The City of Durham Trust

The County Durham Plan

Trust Responses to the Issues and Options consultation

Trust responses to the County Durham Plan

Durham County Council is rerunning the County Durham Plan, starting at the Issues and Options stage. The City of Durham Trust is commenting on 37 of the questions, plus two paragraphs of supporting text. There are three other related consultations that we have also commented on.

The list below shows the questions we are responding to, summarises our response, and links to a PDF with the full text.

Sustainable Transport Strategy

We conclude that it is a research and consultancy report, not a strategy. It fails to meet the key test of any strategy to explain how policy goals will be secured. It is also not sustainable as it does not explain how it will be implemented, funded and ultimately sustained.

Interim Sustainability Appraisal

This is only partial in its scope, and its limitations and omissions are of such significance that the document cannot provide a sufficient and robust Sustainability Appraisal for the proposals and options set out in the Council’s Issues and Options consultation. A fuller review is required.

Paragraph 1.14: Equality Impact Assessment

The EIA has completely failed to take into account the disparity between male and female rates of employment and the trends in these rates over time. Since 2009 the male employment rate in County Durham has fairly consistently been better than the North East average, but the female rate has been markedly worse and the trend appears to be deteriorating.

Question 1: Spatial Vision for County Durham

The Spatial Vision is based on a Sustainable Communities Strategy dating from 2014 which has been overtaken by events, such as the vote for Brexit. It needs to be brought up-to-date.

Question 2: The Strategic Objectives

We say that there needs to be an additional objective to achieve inclusivity by eliminating all gender, race, age and cultural gaps in employment and entrepreneurship. We doubt that the objective of achieveing a 73% employment rate is, in fact, achievable. And the objectives should promote the creation of sustainable, inclusive and mixed communities and maintain an appropriate housing mix.

Question 3: Is County Durham a single Housing Market Area?

This is a technical question, and we argue that the County is a number of overlapping housing market areas.

Question 4: Which population growth scenario do you prefer?

All of the population growth scenarios proposed are too high.

Question 5: Is the ambition to increase the employment rate to 73% realistic?

We say that the employment rate is a crude and unreliable measure. Crude because it masks variations between the genders and between different parts of the County. Unreliable because circumstances have changed too much between 2007 and 2016 for comparisons to be accurate at the level of one or two percent.

Question 6: Windfall allowance for small sites

We welcome the proposal to include a windfall allowance for small sites less than 0.4 hectares (12 houses).

Question 7: Windfall allowance for large sites

We consider that, contrary to the Council's intentions, that a windfall allowance for large sites of over 0.4 hectares (more than 12 houses) should be made.

Question 8: Annual allowance for bringing back empty properties into use

We applaud the proposal to include an allowance of 50 units per year and would endorse a higher figure if evidence emerges in support.

Question 9: Annual alllowance for demolitions

We agree that an allowance of 50 demolitions per year is appropriate

Question 10: Spatial Distribution of Development

We would add a further factor for considering spatial strategy, namely impact on female employment rates.

Question 11: Distribution of Employment

We will make the case for Spennymoor and Durham Gate being a regional market area, and suggest that there are parts of the County which do not have all the attributes needed to be a most attractive market area and yet have a pressing need for more employment opportunities.

Question 13: Distribution of Housing

We do not support the main town focus option, but would support any of the other three options, with the proviso that the evidence does not support as many houses as envisaged so it is not necessary to build on the Green Belt.

Question 14: Green Belt deletions: exceptional circumstances

There are no exceptional circumstances that might justify any Green Belt deletions.

Question 16: Specific Use Employment Sites

We agree that it is appropriate to identify some employment sites that are only suitable for a particular type of employment use, for example research and development.

Question 17: Aykley Heads

We support option (a), only reusing existing land currently used for employment, excluding any Green Belt land.

Question 18: Out of Centre Retailing

We agree that the default threshold of 2,500m² would be appropriate for Durham.

Question 19: Exception Sites

We consider that there needs to be a well-founded base of evidence before deciding this question, and that is not currently available.

Question 20: Rural Tourism

We consider that it is not appropriate to determine this question until there are policies being drafted that may or may not require flexibility in rural areas.

Question 21: Affordable Housing

We recognise that there are circumstances where it would be appropriate to accept a financial contribution to be used to provide affordable housing elsewhere rather than have the affordable housing provided on-site, but argue that this option is allowed only in extremis as it is by its nature socially divisive.

Question 22: Housing for Older People

We feel that developers should be required to build a proportion of homes suitable to meet the needs of older people.

Question 25: Student Accommodation Interim Policy

We support the intention to include this Policy in the County Durham Plan, with the proviso that we may suggest amendments during the pre-submission consultation in the light of up-to-date evidence.

Question 26: Type and Mix of Housing

We argue that there needs to be both county wide targets as well as assessing this on a site-by-site basis.

Question 27: The Existing County Durham Green Belt

We maintain that the existing Green Belt boundaries continue to serve their purpose and consequently there should be no deletions for housing development.

Question 28: New Areas of Green Belt

We say that the priority must be to retain the Green Belt with its current boundary. There is a case to consider taking the outer boundary of the Green Belt around Brandon, Langley Moor and Meadowfield.

Question 30: Major Developed Sites in the Green Belt

We feel it would be useful to have a general policy to continue the existing criteria regarding the development of these sites.

Question 31: Possible New Roads

We do not accept that congestion and delays in and around Durham City are on the scale implied, nor that they have significant adverse economic impacts. Consequently we do not accept that traffic congestion in and around Durham City justifies the building of new roads, and indeed the effects of the two city relief roads proposed would be to increase the total volumes of traffic using the local network, with resultant additional congestion.

Question 32: Traffic in Durham City

We will agree that existing levels of motorised traffic in Durham City have an unacceptable impact on the ability of pedestrians and cyclists to move freely around the city and have wider adverse effects on the city because of the intrusion and pollution caused by motor vehicles. However, we reject the Council’s proposition that the provision of a new by-pass such as a Northern Relief Road is necessary in order to improve conditions for other road users in Durham City: instead the provision of more road space simply increases total motor traffic volumes in the area and ultimately further degrades conditions for other categories of road user.

Question 33: Possible Transport Infrastructure in Durham City

We remain totally opposed to the construction of a Northern Relief Road and to the proposal to relocate the bus station. We support improving pedestrian links between the University and the city centre and filling missing links in sustainable transport access at Aykley Heads, Sniperley, Framwellgate Moor and Newton Hall, together with junction and crossing improvements to give better priority to pedestrians and cyclists. Early action is needed to develop a network of safe walking routes across the City. And finally, we would like to see Metro services extended to Belmont.

Question 34: Durham Western Relief Road

We argue that the Western Relief Road is not needed.

Question 35: Wind Turbine Development

We are not inherently opposed to new wind turbines, but no development should be allowed which interferes with long views of the World Heritage Site.

Question 36: Requiring good design

New housing developments should be required to meet the latest Building for Life standard.

Paragraph 4.122: Energy Efficiency

We cite the finding that although new homes are more energy efficient once built, 50 tonnes of carbon emissions are generated in their construction, compared to 15 tonnes for the refurbishment of an existing property. We therefore urge that refurbishment should be part of the mix.

Question 37: Hot Food Take-aways

We agree that the number of hot food take-aways needs to be limited in our town and local centres. In addition hours of opening need to be limited in residential areas, and steps taken to prevent public nuisance.

Question 38: Water Management, including Flood Risk

We agree with this proposal, but add that more needs to be done to prevent the growth of hard standing, which leads to faster run-off and increases the risk of flash floods.

Question 39: Strategy for the Historic Environment

We argue for the retention of the policies in the previous version of the Plan, as these met with broad support.

Question 40: Magnesian Limestone

We agree that no further sites for new working are required.

Settlement Study Methodology

The Settlement Study seeks to understand the availability of facilities and services within settlements across the county. Previous studies were undertaken in 2009 and 2012, and the Council is updating its methodology before conducting a further study. We have made some suggestions about how it might be improved, and have resubmitted the response we made to the 2012 Study.