Another HMO granted planning permission at 9 Cedar Drive, Farewell Hall
Lib Dem Councillor for Nevilles Cross Ward of City of Durham Parish Learn more
In 2014 the Durham Plan will be considered by an external appointed Inspector who will examine in public the plans set out by the County Council for the future development of our County. There is widespread concern about this plan and its impact upon many communities in the region, not least on Durham City. Below I had set out copies of 3 letters of objection, one from myself and the other two from my colleagues Nigel Martin and Owen Temple (Consett). Whereas Nigel and I are concerned about the over development of Durham City and the needless loss of Green Belt land, out at Consett the concern is the lack of growth and investment.
There has been a prolonged pretence at some form of “consultation” exercise but the County Council’s interpretation of “consultation” is to go around telling people what they intend to do. The public’s protests at their proposals fall on very deaf ears. There is no evidence than any of the representations has had any impact on the drafting of the Plan which seems to have remained unchanged from Day 1.
If the County Council’s Plan is approved in its present form it will cause immense damage to the welfare of the City and its rural setting. This outcome is wholly unnecessary for it panders only to the building lobby and its belief, shared by the officers, that building houses answers all economic needs, creating new jobs and wellbeing and that any damage would somehow be transient. The belief is illusory. Housing creates few new jobs and job-hungry factories do not follow houses. It is the other way round; and factory as well as housing space lies in the east of the county. There is no space in Durham City for the large international factories that create long term employment. The proposed scheme at Aykley Heads is small and specialist and will do nothing to remedy long-term endemic unemployment.
To justify large scale house construction the County Council has manipulated an equation called POPGROUP, a product of Manchester University, which can give you whatever answer you like in terms of population growth over the next 20 years. If you put in the right numbers and make the right assumptions you will get the answer you want. There is an analysis of this equation lower down in which I conclude “in summary, the county council has simply created its own answers to justify consuming Green Belt land with unnecessary additional housing. The model used may be built on an aspiration; but it has no basis in fact.”
My conclusion contained in the formal objection to the County Council was that “without major amendment the emerging Durham Plan is not fit for purpose and represents a major disservice to the people of County Durham now and in the future.”
The letters are available below, within the “Keeping you updated” section of my website and on the below linked pdf files, should you wish to view them.
THE DURHAM PLAN Population notes January 2014
THE DURHAM PLAN GH OBJECTION January 2014
DURHAM PLAN Letter of Objection from OT January 2014
DURHAM PLAN Letter of Objection from NM January 2014
From Councillor Grenville Holland
Dear Mr. Timmiss,
Formal Objection to the pre-Submission Draft of the Durham County Plan
Please accept this letter as an objection to the Plan. I consider that the Plan is ‘unsound’ and procedurally non-compliant for the following reasons.
Without major amendment the emerging Durham Plan is not fit for purpose and represents a major disservice to the people of CountyDurham now and in the future. Please record my formal objection to this Plan and kindly confirm that you have received this objection.
From Councillor Nigel Martin
Merryoaks Housing Allocation (4/LB/05)
I wish to register my objection to the inclusion of the allocation of 250 houses on the site referred to in the plan as located at Merryoaks.
I am one of the elected CountyCouncillors for the Neville’s Cross Division in which the site lies. I have been the elected CountyCouncillor for the area continually since May 1985 (over28 years), and know the area well.
My objections are based on (a) green belt impact, (b) traffic impact, and (c) community impact.
Green Belt Impact
1. The County Durham Plan has been constructed with a strategic aim of making DurhamCity a ‘development hub’ [my words] for CountyDurham. The Plan argues that this aim requires a significant increase in housing around DurhamCity, to which end it identifies several ‘strategic housing sites’ [its words] around the city at Sniperley, North of Arnison and Sherburn Road.
2. The Plan uses the strategic nature of these proposals to justify the removal of green belt status for the three areas concerned. Within the earlier development of the Plan, no other sites were identified as ‘strategic’, and the Merryoaks site was explicitly excluded from housing allocation. The latest version of the SHLAA states that “the site was only deemed unsuitable in the [earlier versions of the] SHLAA on count [sic] of it being located in the green belt”.
3. The stated reason for the late inclusion of the Merryoaks site for housing is due to a submission by Persimmons Homes dated July 2013 in which the company provides a new traffic impact assessment for the development relying on the proposed Western Relief Road. This assessment, provided by Milestone Traffic Planning (MTP), is claimed to give sufficient evidence for the site now to be included as a viable housing site in the Plan.
4. The MTP assessment is based on existing data and it is clear that the Council could, if it had so desired, have commissioned such an assessment itself when considering whether to include Merryoaks at an earlier stage.
5. The fact that the Council chose not to commission such an assessment itself, is clear evidence that the Council has never viewed the Merryoaks site as having intrinsic strategic value in relation to the economic development policy embedded within the Plan.
6. As there is no evident strategic role for this site, and since it lies within the boundary of the existing Green Belt, there is no reason why the legal protections of the Green Belt in this area should be overturned and changed, otherwise the whole principle of Green Belt as long-term protection for certain areas of the countryside is undermined at a fundamental level.
7. On this basis the inclusion of the Merryoaks site for housing in the Plan is wrong and is objected to.
Traffic Impact
8. As stated in para. 3 above, the MTP traffic assessment is crucial to any decision on housing provision on the site. While not wishing to challenge the base traffic numbers into and out of the site at peak times in numerical terms, I do wish to challenge the claimed routes that would be taken by drivers in certain cases.
9. In particular, it is claimed that significant numbers of vehicles travelling to the centre of or to the East of the City will choose to take a route that goes south to the Cock of the North roundabout, then by the A177 (South Road) to the New Inn traffic lights and then east along Stockton Road. This would be perverse behaviour.
10. In the mornings, weekday traffic habitually backs up along South Road up to and often past the current entrance to MountOswald. On the other hand, the inward route from the Duke of Wellington lights down Potters Bank is relatively queue-free and would certainly be the route of choice for any resident from Merryoaks, even with a queue to the lights at the Duke of Wellington (where there is some right-turn lane capacity).
11. Conversely, in the evening, there is usually a long slow-moving queue up Potters Bank to the Duke of Wellington lights, and anyone driving from Stockton Road, to the New Inn lights would surely choose to go up South Road, via the Cock of the North and back to Merryoaks along a relatively uncongested route.
12. These two examples of the outcome data fail to fit with common sense, and must therefore place the exercise under challenge.
13. The MTP assessment also appears to ignore the impact of the already-approved development on MountOswald. In discussing highway capacity on Page 5 of the MTP document, it states that “the need to carry out junction modelling assessments will be informed by future year forecast flows and committed development traffic generation within the vicinity”. It then notes that these include MountOswald and Browney Lane.
14. The phrase “future year forecast flows” appears to imply that the cumulative effects of such flows have not been taken into account in the MTP modelling.
15. In addition there are other minor sites in the area (22 houses on Potters Bank and 14 on Redhill Lane) that are currently being built, together with a projected student hall for 450 residents on the nearby Sheraton Park estate, which have also been ignored in the assessment. The last may not generate a large amount of resident traffic, but it will generate service and staff traffic movements.
16. I believe, therefore, that the evidential base for the traffic assessment is fundamentally flawed and cannot be relied on as a basis for including Merryoaks as a large housing site in the Plan.
17. In any case, the impact on the New Inn junction is unsustainable. The following is an extract from the report to the County Planning Committee in February 2013 on the outline application to develop MountOswald:
“The [MountOswald] application site is considered to be in a sustainable location in terms of proximity and connectivity to Durham City Centre. However, both the A177 and A167 become heavily congested at peak periods and can suffer traffic delays. This is particularly true of the A167/A690 Neville’s Cross junction, and the A177 New Inn junction. Both are traffic light controlled, at peak times operate close to or at capacity, and are constrained in terms of improvement by buildings and infrastructure.”
18. The MTP assessment indicates 91 additional AM peak period traffic movements through the New Inn junction and an additional 85 PM peak period movements through that junction.
19. While mitigation procedures were required as part of the MountOswald approval, development of the Merryoaks site would necessarily imply a further step change in the pressure on the New Inn junction that is clearly unsustainable.
20. For this reason the Merryoaks site is objected to as a housing site.
Community Impact
21. I believe that there has been insufficient consideration given to the impact of newhousing on the community infrastructure of the Neville’s Cross area over the past 30+ years.
22. Defining the “Neville’s Cross area” as that covered by the former Neville’s Cross CityCouncil ward (currently polling districts DFA and DFB), in 1980 there were around 990 housing units. At July 2013 there were around 1,520, an increase of over 53%.
23. At this moment there are 36 houses under construction (Redhills Lane and Potters Bank) and outline permission has been given for around 295 more on MountOswald. These will bring the total to around 1,850 properties, an increase of over 86% since 1980.
24. Development of 250 further properties would bring the increase to over 110% on the 1980 figures. On top of that, a planning application is expected imminently for a student hostel catering for around 450 university students to be built on SheratonPark within the
Neville’s Cross area.
25. On the other hand, since 1980, the area has lost three petrol filling stations, its only postoffice, two corner shops (one now a private house and the other a lettings agency) and one public house (replaced by a restaurant and some sheltered housing).
26. A second public house at the northerly end of the area is to close in the near future to be replaced by a Sainsbury’s local, and the MountOswald development promises a second local convenience store near to the Merryoaks site but on the other side of the A167.
27. In terms of public recreational space, the only facility is the Lowes Barn playing fields on Park House Road with a range of children’s play equipment, a MUGA, a bowling green and a football pitch of a quality that is just playable. Apart from the MUGA, this is essentially the same as in 1980.
28. Further open space and some additional play equipment is promised for Mount Oswald, but a major objection from me at Planning Committee was the lack of provision of any significant public park/recreation area as is present in almost every community of a similar size that one visits anywhere in Britain.
29. The current county council division of Neville’s Cross is probably unique in County Durham in having no community centre or community building apart from local schools, and while the planning application for Mount Oswald promised provision of a community building on the Lowes Barn playing fields, there is little space for something of a size that the area needs.
30. The new housing currently being built, together with MountOswald and Merryoaks will result in around 580 new properties in the area. Using a nationally recognised conversion ratio (0.25 primary age children per household), this would require the provision of around 145 additional primary school places in the area, equivalent to around 5 new classrooms. While two additional ones are currently planned between Neville’s Cross and St Margaret’s primary schools, it is hard to see where the extra three could be physically accommodated. Nothing appears to be planned to bridge this gap.
31. The above describes an area that has grown immensely over the past three decades, and will grow further, but with arguably fewer community facilities now than 30 years ago. By any reasonable definition, the provision of a further 250 houses in the area fails the sustainability test and should therefore be rejected.
Summary
32. The Merryoaks Housing Allocation (4/LB/05) should be removed from the CountyPlan because:
a. It is not a strategic site and so there is insufficient reason to override its current green belt status;
b. The traffic impact assessment provided by Persimmons is flawed and unreliable;
c. The traffic impact on the New Inn junction is unsustainable; and
d. The cumulative community and social impact on the Neville’s Cross area is
unsustainable.
From Councillor Owen Temple
Dear Sirs
Please treat this as my formal response to the County Durham Plan. It is in part commentary, but in particular an objection to the Durham-centric nature of the Core policies 3, 4, 5 (with much of the CIL committed to Durham City Relief Roads), 6, 7, 8, 9 and 10 which primarily concern themselves with Durham City and the Development of Aykley Heads – with policies on Highways, transport and housing development all clustered round the assumption that Aykley Heads is the key to economic prosperity for the county.
Most of the “beef” in the document is addressed towards DurhamCity. Most of the “flannel” to the rest.
I believe that plan’s underlying assumption about Aykley Heads is fundamentally flawed. The vision is that “If developed successfully, Aykley Heads has the potential to become a flagship employment site in the North East Region, attracting world-leading businesses to the city which will drive the step-change envisaged for the economy of County Durham.” My own view is that Durham and Aykley Heads are not uniquely, or even significantly, well situated for business, regardless of the enormous tourist potential of the World Heritage site. Durham is a bottleneck, created by the river and its crossing, and the bottleneck effect is inherent in a tourist centre and sub-regional shopping centre with a single through road. That is not attractive to business which is not particularly interested in, or attracted to, a World Heritage site (unless its business is directly linked to it), nor 15 minute walking access to it. Most businesses are much more interested in a free and easy vehicular movement in all directions, evidenced by the growth of Business Parks on the motorway perimeters of our cities. Aykley Heads is on the wrong side of Durham for that.
World Heritage and commerce are not naturally symbiotic. They can exist alongside each other as a historical product as in London, but tend to co-exist despite their conflicting priorities rather than because of them. The needs of business can also easily be inimical to those of tourism. This policy completely ignores that possibility, that the attempt to turn DurhamCity into a commercial centre may damage the quality of its relatively newly emerging economic existence as tourist centre.
In my view, too, it is illogical to seek to site the major intended magnet for new business in the area which currently has the highest employment levels in the county (not least as a result of having imported public sector jobs in local government into Durham City after Local Government Review following the closure of major public sector buildings across the county). Nor is it a sensible target to “rebalance public and private sector employment” in DurhamCity following that importing of public sector jobs. That balance needs to be achieved across the county. Simply seeking to site more and more jobs in DurhamCity will add to existing highway and transport issues within the county, making outlying communities ever more dependent on jobs that have major travel requirements.
It is not difficult to see this policy as a response to the increasingly crowded County Hall which has resulted from closing so many public service buildings across the county. The desire of some people to develop a new “County Hall” is not a good reason to gamble on this Aykley Heads development as the economic salvation of the county.
Policy 4 – Distribution of Development
There is an unacceptable unevenness between the ratio of employment land to Housing development land/numbers of proposed new houses across the county, with less than 1 hectare of new employment land per 1,000 new houses in the North of the county, and more than 2 hectares of new employment land per 1,000 new houses in the South of the county. Nowhere is that imbalance recognised or justified within the plan.
This a tacit acceptance that the future the North of the County is as a commuter area, and amounts to a willingness to receive council tax from its inhabitants but not to invest in their economic infra-structure, expecting them to have to travel to work in Tyne & Wear or Durham.
Policy 30 – Housing allocation in the North Consett area
I welcome the exclusion of the originally included HA60 site (Berry Edge Farm) from the draft plan. It represented an unwelcome and unnecessary urban sprawl into the surrounding countryside.
I am pleased that the density of housing at H26 has been reduced, but believe that the area remains a problem because of the floodpaths which already trouble the existing residents of Muirfield Close and Turnberry Close below it. I am not convinced that it is a suitable site for development whilst that position remains.
Whilst I accept the proper use of the former BlackfyneSchool footprint for new housing at H21, the size of the allocation is too great because it will build over a football field, when we have already lost a number of football fields through the Academy/Sports Centre development. The land area for housing should be limited to the footprint of the former school buildings and yards.
Notes on the Population Predictions for the County of Durham
(Please note, it is recommended that this letter is read as a PDF file due to the websites inability to display the mathematical symbols and equations correctly.
The PDF is available at THE DURHAM PLAN Population notes January 2014)
In the County Plan housing needs are determined using predicted population levels by 2030. There are several estimates of this population 17 years from now and the National Statistics Office suggested very little change over that period, figures that were used in the Regional Spatial Strategy. Until 2012 the County Council officers agreed with those estimates.
During the construction of the County Plan, however, these estimates changed dramatically as the County Council sought to justify the proposal to construct 22,500 new houses without regard to the number of empty properties available in the County and without regard for the brown field sites which offer some capacity for development.
To achieve an estimated increase of 47,700 residents the County Council used a formula and associated computer programme provided by Manchester University (POPGROUP). The formula is:
Pt+1 = Pt + (B – D) + (IUK – OUK) + (IOV – OOV) ……(1)
births deaths immigration exodus immigration exodus
CountyDurham from United Kingdom from Overseas
This simple linear equation contains 3 non-linear components:
(B – D) can find some expression from the National Statistics Office data and is generally agreed to be a diminishing number when plotted against time. It is predicted to be zero by 2030. Therefore this is a non-linear function made up from two independent variables, dB/dt and dD/dt where t = time.
(IUK – OUK) is unpredictable and depends on variables that lie outside the county and outside its control, for example the economic success or otherwise of neighbouring counties or more rapid improvements in the economies of the south east of England or elsewhere attracting outward migration. In this estimate DurhamCounty cannot be treated as an island behaving independently of all other regions of the UK. Again we have two independent variables dIUK/dt and dOUK/dt over which there is no control because both variables depend on many external influences as yet undefined.
(IOV – OOV) is equally unpredictable and depends mainly on the future development of economies overseas, particularly in Europe and especially in Eastern Europe. A rapid improvement in the economies of Eastern Europe could reduce this parameter to a negative value. UK withdrawal from the EEC (which is in the political frame) would certainly demolish this parameter. Again DurhamCounty is not an island. Once more there are two independent variables dIov/dt and dOov/dt essentially outside the range of prediction.
In making its population estimates the County Council depends entirely on all 3 parameters staying positive and maybe increasing in order to create the population of the County needed for the extra housing already being planned. At no time is a routine standard error given in their estimate to define the confidence level in their data. This is basic to all decision making, especially when radical decisions are being made, because no numbers are absolute and a statement of confidence levels is essential.
Furthermore, unless there is a robust source of data for the accompanying time-series of input data used in the resolution of equation (1) then it is essential that the null hypothesis be adopted and conclusions based upon this equation be treated as invalid.
Indeed it looks very much as if the population prediction relies on the desired housing market rather than the other way round. The population figures cannot, and must not, be manipulated in order to pander to the powerful building lobby.
It is of interest that in 2008, as mentioned above, the ‘Regional Spatial Strategy’ (the RSS) used by the previous Labour government made very modest predictions for the population growth and housing needs of County Durham. Perhaps in the face of pressure from the building lobby this evaluation has recently been scrapped by the present government even though the numbers used by the NSO have not changed.
Population of County Durham, 2011 census = 513,000. Predicted population 2030 = 560,700, an increase of 47,700, needing 22,500 extra houses estimated at 2.2 bodies per house. However, the workforce (18-65 population) in 2011 = 301,900 predicted in 2030 in the same analysis to be 296,800, essentially zero growth. In 2011 the retired population = 110,950 predicted to rise to 157,200 by 2030, an increase of 46,250. Does the retired population need an extra 22,500 houses?
Houses do not provide long term employment; rather, houses traditionally follow centres of employment and housing needs should match the development of those centres wherever they are in the county, eg Nissan, Hitachi. That is, to drive up housing needs it is necessary to confirm future patterns of economic growth and the associated employment levels.
Durham City, by its history, construction and geographical constraints, is not a natural source of industry. It is an administrative, academic and ecclesiastical centre whose level of employment relies on the stability of its funding. Because of constraints in public spending this source should not be expected to increase very much in the next decade and there is little room for significant industrial expansion. The proposed commercial developments at Aykley Heads, by their constrained geographical setting, are modest in size and, because of their anticipated high-tech nature will not employ large numbers of people, all of whom could easily be accommodated on the adjacent housing estate that is being planned and at the already approved Mount Oswald development.
Unfortunately, Durham City is victim to the following statement made by the county council in its draft proposals:
“In addition to the trend projections described below, the County Council has commissioned policy–led projections. These are where aspirations for the population of the county are built into the projections by adopting a target population by 2030 for one of its key age cohorts, the working age population aged 16 to 64. The output from such models is the size of net migration and natural change required to achieve the adopted target.”
In summary, the county council has simply created its own answers to justify consuming Green Belt land with unnecessary additional housing. The model used may be built on an aspiration; but it has no basis in fact.
Grenville Holland