarded as a material consideration for strategic planning purposes.
Appendix A- Preferred Options Statement of Consultation Site Allocations 63 H18 Laurel Drive 18
Appendix A- Preferred Options Statement of Consultation Site Allocations 64 H18 Laurel Drive 18
H18 Laurel Drive
Level of support 1 representation supported the allocation.
Reasons for support A developer registered their support as landowner of the eastern portion of the site (SHLAA ref 1/CO/07). They have undertaken preliminary investigations (ecology, geotechnical) in relation to the physical suitability of their site and to demonstrate it is developable. They would like to see their additional land to the east allocated. The developer supports the provision of a primary school on the west part of the site providing a need is identified.
Several representations noted that if development is needed in Consett then this would be the best site, providing it delivered infrastructure improvements.
Level of objection 16 representations did not support, or raised more general concerns with, the allocation.
Reasons for Objection Theme Issue Our Response
Existing housing stock Leadgate needs a higher percentage of high Evidence underpinning the Plan informs that this site quality larger houses so the high density of could deliver 10% affordable housing as part of the 290 houses on a greenfield site should be mix. This is the lowest requirement, reflecting the reduced and more affordable housing sites relative level of viability and need to balance the housing created in Shotley Bridge and Lanchester to stock. The gross density is below the average of 30 to provide more balanced communities. the hectare which is normally used to calculate an indicative yield, which reflects the need to create structural planting and facilities on the site. Development occurring in Shotley Bridge or Lanchester would be expected to deliver a proportion of affordable housing to address need in those areas.
Appendix A- Preferred Options Statement of Consultation Site Allocations 65 18 H18 Laurel Drive
Consett does not need additional housing - Consett and Stanley are considered suitable locations should be directed to Stanley instead. for further residential development. The council have assessed all the suitable and deliverable sites in both towns and identified where development opportunities exist through the allocations in the Plan. Development should be directed to smaller Housing allocations give priority to suitable, deliverable brownfield sites. previously developed land in the first instance, as set down in the Rationale for Housing Allocations document which forms part of the CDP evidence base. The council promotes brownfield sites for development through the Brownfield Land Register. Suitable, deliverable green field sites are chosen where there are no previously developed sites available. Concern selling off land assets without any Development will provide many local benefits including local benefit. through employment creation (construction phase) and increased support for local services and facilities. Development is also required to offset the environmental impacts of development. The Plan includes policies which require a proportion of specialist housing (affordable, accessible housing) within new residential schemes, ensuring social benefits as well. Infrastructure The site is located just that bit further from theThe site is well located in relation to services and well amenities so most people will drive to work, served by buses on Leadgate Road. The site is also drive their children to school, drive to the adjacent to the C2C national cycle route. The Plan shops, etc. includes requirements for improved links to services and provision of a school on the site.
Existing infrastructure is already inadequate. The Plan includes a requirement for developers to mitigate any such impacts over and above the existing situation which arise from new development.
66 Appendix A- Preferred Options Statement of Consultation Site Allocations H18 Laurel Drive 18
Several responses questioned the need for Consett is identified as a suitable location for further more housing in Consett, however if more development given that it is well-contained in relation development is planned then this is the best to services and facilities, schools and employment site (providing it delivers a new school and opportunities. The council have assessed this site as other facilities) as it has good road access, cansuitable and deliverable. be accommodated without disruption to existing residents. Highways 290 new houses will put more pressure on The site has been assessed through the Strategic local roads and in particular the ring road andHousing Land Availability Assessment (SHLAA) 2019 its roundabouts. What traffic safety measuresas being suitable. The Plan includes requirements for will be put in place particularly at the Villa Realimproved pedestrian links with Leadgate local centre. and Drovers roundabouts to ensure the safetyFurther highway and footway improvements are likely of walkers, cyclists and those with visual or to be required to ensure a safe access arrangement, hearing impairment? I believe we need which will be provided through more detailed design pedestrian crossings with lights and sound to work. enable visually, hearing and physically impaired people, able bodied walkers and bicycle users to cross the roads safely and to support healthier communities through walking and cycling. Bearing in mind the traffic jams currently beingVehicle trips have risen in general terms, with experienced, high concern now raised at the subsequent impacts in relation to journey times. This allocation for over 700 more new homes in is comment across the highway network, and the council Consett which will put more pressure on trafficseeks to manage this through planned works and through Stanley. improvements. The council also promoted and support for modal change to more sustainable transport options. The Plan includes policies to reinforce this, for example by providing appropriate and direct routes for walking, cycling and bus access, amongst other things. Employment There is little new economic growth in the The Plan supports further employment growth in the Consett area (except for the coal extraction Consett area through the allocation of sufficient suitable which is unwanted and will only provide jobs land. The council supports existing businesses (for for a few years). More housing, therefore, example through targeted business and building
Appendix A- Preferred Options Statement of Consultation Site Allocations 67 18 H18 Laurel Drive
would unbalance the already improvements) as well as a range of initiatives to precariously-balanced community which is improve employment levels including through striving to accommodate the existing apprenticeship opportunities. newcomers.
68 Appendix A- Preferred Options Statement of Consultation Site Allocations H19 South of Knitsley Lane 19
Appendix A- Preferred Options Statement of Consultation Site Allocations 69 19 H19 South of Knitsley Lane
H19 South of Knitsley Lane
Level of support 1 representation agreed with the allocation.
Reasons for support The site owner lodged their support for this site allocation, subject to:
the yield being extended (as per previous CDP figure of 370 dwellings);
inclusion of additional site to south (ref 1/CO/44) to ensure sufficient landscape buffer and more logical site layout; and
deletion of the community centre requirement, as there is an existing one nearby in Delves Lane which would provide for this need.
Level of objection 120 representations disagreed with the allocation.
Reasons for Objection Theme Issue Our Response
Existing housing stock Too much housing identified for Consett - Consett and Stanley are considered suitable disproportionate strategy. There is sufficient housinglocations for further residential development. already in Consett. The council have assessed all the suitable and deliverable sites in both towns and identified where development opportunities exist through the allocations in the Plan.
There are many vacant properties that should be The Plan has made allowance for the reuse of used rather than building more homes. What is theempty homes as part of the calculation for plan to bring empty homes back into use? determining how many new homes are needed.
70 Appendix A- Preferred Options Statement of Consultation Site Allocations H19 South of Knitsley Lane 19
Whilst bringing empty homes back into use falls outside of the scope of the Plan, the council's Empty Homes Team address this issue. Additional land is required to meet future projected needs in addition to the houses that are brought back into use. The site is greenfield and the strategy states Housing allocations give priority to suitable, brownfield sites should be developed as a priority. deliverable previously developed land in the first Brownfield sites are available in Consett (e.g. instance, as set down in the Rationale for Genesis sites), and in Stanley (e.g. School of Housing Allocations document which forms part Technology and South Moor Community Hospital of the County Durham Plan evidence base. The sites), Chester-le-Street etc. where more council promotes brownfield sites for development is required. development through the Brownfield Land Register. Suitable, deliverable green field sites are chosen where there are no previously developed sites available. Infrastructure The town centre and associated infrastructure (roadThe Plan includes a requirement for developers network, bus services, shops, policing, fire services,to mitigate any such impacts on infrastructure health care, etc.) should be improved before more over and above the existing situation which arise houses can be built. No provision has been made from new development. The statutory utility in the plan for the required infrastructure to supportproviders have been consulted throughout the increase in population. GPs and dentists are alreadyplan making process and there is no indication over-subscribed and people already have to travel that any shortfalls resulting directly from the significant distances to access them. Struggle to development of the site cannot be mitigated. recruit GPs to the area.
Schools and nurseries are oversubscribed and The Infrastructure Delivery Plan informs the people already have to travel significant distances infrastructure requirements within the Plan. This to access them. The local schools are full to recognises the need to ensure that all new capacity and are even exceeding the maximum development is supported by appropriate number of pupils per year group. This has a negativeinfrastructure provision and mechanisms are impact on the standard of education with teachers embedded within the policy framework to require already struggling with the sheer volume of childrenthis of developers where applicable, for example and range of needs. I know that Delves Lane in relation to additional school places, Primary has recently had to convert its library into classrooms and facilities.
Appendix A- Preferred Options Statement of Consultation Site Allocations 71 19 H19 South of Knitsley Lane
a class room to accommodate for extra pupils and has no more room to expand further. Consett Academy has had to reject 1 in 5 pupils according to a governor, due to the lack of places. St Bede's Catholic Secondary school was also full this year, meaning that pupils had to travel as far as Tanfield to find a Comprehensive School - Tanfield now has limited space because of this. Plans to expand the schools may not suffice due to the amount of planned housing proposed in the plan. Delves Lane Primary has developed a successful The council support the improvement of schools strategy to put play at the heart of pupil learning. throughout the county. The allocation policy has The school have developed wide range of outdoor been amended to include provision of additional play equipment (dens, mud kitchens, etc) which screening around Delves Lane Primary School have contributed to the school being awarded as ato minimise impacts of new development both leader in this approach and positive impacts on during construction and through occupation. attainment. The proposed development would adversely impact upon this through the construction phase and may lead to safeguarding issues.
Poor facilities in surrounding area - Allensford ParkThe council are working with caravan park - half the equipment is missing and dangerous. Theregarding improvements to the area, however path between Millfield and Eggleston has never beenthis is still ongoing with no final decision to date. finished off - dangerous in the dark. The path between Millfield and Eggleston is a public footpath and is maintained to that standard, however it is not adopted at the current time. Should the condition of the pathway deteriorate and resources allow, the Authority may decide to bring the whole path up to adoptable standard or secure funding to surface it however there have been no complaints about its condition in recent years.
72 Appendix A- Preferred Options Statement of Consultation Site Allocations H19 South of Knitsley Lane 19
Between no 29 and 30 Deepdale Drive are the The statutory utility providers have been sewerage works for the whole of the Dales View consulted throughout the plan making process estate - development would mean these pipes wouldand there is no indication that any shortfalls have to be moved, which would cause significant resulting directly from the development of the disruption to over 200 existing homes. site cannot be mitigated. In the case of large pipes development is planned so that there is an easement above to ensure access in the future should it ever be required. The site currently provides safe link through to C-2-CThe allocation policy has been amended to ensure development provides access routes to the Lanchester Valley Walk. Environment The site functions as an important green space for The allocation policy has been amended to this area of Consett. It is particularly important to ensure development provides a substantial area many local residents (elderly, disabled, low car of open space for public access that connects ownership) who cannot readily access comparablewith existing adjoining housing and the green space. The area provides significant health Lanchester Valley Walk. This will ensure that and well-being benefits (recreation, start gazing, open space benefits remain for existing etc). residents, while ensuring that the quality of this space is improved to ensure access for all users.
The site harbours an abundance of flora and faunaAn assessment has been undertaken which including many protected species. Replanting the show that there are no protected species records greenery will take decades to re-establish. in the vicinity of the site that raise concerns. The site is therefore highly unlikely to hold UK Priority Habitats and the habitats present appear to be common and of low to medium distinctiveness. Although development on the site could result in the net loss of biodiversity the development would be expected to provide ecological linkages to the wider countryside especially via the wooded corridor of the Lanchester Valley Railway Path. The ditch and stream through the site should be retained and enhanced to create a wildlife corridor and
Appendix A- Preferred Options Statement of Consultation Site Allocations 73 19 H19 South of Knitsley Lane
potentially be included as part of the SUDS solution for any development. These enhancements would help to deliver on-site biodiversity benefits, with any residual impacts on biodiversity being dealt with through off-site compensation.
Development would encroach onto existing The existing allotments would not be harmed by allotments. development on this site. Allotments are protected under separate legislation, and development creates opportunities to enhance existing open space provision through contributions. The plan includes a requirement to provide a substantial area of open space on the site. The land adjacent to the allotments would lend itself to such a use given the topography in that part of the site, along with the route of the ditch and stream which is identified as a potential tract of green infrastructure and a target for enhancement. Mature hedgerows and trees on the site. The site is a mixture of grazing land and scattered scrub. The grazing units are liable to be poor semi-improved grasslands and the scrub habitats are dominated by hawthorn and gorse scrub. The areas of scrub border a small stream that runs through the centre of the site. The hedgerows on site are gappy and unlikely to be in good condition. Nevertheless, any scheme on the site would be expected to include new and additional landscaping to ensure the site is integrated into the landscape and to ensure biodiversity benefits.
74 Appendix A- Preferred Options Statement of Consultation Site Allocations H19 South of Knitsley Lane 19
The area is known to flood. Streams on the site flowThere is no recorded history of flooding on the into Smallhope Burn which flows through Lanchestersite. The water courses which run through the and any development could exacerbate flooding site should be retained and enhanced to create problems in Lanchester. There is an underground a wildlife corridor and potentially be included as spring that used to manifest at the bottom of the hill.part of the sustainable drainage solution for any development. The controlling of discharge of water from the site would benefit Lanchester and would not make it worse.
These enhancements would also help to deliver on-site biodiversity benefits.
The proposal will put more strain on the sewage andThere is adequate sewage capacity at Knitsley drainage system. Storm drains near Fellside have Sewage Treatment Works. The facility has been flooded in the past and adding residential upgraded to maintain site compliance and development would mean this would need to be headroom exists for additional housing. Flood upgraded or even replaced to cope with future risk and surface water issues relating to the site flooding. have been considered. The Plan places a requirement on developers to address any such issues for a scheme to be granted planning permission. The council is satisfied that any surface water issues could be adequately mitigated as part of a detailed scheme being submitted for planning permission. The site contains a number of mineshafts that wouldThe site is not identified as a site of potential require filling before houses could be built. The siteland contamination, however the site lies within is on bad ground and the land would need piling tothe Durham Coalfield. There may be stability enable houses to be built. This will require augers and ground gas issues associated with the coal to drill into the ground and this can cause structuralmeasures, so any development would be damage to surrounding land and housing. required to contact the Coal Authority for further advice. Air and noise pollution from construction phase. It is accepted that during any construction phase there will be a degree of disturbance which is unavoidable. However, conditions are normally attached to a planning consent to safeguard
Appendix A- Preferred Options Statement of Consultation Site Allocations 75 19 H19 South of Knitsley Lane
residential amenity, for example through considerate construction practices and controlling operating hours. Air, light and noise pollution from increased traffic. It is accepted that development of this sort will introduce additional vehicle movements to the area. However given the scale of the proposal it is not considered that pollution would increase to a level significantly in excess of existing levels, or to a point where air quality safe levels would be exceeded. Development at Hownsgill (new bus depot and The bus depot at Hownsgill has been assessed proposed gas fired power station) will increase for environmental impacts and no concerns were pollution in the area, which would be harmful for raised in relation to potential impacts for nearby existing and potential new residents. residents/workers. In the event that a power station is built at Hownsgill this would also need to ensure that pollution levels were not detrimental to neighbouring uses in order to gain planning permission. Employment There are very few jobs in the local area and there The Plan supports further employment growth are not any plans for more to be created. Where in the Consett area through the allocation of will the new employment proposed come from as sufficient suitable land. The council supports people have to commute given out flux of former existing businesses (for example through employers? targeted business and building improvements) as well as a range of initiatives to improve employment levels including through apprenticeship opportunities. There are a number of sites with a past industrial use in the surrounding area such as iron works, quarry etc. When the site is development these all need to be considered in the risk assessment.
Social Site is common land as agreed by Councillors in theThe site is not regarded as Common Land. 1980s/90s - what written agreements exist from that period?
76 Appendix A- Preferred Options Statement of Consultation Site Allocations H19 South of Knitsley Lane 19
Strong local community spirit – proposed The site has been identified as a suitable site in development is not welcome amongst local residentsplanning terms. The council have considered (facebook petition). all relevant responses in respect of the site and amended the development requirements and site area to take into account these valid concerns. Loss of views and visualNegative impacts on the character of Consett – Consett is one of the largest towns in County amenity from existing turning into a city. Loss of rural feel and character.Durham. Nevertheless it's character is to some estates extent formed by its setting within a largely rural area. While development is planned for the town to provide continuing support for services, other schemes are in place (for example the town centre regeneration and the Land of Oak and Iron project) to compliment this growth and to help support and enhance culture and heritage in the town. New dwellings would lead to loss of privacy for The Plan sets down policy requirements to existing residents. ensure development is well-designed and includes sufficient amenity and privacy for new and existing residents. A new Supplementary Planning Document is being prepared to set down adequate and consistent privacy/amenity distances throughout the County. Negative impact on house prices There is no evidence to suggest that existing housing sales suffer as a result of new house building. The Plan strategy seeks to balance delivery throughout the county, to ensure that it occurs in locations with good demand. Any impacts on existing house values cannot be regarded as a material consideration for strategic planning purposes. Highways The road leading down from Langdon Close The allocation requirements have been will become incredibly busy making it unsafe amended to remove the link road between the for children to play and walk around safely. existing distributor road and Hownsgill Drive.
Appendix A- Preferred Options Statement of Consultation Site Allocations 77 19 H19 South of Knitsley Lane
There is a planned play park area at the top of this road which will render it completely unsafe and unsuitable due to the increased traffic flows. The proposed highway connection to Hownsgill Drive will have a negative impact on the local community. Traffic will use the route via Stockerley Lane/Hurbuck Cottages to access the A691 avoiding the congested A692, particularly at peak times. This this will turn a quiet access road into a new south western bypass for Consett. Already, HGVs from the Hownsgill Industrial estate mistakenly try to travel down the road before realising it is a dead end. The Consett bypass is well used, particularly on Friday and Saturday nights when cars and bikes race up and down. Creating a link through this site would worsen the problem by providing more highway for these activities, making it harder for police to control. The proposed through road will be extremely costly for the developer of such a small number of homes. Are there more planned developments for this area? Persimmon Homes currently own the site in question, if they develop the site would they be required to build the bypass or is this just the council hoping that they will?
The development will be prejudicial to highwayThe site has been assessed through the safety particularly when developed in Strategic Housing Land Availability Assessment conjunction with the other sites with planning (SHLAA) 2019 as being suitable. Nevertheless consent or proposed for allocation in the area.the Plan includes requirements for improved
78 Appendix A- Preferred Options Statement of Consultation Site Allocations H19 South of Knitsley Lane 19
Increased traffic in the area would put cyclistsaccess links through the site to ensure safe at risk. route for pedestrians and cyclists. A link is There have been a number of fatal road specified to improve access to the Lanchester accidents, many attributed to poor road Valley Walk (which is a key cycle route in the conditions including insufficient gritting during area). winter months. Pedestrian safety - especially children who walk to school along path linking Redmire and Templetown estates.
Increased commuting and congestion – increased Vehicle trips have risen in general terms, with travel times to local areas of employment. Traffic subsequent impacts in relation to journey times. congestion is already a major concern in Consett This is comment across the highway network, as a whole and particularly in Delves Lane. and the council seeks to manage this through planned works and improvements. The council also promoted and support for modal change to more sustainable transport options. The Plan includes policies to reinforce this, for example by providing appropriate and direct routes for walking, cycling and bus access, amongst other things. Concern that the access will be taken from RedmireThere is no vehicular link proposed between Drive. Redmire Drive and the allocation site.
Appendix A- Preferred Options Statement of Consultation Site Allocations 79 H20 Rosedale Avenue 20
Appendix A- Preferred Options Statement of Consultation Site Allocations 80 H20 Rosedale Avenue 20
H20 Rosedale Avenue
Level of support No representations supported the allocation.
Reasons for support
Level of objection 5 representations did not support, or raised concerns with, the allocation.
Reasons for Objection Theme Issue Our Response
Existing housing stock If developed for bungalows they should be built to The final type and mix for the site would be ensure adequate space for occupants - many new determined through any planning application. homes are too small. The Plan sets down a requirement for specialist housing as part of this mix, which ensures that a proportion is designed to meet the needs of older people (i.e. level access bungalows or flats), Concern selling off land assets without any local Development will provide many local benefits benefit. including through employment creation (construction phase) and increased support for local services and facilities. Development is also required to offset the environmental impacts of development. The Plan includes policies which require a proportion of specialist housing
Appendix A- Preferred Options Statement of Consultation Site Allocations 81 20 H20 Rosedale Avenue
(affordable, accessible housing) within new residential schemes, ensuring social benefits as well. Infrastructure Development will exacerbate infrastructure The Plan includes a requirement for developers deficiencies - inadequate medical provision, traffic to mitigate any such impacts over and above congestion, flooding, pressure on education, hospitalthe existing situation which arise from new overcapacity and may close down. No further development. housing should be built until existing infrastructure is acceptable to community.
Further pressures and impacts on waste collectionsThe County Durham Plan ensures that and broadband speed. development is planned, which means that infrastructure and services such as waste collection are factored into provision and any improvements. The council is working in partnership with the Government to help improve broadband speeds for residents through several initiatives.
Environment Development should be sensitively planned to Development is required to respond to local ensure a quality of place and life. character and the surrounding area in relation to design and materials. The Plan sets down policy requirements to ensure development is well-designed and includes sufficient amenity and privacy for new and existing residents. Brownfield land should be developed before Housing allocations give priority to suitable, greenfield sites. deliverable previously developed land in the first instance, as set down in the Rationale for Housing Allocations document which forms part of the County Durham Plan evidence base. The council promotes brownfield sites for development through the Brownfield Land Register. Suitable, deliverable green field sites are chosen where there are no previously developed sites available.
82 Appendix A- Preferred Options Statement of Consultation Site Allocations H20 Rosedale Avenue 20
Highways Development would increase traffic congestion ontoThe council have not identified any highway Rosedale Avenue especially around peak times. problems in relation to this site. Traffic flows in and out of the site would be relatively low-level given the scale of the site and the anticipated number of vehicle movements.
Appendix A- Preferred Options Statement of Consultation Site Allocations 83 H21 Chaytor Road 21
Appendix A- Preferred Options Statement of Consultation Site Allocations 84 H21 Chaytor Road 21
H21 Chaytor Road
Level of support 1 representation supported the allocation.
Reasons for support
Level of objection 1 representation registered concerns with the allocation.
Reasons for Objection Theme Issue Our Response
Existing housing stock Concern selling off land assets without any local Development will provide many local benefits benefit. including through employment creation (construction phase) and increased support for local services and facilities. Development is also required to offset the environmental impacts of development. The Plan includes policies which require a proportion of specialist housing (affordable, accessible housing) within new residential schemes, ensuring social benefits as well.
Appendix A- Preferred Options Statement of Consultation Site Allocations 85 H22 High West Road 22
Appendix A- Preferred Options Statement of Consultation Site Allocations 86 H22 High West Road Crook
Level of 8 people agreed with the allocation. support
Reasons for • It will bring more people into Crook and therefore boost economy, support • Scope for the proposal to facilitate improvements to infrastructure, services and facilities • it will also create more opportunity for the younger generation from Crook to remain in the town and not have to move away. • The proposed sites location is ideal, it is close enough to walk into the town and use the facilities and go shopping, use the restaurants and bars. • There are bus stops close to the site for commuters who choose to use public transport to go to work. • It is close to primary schools and the bus stops to secondary schools. • Crook itself and small business would benefit from more people staying/living in Crook instead of having to move away. • It would bring income and jobs into Crook. • It is close to Durham and Newcastle and ideal for commuters and also close to the countryside. • Provides scope to improve housing choice and mix (e.g. bungalows and other accommodation suitable for retirees)
Level of 66 representations were made opposing the site. objection
Reasons for Theme Issue Our Response Objection Infrastructure • Crook struggles to live up to its This site was identified as a suitable deliverable site categorisation as a main town with the which is capable of meeting part of the housing loss of employment, services and requirement for the Housing Market Area during the plan facilities over the years whose capacity period in accordance with the preferred Spatial Strategy. is already breached before any further housing. Through the associated Infrastructure Delivery Plan the Plan recognises the need to ensure that all new • GPs and dentists could not support development is supported by appropriate infrastructure further housing development. provision and mechanisms are embedded within the policy framework to require this of developers where • Schools could not support further applicable. The Plan includes a requirement for housing development. No secondary developers to mitigate any such impacts over and above school in town which means children the existing situation which arise from new development. need to travel a distance away. Local It has also considered future employment and retail needs schools are full up. and made allocations where appropriate to do so.
• Transport & roads could not support The Plan is being developed in a context where we are further housing development. engaging with infrastructure providers including the local education authority and health providers to understand • Insufficient shops to support housing the infrastructure requirements and necessary mitigation growth. that the developer will need to incorporate into any forthcoming planning application.
• Insufficient leisure facilities to support The site has been assessed through the SHLAA process further growth. as suitable for housing development. No adverse highway impacts have been identified which would deem • Insufficient children’s play facilities to the site unsuitable. The policy mitigation recognises the support housing growth. relationship of the site to traffic around Durham.
• Recent new developments have added Housing growth has direct positive implication in to pressure and have not resulted in supporting town centres and the wider regeneration of improvements to infrastructure. settlements. This is evidenced elsewhere in the county, for instance Consett. • Proposal will contribute very little to Durham western Relief Road which The scale of the site provides opportunities to assist in seems to be the key driver for the site. supporting opportunities to improve accessibility to alternative modes of sustainable travel.
• The site is remote from railway services There is no evidence to suggest that the development of which will result in higher car use. this site will place a strain upon policing.
• Public transport opportunities are poor The developer will be required to work alongside utility particularly in the evening which will providers at planning application stage. At this point in result in higher car use and Crook will the planning process utility providers have raised no become a dormitory town. objections to the site in question.
• Site will add to congestion.
• Insufficient employment opportunities to support growth.
• Sites closer to less rural towns with greater services and facilities should be pursued.
• High levels of commuters will not regenerate the towns facilities.
• Poor access to A&E facilities.
• Site would require a Crook bypass.
• There is no infrastructure development plan.
• Strain on policing in area.
• Consider that planning for in migration is reckless particularly given lack of jobs and infrastructure in Crook.
• Adverse impact upon water pressure which is already an issue in the area.
Alternative • Alternative PDL sites should be The site has been assessed with all others identified in sites pursued in the town. the area through the SHLAA process using a consistent methodology. Housing allocations have been selected • Land at Woodhouses Close, from suitable, viable, deliverable sites using a consistent Coronation and Eldon Lane should be methodology which prioritises the reuse of PDL site first redeveloped instead. which are suitable, viable and deliverable within the Plan period to meet the Spatial Strategy. This is set out in the • Proposal fails to meet governments Rationale For Housing Allocations document. The site brownfield first policy. Loss of green has been selected having applied a PDL first field land which is contrary to planning methodology consistently across the county. Only then policy to maximise profit rather than has green field undeveloped land been considered. reusing previously developed land in the area. Sites referred to have been considered and discounted through this process on suitability and/ or viability • There are sufficient empty homes to grounds. The housing requirement has made an meet Crook’s future needs. allowance for empty homes which will be brought back into use through the plan period. • Had the points system of the Settlement Study been applied The Settlement Study has been amended and no longer correctly Crook would not have been categorised settlements into typologies. Rather it sets out awarded Main Town Status. the degree of access to services and facilities. In comparison to other settlements Crook does perform well in relation to the range of services and facilities which it currently offers. The council maintains that this settlement is capable of supporting the level of growth proposed with mitigation. Flood Risk • Properties and highways are already There is a policy requirement for surface water flooding to affected by surface water flooding from be mitigated which any forthcoming planning application the site. This will be exacerbated by would need to comply with. The site presents great the development. opportunity to mitigate existing issues within the site as well as ensuring that surface water flooding issues are not • Adverse impact upon culvert which exacerbated, rather improved outside the site as a runs through property which is already consequence of the development. The scale of the site is over loaded in times of rain in terms of such that suitable Sustainable Urban Drainage can be breaching capacity or being diverted. achieved.
• Not convinced the correct technical calculations have been done to ensure there is capacity to deal with rainfall. Reference made to capacity of pond above site and previous flood mitigation work undertaken in 2013.
Residential • Invasion of privacy and overlooking will The site is of a scale to ensure that adequate separation Amenity result, particularly given some can be achieved between existing and proposed properties are set below the level of the dwellings. site and have very short rear gardens. The eventual scheme will be required to meet the • Concerns about how residential standards set out in the design SPDs which are being amenity will be safeguarded. prepared in conjunction with the plan and which deal with the material matters raised regarding amenity which fall • The loss of green spaces for residents within the scope of planning control. to enjoy walking and leisure time, due to the loss of rights of way and rural Open space within the site will be pursued through the surroundings. generic policy requirements set out elsewhere in the Plan at planning application stage. • Increase in noise, disturbance which will affect mental health. It is considered that locating housing next to existing housing results in compatible land uses next to one • Increase in pollution (smell noise and another. dust). The amenity issues raised through this consultation are • Loss of open rural aspect. not considered to be significant enough to deem the site unsuitable. The site is of a sufficient scale to be able to • Devaluation of existing property prices achieve appropriate layout, orientation and distances in a context where house prices have between properties within and beyond the site. already stagnated. Compensation will be sought. Individuals loss of open aspect/ view is not a material planning consideration. The site is of a scale which could accommodate substantial landscaping and green areas • The new houses will have an both within and around the site. overbearing and overshadowing impact
upon existing properties Devaluation of property is not a material planning
consideration and there is no mechanism to pursue • Loss of a well -loved amenity area compensation from the council in this regard. which has public footpaths crossing it.
• Could a restriction be placed upon the The council cannot put time limits on the completion of a developer to complete the site within a planning consent. reasonable time frame? No air quality issues have been identified as a • Fear of flooding. consequence of this proposal.
• Proposed landscaping will result in root Residents are not being given less priority. One of the encroachment. roles of the planning system is to give certainty to developers yet at the same time manage and balance the • Negative impact upon air quality which competing impacts of new development in the public can be a cause of cancer and interest. It is considered that the policy framework respiratory disease. contained within this Plan provides a mechanism to enable the council to do this. The Plan site allocations • Impact upon health due to medical establish the broad principle of development only. Whilst condition which will be exacerbated by the site assessment and public consultation responses fear of or actual amenity impacts set have identified some potential issues relating to this site, out above. it is considered that there is scope for these to be overcome through the application of the policies • Why do residents have less rights that contained within the plan at planning application stage prospective residents of the site? and through the implementation of mitigation required as part of construction phase. The council therefore maintains that this is an appropriate site allocation.
Highway • Site will generate a high level of car The suitability of the site from a highway perspective has Safety and borne trips. been carefully assessed. This has included the accidents accessibility within the locality. It is considered that the required • A689/ A690 is an increasingly busy highway works could result in traffic calming in an area of road with many drivers regularly concern to residents. No unacceptable adverse effects exceeding the 30 miles per hour speed which would be prejudicial to highway safety have been limit, a vast number of cars, buses and identified. The Highway Team are satisfied that a safe heavy goods vehicles using the route, access can be attained and that appropriate pedestrian overtaking dangerously and making it connections can be made with the current footpath increasingly difficult for the residents to network. exit their drives and properties in vehicles and on foot safely. There have A detailed Traffic Assessment would be required to been a number of accidents recently support a forthcoming planning application. The Highway with fatalities in the past. The Team have confirmed that in principle a safe access can development will exacerbate this. be achieved with mitigation and no adverse impact upon the local highway network would result. • The access being proposed is at an accident and speeding blackspot. The Plan can never prevent people from choosing using the car as their choice of travel. However it seeks to • Visibility at the crest of the hill is poor. provide opportunities to encourage people to make smarter choices in relation to alternative modes.
• Poor relationship of access with other The site has been the subject of a rigorous assessment surrounding junction at Woodifield Hill. through the SHLAA process which has taken into account the degree of accessibility that the site has to local • The footpath along High West Road is services and facilities. The council maintains that this is a inadequate to serve the development sustainable choice, relative to other reasonable options and increased use of the road will available, having balanced all of the social, environmental impact upon pedestrian safety. and economic credentials of this site and considered it against other sites through a robust, consistent site • Concern that the site would only be selection methodology. served by one vehicular access which is unsafe. The proposed housing scheme will need to be demonstrated improved permeability which is required • Query as to whether a traffic impact through the application of relevant policies contained assessment has been undertaken. elsewhere within the Plan.
• The spatial distribution proposed will There is no evidence to substantiate the claim that not reduce greenhouse gases. parking in the town centre will be exacerbated as a result. Though it is anticipated that residents will support the use of the town centre and will be provided with opportunities • Given position, distance and to use alternative transport modes through quality design topography the site will be cut off from features. the remainder of the town.
• It will exacerbate parking problems in the town centre.
Environment • The development of the site will result The SHLAA assessment has not identified any issues that in detrimental effect on nature and would be a ‘show stopper’ to development in respect to wildlife, particularly bats. Many small ecological issues. Any forthcoming planning application birds nest in the hedgerows and what would be subject to ecological related policy set out will happen to the field mice, voles, elsewhere in this Plan and would need to be supported by hedgehogs, butterflies, hares, Skylarks, up to date appropriate ecology surveys undertaken prior owls, Swifts, Swallow, Curlew and deer to its submission and any identified necessary mitigation that share this precious habitat. implemented.
• Loss of trees. The loss of part of a LCA has been assessed through the SHLAA process alongside landscape impact and this has • Has an ecology survey been not been deemed significant enough to deem the site undertaken? unsuitable.
• Great Crested newts in the pond above The proportion of land that will be lost from agriculture to the site. housing is not considered to be significant in relation to the county’s wider context. The Plan makes provision to • Loss of a Landscape Conservation facilitate the effective use of soils in a specific policy that Area. would be applied to any forthcoming planning application.
It is considered that whilst this will transform the entrance • Reduction in agricultural land and to Crook that through good design this site offers potential opportunity particularly in the context of to result in a positive outcome. The SHLAA assessment BREXIT. has confirmed that any adverse impacts have scope to be mitigated through landscaping, design and layout to a • Adverse impact upon character of area degree which will not be objectionable. These details will including loss of rural entrance into be progressed and controlled through the planning town. application process.
The council is aware of mining legacy issues in the area. • Coal mining legacy issues exist. DCC With this in mind the Plan makes provision through a unstable land map suggests the site is specific policy to ensure that these are fully addressed a high- risk area. Site was previously through the Development management process at mined. planning application stage. The site would be subject to a
detailed assessment in accordance with specific relevant policy set out within the Plan pertaining to this issue.
Scale and • This will become the first phase of a The site boundaries proposed are clearly delineated on housing larger development which will further the Policy Map accompanying the Plan. Assumptions needs exacerbate concerns. that this may change are unfounded and are not a basis to object to this proposed allocation. • No evidence of need for this housing. This site was identified as a suitable deliverable site which is capable of meeting part of the Local Housing • Lots of vacant houses that should be Need for the Housing Market Area during the plan period. reoccupied first. This need has been calculated using a government-based methodology. • The plan seeks to encourage migration rather than plan for the existing The Plan has made allowance for the reuse of empty populations housing needs. homes and sites that already benefit from planning consent as part of the calculation for determining how • There are committed housing sites in many new homes it needs to plan for. Whilst bringing the area to meet demand. empty homes back into use actually falls out with the scope of the Plan the council has an Empty Homes Team • There are houses for sale in the town to who are carrying out activity to address this issue across meet demand. the county.
• Risk of a failed half completed The Plan identifies a range of sites in terms of scale and development like what has happened location to provide a flexible housing land supply capable elsewhere e.g. Tow Law. of meeting future needs throughout the plan period.
The site has been assessed through the SHLAA and • Smaller alternative sites exist that housing allocation process and have been found to have should be allocated instead. no barriers to development and would be viable having
taken into account costs relating to policy requirements. • Large land releases are not justified for There is no evidence to suggest that the development the number of units left to allocate land would fail. There is a well- established developer who is for. promoting the site through the plan making process.
• Higher density developments would The yield expressed is an indicative figure based upon an reduce amount of land required for average density of 30 dwellings per hectare. allocations. The Plan also requires that all new housing developments • There is a reliance upon lower density of 10 units or more deliver a proportion of units which are homes when the age profile of the suitable for older persons. population is shifting to older people. Should be addressing older persons The site is considered to be deliverable within the Plan agenda rather than promoting further period. There is a known developer promoting the site, housing growth for migrants into area. the site is suitable, and its viability could withstand the policy requirements relating to housing need, open space and infrastructure. • Concern raised it is 4th largest housing development proposed in the county The Plan requires the site to deliver affordable and older proposed in an area of low demand, persons housing as part its mix. The market will low level of facilities and remote. determine the mix which the developer will pursue.
The Plan seeks to balance the needs of all sectors of our • Yield is too low and there is no community. The Plan has been the subject of an justification for this (site promoter). Equalities Impact Assessment (EqIA) and a Health Impact Assessment (HIA). It includes policies which are either • Should be planning for what existing directly specific to older people e.g. the provision of older and future population need (single peoples housing or which have criteria which will be of persons, older persons benefit to meeting the needs of older people e.g. design accommodation) not what developers criteria. The content of the Plan and accompanying want to build. design SPDs have also been prepared having regard to the needs of those suffering from dementia. • No provision is made for older persons and those with specialist needs within the plan.
Other • Development will cut off two farms and The site has been promoted through the SHLAA process make them unviable to operate. by the land owner who has considered their long-term business plan and operational requirements.
• Crook needs a comprehensive plan for The CDP is a comprehensive plan for the county. There the future, not new housing. are further opportunities for local communities to undertake neighbourhood planning to plug any gaps and supplement the CDP where they see fit.
• Proposal does not accord with the The proposal is considered to have potential to accord vision and objectives of the CDP. with the vision and objectives of the Plan providing that all policy criteria contained within it and the design SPDs are • The selection of the site is not adhered to at planning application stage. It is considered consistent to numerous statements that the responses made above to the representations made demonstrate that this site does not conflict with the • A series of questions are raised which objectives of the Plan. relate to specific matters that would be the subject of discussion with the A series of questions are raised, and statements made applicant during the development which relate to specific matters that would be the subject management process. of discussion with the applicant during the development management process or are addressed in the above • Insufficient detail is available. responses to the above representations.
• Consultation event was poor. It is not the role of the Plan to meet the infrastructure needs of the existing population. Rather it must make provision to ensure that new development needs are adequately met so as not to exacerbate any existing • How will additional waste generated deficiencies and to include policy criteria which will allow from population growth be disposed of? future planning applications submitted by providers to be
determined in a manner which results in a sustainable
development.
The level of detail available at this stage of the planning
process is consistent with government requirements and
advice. Layouts and further site -specific detail and information will form the basis of a detailed planning application which would come after the principle of development is established through the plan making process.
The consultation was undertaken in accordance with the Statement of Community Involvement and provided the available information which is proportionate to the plan making process. The event was staffed with knowledgeable officers. The turn -out was high which may have impacted upon the available resource. Council representatives returned to the venue upon request for a public meeting within the consultation period.
The Plan addresses existing and future waste requirements for the county, having taken into account future population growth and means of waste disposal.
Evidence • Inconsistent assessment with other The SHLAA assessments have been reviewed for base issues sites in Crook which have been accuracy and consistency and where necessary categorised as amber unsuitable in the amendments have been made to address the concerns SHLAA. raised.
• SHLAA site assessment has The Settlement Study has been amended and no longer inaccuracies categorised settlements into typologies. Rather it sets out the degree of access to services and facilities. In • The plan has not been positively comparison to other settlements Crook does perform well prepared. There are errors in the in relation to the range of services and facilities which it Settlement Study which has been used currently offers. The council maintains that this to define Crook as a main town. settlement is capable of supporting the level of growth proposed with mitigation.
H23 Former Spennymoor Day Centre 23
Appendix A- Preferred Options Statement of Consultation Site Allocations 98
H23 Spennymoor Day Centre
Level of 1 person agreed with the allocation. support
Reasons for No reasons were given. support
Level of 8 people disagreed with the allocation: objection
Reasons for Theme Issue Our Response Objection Existing There is sufficient housing already in This site was identified as a suitable deliverable site housing Spennymoor. which is capable of meeting part of the housing stock requirement for the Housing Market Area during the plan period. There are many vacant properties that should The Plan has made allowance for the reuse of empty be used rather than building more homes. homes as part of the calculation for determining how What is the plan to bring empty homes back many new homes it needs to plan for. Whilst bringing into use? empty homes back into use actually falls out with the scope of the Plan the council has an Empty Homes Team who are carrying out activity to address this issue across the county. Infrastructure Shops, schools and community facilities are Through the associated Infrastructure Delivery Plan the needed to support housing Plan recognises the need to ensure that all new development is supported by appropriate infrastructure provision and mechanisms are embedded within the policy framework to require this of developers where applicable. GPs are over subscribed to support increase in The Plan includes a requirement for developers to population mitigate any such impacts over and above the existing situation which arise from new development. Schools are oversubscribed, particularly a new The Plan includes a requirement for developers to primary school is required to support increase mitigate any such impacts over and above the existing in population. situation which arise from new development.
No provision has been made in the plan for the The Plan includes a requirement for developers to required infrastructure to support increase in mitigate any such impacts over and above the existing population situation which arise from new development.
Environment Should retain site as green space This is a previously developed site within the built- up area within a predominantly residential area. The Plan seeks to safeguard existing open spaces and secure the provision of additional open spaces to support new developments. However, it does not make specific provision for additional open space, this is the role of a neighbourhood plan should the Spennymoor Town Council consider it appropriate to pursue and is a matter which you may wish to pursue with them. Employment Where will the new employment proposed The Plan makes provision for the protection of existing come from as people have to commute given employment sites and the provision of new sites across out flux of former employers? the county to meet the projected forecasts.
Highways The development will be prejudicial to highway No adverse highway impacts have been identified in safety particularly when developed in respect to this site as evidenced in the Strategic Housing conjunction with the other sites with planning Land Availability Study 2019 (SHLAA). consent or proposed for allocation in the area.
Newly erected speed signs on the road are not This matter falls out with the scope of a development effective and speed limits are broken daily. plan.
The increase in houses with lead to congestion No adverse highway impacts have been identified in at the junction to Durham Road, into the village respect to this site as evidenced in the Strategic Housing on to both North Road and Durham Road, the Land Availability Study 2019 (SHLAA). Black Horse on to Tudhoe Colliery as well as St Charles Lane coming out at the Daleside arms.
People will use the village roads as a cut This matter falls out with the scope of a development through increasing the volume of traffic and plan. mostly likely accidents.
The road network has insufficient capacity to No adverse highway impacts have been identified in support further housing growth. respect to this site as evidenced in the Strategic Housing Land Availability Study 2019 (SHLAA).
H24 Former Tudhoe Grange Lower School, Durham Road 24
Appendix A- Preferred Options Statement of Consultation Site Allocations 102
H24 Durham Rd Spennymoor
Level of 1 representation supported the proposed allocation. support
Reasons for No reasons were given. support
Level of 20 representations disagreed with the proposed allocation: objection
Reasons for Theme Issue Our Response Objection Housing • There is sufficient housing already in This site was identified as a suitable deliverable site Supply Spennymoor. which is capable of meeting part of the housing • There are many vacant properties that requirement for the Housing Market Area during the plan should be used rather than building period. more homes • It is difficult to sell older housing within The Plan has made allowance for the reuse of empty Spennymoor because of the level of homes as part of the calculation for determining how new house building that is occurring. many new homes it needs to plan for. Whilst bringing • What is the plan to bring empty homes empty homes back into use actually falls out with the back into use? scope of the Plan the council has an Empty Homes Team who are carrying out activity to address this issue across the county.
There is no evidence to suggest that older housing sales suffers as a result of new house building. Infrastructure • Shops, schools and community Through the associated Infrastructure Delivery Plan the facilities are needed to support housing Plan recognises the need to ensure that all new • No provision has been made in the plan development is supported by appropriate infrastructure for the required infrastructure provision and mechanisms are embedded within the • Electric, gas and sewerage capacity policy framework to require this of developers where are already at its maximum. applicable. • GPs are over subscribed to support increase in population The Plan includes a requirement for developers to • Dentists are oversubscribed to support mitigate any such impacts on infrastructure over and increase in population above the existing situation which arise from new • Schools are oversubscribed, development. particularly a new primary school is required to support increase in The site has previously been the subject of a Traffic population. Assessment which has concluded that there is capacity • The road network has insufficient within the road network subject to some minor mitigation capacity to support further housing measures being implemented. growth, particularly during peak times and school drop offs. This is a previously developed site within the built- up area within a predominantly residential area. The Plan • Retain site as green space seeks to safeguard existing open spaces and secure the • Use site for a much-needed new school provision of additional open spaces to support new
developments. However, it does not make specific
provision for additional open space, this is the role of a neighbourhood plan should the Spennymoor Town Council consider it appropriate to pursue and is a matter which you may wish to pursue with them.
Any proposals for a new school will be the subject of an options appraisal exercise regarding suitable, available land and does not form part of this Plan. Highway • The development will be prejudicial to No adverse highway impacts have been identified in Safety highway safety particularly when respect to this site as evidenced in the Strategic Housing developed in conjunction with the other Land Availability Study 2019 (SHLAA). sites with planning consent or proposed for allocation in the area. The concerns raised regarding the appropriateness of the • The football academy parking provision location of new footpaths and parking arrangements for will be lost and will cause overspill into the football academy would be the subject of any the surrounding streets. forthcoming planning application. Residents would be • Concern raised about the location of able to consider the detailed proposals and make any any footpaths to the rear of resident’s representations at that stage. The purpose of site property from a safety perspective. allocations is to establish the principle of development as • Newly erected speed signs on the road being suitable and the finer detail is considered and are not effective and speed limits are managed through the planning application process which broken daily. follows thereafter. • The increase in houses with lead to congestion at the junction to Durham Matters relating to speeding traffic and other driver related Road, into the village on to both North issues unfortunately fall out with the scope of a Road and Durham Road, the Black development plan. Horse on to Tudhoe Colliery as well as St Charles Lane coming out at the Daleside arms. • People will use the village roads as a cut through increasing the volume of traffic and mostly likely accidents.
Clarifications • Can the land be bought back as The allocation of the site would not prohibit residents to gardens were previously reduced to approach the land owner to negotiate purchase of land. make way for the school? That is a matter to be agreed with the landowner out with • Wording in plan refs to site of former the plan making process. school however it seems to take in more land, this point needs clarified The precise boundaries of the site are defined on the • Where will the new employment Policies Map which forms part of this Plan. It is that proposed come from as people have to rather than the site name which defines the site area in commute given out flux of former question. employers? The Plan makes provision for the protection of existing employment sites and the provision of new sites across the county to meet the projected forecasts. Residential • Concerns about disruption during It is possible to attach some conditions to a subsequent Amenity construction phases of sites planning consent for the development of the site in the • There are important trees and interests of safeguarding residential amenity. However, it hedgerows on the site that should not is accepted that during any construction phase there will be lost and should be afforded TPO be a degree of disturbance which is unavoidable. status as they play an important role in visual amenity, privacy and wildlife. The trees in question do not meet the credentials to be The plan does not safeguard these. assigned TPO status. However, there are policies within • Old trees within site suffer from falling the Plan which seek to safeguard flora and fauna and branches and require management visual amenity and privacy which would be relevant to the works consideration of any forthcoming planning application. • Concern about type of boundary treatment between existing and Tree management works are a matter which fall out with proposed properties. the plan making process.
Evidence • Planning policies should be based on A new Playing Pitch Strategy (PPS) for County Durham is robust and up to date assessments of in preparation and will update and replace the PPS and the needs for open space, sports and associated Playing Pitch Action Plans from 2013. The recreation facilities and opportunities PPS will assess the current and projected supply and for new provision. The PPS coverage demand for pitches, including a technical analysis of pitch for County Durham will become out of quality and usage levels. The findings of these date as the Plan progresses to assessments will provide the evidence of where provision adoption. Where a PPS is out of date it needs further consideration and/or to be is not possible for a Plan to be able to protected/enhanced and inform the development of both justify allocations, which seek the strategic and sport specific recommendations. The development of playing field sites, strategy will set out site by site recommendations based unless it is proposed that the playing on predetermined areas aligned to the County Durham field be replaced as part of the plan. Plan (five delivery areas). It is noted that the development site will be required to maintain a suitable maintenance access to the adjacent playing pitches. H25 Former Tudhoe Grange Upper School, St Charles Road 25
Appendix A- Preferred Options Statement of Consultation Site Allocations 106
H25 St Charles Rd Spennymoor
Level of 1 representation supported the proposed allocation. support
Reasons for No reasons were given. support
Level of 31 representations disagreed with the proposed allocation: objection
Reasons for Theme Issue Our Response Objection Housing • There is sufficient housing already in This site was identified as a suitable deliverable site Supply Spennymoor. which is capable of meeting part of the housing • There are many vacant properties that requirement for the Housing Market Area during the plan should be used rather than building period. more homes • What is the plan to bring empty homes The Plan has made allowance for the reuse of empty back into use? homes as part of the calculation for determining how • There are other sites within the vicinity many new homes it needs to plan for. Whilst bringing that would be more appropriate to empty homes back into use actually falls out with the accommodate all/ some of the units scope of the Plan the council has an Empty Homes Team proposed on this site. who are carrying out activity to address this issue across the county.
There is no evidence to suggest that older housing sales suffers as a result of new house building.
All suitable sites within the vicinity of the site have been considered and discounted for the reasons set out in the Rationale for Housing Allocations document. Heritage • The Evidence Base, does not fully The council has undertaken a heritage assessment in address the historic environment for the addition to the assessment through the Strategic Housing housing allocations identified in Policy Land Availability Assessment 2019 (SHLAA) of the 5, or constitute a potential heritage impacts that could arise through the proper assessment. The SHLAA development of the site. It is considered that these can assessment is not sufficient, identifying be adequately mitigated through the retention of a only the presence or absence of substantial undeveloped area of open space at the heritage assets rather than assessing northern part of the site along with sensitive positioning impact on significance. An assessment and use of materials. The latter is specified within the is required which would inform stronger policy. mitigation in the policy. The Council should clearly demonstrate that the appropriate assessment has been undertaken, and if any harm is identified to heritage assets, demonstrates how that harm might be removed or reduced. If, at the end of the process, it is concluded that the development would still be likely to harm elements which contribute to the significance of the heritage assets, then the sites should not be allocated unless there are clear public benefits that outweigh the harm (as is required by the NPPF, paragraphs 195 and 196). • The extent of the site boundaries includes land which should be safeguarded from development in the interests of ensuring separation between Tudhoe and Spennymoor continues.
Infrastructure • Shops, schools and community Through the associated Infrastructure Delivery Plan the Capacity facilities are needed to support housing Plan recognises the need to ensure that all new • GPs are too over subscribed to support development is supported by appropriate infrastructure increase in population provision and mechanisms are embedded within the • Dentists are oversubscribed to support policy framework to require this of developers where increase in population applicable. • Electric, gas and sewerage capacity is already at its maximum. The Plan includes a requirement for developers to • No provision has been made in the plan mitigate any such impacts on infrastructure over and for the required infrastructure above the existing situation which arise from new • Schools are oversubscribed, development. particularly a new primary school is The statutory utility providers have been consulted required to support increase in throughout the plan making process and there is no population. indication that any shortfalls resulting directly from the • The road network has insufficient development of the site cannot be mitigated. capacity to support further housing growth The site has previously been the subject of a Traffic • Retain site as green space Assessment which has concluded that there is capacity • Where will the new employment within the road network subject to some minor mitigation proposed come from as people have to measures being implemented. commute given out flux of former employers? This is a previously developed site within the built- up area within a predominantly residential area. The Plan seeks to safeguard existing open spaces and secure the provision of additional open spaces to support new developments. However, it does not make specific provision for additional open space, this is the role of a neighbourhood plan should the Spennymoor Town Council consider it appropriate to pursue and is a matter which you may wish to pursue with them.
The Plan makes provision for the protection of existing employment sites and the provision of new sites across the county to meet the projected forecasts.
Highway • The football academy parking provision The concerns raised regarding the parking arrangements Safety will be lost and will cause overspill into for the football academy would be the subject of any the surrounding streets. required forthcoming planning application. Residents • The development will be prejudicial to would be able to consider the detailed proposals and highway safety particularly when make any representations at that stage. The purpose of developed in conjunction with the other site allocations is to establish the principle of development sites with planning consent or proposed as being suitable and the finer detail is considered and for allocation in the area. managed through the planning application process which • Proposed access road is directly follows thereafter. behind existing properties will not only increase traffic and noise it will also be No precise site layouts have been devised as part of this on an already dangerous bend. Plan. Any forthcoming scheme wold ned to meet current • Newly erected speed signs on the road highway design and safety standards. are not effective and speed limits are broken daily. Issues relating to speeding and use of short cuts fall • The increase in houses with lead to beyond the scope of the plan making process. congestion at the junction to Durham Road, into the village on to both North No adverse highway impacts have been identified in Road and Durham Road, the Black respect to this site as evidenced in the Strategic Housing Horse on to Tudhoe Colliery as well as Land Availability Study 2019 (SHLAA). The site has also St Charles Lane coming out at the previously been the subject of a Traffic Assessment which Daleside arms. has concluded that there is capacity within the road • People will use the village roads as a network subject to some minor mitigation measures being cut through increasing the volume of implemented. traffic and mostly likely accidents.
Consultation The consultation was arranged and conducted in • At the public consultation event accordance with the council’s protocol on this insufficient information was available matter to ensure meaningful engagement and all • A full consultation needs to be arranged representations submitted have been considered with residents (a public open and responded to. Where appropriate and consultation) once a vendor has been justified this has resulted in amendments to the selected and before a contract has Plan. The purpose of the plan making process is been issued in order that all objectives to establish the principle of development. There can be fully scrutinised. will be further consultation on the Submission • The consultation is a tick box exercise version of the Plan. Further detail regarding a and residents are not listened to. specific development scheme is the subject of a • The need for further public engagement later planning application which residents will be throughout the planning process given the opportunity to consider and make detailed representations to. Clarifications • Will I be consulted, once the vendor The purpose of the plan making process is to establish has been appointed, as to their plans. the principle of development. The detail regarding a • Will there be an assurance that the land specific development scheme is the subject of a later will not be held onto for years on order planning application which residents will be given the that a greater profit can be made. opportunity to consider and make detailed • Assurances requested that residents representations to. This will include consideration of the view and space will not be affected. impact that the detailed design has on residential amenity • The SHLAA boundary does not align in terms of outlook and privacy. with the allocation boundary. • No feedback on the previous The Plan cannot specify that a site has to be developed development brief on the site has been within a certain timeframe. However, the evidence undertaken relating to this site confirms that it is suitable and capable • There are no detailed plans to consider of being delivered within the lifetime of the CDP.
The SHLAA Assessment relates to the whole of the site allocation. This can be viewed on the mapping which accompanies the Plan and the SHLAA. The site title does not impact upon the suitability of the site for housing purposes.
The council has not progressed the development brief given the site is being progressed through the plan making process. However, the findings of the consultation have informed the preparation of the plan in terms of the site allocation. It is anticipated that public consultation will be undertaken as part of the process relating to any forthcoming planning application.
Evidence • Planning policies should be based on A new Playing Pitch Strategy (PPS) for County Durham is robust and up to date assessments of in preparation and will update and replace the PPS and the needs for open space, sports and associated Playing Pitch Action Plans from 2013. The recreation facilities and opportunities PPS will assess the current and projected supply and for new provision. The PPS coverage demand for pitches, including a technical analysis of pitch for County Durham will become out of quality and usage levels. The findings of these date as the Plan progresses to assessments will provide the evidence of where provision adoption. Where a PPS is out of date it needs further consideration and/or to be is not possible for a Plan to be able to protected/enhanced and inform the development of both justify allocations which seek the strategic and sport specific recommendations. The development of playing field sites, strategy will set out site by site recommendations based unless it is proposed that the playing on predetermined areas aligned to the County Durham field be replaced as part of the plan. Plan (five delivery areas). It is noted that the development site will be required to maintain a suitable maintenance access to the adjacent playing pitches. Residential The retention of pitches which are not regularly The pitches are currently in use by a local football club. Amenity used is favoured over the interests of The pitches are required to ensure that an appropriate residents. supply is maintained within the area in accordance with the Playing Pitch Strategy.
An undeveloped landscaped area is specified within the policy to ensure that amenity is safeguarded to an acceptable level. This area correlates broadly with the area to which representations relate. Impact upon The existing trees and hedgerows should be The developer will be required to undertake a tree survey existing retained, particularly those adjacent to and submit a landscaping scheme as part of the planning vegetation properties on St Charles Road. application process. There are other policies within the plan that will control landscaping and the provision of The existing trees within the site should be open space within the site. The area to be maintained as protected by a Tree Preservation Order undeveloped open space includes the area within which trees along the boundary with properties on St Charles Road are located.
The need for a TPO will be considered in conjunction with the consideration of any future planning application for the site. The TPO process is separate to the plan making process. Yield The site area should be reduced or amended The council considers that the most appropriate site to incorporate some of the playing pitches. boundary has been identified, bearing in mind the need to retain the pitches. The yield specified in the policy is indicative using a standard methodology. The final yield will be confirmed through a formal planning application and will be design led.
Impact upon The site has a range of biodiversity interest. The council considers that the site can be developed in a ecology manner in which any impacts upon biodiversity can be mitigated. There are policies within the Plan which would control this. Flood risk Concerns about drainage in relation to existing The drainage team have confirmed that any surface water properties. flooding issues within the site can be mitigated.
H26 Land to East of Ash Drive 26
Appendix A- Preferred Options Statement of Consultation Site Allocations 110
H26 Ash Drive, Willington
Level of 1 representation supported the proposed allocation. support
Reasons for The site is well located and accessible to a range of services and facilities. There are no known technical constraints. support
Level of 6 people disagreed with the allocation: objection
Reasons for Theme Issue Our Response Further Objection Action Residential • Devaluation of property due to Devaluation of property values and impact upon sales Amenity proximity to new development, loss of potential of existing properties is unfortunately not a view and noise during construction material planning consideration that can be taken into phase which will never be recovered. account in plan making. • As proposals have been published it will be impossible to sell property now It is possible to attach some conditions to a subsequent even though the development may take planning consent for the development of the site in the some time to proceed. interests of safeguarding residential amenity. However, it • Impact on residential amenity from is accepted that during any construction phase there will extensive noise and building site be a degree of disturbance which is unavoidable. Issues pollution and other inconveniences. regarding security during construction phase is not a planning matter unfortunately. • Security of existing homes is also likely to suffer as new build sites are The Plan cannot specify that a site has to be developed commonly prone to anti- social within a certain timeframe. However, the evidence behaviour and theft and neighbouring relating to this site confirms that it is suitable and capable existing premises can often be targeted of being delivered within the lifetime of the CDP. and/or affected in such activities. • Although there is a planning permission on the former garage forecourt to restore it back to a petrol station and local shop, this area at the moment is an eyesore. If the suggested works do not materialise for some years, then residents will have no choice to travel a mile or more up the road which is then creating more congestion in the main shopping area of Willington in the High Street and Commercial • The new development will completely block views and result in overlooking. • Disturbances during the construction phases will be inevitable. Land • The requirement for large land releases This site was identified as a suitable deliverable site Availability/ is not justified for this relatively small which is capable of meeting part of the housing Allocations number of dwellings required and requirement for the Housing Market Area during the plan concern that the preferred strategy of period. The Plan has also made allowance for demolitions the 2015 County Durham Plan, and the reuse of empty homes as part of the calculation entailing large green belt deletions in for determining how many new homes it needs to plan for. order to pay for road infrastructure, has Whilst bringing empty homes back into use actually falls been carried over despite a change in out with the scope of the Plan the council has an Empty circumstances. Homes Team who are carrying out activity to address this issue across the county. The amount of land required to accommodate the projected housing requirement over the lifetime of the Plan has also taken into consideration the number of recent completed units, as well as units benefiting from planning permission already. Housing • the demographics of the County are The Plan includes a policy which will secure an element Supply changing rapidly towards a population of dwelling units which are suitable for older persons as which contains a greater number of part of new housing schemes. older people and more people in smaller households and therefore concern with the repeated use of the word ‘houses’ rather than ‘dwellings’. • DCC should be planning for a range of housing types to meet the needs of the ageing population, a range of household sizes, and a population who are increasingly unable to afford larger new-build dwellings.
Land • An exclusive focus on building houses The Plan adopts an average density of 30 dwellings per Availability & rather than denser forms of hectare. However, this in itself does not preclude Transport development does not permit the most securing denser developments where this is appropriate efficient use of land, or the form of to the character of the area and does not compromise development which best facilitates design and layout. walking, cycling and public transport. • More efficient use of land could The methodology used to select the housing allocations is significantly reduce the need for based upon giving priority to suitable, deliverable additional greenfield land development previously developed land before suitable, deliverable and reduce the number of private car green field sites. This is set out in detail within the journeys over the Plan period, and this Rationale for Housing Allocations document which forms does not seem to have been taken part of the CDP evidence base. seriously. This is intrinsically unsustainable. There is an inverse A reduction in the use of the motor vehicle is in part correlation between housing density determined by location of new development. However, it and distance travelled. That is, people also relies upon other transport related activities which living in very dispersed developments the council and partners are undertaking, and which fall have to travel further to access out with the scope of this Plan. facilities, services, and employment, and are more likely to use private cars for local journeys. It has also been The plan seeks to strike a balance between the needs of shown that dispersed developments all parts of the county, regardless of remoteness and are harder to serve by public transport, securing sustainable patterns of development. because there are fewer dwellings within walking distance of any public transport stop. Very low densities are also an extremely inefficient use of land.
Highways • The existing estate has narrow roads Access to the site would be from a separate point off the Safety and the bus service that runs, cuts part A690 and therefore the development of this site would not of the estate out on an evening due to impact upon the existing estate road network. the congestion from parked cars that return from work. The site has been assessed through the Strategic • The access from the A690 is a safety Housing Land Availability Assessment (SHLAA) 2019 as concern, with traffic from 200 homes all being suitable. That assessment has confirmed that a trying to get in and out through one safe access could be secured from A690. access onto a fairly small roundabout of the main road into & out of Durham will The Settlement Study has concluded that Willington be difficult. performs well in terms of its access to services and • Due to Willington itself only having a facilities relative to other settlements within the county. butcher, greengrocer and a small co-op store, many occupants will have to go The Plan includes policies to maximise the provision of to Spennymoor, Bishop Auckland or opportunities for prospective residents to use alternative Crook to do their weekly shopping. means of transport to the car. Driving to each of these is problematic. • The nearest train station is Bishop Auckland.
Transport • The site is poorly served by public The site presents opportunities for existing public transport. transport to be improved. The Plan includes policies to maximise the provision of opportunities for prospective residents to use alternative means of transport to the car. Infrastructure • There are no play areas/equipment and The Plan includes a policy requirement relating to the Capacity with the further development this will be provision of open space to serve prospective residents. more of a safety issue as the children are playing in the street and onto the Through the associated Infrastructure Delivery Plan the roads. Plan recognises the need to ensure that all new • The proposal of over 400 houses is not development is supported by appropriate infrastructure backed up with any further provision and mechanisms are embedded within the infrastructure to build new or extend policy framework to require this of developers where school facilities and it is already difficult applicable. In addition, the Plan has been developed in for families to get their children in the discussion with utility providers. nearest school • There is no provision to extend the The Plan includes a requirement for developers to NHS facilities in the town which are mitigate any such impacts over and above the existing already at capacity. situation which arise from new development. • In the past power cuts were frequent. Improvements have taken place, There is no evidence that the development of this site however the demand from an additional would result in the misuse of the existing recreational 200 homes will put a greater strain on resources within the locality. the power, gas, water & telecoms. • The water pressure is already very variable, particularly during summer months. • Phone and internet connections are poor. • The treatment works are located by the river South of the estate (directly in line with the proposed development courtesy of the prevailing South Westerly wind) and were upgraded around 10 years ago in order to cope with the load from the new estate built on the former carpet factory. It is likely the treatment works would require further upgrades to accept increased flows. The other aspect is delivery of waste water to the works. The inlet is at the opposite end of the site from the new development, as such connection will rely on either joining the drainage network on the Wear Valley Estate (already liable to blockages) or create a new branch through steep sloping farmland. • All schools in Willington are at capacity. • The town requires more facilities for the people who live there at present. The new houses recently built on the former carpet factory have already put a strain on the town. Willington already has enough people, it requires investment in the existing development & resources to adequately serve the current population, not an increase in population. • There are a number of public footpaths (including a BOAT immediately South of the proposed site) parks and a nature reserve within walking distance of the proposed site, the increased use & misuse is of concern.
Housing • Houses are not needed given existing This site was identified as a suitable deliverable site Supply planning consents though there is a which is capable of meeting part of the housing shortage of family bungalows of 2 or 3 requirement for the Housing Market Area during the plan bedrooms within Willington which period. results in residents having to make The Plan requires a mix of housing to be provided, adaptations or move out of the area. including those suitable for older persons, which may include bungalows and affordable housing. Land • The CDP states development of The methodology used to select the housing allocations is Availability/ brownfield sites are preferable to green based upon giving priority to suitable, deliverable Allocations field but this represents Green field previously developed land before suitable, deliverable Development as the land parcel is green field sites. This is set out in detail within the currently farmland, and Rationale for Housing Allocations document which forms • The site projects substantially beyond part of the CDP evidence base. the most Easterly line of existing development forming Willington. The The potential landscape impact of the site has been urban sprawl by placing 200 houses on assessed through the Strategic Housing Land Availability this site would be highly invasive to the Assessment 2019 (SHLAA) which has concluded that the rural landscape, and potentially pave impacts of development can be adequately mitigated so the way for the principle of that they are not unacceptable. development in the fields beyond. • Areas more central to Willington would Other policies within the Plan support the regeneration of benefit greatly from regeneration. areas within the existing built up framework which are not • Council should be allocating brownfield specifically allocated within the Plan for development. land for housing. Tenure Mix • The reputation of the estate has There is no evidence to suggest that older housing sales improved, and it is presently a relatively suffers as a result of new house building. Rather, it is quiet and increasingly more desirable widely documented that new housing can have place to live. Despite this, house prices regeneration benefits for communities. are low and take typically 6-12 months to sell. There is still a lot of council houses and private rentals, many of whom are long term tenants. With a brand new estate on its doorstep, the new development would be much more appealing for both buyers and tenants. Concern raised that houses will struggle to sell more, prices will fall, rental income will drop, and the estate will revert back to its former state.
Complaints & • The council has a duty to compensate There is no obligation on the council to compensate Requests residents for the adverse effects they residents regarding the allocation of land for development are now having to suffer. purposes.
Flood Risk • Surface water issues with increased Flood risk and surface water issues relating to the site runoff and potentially 8.9ha of have been considered. The Plan places a requirement on infiltration area lost will lead to developers to address any such issues for a scheme to significant issues. The site is relatively be granted planning permission. The council is satisfied flat, and it is common during heavy that any surface water issues could be adequately rainfall events for ponding to occur in mitigated as part of a detailed scheme being submitted for the field, on the roads through the Wear planning permission. Safety is an important consideration Valley Estate and more worryingly to when considering any subsequent proposal to address see the roundabout on the A690 (the any flooding issues. proposed sole access point) to flood entirely to the point at which it becomes impassable. The fields North of the A690 slope towards the A690 and are fairly flat on the opposite side until they drop away to meet the river. The soils are clay, so surface water accumulates on the plateau, this is particularly bad in autumn when the drains get clogged with silt & leaves it is usually around late spring before they improve. • Attenuation ponds will most likely be required and present a high risk to children.
Biodiversity • The site is separated from the Wear The treatment and retention of hedgerows and trees Valley Estate by a hedgerow, which would be managed at detailed planning application stage. can be seen in its current position on The Plan includes policies to safeguard biodiversity 1945 overhead photography and has interests and any subsequent planning application would ecological value having a wide variety need to accord with these policy requirements and where of birds Bull finches, gold finches, necessary provide acceptable mitigation. wrens, wagtails & as well as the blackbirds, various tits, sparrows & pigeons. This should be retained. • A variety of owls including a barn owl and bats hunt over the green behind Ash Drive, the field, hedgerow & the green. • Old House Beck & the ditches along the byway may well be home to great crested newts & water voles. • Foxes and badgers are in the area too based on the casualties seen on the side of the A690.
H27 Former Etherley Lane Depot 27
Appendix A- Preferred Options Statement of Consultation Site Allocations 113 H27 Former Etherley Depot Bishop Auckland
Level of 1 representation agreed with the allocation. support
Reasons for No reasons were given. support
Level of 2 representations disagreed with the allocation: objection
Reasons for Theme Issue Our Response Objection Housing • There is already sufficient new homes This site was identified as a suitable deliverable site Supply being built in the area. which is capable of meeting part of the housing • There are vacant houses that should be requirement for the Housing Market Area during the plan reoccupied before new homes are built period.
The Plan has made allowance for the reuse of empty homes as part of the calculation for determining how many new homes it needs to plan for. Whilst bringing empty homes back into use actually falls out with the scope of the Plan the council has an Empty Homes Team who are carrying out activity to address this issue across the county. Additional land is required to meet future projected needs even where these are brought back into use. Infrastructure • GPs and schools are at capacity Through the associated Infrastructure Delivery Plan the Capacity Plan recognises the need to ensure that all new development is supported by appropriate infrastructure provision and mechanisms are embedded within the policy framework to require this of developers where applicable. Highways • Further housing will increase The highway implications of the development of this site Safety congestion in the locality have been considered through the Strategic Housing Land Availability Assessment 2019 (SHLAA) and this has confirmed that the development of the site would not give rise to any unacceptable impacts in respect to highway matters. Residential • Concern that location of affordable There is no evidence that the provision of affordable Amenity homes on the site will devalue property housing will devalue existing properties. Best practice suggests that affordable units should be dispersed within a housing scheme. There are many different affordable housing products within the market. The council has a duty to plan to meet all housing needs. Land The calculation of the amount of land required to Availability/ • More land should be allocated in accommodate additional new homes and the subsequent Allocations Bishop Auckland to enable range and selection of the housing allocations takes into account choice. This is a small site which will those units which already benefit from having planning not significantly contribute to overall consent. Therefore, there are a number of units already needs and has limited marketability. in the pipeline, over and above the number specifically Woodhouses Farm is suggested as a allocated for housing purposes in the Plan. The council suitable site to meet needs. will monitor actual housing delivery in all areas and where delivery is not as expected a review of the Plan may be triggered.
The reasons why the site referred to has not been selected as a housing allocation are set out in the rationale for Selecting Housing Allocations document which forms part of the Plan’s evidence base.
H28 Former Chamberlain Phipps 28
Appendix A- Preferred Options Statement of Consultation Site Allocations 116
H28 Former Chamberlain Phipps
Level of 2 representations supported the allocation. support
Reasons for • The site comprises a brownfield site close to a wide range of food/non-food shopping facilities provided at Bishop support Auckland Retail Park. The site is now characterised by extensive areas of hardstanding, and it has an unkempt appearance with some evidence of fly tipping having taken place along the site frontage. • A full application for the erection of 75 no. dwellings was recently refused planning consent as the Council identified harm in respect of traffic impact in the Tindale Crescent area (specifically the Maud Street/Greenfields Road/Dilk Street junction) Gleeson has submitted an appeal in respect of the refused application and the outcome will determine the nature of mitigation (if any) required at the Tindale Crescent cross roads. • There is more than way of achieving such mitigation and essentially the key issue to be considered is the extent and cost of works. This does not however represent a showstopper that could prevent delivery of the draft allocation - Gleeson does not wish to deliver a mitigation scheme that is more extensive than necessary, and the company is firmly of the view that any works required by the County Council should be reasonable, necessary and proportionate. Since submission of the appeal Gleeson has investigated the possibility of improving footway links along Greenfields Road to improve the connectivity of the proposed development. A new section of footway along the western side of Greenfields Road is therefore proposed within the adopted highway, which will permit occupants of the development to more easily access public transport, services and employment to the south of the appeal site. A technical drawing of the footway is attached to this representation. • The site also has an industrial history and requires remediation there is no demand for the site for employment use and therefore a housing scheme is realistically the only viable way for the site to be tidied up and remediated.
Level of 2 representations disagreed with the proposed allocation: objection
Reasons for Theme Issue Our Response Objection Housing • There are already sufficient new homes This site was identified as a suitable deliverable site Supply being built in the area. which is capable of meeting part of the housing • There are vacant houses that should be requirement for the Housing Market Area during the plan reoccupied before new homes are built period.
The Plan has made allowance for the reuse of empty homes as part of the calculation for determining how many new homes it needs to plan for. Whilst bringing empty homes back into use actually falls out with the scope of the Plan the council has an Empty Homes Team who are carrying out activity to address this issue across the county. Additional land is required to meet future projected needs even where these are brought back into use. Infrastructure • GPs and schools are at capacity Through the associated Infrastructure Delivery Plan the Capacity Plan recognises the need to ensure that all new development is supported by appropriate infrastructure provision and mechanisms are embedded within the policy framework to require this of developers where applicable. Residential There is no evidence that the provision of affordable Amenity • Concern that location of affordable housing will devalue existing properties. Best practice homes on the site will devalue property suggests that affordable units should be dispersed within a housing scheme. There are many different affordable housing products within the market. The council has a duty to plan to meet all housing needs. Highways • Further housing will increase The highway implications of the development of this site Safety congestion in the locality have been considered through the Strategic Housing Land Availability Assessment 2019 (SHLAA) and this has confirmed that the development of the site would not give rise to any unacceptable impacts in respect to highway matters. Land • More land should be allocated in The calculation of the amount of land required to Availability/ Bishop Auckland to enable range and accommodate additional new homes and the subsequent Allocations choice. This site has limited selection of the housing allocations takes into account marketability. Woodhouses Farm is those units which already benefit from having planning consent. Therefore, there are a number of units already suggested as a suitable site to meet in the pipeline, over and above the number specifically needs. allocated for housing purposes in the Plan. The council will monitor actual housing delivery in all areas and where delivery is not as expected a review of the Plan may be triggered. The reasons why the site referred to has not been selected as a housing allocation are set out in the rationale for Selecting Housing Allocations document which forms part of the Plan’s evidence base.
H29 Bracks Road 29
Appendix A- Preferred Options Statement of Consultation Site Allocations 119 H29 Bracks Road Bishop Auckland
Level of No representations supported the allocation. support
Reasons for No reasons were given. support
Level of 22 representations disagreed with the allocation: objection
Reasons for Theme Issue Our Response Objection Land • Land Typology: the site is designated The SHLAA Assessment sets out the credentials of the as mostly greenfield however it is site in terms of suitability using a consistent methodology. wholly open arable /agricultural land. This includes prioritising suitable deliverable PDL sites Other areas which have been first. described as greenfield have been discounted due to being agricultural A site is not unsuitable merely on the basis of it being land e.g. 3/BA/38. There are a number agricultural land. Landscape impact and topography are of areas nearby identified as greenfield credentials which has been carefully assessed as part of sites which are actually scrub land and this process. visually unattractive compared to this agricultural land associated with the The site has been selected having used a consistent Durham Dales area. Site 3/BA/31a is methodology set out in the rationale For Housing 100% agricultural land, providing both Allocations document. natural beauty and a valuable local food/employment source. The Plan accepts that in order to meet the full Local • Topography: As outlined in the Housing Need some agricultural land will be lost however allocations rationale document features this is not considered to be a significant amount. exist which may impact on the layout and design of any development and Devaluation of property is not a material consideration there is a drop in levels due to being at and the compatibility of a housing development with its the top of a hill. The development surroundings has been adequately assessed through the would be an incursion into the attractive SHLAA process. countryside as it would be visible to existing properties and the existing A688. The land is raised above the level of the adjoining Brack's Road and neighbouring housing in Redworth Grove and Wynyard Grove. Development on this land would severely disadvantage the residents of Brack's Road, Wynyard Grove and Redworth Grove as in recent years they have seen adjacent land heavily developed into a number of large residential estates to the West, North and South. If the one remaining piece of farmland to the East is allowed to be developed this would enclose the residents on all sides with modern housing of a very different style to their own resulting in a reduction in the property market value. • The area is agricultural land and this goes against the council’s policy on protecting and enhancing the natural and historic environment. • The proposed development lies within DCCs own designated Landscape Improvement Priority Area and would be in direct conflict with, and contrary to the principles and spirit of their policy of landscape conservation and improvement. The presence of 50 houses on this parcel of agricultural land, clearly visible from a number of directions, will have a strong, adverse and detrimental impact
Housing Mix • Adjacent Uses: It is incorrectly stated Comment noted. However, this does not impact upon the that the proposed site will abut a assessment of the site’s suitability for housing in principle. recently developed Taylor Wimpey The appearance of the new units would be carefully estate. The Taylor Wimpey houses managed through a planning application to ensure that were built in the 1960’s therefore any they integrate successfully into their surroundings. development would not be in keeping with existing properties in the area.
Housing • There is sufficient new housing in the The site is required to help meet the full Local Housing Supply area. Need within the lifetime of the Plan. • The properties on the adjacent side of Existing residents do not have a right to a view and right the road were purchased with country to light is a civil matter. Devaluation of property is not a views, many bungalows, the building of planning matter. houses may impact on the right to light and decrease value significantly, Housing delivery is governed by demand and supply. In • There is no guarantee that a builder will the current economic climate, a developer is unlikely to be able to sell any new homes. construct units only to stand empty. The viability evidence which underpins the plan suggests that the site is viable and has a reasonable prospect of being delivered within the lifetime of the Plan. Infrastructure • Access to Services and Facilities: As The site relates to one of the county’s largest towns which Capacity cited in the allocations rationale offers the full range of services and facilities which are document for 3/BA/31b (adjacent to accessible from the site. Opportunities to improve 3/BA/31a) the site is not within walking permeability and access by alternative sustainable distance of services and facilities a transport will be pursued through the application of other reason for refusing planning relevant generic policies set out in the Plan at planning permission. An increasing number of application stage. services are being taken away from Through the associated Infrastructure Delivery Plan the Bishop Auckland town centre and Plan recognises the need to ensure that all new repositioned in the Tindale area a development is supported by appropriate infrastructure considerable distance away with large provision and mechanisms are embedded within the areas of scrub land available (to the policy framework to require this of developers where rear of the Premier Inn) to develop applicable. The Plan includes a requirement for housing allocations on which would improve not only the appearance of the developers to mitigate any such impacts over and above land but also provide it with a useful the existing situation which arise from new development. purpose. • There is a lack of public facilities in the Bishop Auckland area. The hospital that now has no accident and emergency, schools dentists and GPs are all at capacity • The site, which is out of reach of the minimum distance from amenities, in contravention of the councils own planning policy and is therefore not serviced by adequate safe access to main road arteries. • The site is not in walking distance of services and amenities. • Local doctors surgeries and other amenities are already overstretched, additional housing would further stretch these as there are no plans to open new such amenities. • The proposed development site has no direct bus route to either the nearest supermarket or to the nearest shopping centre, both of which are over 1.5 miles away or to other essential services, all of which require the use of a car so adding to road congestion. Again, this is contrary to DCCs policy which promotes a low carbon footprint.
Highways • Highways/Access Issues; As cited in The SHLAA assessment confirms that a safe access can Safety the allocations rationale document for be achieved in principle with mitigation which is 3/BA/31b & 31c there would be a considered acceptable. The precise details will be requirement for a footpath and considered at planning application stage and residents widening of the existing road to enable will have an opportunity to comment on the finer detail of appropriate access. However, this a scheme at that stage. would not be possible due to the existence of mature hedgerows and The SHLAA assessment has not identified any issues trees which cannot be removed. The with the local highway capacity as a consequence of this retention of existing hedgerows was a site being developed which would demand the mitigation condition stipulated with the granting of suggested. planning permission for the Persimmon site 3/BA/48 (Hazelbank) therefore this The positioning and design, including any need for must be consistently applied across the specialist glazing and acoustic fencing in relation to the board. proposed units will need to take into account the adjacent • Concern is raised that Bracks Road is a bypass. This is not considered to be a reason to deem hard junction to exit on to Durham road the site unsuitable for housing purposes. due to rail backs from New Coundon roundabout at peak times. • The area would be congested with even more traffic and the beautiful countryside would be changed forever with a detrimental effect for all residents living close by. • Site borders a high-speed bypass & creates a safety risk, which would pose a noise and health risk to the residents who might live there. • There is no footpath or suitable existing access to the site. • Bracks Road is also very busy already and used as a short cut from the A688 to Durham Road, often at high speeds and a danger for children living in the area. This risk will be increased due to more vehicles (potentially 100 as most houses these days have multiple vehicles) being used and more children in the area. • The manoeuvre of turning right into Durham Road at the north end of Bracks Road has its own safety risks (note the number of accidents from vehicles leaving the road at this junction) and the increased volume of traffic from the proposed development will add to the risks. These significant road safety risks are unacceptable. My comments and objections are supported by evidence from leading organisations and the Durham County Councils own policies and guidelines which do contradict many of the assertions made in the Site Assessment 3/BA/31a. • The addition of a potential 50+ vehicles attempting the manoeuvre of accessing the A688 at the south of Bracks Road, in the face of high volumes of speeding traffic at peak times exacerbates an already existing dangerous road hazard. • The land proposed is very close to the busy A688, the noise pollution from this road would have a negative impact on the ability to sell houses on the proposed site. • Bracks Road is a minor road with a single pedestrian footpath on the opposite site to the proposed building site, this would cause further risk to safety of all pedestrians accessing this site, if the road was to be narrowed to include a footpath to the new site this would further narrow Bracks Road causing additional danger to drivers and pedestrians! • There will also be a significant increase in traffic in the area. • DCC will have to re-install the traffic lights again at the top of Durham Road (near Redworth Grove access / Grange dead-end).
Landscape • Landscape Impact As already outlined Through the SHLAA assessment process full Impact in the allocations rationale document consideration has been given to landscape impact and the adjacent 3/BA/31b&c this is topography credentials and no impacts which would deem agricultural use land and recognised the site to be unsuitable in relation to these have been within as a landscape conservation identified. Each site has been judged on its own merits priority area (LCPA). This site and therefore there will be differences given the (3/BA/31a), being wholly agricultural subjective nature and varying site contexts involved. land, has been incorrectly designated as a LIPA and should have been designated as a LCPA the same as other adjacent agricultural land with the same use. In addition to this the rationale document further states that the development of 3/BA/31a would result in an adverse residual landscape and visual impact. This is due to the site being visible from a significant distance (several miles) due to it being situated on an elevated hillside. • Considerations to landscape and visual impact have been taken into consideration on other sites such as 3/BA/31c and 3/BA/38 therefore why are there inconsistencies in which ways the rationale has been applied? Biodiversity • Biodiversity Impact: As outlined in the Any ecological interests relating to the site would be allocations rationale document an managed through the application of relevant ecological otter/water vole survey is needed and policy set out elsewhere in the Plan at planning the site requires significant non- application stage. The purpose of the SHLAA is to accessible buffer from river and habitat identify the potential for any ‘show stopper’ credentials improvements. In addition, the land is which would render a site unsuitable in principle even with home to many native species of wildlife mitigation. No such adverse impacts have been identified including woodpeckers which are not in this instance. Any subsequent planning application will commonly found in the Bishop need to be supported by appropriate ecological surveys at Auckland area. the time that an application is submitted to ensure that the • The surrounding land holds most up to date information relating to a site is obtained. environment for numerous wild animals, birds of prey, protected bats, hedgehogs etc • Bats are associated with the site. Flood Risk & • Flood risk: In the allocations rationale The DCC Drainage team have considered the site and Drainage document it is incorrectly stated that have advised that no significant issues are apparent and none are identified. Having lived in the appropriate mitigation will, if required be secured through area for several years (including a planning application for the site as part of the previously at Wynyard Grove) it is forthcoming detailed layout. regularly observed that the existing site in question and adjoining Bracks Road suffers from surface water flooding issues due to the gradient of the land. This would be greatly compounded should housing and associated infrastructure be permitted posing a major safety risk to existing residents in the area along with road users, including the adjoining A688. • Drainage issues. • The site is also at risk of extensive flood risk and the area in question already has a long history of flooding issues. • The agricultural land is on a hill, and if removed will cause flooding issues, where there is already issues due to the last housing project. The drainage infrastructure cannot withstand any more. The bottom of the hill often floods and the properties there will be at greater risk should the natural flood defence of agricultural land be removed. (no flood risk has been mentioned; however, this is already a problem and the council were notified). • Properties towards the southern part of Bracks Road have been subjected to their driveways, gardens and, in some cases, their garages being flooded. At times of heavy rain, large volumes of water can be observed flowing from the proposed housing site at various places along its length parallel to Bracks Road. This water then traverses the roadway and flows towards the gullies. However, these gullies often overflow in times of heavy rainfall and the level of overflow of water has, in recent times and despite the raising of the reduced driveway kerbs, needed to be controlled by physical means, such as sandbags. By creating hard surface areas in the field proposed for development, the natural absorption of the rainwater will be very severely reduced with the consequence of increasing the risk of flooding to the properties mentioned above. Residential • Additional consideration should be Devaluation of property is not a material planning Amenity given to the amount and scale of consideration which can be taken into account. There is development these residents have no evidence to suggest that new housing will result in an already reluctantly accepted around increase of crime. The subsequent scheme set out in any them in recent years and the forthcoming planning application will need to comply with associated loss of beautiful countryside design criteria aimed at designing out crime. as well as the negative impact on house prices in the area. Any impact from the bypass will be considered fully at • Increased crime. Local police are planning application stage and if justified appropriate already stretched, more housing (in mitigation will be required as part of the layout and particular social housing) will increase detailed design and construction of units. This is not burglary and theft. considered to be a matter which cannot be resolved. • There is no natural soundproofing. Residents of Hazelbank were told the tree line would provide adequate sound proofing however this is not the case and would not be the case for a new housing estate either. Land • Brownfield land would be a better use The methodology used to select the proposed housing Availability/ of land than a farmers field that allocations, including this site has given priority to Allocations provides income. suitable, deliverable sites. This can be viewed in the • There are plenty of other brown field rationale for Housing Allocations document. sites in Bishop Auckland that might be used alternatively. The level of housing growth planned for bishop Auckland • Insufficient housing is allocated to is based upon the preferred Spatial Strategy and takes Bishop Auckland. It is one of the into account existing planning consents in the pipeline as largest towns in the County with well as identifying new sites. significant areas of employment, shops, The council considers that it has identified a sufficient, services and schools. The large flexible and varied supply of housing sites to meet the full commitment at Etherley Moor calculated Local Housing Need by the end of the plan recognised, although this leaves a period. dearth of smaller sites which can come forward quickly and easily, increasing The site at primrose Villas has been assessed as the risk of non- delivery. This is unsuitable within the SHLAA (2019) and therefore has not contrary to guidance in NPPF and been allocated for housing purposes. The site would result in limited choice for the assessment can be viewed in the Individual SHLAA Site large population of existing and future Assessment document. All other land identified through residents of the town. There are more the SHLAA process has been assessed in terms of its houses allocated to the towns of Crook suitability and deliverability and sites have been selected (350), Willington (200) and Consett for allocation using a consistent methodology set out in (830) none of which benefit from the the rationale For Housing Allocations document. range of services including secondary education, range of employment sites and town centre offering as Bishop Auckland which has been allocated 135 new homes. • It is not understood why an allocation is made at Bracks Farm (H/29) for 29 houses when this site is much more poorly related to the town than other more central sites. An allocation for 50 - 60 dwellings should be made at our client’s site at Primrose Villas (site 1), which is located close to the housing commitment at Etherley Moor, and all local amenities, the school and employment areas. The site is well enclosed and would form a natural and logical extension to well- established and popular residential areas of the town. An allocation of up to 10 houses at our client’s site at Etherley Lane should be made, (site 2) which would tie in with the adjacent allocation for 10 houses on the former depot, improve certainty to both owners / developers, increasing the prospects of delivery and potential viability of both sites. • More land should be allocated in Bishop Auckland to enable range and choice. This site has limited yield and marketability. Woodhouses Farm is suggested as a suitable site to meet needs. • Other suitable more central sites should be pursued. • There are under- utilised allotments in Bishop Auckland that should be used instead. Visual • The visual impact on the area would be The visual and landscape impact has been assessed Impacts significantly changed and this will be through the SHLAA process and has been deemed to be viewed from miles around due to the acceptable. location of the proposed site. • The area in question seems to have become very overcrowded and ascetically unpleasing with housing being built in areas of natural beauty without any thought for the negative impact on the countryside and the community/residents as a whole. Policy • The plan also is in direct contravention The CDP policies reflect the policy approach required by of policy of protecting a natural and national planning policy (NPPF) and provide a new local historic environment and a policy of planning policy framework for the determination of future keeping a low carbon footprint. planning applications. These policies will supersede the existing Wear Valley District Local Plan. Pollution • Houses will be an excellent noise Comment about the acoustic qualities of new housing is reduction 'acoustic fence’ noted. • Dust and noise from construction work The planning process accepts that there will be a degree will affect residential amenity. of disturbance during construction which may not always • The 2008 Ambient Air Quality Directive be controllable through planning conditions being sets legally binding limits for attached to any subsequent planning consent. concentrations in outdoor air of major air pollutants that impact public health No implications on air quality in this location have been such as particulate matter and nitrogen identified as a consequence of a development of this dioxide.These come from vehicle limited scale. exhaust fumes. Air quality is a consideration in Strategic The council’s response regarding noise impacts is set out Environmental Assessment and its earlier. appraisal can be used to shape an appropriate strategy. It must consider the impact of point sources of air pollution, which is pollution that originates from one place. In this case, the point of source is the particular section of the A688 which runs adjacent to the proposed site H29 at a distance of only 3 metres from its eastern boundary. From the Bone Mill Bank / Bracks Farm roundabout just south of the proposed site, there is a relatively steep incline for approx. 1000m to the Coundon Gate roundabout at the A688/ A689 interchange. There is a localised and very significant rise in exhaust pollution as vehicles accelerate from the southern roundabout in both traffic lanes northbound for a distance of approx.800m, the majority of which is adjacent to the proposed site. At peak times, this pollution is sufficiently concentrated to be noticeable on Bracks Road, some 50 to 100m to the west of the A688. The Government Policy Paper, updated May 2015, states Air pollution, for example from road transport, harms our health and wellbeing. It is estimated to have an effect equivalent to 29,000 deaths each year and is expected to reduce the life expectancy of everyone in the UK by 6 months on average. In addition, there is increasing evidence of direct links between road traffic noise and various types of illness, like heart attacks and strokes.) At all times of the day in Bracks Road, road traffic can be heard loudly, from the low pitched, loud noise from heavy goods vehicles accelerating up the A688 to high pitched extremely noisy motor cycles, as well as the noise of cars. The impact will be much greater on the site proposed for housing development H29, with a significant, continuous impact on the families inhabiting those properties. This assertion is supported by the World Health Organisation who state the level of noise from traffic is correlated with the traffic flow rate, the speed of the vehicles, and the proportion of heavy vehicles, which, together with motorcycles, tend to be about twice as loud as motor cars. Special problems arise in areas where the traffic movements involve a change in engine speed and power, such as at traffic lights, hills, and intersecting roads. (World Health Organisation (WHO) revised 1999 -Environmental Health Criteria for Noise; Road traffic 2.3.2) British Standard 8233 (1999) gives maximum tolerable noise levels from road traffic for houses and their gardens. Whilst the road traffic noise can be attenuated through double and triple glazing and other methods of insulation, the noise outdoors cannot be reduced significantly. In Section 7.6.1.2 of the British Standard, gardens are considered, and maximum tolerable levels are given. It is asserted that those levels will be exceeded in the gardens of the proposed development. In light of the above, it seems incredulous that DCC is considering house building on this site, putting 50 families at risk.
Consultation / • An insincere response from DCC which The consultation and associated feedback provided has Complaints feebly attempts to alleviate concerns been undertaken in accordance with the council’s raised is anticipated. A willingness to Statement of Community Involvement. Further engage in a meaningful discussion to meaningful engagement will be sought through the broach the plans to prevent a consultation on the Submission version of the Plan. misguided plan is expressed. Local Media will be informed.
H30 Copelaw 30
Appendix A- Preferred Options Statement of Consultation Site Allocations 122 H30 Copelaw 30
H30 Low Copelaw
Level of support 5 representations supported the allocation.
Reasons for support A consistent theme was that the allocation should be increased from 600 to the 950 identified in the previous withdrawn CDP. Site is close to Aycliffe Business Park which is largest employment site in the County. Site has good access to strategic routes and networks. Site can be developed as a sustainable urban extension. Support the allocation of the site which is deliverable, viable, suitable and achievable. Site is close to housing and existing facilities. Pedestrian and cycling links need to be enhanced.
Level of objection 9 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response Housing numbers/tenureThe number of houses for the site has been reducedThe allocations reflects the anticipated build out mix from 950 units (previous CDP) to 600. Will this meanrate for the site within the plan period. The site more executive houses for the site? will actually accommodate 1,400 houses in total The housing allocation in relation to the size of the and the policy text has been amended to clarify site means the development is a low density and anthis, and this will include a ranges of house types inefficient use. and tenures including affordable and potentially larger properties developed at a lower density, as well as community facilities.
Infrastructure Shops, schools and community facilities are neededThrough the associated Infrastructure Delivery to support housing. Plan the Plan recognises the need to ensure that all new development is supported by appropriate infrastructure provision and mechanisms are embedded within the policy
Appendix A- Preferred Options Statement of Consultation Site Allocations 123 30 H30 Copelaw
framework to require this of developers where applicable. The site will be developed with community facilities including a local centre. High pressure gas transmission system crosses The north east corner of the Copelaw site will part of the site. National Grid prefers that buildings be enhanced as open space with no built are not built directly over its lines to protect amenitydevelopment proposed in the vicinity of the gas of future occupiers and to enable quick and easy pipeline. access to carry out maintenance. Sustainability/Access Concerns that the Copelaw site is severed from theDespite the current barrier created by the A167, main settlement by a main road and not within easyseverance issues to the town will be overcome walking distances of employment opportunities andby improved crossing facilities with Central town centre. Pedestrian and cycle links across the Avenue to promote sustainable modes of A167 should be by way of a bridge. transport and pedestrian access from the site. The site will provide a safe and attractive environment for walking and cycling which encourages local journeys to be made by foot or by bicycle. Walking and cycling routes across the A167 will be designed to encourage and enable convenient pedestrian/cyclist crossing at formal crossing points. Development will be designed to facilitate easy movement and sustainable access via all modes of transport (including public transport, walking and cycling) within the site, further enhancing and creating sustainable connections from the site to the Town Centre, Aycliffe Business Park and other local complimentary land uses. Newton Aycliffe is one of the County’s principal towns, and home to the largest employment estate in the County (Aycliffe Business Park) which is only 0.5 miles to the south of the site.
124 Appendix A- Preferred Options Statement of Consultation Site Allocations H31 Eldon Whins 31
Appendix A- Preferred Options Statement of Consultation Site Allocations 125 31 H31 Eldon Whins
H31 Eldon Whins
Level of support 1 representation supported the allocation, and 1 representation had no objections.
Reasons for support No reasons were given.
Level of objection 2 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response Use of Greenfield land Look to other site not greenfield The methodology used to select the housing allocations is based upon giving priority to suitable, deliverable previously developed land before suitable, deliverable green field sites. This is set out in detail within the Rationale for Housing Allocations document which forms part of the CDP evidence base. Clarifications The Rural Urban Classification Map (P84) producedThe Defra Map is based Lower Super Output by Defra shows Middridge as part of an Urban Area.Area (LSOA) which use the rural urban classification from the Census (2011). Middridge Parish is however recognised as a designated rural area under the The Housing (Right to Enfranchise) (Designated Protected Areas) (England) Order 2009. Highways Concerned that the extra traffic will create problemsSite now has planning permission and the along the road in to Middridge. highway impact of developing the site was found to be acceptable.
126 Appendix A- Preferred Options Statement of Consultation Site Allocations H32 Land at Woodham College 32
Appendix A- Preferred Options Statement of Consultation Site Allocations 127 32 H32 Land at Woodham College
H32 Land at Woodham College
Level of support 0 representations supported the allocation.
Reasons for support
Level of objection 7 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response Visual Impacts The new houses will be situated right outside and Loss of a view is unfortunately not a material in front of existing housing and will result in the lossplanning consideration that can be taken into of a view. account in plan making. However, the design and layout of development will have to accord with the 'Sustainable Design in the Built Environment' and 'Amenity and Pollution' policies. Infrastructure For a playing pitch strategy (PPS) to be consideredA new Playing Pitch Strategy (PPS) for County up-to-date, it should have been undertaken within Durham is in preparation and will update and the last three years. County Durham's overarching replace the PPS and associated Playing Pitch PPS was adopted in 2014, then the 14 Playing PitchAction Plans from 2013. The PPS will assess Action Plans which sit beneath it were completed the current and projected supply and demand during 2015. The PPS coverage for County Durhamfor pitches, including a technical analysis of pitch will become out of date as the Plan progresses to quality and usage levels. The findings of these adoption. Where a PPS is out of date Sport Englandassessments will provide the evidence of where considers that it is not possible for a Plan to be ableprovision needs further consideration and/or to to justify allocations which seek the development ofbe protected/enhanced and inform the
128 Appendix A- Preferred Options Statement of Consultation Site Allocations H32 Land at Woodham College 32
playing field sites, unless it is proposed that the development of both strategic and sport specific playing field be replaced as part of the plan. recommendations. The strategy will set out site Woodham College allocation would prejudice the by site recommendations based on use of playing field in lieu of evidence which showspredetermined areas aligned to the County that there is a surplus of playing pitches across theDurham Plan (five delivery areas). It is noted respective areas, which is not considered to accordthat the development site will not impact upon with paragraph 74 of the NPPF or Sport England's playing pitches and any development on the site Playing Field policy. of the former school buildings will be required to maintain an access to the adjacent playing pitches.
Environment Loss of green space used by many people includingThe Green Infrastructure policy will ensure that dog walkers and children to exercise. there is sufficient quantity of open space provided as part of any new development. This includes amenity green space and children's play area. Look to other sites not greenfield Previously developed land is considered for housing allocations first however there are insufficient, deliverable sites and therefore greenfield land is also required.
Highways Access for Woodham College is inadequate and Minor localised highway improvements are would cause worsening traffic and safety issues. required. Site to be accessed via single junction onto existing public highway (Hardinge What will be the access/egress from the site? TrafficRoad/Wiseman Walk). congestion will be increased if houses are built here.
Appendix A- Preferred Options Statement of Consultation Site Allocations 129 H33 Cobblers Hall 33
Appendix A- Preferred Options Statement of Consultation Site Allocations 130 H33 Cobblers Hall 33
H33 Cobblers Hall
Level of support 0 representations supported the allocation.
Reasons for support
Level of objection 4 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response Use of Greenfield Land Look to other sites not greenfield The methodology used to select the housing allocation is based upon giving priority to suitable, deliverable previously developed land before suitable, deliverable greenfield sites. This is set out in detail within the 'Rationale for Housing Allocations' document which forms part of the CDP evidence base. Land Stability This area was originally designated as unstable land There is no evidence of any land stability issues and the area is very special regarding the planting and adjacent land parcels at Cobblers Hall have and shrubs in the locality. been developed out in recent years without any stability issues. To the north of the site is a The land has previously been deemed unsuitable designated Local Wildlife Site ('The Moor') which for housing due to subsidence issues. is a protected site and a benefit to the area in terms of fauna and flora.
Appendix A- Preferred Options Statement of Consultation Site Allocations 131 33 H33 Cobblers Hall
Open Space Loss of open land. Newton Aycliffe as a new town has been planned and developed with extensive areas of Newton Aycliffe has an abundance of trees and lotsopen/green spaces which recognised within the of green spaces. Open Space Needs Assessment (OSNA) and afforded protection by the Green Infrastructure policy. This site has long been earmarked for housing development and previously benefited from outline planning permission for housing. Land The vacant Southerne Club site which has remainedThe Southerne Club site has previously had Availability/Allocations a wasteland would have significantly less impact planning permission for a 60-bed residential care and would be more suitable. home (7/2011/0214/DM). Infrastructure More housing would put greater strain on the localThrough the associated Infrastructure Delivery GPs Plan the Plan recognises the need to ensure that all new development is supported by appropriate infrastructure provision and mechanisms are embedded within the policy framework to require contributions from developers to this where applicable.
132 Appendix A- Preferred Options Statement of Consultation Site Allocations H34 Land at Eldon Bank Top 34
Appendix A- Preferred Options Statement of Consultation Site Allocations 133 34 H34 Land at Eldon Bank Top
H34 Eldon Bank Top
Level of support 0 representations supported the allocation.
Reasons for support
Level of objection 1 representation did not support the allocation.
Reasons for Objection Theme Issue Our Response Use of Greenfield Land Look to other sites not greenfield The methodology used to select the housing allocation is based upon giving priority to suitable, deliverable previously developed land before suitable, deliverable greenfield sites. This is set out in detail within the 'Rationale for Housing Allocations' document which forms part of the CDP evidence base.
134 Appendix A- Preferred Options Statement of Consultation Site Allocations H35 Adjacent Hunwick Primary School 35
Appendix A- Preferred Options Statement of Consultation Site Allocations 135 35 H35 Adjacent Hunwick Primary School
H35 Adjacent Hunwick Primary School
Level of support representations supported the allocation.
Reasons for support
Level of objection 54 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response Highway Access / SafetyAccess via Quarry Farm Close is unacceptable. The site is no longer proposed as a site An increase in traffic could pose a risk to allocation because significant surface water pedestrians, especially playing children. flooding has been identified. Traffic is dangerously high throughout the village. Concerns regarding construction traffic in the cul-de-sac. Infrastructure Public transport within the village has declined. There are insufficient local amenities and facilities within the village. Concerns that the school cannot accommodate additional children. Environment Previously developed land should be developed in preference.
Flooding occurs on a regular basis.
136 Appendix A- Preferred Options Statement of Consultation Site Allocations H35 Adjacent Hunwick Primary School 35
Landscape quality. Economy There are no employment opportunities within the village. Other There was a planning application refused in 1994 for 25 dwellings.
Appendix A- Preferred Options Statement of Consultation Site Allocations 137 H36 North Blunts 36
Appendix A- Preferred Options Statement of Consultation Site Allocations 138 H36 North Blunts 36
H36 North Blunts
Level of support 1 representations supported the allocation.
Reasons for support It was commented that the site is in a sustainable and accessible location and would help contribute to land supply and widen and diversify the local housing market.
Level of objection 2 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response
Empty Homes There are many empty homes in Peterlee which Bringing empty homes back in to use is a key need to be bought back and updated. priority for the council. We also recognise the issues experienced in some areas as a result of concentrations of vacant, underused properties and will continue to work with all relevant agencies and in particular Homes England to pursue funding that will allow as many properties as possible to be brought back into use.
Environment Habitat Regulations, sites should be subject to a full The CDP has been subject to a full HRA which site specific screen test. has gone through the whole process, so all sites within 6km of the coastline (including Murton Colliery) have been subject to Appropriate Assessment.
Appendix A- Preferred Options Statement of Consultation Site Allocations 139 H37 Seaham Colliery 37
Appendix A- Preferred Options Statement of Consultation Site Allocations 140 H37 Seaham Colliery 37
H37 Seaham Colliery
Level of support 1 representation supported the allocation.
Reasons for support It was stated that Seaham is fabulous and a good job has been done there.
Level of objection 3 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response Habitats Regulations Assessment The proposed housing allocation is not justifiedThe CDP has been subject to a full HRA (HRA) or sound or legally compliant by virtue of the which has gone through the whole process, provisions of the Habitat Regulations. Contendso all sites within 6km of the coastline that the housing allocation does not accord with(including Murton Colliery) have been the Court of Justice of the European Union subject to Appropriate Assessment. (People over Wind) which has implications in relation to any development proposals or plans that may affect European nature conservation sites. The recent ruling has established that where a Habitats Regulations Assessment may be required for a development, mitigation cannot be taken into account when considering the screening test for likely significant effects as part of the Habitats Regulations Assessment (HRA). The sites cannot now be screened out of requiring a full appropriate assessment at the initial stage on the basis of taking into account
Appendix A- Preferred Options Statement of Consultation Site Allocations 141 37 H37 Seaham Colliery
mitigation which may come forward. No evidence can be identified that the sites have has been the subject of a full site-specific screening test for likely significant affects. This is now a requirement that must be undertaken even at the plan stage. It is therefore considered premature and inappropriate to bring forward these sites, in advance of them being screened for likely significant effects. This matter can no longer simply be addressed through a generalised application of mitigation measures as has been applied previously to developments within 6km of the coastline.
Transport Query whether there would be access to the No precise site layouts have been devised Avenue for bus stops and shops as part of this Plan. Any forthcoming scheme would need to meet current Development would cause traffic congestion. highway design and safety standards, and permeability and pedestrian access would be promoted.
The site has previously been the subject of a Traffic Assessment which has concluded that there is capacity within the road network subject to some minor mitigation measures being implemented.
Residential Amenity Increased footfall past causes concern and Matters such as littering falls outside the existing littering will be exacerbated by more scope of a development plan. housing. No precise site layouts have been devised Overlooking and privacy concerns. as part of this Plan, however, the layout of new housing would be expected to make provision for adequate amenity and privacy.
142 Appendix A- Preferred Options Statement of Consultation Site Allocations H38 Former Seaham School 38
Appendix A- Preferred Options Statement of Consultation Site Allocations 143 38 H38 Former Seaham School
H38 Former Seaham School
Level of support 1 representation supported the allocation.
Reasons for support No reasons were given.
Level of objection 1 representation did not support the allocation.
Reasons for Objection Theme Issue Our Response Habitats Regulations The proposed housing allocation is not justified or The CDP has been subject to a full HRA which Assessment (HRA) sound or legally compliant by virtue of the provisionshas gone through the whole process, so all sites of the Habitat Regulations. Contend that the housingwithin 6km of the coastline (including Former allocation does not accord with the Court of JusticeSeaham School) have been subject to of the European Union (People over Wind) which Appropriate Assessment. has implications in relation to any development proposals or plans that may affect European nature conservation sites. The recent ruling has established that where a Habitats Regulations Assessment may be required for a development, mitigation cannot be taken into account when considering the screening test for likely significant effects as part of the Habitats Regulations Assessment (HRA). The sites cannot now be screened out of requiring a full appropriate assessment at the initial stage on the basis of taking into account mitigation which may come forward. No evidence can be identified that
144 Appendix A- Preferred Options Statement of Consultation Site Allocations H38 Former Seaham School 38
the sites have has been the subject of a full site-specific screening test for likely significant affects. This is now a requirement that must be undertaken even at the plan stage. It is therefore considered premature and inappropriate to bring forward these sites, in advance of them being screened for likely significant effects. This matter can no longer simply be addressed through a generalised application of mitigation measures as has been applied previously to developments within 6km of the coastline.
Appendix A- Preferred Options Statement of Consultation Site Allocations 145 H39 Camden Square 39
Appendix A- Preferred Options Statement of Consultation Site Allocations 146 H39 Camden Square 39
H38 Former Seaham School
Level of support 1 representation supported the allocation.
Reasons for support No reasons were given.
Level of objection 1 representation did not support the allocation.
Reasons for Objection Theme Issue Our Response Habitats Regulations The proposed housing allocation is not justified or The CDP has been subject to a full HRA which Assessment (HRA) sound or legally compliant by virtue of the provisionshas gone through the whole process, so all sites of the Habitat Regulations. Contend that the housingwithin 6km of the coastline (including Former allocation does not accord with the Court of JusticeSeaham School) have been subject to of the European Union (People over Wind) which Appropriate Assessment. has implications in relation to any development proposals or plans that may affect European nature conservation sites. The recent ruling has established that where a Habitats Regulations Assessment may be required for a development, mitigation cannot be taken into account when considering the screening test for likely significant effects as part of the Habitats Regulations Assessment (HRA). The sites cannot now be screened out of requiring a full appropriate assessment at the initial stage on the basis of taking into account mitigation which may come forward. No evidence can be identified that the sites have has been the subject of a full site-specific screening test for likely significant affects. This is now a requirement that must be undertaken even at the plan stage. It is therefore considered premature and inappropriate to bring forward these sites, in advance of them being screened for likely significant effects. This matter
Appendix A- Preferred Options Statement of Consultation Site Allocations 147 39 H39 Camden Square
can no longer simply be addressed through a generalised application of mitigation measures as has been applied previously to developments within 6km of the coastline.
148 Appendix A- Preferred Options Statement of Consultation Site Allocations H40 Murton Colliery 40
Appendix A- Preferred Options Statement of Consultation Site Allocations 149 40 H40 Murton Colliery
H40 Murton Colliery
Level of support 1 representation supported the allocation.
Reasons for support No reasons were given.
Level of objection 1 representation did not support the allocation.
Reasons for Objection Theme Issue Our Response Habitats Regulations The proposed housing allocation is not justified or The CDP has been subject to a full HRA which Assessment (HRA) sound or legally compliant by virtue of the provisionshas gone through the whole process, so all sites of the Habitat Regulations. Contend that the housingwithin 6km of the coastline (including Murton allocation does not accord with the Court of JusticeColliery) have been subject to Appropriate of the European Union (People over Wind) which Assessment. has implications in relation to any development proposals or plans that may affect European nature conservation sites. The recent ruling has established that where a Habitats Regulations Assessment may be required for a development, mitigation cannot be taken into account when considering the screening test for likely significant effects as part of the Habitats Regulations Assessment (HRA). The sites cannot now be screened out of requiring a full appropriate assessment at the initial stage on the basis of taking into account mitigation which may come forward. No evidence can be identified that
150 Appendix A- Preferred Options Statement of Consultation Site Allocations H40 Murton Colliery 40
the sites have has been the subject of a full site-specific screening test for likely significant affects. This is now a requirement that must be undertaken even at the plan stage. It is therefore considered premature and inappropriate to bring forward these sites, in advance of them being screened for likely significant effects. This matter can no longer simply be addressed through a generalised application of mitigation measures as has been applied previously to developments within 6km of the coastline.
Appendix A- Preferred Options Statement of Consultation Site Allocations 151 H41 Dunelm Stables 41
Appendix A- Preferred Options Statement of Consultation Site Allocations 152 H41 Dunelm Stables 41
H41 Dunelm Stables
Level of support 2 representations supported the allocation.
Reasons for support It was commented that the site can deliver a high number of units and is an important regenerative site.
Level of objection 0 representations did not support the allocation.
Appendix A- Preferred Options Statement of Consultation Site Allocations 153 H42 Grove Works 42
Appendix A- Preferred Options Statement of Consultation Site Allocations 154 H42 Grove Works 42
H42 Grove Works
Level of support 2 representations supported the allocation.
Reasons for support The site will involve infill and previously-developed land.
Level of objection 9 representations did not support the allocation.
Reasons for Objection Theme Issue Our Response Housing The site would be well suited to elderly residential accommodation.
The site is no longer allocated owing to further evidence which has raised concerns regarding site viability.
Environment Site allocations should avoid harming the The site is no longer allocated owing to further significance of both designated and undesignated evidence which has raised concerns regarding heritage assets, including effects upon their site viability. setting. Whilst the SHLAA assessment for Grove Works (H42) does discuss the need for a sensitive approach, it assumes that the existing buildings can be cleared without an assessment of their
Appendix A- Preferred Options Statement of Consultation Site Allocations 155 42 H42 Grove Works
contribution to the special interest of Barnard Castle Conservation Area. Even with the (limited) assessment given, there is no historic environment mitigation included in the policy. We would recommend that the Council clearly demonstrates that the appropriate assessments have been undertaken, and if any harm is identified to heritage assets, demonstrates how that harm might be removed or reduced. If, at the end of the process, it is concluded that the development would still be likely to harm elements which contribute to the significance of the heritage assets, then the sites should not be allocated unless there are clear public benefits that outweigh the harm (as is required by the NPPF, paragraphs 195 and 196).
Infrastructure No corresponding increase in public services The site is no longer allocated owing to further including doctors, policy, fire and ambulance to evidence which has raised concerns regarding accommodate the additional housing which has site viability. been built in recent years. Highways Traffic needs to be controlled within the town. The site is no longer allocated owing to further evidence which has raised concerns regarding site viability.
156 Appendix A- Preferred Options Statement of Consultation Site Allocations H43 Land off Leazes Lane 43
Appendix A- Preferred Options Statement of Consultation Site Allocations 157
H43 Land off Leazes Lane
Level of 1 representation supported the proposed allocation support
Reasons for No reason was given support
Level of 7 representations objected to the proposed allocation objection
Reasons for Theme Issue Our Response Objection Land • The housing allocations do not seek to The CDP includes a flexible policy approach to support Availability/ improve the lower dales or western rural communities. In allocating further land for housing Allocations settlements. The smaller communities according to the preferred spatial strategy the Plan has of Weardale have no allocations taken into account existing unimplemented planning beyond historic sites that have not been consents which exist across the county and including the pursued by the developers. The dales area to which this representation refers. Furthermore, the become sleeper communities that are Plan makes further provision for suitable housing to be losing local services due to closure of provided on unallocated sites and within the countryside schools etc. where policy criteria are met.
The site selection methodology to meet the preferred • Of all the local centres proposed for Spatial Strategy is set out in The Rationale for Housing housing allocations there are large Allocations document. Viability is one element of site inconsistencies in the quantum of selection but is not the only driver in terms of the housing units, both compared to land development of the Preferred Spatial Strategy. values which is linked to deliverability and geographical coverage. The The Head of the school referred to recently addressed average total allocation size for local Stanhope Parish Council in respect to his plans for the centres across the County is c100 units sixth form. The falling school roles are attributed to a and should be appropriately distributed number of other factors which fall beyond the scope of the to support the rural and tourism Plan and housing land supply. economy of West Durham. Furthermore, the higher viability of The site selection methodology referred to above clearly housing in these areas further supports prioritises suitable, deliverable PDL sites such as H43. a larger allocation for Wolsingham as housing is more likely to be delivered than in less viable areas. Ultimately the current approach stifles the areas vitality and will be detrimental to its growth and prosperity.
• Wolsingham Sixth Form College is closing in order to release the land for housing. How is this sustainable? The rural communities have been ignored in the Plan to make way for a more prosperous Durham City.
• Any sequential advantages of using PDL should be balanced by the poor sustainability of H43 in comparison to our client’s land.
Infrastructure • Concern expressed about provision of Through the associated Infrastructure Delivery Plan the schools, doctors and transport links in Plan recognises the need to ensure that all new the area. development is supported by appropriate infrastructure provision and mechanisms are embedded within the • Whilst this site is previously developed policy framework to require this of developers where land this must be balanced against the applicable. The Plan includes a requirement for poor relation to the existing settlement, developers to mitigate any such impacts over and above facilities and services which will mean it the existing situation which arise from new development. will become an isolated cluster of housing with a minimal functional role The site has been assessed as suitable in the SHLAA in supporting the settlement, the site is and is considered to have acceptable access to services further from bus stops and grows the and facilities capable of supporting development. The settlement northward as opposed to a policy has been the subject of rural proofing to ensure traditional linear pattern of that rural areas are not prejudiced and treat inequitably. development. A new Playing Pitch Strategy (PPS) for County Durham is • Planning policies should be based on in preparation and will update and replace the PPS and robust and up to date assessments of associated Playing Pitch Action Plans from 2013. The the needs for open space, sports and PPS will assess the current and projected supply and recreation facilities and opportunities demand for pitches, including a technical analysis of pitch for new provision. The PPS coverage quality and usage levels. The findings of these for County Durham will become out of assessments will provide the evidence of where provision date as the Plan progresses to needs further consideration and/or to be adoption. Where a PPS is out of date it protected/enhanced and inform the development of both is not possible for a Plan to be able to strategic and sport specific recommendations. The justify allocations, which seek the strategy will set out site by site recommendations based development of playing field sites, on predetermined areas aligned to the County Durham unless it is proposed that the playing Plan (five delivery areas). It is noted that the field be replaced as part of the plan. development site will be required to maintain a suitable maintenance access to the adjacent playing pitches.
Heritage • Site allocations should avoid harming A Heritage Assessment has since been carried out in the significance of both designated and respect to the site as part of the Submission version of undesignated heritage assets, including the Plan in response to this concern. It is considered that effects upon their setting. The this addresses the concern raised. The site has also Evidence Base does not fully address been the subject of Sustainability Appraisal which the historic environment for the housing balances the social, economic and environmental allocations identified in Policy 5 or credentials of the site, including heritage impact. constitute a proper assessment. Assessment of individual allocations in the SHLAA Individual Site Assessments is not sufficient, identifying only the presence or absence of heritage assets rather than assessing impact on significance. For example, from an initial look through the allocations, we have noted the following: The SHLAA assessment for Land off Leazes Lane (H43) is contradictory: its 'heritage assessment' concludes it is likely to have a major negative impact on Wolsingham Conservation Area whilst the 'outcome' on the same page says it would not. No mention of historic environment impact is given in the policy. We would recommend that the Council clearly demonstrates that the appropriate assessments have been undertaken, and if any harm is identified to heritage assets, demonstrates how that harm might be removed or reduced. If, at the end of the process, it is concluded that the development would still be likely to harm elements which contribute to the significance of the heritage assets, then the sites should not be allocated unless there are clear public benefits that outweigh the harm (as is required by the NPPF, paragraphs 195 and 196).
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