Durham Inspector – You Need Evidence of Exceptional Circumstances before not after identifying Green Belt Loss

Here

To my mind the key killer passage

First, there is no need to release 3 large sites from the Green Belt to meet the objectively assessed housing requirement. Secondly, the reasoning and justification for a `critical mass’ for Durham City is weak and unconvincing. Thirdly, there are significant shortcomings in the assessment of capacity within the built up area. …Fifthly, it is plain to me from several of the hearing sessions that the Council has not responded to submissions from FDGB, the CDT and others that all options for development outside the Green Belt should be assessed. Whilst it has consulted on the general principle of concentrated development versus dispersed development to other towns and villages around the County in its high growth strategy, there has been no evidence published of an assessment for Central Durham of a lower overall growth strategy with higher levels of brownfield development and dispersed development to nearby towns and villages. The unwillingness to consider and test such an alternative strategy is a critical flaw in the local plan process. It is not surprising to me that this has led to some 3,596 representations against the CDP.

Fourthly … the `exceptional circumstances’ were formulated well after the decision had been taken to remove the strategic sites from the Green Belt. It was not until the 2012 Durham City Green Belt Site Assessment Phase that exceptional circumstances were first mooted. No exceptional circumstances are included in the 2010 Durham City Green Belt Assessment Phase.

The 2010 Core Strategy Issues and Options document acknowledges the need for exceptional circumstances but does not identify them.  The Council has not provided the required justification for releasing Green Belt sites in respect of Green Belt purposes in Green Belt assessments and the SA and has simply identified the least damaging of the sites.

Sites outside the Green Belt that are accessible to key employment sites in the City have not been rigorously tested. Therefore, there can be no justification for releasing 3 large Green Belt sites….

Importantly, this ambition for growth on the scale desired does not respect the special character of the City. Durham City is already a city of regional, national and international importance based on its existing assets and development on the scale envisaged will do little to improve it and is more likely to harm it. The setting and special character of Durham City derive their importance not only from direct views of buildings on the peninsula or from the intrinsic architectural or landscape quality of the town and its setting, but from the relationship between the physical size and topography of the built-up area and the open areas around it. In essence the character of Durham does not derive solely from views of the Cathedral and Castle, which are at the centre of a World Heritage Site, but from the relationship between them and the actual size of the built-up area. Any increase in the physical size of the City, irrespective of any effects on views or countryside quality, would be likely to have a generally harmful effect on the character of the City. The fingers of open space which extend right into the built-up area are of particular importance in terms of the special character of Durham…

Whilst I agree that Aykley Heads should be supported as a strategic employment location, on the evidence that is before me, there are no exceptional circumstances to justify removal of Area C from the Green Belt. Area C is an elevated location which is integral to the green setting of the City included in the 2004 Green Belt designation. It continues to fulfil several Green Belt purposes as set out in the NPPF.74 Other parcels of land including Area A and the proposed development in the north around the former police headquarters can be considered at the Site Allocation stage.

 As submitted therefore, Policy 7 seems to be unsound as it conflicts with requirements in the NPPF.

Durham is almost unique (together with Bath) in that the primary purpos eof the Green Belt is not to prevent sprawl of  large city but the protect the setting of an historic town, with an elevated cathedral (World Heritage site) at its centre.  Indeed the invese of Bath where the world heritage site lies in a valley.  So building on elevated ridges overlooking the city was especially harmful.  It would seem a much reduced Green Belt loss, principally the strategic employment site, would be acceptable only rather than meeting the ambition of a much larger city incompatible with the World Heritage status.

 

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