Senior Planning Officer
Commercial Development Directorate
Sunderland City Council
15 October 2019
CORE STRATEGY AND DEVELOPMENT PLAN
We welcome the recommendations made by Inspector Dakeyne that sites HGA2 and Safeguarded Land South of East Springwell and the area around Peareth Hall Farm and Gospel Hall remain within the greenbelt. We wholeheartedly agree that the combined sites form a fundamental part of the gap between Springwell Village and the A194(M) and built up area of Washington. And that it also forms part of the landscape setting of the village, being within an area shown for ‘Landscape Protection and Enhancement’ in the Landscape Character Assessment. We welcome Council’s modifications to the CSDP reflecting these recommendations and feel that without these modifications there would be considerable risk to the character and setting of Springwell Village.
However there are a number of comments we would like to make in relation to site HGA1 – South West Springwell (North of Mount Lane), each relying on information that has emerged since the EIP and each relating to the soundness of the Plan:
- Political developments and further uncertainty since the production of the Core Strategy and Development Plan, and since the closing date of the consultation, mean that the number of jobs on which the housing need is predicated is very much in doubt and therefore cannot be used as justification for deletion of precious greenbelt land. The time is not right to take such an irreversible decision.
- Public Transport: The Council’s Doc EX17.008 Bus Operation Frequency is inaccurate and misleading. The site is not served by public transport.
The bus stops shown on the plan as ‘Springwell School’, Springwell Village North & south’ and ‘Mount Lane’ merely serve scholars and a part time (10am-4.50pm Mon-Sat) mini-bus shuttle service that is entirely unsuitable for travelling to major conurbations and employment sites, within reasonable timeframes. By the nature of this service, journeys are extremely lengthy. Commuters travelling to Gateshead, Newcastle or Sunderland must use the stops in the centre of the village or for Sunderland only, Peareth Hall Road. Both are much more than 800metres from HGA1. The reality is that people living on HGA1 will travel by car, incurring all of the attendant adverse effects on environment, wildlife and ecology. .
It should be noted that the only bus service to Sunderland from the village is the 56 and incurs a journey time of approximately 45 minutes, meaning a daily return commute to destination can take up to 2 hours.
Therefore site HGA1 is not accessible with public transport – all bus stops are further than 800 metres away and deemed “low access”.
Clearly this impacts upon the Sustainability Appraisal (incorporating SAE Appendix E (where it is incorrectly rated ‘xx’ – it should be rated ‘-‘. The proposed development is not sustainable.
c. Other Sustainability Assessment Issues:
Biodiversity is rated “o” – a nonsense given this is a wildlife corridor
Access to Primary School – rated “xx” when it is much is further walking distance than 500m
Cultural Heritage – Historic Environment rated “o” – when it is in close proximity to the Bowes Railway
Greenbelt Purposes: the SA assessment of “uncertain” impact makes no sense given that this proposal is for a deletion of the greenbelt. The negative impact is obvious
The judgment in Calverton Parish Council v Nottingham City Council and Ors(2015) – para 19 :
“The second sentence of paragraph 83 (NPPF) supplies a fetter or brake on development which would, were it not for the Green Belt, otherwise be sustainable; but in deciding whether exceptional circumstances pertain regard must be had to the whole picture, including as I have said the consequences.”
“Planning Authorities must “consider the Greenbelt boundaries having regard to their intended permanence in the long term”.“
The same judgement states “sustainable development embraces environmental factors, and such factors are likely to be negatively in play where release of Greenbelt is being considered”.
Even if the conclusions of the Sunderland Council’s Sustainability Assessment are upheld – and we strongly dispute them because of the inaccuracy of the data (see b and c above) – we submit that the Council has not considered the wider setting and circumstances of this site, the implications of using it for housing and the consequences of development – sustainable or otherwise.
- We strongly disagree with the Council’s assertion that the deletion of this site from the greenbelt represents “a logical rounding-off of the village, with the creation of a new durable Green Belt boundary”. The proposal to amend the greenbelt boundary to simply provide a more convenient line on a plan is an unacceptable reason to make such a radical decision. This contradicts the policy to protect “the character and setting” of Springwell Village.
The greenbelt in this area presents a unique perspective and affords immediate and easy access to the countryside and rich wildlife habitats and is a very important aspect of the setting of Springwell Village and the Bowes Railway. It is a huge part of the identity of the village and should not be lost for the sake of “rounding off”.
CSDP 2015-33 Publication Draft September 2019, p49 HGA1(iii) states ” ensure that the open aspect of Bowes Railway SAM is retained. This is impossible with development of HGA1.
This does not support “rounding off” as a reason to amend the greenbelt boundary.
- Since the EIP, Northumbrian Water Limited has submitted a planning application ref:19/01280/FU4 for a reservoir on land immediately north of Mount Lane and south of site HGA1. This is a huge development that will impact severely the whole area. Despite remaining within the greenbelt, the 9 acres site will not be accessible to the public and there will be in effect an 8-10 metre steep embankment facing Mount Lane, restricting views, affecting the wildlife corridor and altering the whole landscape and character of the area. Another huge intrusion and significant, unacceptable change to the setting of Springwell Village. Given the nature of the application – the protection of water supply and the very limited opportunities for suitable sites for reservoirs – it is likely to exhibit exceptional circumstances and receive approval. This is a significant change since the EIP and it is the background against which the proposed housing development should now be considered.
CSDP 2015-33 Publication Draft September HGA1 (iv) states the intention to “maintain wildlife & open corridor”. It is impossible to maintain this with the reservoir development adjacent to the site. A housing development on HGA1 can only exacerbate this situation.
There is also a planning approval for a cattery and dog kennels at Fern Hill (west of the NWL site and HGA1) which presents further impacts on the environment, ecology and setting of the area. This has not been considered.
- The plans for the reservoir reveal an access road for site HGA1 to the east of the site. Clearly this will be the only entry and exit route for the proposed housing development. This detracts from the safety of the access road to Broom Court, severely affects Mount Cottage and increases traffic volumes on Mount Lane. Mount Lane is a narrow country lane that is constrained by a bottleneck at its western end. The bottleneck is created by terraced houses so widening is impossible. The Inspector already has photographic evidence.
Traffic turning left onto Mount Lane travelling eastwards will need to turn onto Springwell Road which is already very heavily used and at unacceptably high levels for the very narrow village roads. Photographs taken since the EIP are attached.
The Council’s EX19.011 CSDP Infrastructure Delivery Plan cites no measures to mitigate these issues.
- I refer to the Council’s response to Inspector Dakeyne’s recommendations as follows: “the Council is satisfied that through the Allocations and Designations Plan it will be able to identify a sufficient supply of sites to ensure that a buffer of approximately 10% is retained. This will include consideration of the following sources of supply: • Sites identified as deliverable and developable within the Strategic Housing Land Availability Assessment (SHLAA); • Potential for accelerated construction on existing large sites which currently extend beyond the Plan Period; • Inclusion of other sites within the Existing Urban Area which have become available since the publication of the latest SHLAA; and • Potential for an early release of the Safeguarded Land. Taking into account the need to replace the existing Unitary Development Plan (1998) “
The availability of more brownfield/urban sites- identified/cited since the EIP for housing means that “exceptional circumstances” to build on greenbelt are not demonstrated and certainly cannot be justified on site HGA1. The effect of losing the proposed number of houses from the Plan is negligible. They can easily be accommodated on more accessible and well served (by public transport, roads, schools, shopping and medical services) sites eminently more suitable for housing.
We trust you will give these comments due consideration.
Springwell Village Residents Association
We agree to our data being used by Sunderland Council and the Planning Inspectorate in relation to the Core Strategy and Development Plan process.