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Durham University, I Submit the Following Written Representations to the Durham City Neighbourhood Plan Consultation 2020

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Durham University, I Submit the Following Written Representations to the Durham City Neighbourhood Plan Consultation 2020 17th February 2020 Spatial Policy Team Regeneration and Local Services Room 4/24 County Hall DH1 5UQ [email protected] Dear Sir or Madam, Representations to the Draft Durham City Neighbourhood Plan Consultation 2020 Introduction On behalf of Durham University, I submit the following written representations to the Durham City Neighbourhood Plan Consultation 2020. Our comments are outlined in the below table. Reference Existing text Proposed Action & Comment Chapter 2: Background Page 8 - 2.7 Durham University's expansion from about The University have previously made Paragraph 2.7 3,000 students in the early 1960s to over 18,000 representations to the Neighbourhood Plan and 2.8 in Durham City today has added much economic that it considers these paragraphs to be benefit as well as prestige to the City. However, a unbalanced without evidence and based on commensurate increase in University anecdote. accommodation has not been provided and many family homes have been converted into student Over the same period most towns and cities accommodation, to the extent that in several have had a similar evolution due to the areas permanent residents are a minority and in changing residential, retail & leisure some a rarity. preferences of the local populace. These 2.8 This change in property use means that large paragraphs indicate that the changes faced areas of the City are predominantly populated by by Durham City are purely as a result of the young adults for half of the year and virtually growth of Durham University which is an empty the other half, with consequent effects on overly negative interpretation and without local shops, facilities and community cohesion. substantive evidence. The local retail offer has suffered from a loss of independent family-friendly shops and The University considers that its growth has department stores. Leisure facilities are geared to actually insulated Durham City from the the evening economy. The City has lost its worst of deprivations suffered by much internationally renowned ice rink, its multi-screen cinema (though this has now been replaced), larger towns and cities in the North East such much green space and sporting facilities, youth that the city continues to be an attractive clubs and scout and guides groups. Schools, place to live, work, study and invest. doctors, libraries and other public services are Recently the University has invested £30m affected by the distorted population structure of into facilities at the Maiden Castle Sports the City. The University has published a Strategy Park, which is heavily used by the local and Estates Masterplan (Durham University, community. Without this the nearest 2016, 2017a) setting out its intention to grow in comparable facilities would be in Newcastle. David W Loudon MCIOB, CBIFM, MBA Director Mountjoy Centre, Mountjoy, Durham, DH1 3LE Telephone +44 (0)191 334 6000 www.durham.ac.uk student numbers to a total of 21,500 in Durham City by the year 2026/27. This raises major issues Therefore, we request that these paragraphs around the capability of the City – socially, be rewritten in a more positive/neutral tone economically and environmentally – to similar to and in line with wording included accommodate significant additional pressures on in the Local Plan Submission Draft to outline the housing stock, local services, the retail offer, the positive impacts that the growth of the pedestrian congestion, and community balance. University has had; including attracting new businesses, creating jobs, increasing entrepreneurship, increasing diversity in science and high-tech industries and the role it has played in developing the tourism offer. Chapter 4: Planning Policies & Proposals for Land Use Page 28 – Policy Policy S2: The Requirement for Masterplans The policy requirement for a masterplan to S2: The A masterplan for all major development sites will be produced and used as a material Requirement for be required to ensure the highest quality of design consideration in the determination of Master Plans in our historic neighbourhood and to prevent applications is not considered necessary or large-scale change through piecemeal to be in accordance with the NPPF. The development. policy specifically mentions issues relating to traffic, impacts on views and landscape, all of which are material considerations and would be taken into consideration and assessed during the determination of any detailed planning application on a case by case basis. Notwithstanding the above, the policy is not specific. The PPG outlines at paragraph 041 that neighbourhood plan policies should be ‘clear and unambiguous’ and should be ‘drafted with sufficient clarity that a decision maker can apply it consistently and with confidence when determining planning application.’ In this case, there is a lack of clarity as to when a masterplan would be required and it is therefore not considered to accord with guidance in the PPG. This policy is not considered to accord with the NPPF and PPG and should be removed. Page 29 – 4.29 Durham County Council’s Durham City The reference to Milburngate and the Paragraph 4.29 Masterplan Update (October 2016) refers to the Durham City Masterplan Update is not Milburngate House site and states that the relevant. Milburngate as a site has been Council “will work through the planning process to through detailed and rigorous planning ensure a high quality and sensitive scheme is application process and the masterplanning developed on this exceptional site within view of element was included as part of the the World Heritage Site” (p.8). This is precisely the application process. The DCC Durham City sort of site to which this policy on master plans David W Loudon MCIOB, CBIFM, MBA Director Mountjoy Centre, Mountjoy, Durham, DH1 3LE Telephone +44 (0)191 334 6000 www.durham.ac.uk would apply. Other such sites in Our Masterplan Update is not planning policy but Neighbourhood are Aykley Heads, Mount Oswald, strategic guidance. Mountjoy, Hild/Bede and Elvet Riverside; others This paragraph makes reference to several might become available in the future. University sites, including Mountjoy, Hild/Bede and Elvet Riverside. Development of these sites is addressed within the Durham University Estate Masterplan which already sets out the strategic guidance and intentions for the sites. Consideration of issues including impact on the WHS and views and design will be fully considered and addressed as part of any planning application. Planning applications will be determined in accordance with section 4 of the NPPF (decision-making) and will satisfy the appropriate tests and level of detail required on a site by site basis. This includes giving due consideration to design policies and guidance, including relevant management plans and conservation area appraisals. As such there should not be a separate requirement for a masterplan and this approach is not supported by the NPPF. Page 35 – Policy Development proposals within the World It should also be noted that the NPPF H1: Protection Heritage Site must sustain, conserve and enhance highlights at paragraph 200 that of the World the World Heritage Site by: opportunities for new development within Heritage Site a) taking account of both the historical and WHS that enhance or better reveal their present uses of the World Heritage Site; and significance should be taken. This policy b) proposing high quality design which contributes should also accord with the NPPF to the quality and significance of the World paragraph’s 193-196 which sets out the Heritage Site; and relevant tests for considering the impacts of c) using materials and finishes appropriate to the development on heritage assets. vernacular, context and setting; and d) seeking balance in terms of scale, density, massing, form, layout, landscaping and open spaces. Page 37 – 4.39 The implementation plan will be undertaken There are two Paragraph 4.39’s. The second Paragraph 4.39 by the World Heritage Site Coordinating follows paragraph 4.44 and precedes 4.45. Committee whose local representatives include This should be renumbered. Durham Cathedral, Durham University, St John’s Also strictly speaking University College is College and University College (as landowners)… not a landowner with the ownership of the Castle, Palace Green and the surrounding buildings resting with Durham University. David W Loudon MCIOB, CBIFM, MBA Director Mountjoy Centre, Mountjoy, Durham, DH1 3LE Telephone +44 (0)191 334 6000 www.durham.ac.uk Page 39 – 4.48 Views of the Cathedral from within Our Chapter 16 of the NPPF sets out that when Paragraph 4.48 Neighbourhood are many and various: they considering the impact of a development on include the well-known view from a train on the the significance of a designated heritage Viaduct and also the view from the railway station, asset, great weight should be given to the Wharton Park, Observatory Hill, the University of asset’s conservation (and the more Durham Hill Colleges, Farnley Rise, the approach important the asset, the greater the weight to the peninsula from Kingsgate Bridge and the should be) (para 193). Where a proposed slip road from the Motorway to Gilesgate development will lead to substantial harm, roundabout. Plan 2 from the Durham World local planning authorities should refuse Heritage Site (2017, p.19) Management Plan consent unless it can be demonstrated that shows notable viewpoints (see Map 2 in the the substantial harm or total loss is Neighbourhood Plan). This list is indicative and not necessary to achieve substantial public exhaustive. It is essential that views of the World benefits that outweigh that harm or loss Heritage Site are not obstructed by new (para 195). Where a proposed development developments. will lead to less than substantial harm, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use (para 196). Based on the above, paragraph 4.48 of the draft plan is not considered to accord with the NPPF and the relevant tests for assessing harm and should be amended to reflect the approach set out in the NPPF.
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