Zoe Thirlaway From: Robert Dibden [[email protected]] Sent: 09 December2013 16:45 To: CDP Consultation Cc: Kate McGill; [email protected] Subject: Representation to the Pre-submission Draft of the County Durham Plan [NLP DMS.FlD262720] Attachments: 22336 NWL Plawsworth Reservoir Rep 09-12-2013.PDF Dear Sir/Madam, Please find attached a representation to the Pre-submission Draft of the County Durham Plan, made on behalf of our client, Northumbrian Water Limited, in respect of land at Plawsworth Reservoir, Plawsworth. We would be grateful if you could plea5e confirm receipt of our representation. Should you have any queries regarding the representation, please do not hesitate to contact Kate McGill or myself. Kind regards, Robert Robert Dibden Planner Nathaniel Lichfield & Partners, Generator Studios, Trafalgar Street, Newcastle Upon Tyne NE1 2LA T 0191 261 5685 / E rdibden nlnolanninricorn nlpplanning.com -Brochures&Reports Sal0, NIP Graphic Design: I -aI 4 - Mapping & Data f” Delivering innovative design solutions -Events 6. I Click hereto view ott new Graphic Design Brochure - Branding riJ This email is for the use of Lhe addressee, It may contnjn information which is confidential and exempt from disclosure. If you are not the intended recipient you must not copy, distribute or disseminate this email or altrhn,ents to anyone other than the addressee, If you receive this commun,c,at,cn in error please advise us by telephone as soon as possible. Nalhaniel Lichheld & Partners Limited is registered in England. no. 2778116. Onr registered office is at 13 Regents Wharf, All Saints Street, London Ni 9RL. Think of the environment. Please avoid printing this email unnecessarily. 1 2011-2012 Planning ‘f JuitGIvMg 201.2-2013 ((Awards Nathaniel Lichfield Consultancy Ctth 7.., Partners ‘ , & of the Year 1fl 2013 Planning. Design. Economics. Freepost Spatial Policy Generator Studios Trafalgar Street Room 4/24 Newcastle upon Tyne NE1 2LA Durham County Council 0191 261 5685 County Hall newcastle@n p planning. corn Durham County Durham nlpplanning.com DH1 5UQ Date 09 December 2013 Our ref 22336/JW/RDi/5968O78v2 Dear Sir/Madam Representations to County Durham Pre-Submlssion Draft Local Plan We write on behalf of our client, Northumbrian Water Limited (NWLI), in order to set out representations to the above document in respect of land at Plawsworth Reservoir, Plawsworth (please see attached plan at Appendix 1). These representations request that the Green Belt boundary should be amended to exclude the Plawsworth Reservoir site and the residential property to the north of the site, to create a clearer, more logical, and defensible Green Belt boundary. We consider that, without an amendment to the Green Belt boundary at Plawsworth, this aspect of the Local Plan is not sound as it is neither consistent with national policy nor positively prepared, as discussed below, Context — Plawsworth Reservoir, Plawsworth Plawsworth Reservoir comprises 0.18 ha of previously developed land located to the east of the A167, within the built-up area of Plawsworth. The site, which is owned by NWL, consists of an abandoned reservoir and is bordered to the north and south by residential properties, to the east by open fields, and to the west by the A167 beyond which lies a residential hostel complex. The site is currently grassed over and contains a covered water tank associated with its previous use. It is located predominantly within the Green Belt as defined under Policy NE3 of the Chester-le-Street Local Plan (adopted 2003) and is not identified for development. Plawsworth Conservation Area (Policy BE3) is located immediately to the south of the site. NWL consider that the site represents an excellent opportunity to deliver a sustainable, infill residential development. The site benefits from a sustainable location, being situated within the linear urban form of Plawswofth, between two existing residential properties, and within 350m of the nearest bus stands. There are no significant technical constraints that would prevent the site from coming forward for development and it is envisaged a sliproad access off the A167 could facflitate safe access to the site. Furthermore, the site is available for development now. The only restriction to bringing the site forward for a housing development now and contributing towards the Council’s 5 year housing land supply is the site’s location within the Green Belt. As set out below NoU,an’oI uchtield & Partners Lmited flDgrstcrcd in Engtsnd No. 2778116 orfices also n 14 Regents Wharf Regulated by the RICS NI Saints Stroel cardiff London Ni DRL Leeds London Manchester Nathaniel Lichfield & Partners Planning. Design. Economics. therefore, we recommend that as part of the amendments to the Green Belt which the Council are proposing through the Local Plan, the Plawsworth Reservoir site and the land to the north should be removed from the Green Belt. Vision and Objectives NWL broadly support the Plan’s overall vision that, by 2030, County Durham will have a thriving economy and the County’s distinctive, multi-centred settlement pattern will comprise sustainable, regenerated communities as key locations for new development. In particular, NWL support ‘. Objective 7 regarding housing need, which aims . to ensure that new housing is accessible to, and meets the needs and aspirations of, County Durham’s current and future residents.” This is broadly consistent with national policy and is therefore considered sound. However, in recognition of the need to promote the ongoing sustainability of settlements such as Plawsworth, NWL would suggest the reinsertion of text from the Local Plan Preferred Options Objectives, which stated: “To improve the environmental quality, public services, retail, leisure, education, employment and housing offer of small towns, villages, and neighbourhood centres across the County as a means of tackling economic and social deprivation.” This re-insertion will contribute towards ensuring that the Local Plan is positively prepared and will achieve sustainable development. Policy I — ‘Sustainable Development’ NWL strongly support Policy 1, which seeks to ensure the delivery of sustainable development in County Durham. Most importantly, NWL welcome The acknowledgement of the NPPFs presumption in favour of sustainable development and the Council’s commitment to working with applicants to approve development, where possible, without delay. The Plan is therefore considered sound in this regard. Policy 2 — ‘Spatial Approach’ NWL welcome the principles of the Council’s spatial approach to development, as set out in Policy 2, in particular the assertion that settlements not classed as Main Towns, Smaller Towns or Larger Villages will nonetheless deliver levels of development commensurate to their size and needs. This is considered a sufficiently eftective, flexible and positively prepared approach for the Plan to be found sound. Policy 3 — ‘Quantity of New Development’ The Council’s strategy of meeting the needs and aspirations of present and future residents of County Durham, and delivering a thriving economy, through the provision of an additIonal 31,400 new homes of mixed type, size and tenure, is supported. However, NLP’s HEaDROOM methodology has found that the increase in the level of housing proposed will not meet the Council’s aspirations to deliver 30,000 new jobs throughout the County and, as such, the economic and housing strategies don’t align. NLP’s methodology has found that in excess of 48,000 new homes over the plan period is required to align with economic growth forecasts, P2/6 5968078v2 Nathaniel Lichfield & Partners Planning. Design. Economics. NWL welcome the clear confirmation that the amount of housing proposed is a target to be exceeded. This is a sufficiently flexible approach, consistent with national policy, which wilt make the Plan sound in this regard. Policy 5 — ‘Developer Contributions’ NWL acknowledge that new development should contribute towards the provision and/or improvement of physical, social and environmental infrastructure. However NWL suggest Policy 5 is currently unsound in the context of national policy, and should be reworded to align more closely with paragraphs 203-206 of the NPPF. In particular it should reflect the fact that obligations should only be used where it is not possible to address unacceptable impacts through a planning condition, and should conform to paragraph 204 of the NPPF, being: • Necessary to make development acceptable in planning terms; • Directly related to the development; and • Fairly and reasonable related in scale and kind to the development. Policy 14 — ‘Green Belt’ It is noted that Plawswofth Reservoir is identified as being within the Green Belt in the Local Plan, However, as previously developed land’ adjoining a built up area, NWL request that Plawsworth Reservoir and the property to the north be removed from the Green Belt. The Plan’s current approach to the definition of the Green Belt in this location is considered unsound in terms of its consistency with national policy. The NPPF advises at paragraph 85 that local planning authorities should “...define [Green Belti boundaries clearly, using physical features that are readily recognisable and likely to be permanent” and ‘not include land which it is unnecessary to keep permanently open”. Until recently Plawsworth Reservoir was a functioning utilities facility, with a clear built footprint. It is bounded by residential properties to the north and south, and the A167 to the west. As such NWL consider that Plawsworth Reservoir and the property to the north should be removed from the Green Belt to allow its development as part of the urban grain of Plawsworth end provide a clearer, more logical, and defensible boundary to the Green Belt to the north and east. The removal of Plawsworth Reservoir from the Green Belt would have no impact upon the purpose of the Green Belt in this location, and would not result in any coalescence of nearby settlements. Policy 15 — ‘Development on Unallocated Sites’ and Policy 35 — ‘Development In the CountrysIde’ As currently drafted, and when considered together, NWL consider Policies 15 and 35 to be mutually incompatible.