Cover: The route of the County Council’s proposed Western Relief Road through the countryside of the Browney Valley in Durham’s Green Belt CONTENTS ___________________________________________________________________ __ Page The case in summary for withdrawal of the County Durham Plan 5 Objection to consultation procedures 9 Population and household projections 13 Objection to Policy 1 17 Objection to Policy 2 19 Objection to Policy 3 21 Objection to Policy 4 23 Objection to Policy 5 25 Objection to Policy 6 27 Objection to Policy 7 31 Objection to Policies 8, 9 and 10 33 Objection to Policy 12 37 Objection to Policy 14 39 Objection to Policy 30 42 Objection to Policy 32 43 Objection to Policy 48 45 Appendices: A.1 Friends of the Durham Green Belt pro-forma letter of objection 47 A.2 Newspaper report of meeting addressed by Jonathon Porritt, 4 July 2012 48 A.3 The Friends’ Green Belt leaflet 49 A.4 Other Key documents relevant to this submission 50 A.5 Durham at the Crossroads 51 3 4 THE CASE IN SUMMARY FOR WITHDRAWAL OF THE SUBMITTED COUNTY DURHAM LOCAL PLAN _________________________________________________________________________ __ The Friends of the Durham Green Belt are concerned about issues of procedural compliance and soundness of the County Durham Draft Local Plan and recommend that the Plan should be withdrawn at this stage in order that the weaknesses identified below can be remedied. A critical failure of the Plan is to be found in the population and housing forecasts. The trend in population changes in recent years has been relatively static or slightly growing. Despite this, the Plan’s trend projections have been inflated to suggest a much higher level of inevitable population increase. The Plan then aspires to increase it even further to meet a predetermined house-building target. This is a wholly unacceptable basis for the Plan. Durham County Council’s vision for a successful local economy with high levels of employment, population and housing is expressed in a high growth strategy, the feasibility of which has remained untested. The Council’s alternatives are only variants on their preferred high growth strategy, leading to a dismissal of other possibilities. Our objection is that reasonable alternatives have not been considered (other than alternative distributions of the high growth strategy favoured by the Council). This led to our development of a ‘moderate growth’ alternative, which we submitted for assessment against the Plan proposals. Rather than assessing the two, the Council simply set our alternative aside. The Council’s high-level growth strategy is apparently unchallengeable. Under the provisions of ‘The Duty to Cooperate’, local authorities within a region should agree reasonable strategic levels of growth. No such agreement is apparent, with the consequence that all local authorities are promoting economic growth and housing targets that are likely to prove collectively unachievable. This in turn will lead to wasteful competition between developers to provide housing sites. If the Durham City economy grows at a slower rate than that proposed in the Plan, then the attractive housing sites in the Green Belt are likely to become dormitories for commuters to Tyneside, Wearside and Teesside rather than an essential requirement generated by employment growth in the City. Under this scenario, it is difficult to understand where the benefits are for Durham City and the County as a whole. In the absence of options based on more realistic growth, the consequences for the remainder of the County remain unexplored. One possibility is that areas outside Central Durham that continue to need regeneration will be starved of resources, a question that has been avoided in the optimistic ‘growth for all’ vision. The impact on Durham City’s Green Belt remains the focus of our objection. The willingness of the County Council to accommodate 4,000 dwellings, a further exclusive executive housing site, a commercial development site and two relief roads in the Green Belt to achieve a ‘critical mass’ for the City is quite plainly contrary not only its own Green Belt policy but also national policy. There are no ‘very special circumstances’ that demand it. On the contrary, there is every reason to invest in Durham City’s future by exploiting its special strengths as a World Heritage Site and a city with a world-class University that spins out high technology and knowledge-based enterprises in the County such as at NetPark in Sedgefield. The Plan contains exemplary policies based on sustainability principles but these are treated as discretionary rather than mandatory where proposals do not accord with them, such as housing and two relief roads in the Green Belt and executive housing in an historic landscape. 5 The Draft Plan fails to treat student accommodation as a strategic matter. The County Council and the University have not identified any new major site to accommodate planned increases in student numbers. Without a strategy for student accommodation, the conversion of houses into multi-occupation and the exploitation of brownfield sites in the City for new student accommodation will continue. For many people in Durham, this failure alone is sufficient to judge the Plan as unsound In the round of consultation finishing on 9th December 2013 (which was presented by the Council as another chance to comment), it was not made clear that this was the one and only opportunity to object to any aspect of the Plan. Even if a member of the public understood that the opportunity existed, it is likely that the terminology in which a formal objection should be made would deter any potential objector. The Friends of the Durham Green Belt were so concerned at this lack of clarity that we published a letter in the Durham Advertiser on 20th November 2013. This was an invitation to members of the public to send it to the Council in its entirety or in a modified form to compensate for the Council’s failure to face up to the possibility that there might be considerable objection to its proposals. There are many consequences resulting from the inflated population and housing forecasts and from the refusal to treat any contrary views seriously. We have listed in the schedule below our separate elements of objection, but we believe them to be in combination a devastating commentary on an unsound and potentially non-compliant Plan. Policy or Policy Nature of the Objection Statement Consultations Contrary to the NPPF requirement on ‘empowering local people to shape their surroundings’, the County Council has constructed elaborate and costly consultation exercises with little evidence of willingness to respond positively to contrary views or to simplify the process to encourage genuine public engagement. Paragraphs 4.22 to Elements of the forecasting process are extremely unconvincing. 4.27 – Population and There is a very strong case for new population and household housing forecasts forecasts being undertaken and agreed before consideration is given to any other aspects of the Plan. Policy 1 – Sustainable Sustainability criteria are treated as discretionary to enable non- development conforming proposals to be judged to be sustainable development. Policy 2 – Spatial The hierarchy of settlements included in the Policy is approach accompanied by text that concedes that growth in Durham City is more likely to dominate. In the event that growth is lower than the target for the County set by the Plan, the allocations in the City will all be taken up, and the allocations in the remainder of the County will fail to develop. The Plan must examine this more probable lower growth scenario to protect the interests of the rest of the County and protect the City from over-development. This would require major consequential changes to Policies 4, 6 and 8 and their accompanying reasoning. 6 Policy 3 – Quantity of The Council has failed in its ‘Duty to Cooperate’ with new development neighbouring authorities to agree compatible strategic population and housing levels. In addition, unsound population forecasts have resulted in allocations of housing within the Durham City Green Belt. Competition for housing development will lead to Green Belt sites providing homes for commuters to Tyneside, Wearside and Teesside. Policy 4 - Distribution The distribution of housing developed is unbalanced, with too of development much in Durham City, and with inadequate recognition of windfall, brownfield, empty homes and vacated student conversions in the City. Policy 5 – Developer We object to the use of developer contributions for the building of Contributions unsustainable relief roads. Policy 6 – Durham City The willingness of the County Council to accommodate 4,000 dwellings, a commercial development site and two relief roads in the Green Belt to achieve a ‘critical mass’ for the City is quite plainly contrary not only its own Green Belt policy but also national policy. There are no ‘very special circumstances’ that demand it. On the contrary, there is every reason to invest in Durham City’s future by exploiting its special strengths as a World Heritage Site and a city with a world-class University that spins out high technology and knowledge-based enterprises in the County such as at NetPark in Sedgefield. Unrealistic targets for employment, population and housing growth in the County and lack of consideration of reasonable alternatives including a ‘moderate growth’ alternative put forward by the Friends of the Durham Green Belt. The Council’s ‘critical mass’ justification to enhance Durham City’s status is spurious in relation to its international reputation. Also the absence of an assessment of the impact on areas outside Central Durham of slower growth (no ‘Plan B’ to ensure that Durham City does not grow at the expense of all other areas). Policy 7 – Aykley To allocate 7.5 hectares of Green Belt for prestige office Heads development is contrary to Green Belt policy.