Infographic from Newcastle City Council’s consultation website

Newcastle City Council recently consulted on the replacement to the current “Local Plan”. This is SPACE for Gosforth’s response. You can find out more about the consultation and questions asked in our previous blog Local Plan 2040.

Re: Newcastle Local Plan Early Engagement

Thank you for the opportunity to comment on the proposed Newcastle upon Tyne Local Plan.

We are a community group based in Gosforth, Newcastle upon Tyne. SPACE stands for Safe Pedestrian and Cycling Environment. Our group was established in 2015 due to residents’ concerns about road danger and air pollution in our local neighbourhood. You can find our group objectives on our website www.spaceforgosforth.com/about.

While transport is only part of what is needed to achieve the city’s ambitions, it is fundamental to how the city uses its public spaces, and critical to whether the city will achieve its ambitions or not.

We support the Council’s intention that “At the core of the Newcastle Plan there needs to be a strong emphasis on placemaking, health and wellbeing, and sustainable living which will help us reach Net Zero” and agree that “these are critical to Newcastle’s strength as a place, to the city’s ability to adapt to the climate crisis and to improve the lives of residents.”

Walking, wheeling and cycling improve health and wellbeing, improve sustainability and support good quality placemaking.

This was recognised in the Development and Allocations Plan which said, “Improving accessibility for walking and cycling has multiple benefits, including the creation of safer, more attractive places, improved physical and mental health and reduced carbon emissions and climate change impacts from transport.” This new Local Plan should build on this with an even stronger focus on walking and cycling and sustainable travel.

By 2030, the city should already be well on the way to achieving Net Zero, including for transport. The future Local Plan should therefore ensure further development will be consistent with this, minimising additional emissions from development, ensuring new homes are carbon neutral and ensuring new developments prioritise walking and cycling.

Walking and cycling support all the Local Plan’s nine ambitions as follows.

1. Healthier City

• The benefits of exercise to physical and mental health are well-known. Good quality walking and cycling infrastructure allows people to build exercise into their normal daily activities, saving money and benefiting the environment at the same time.
• Access to low-cost transport like walking and cycling makes it easier to access local services and facilities.
• Reducing traffic makes places more sociable by reducing severance; and reduces air and noise pollution that adversely affect health.

2. Greener City

• Reducing traffic is essential as part of achieving Net Zero. Even with an ambitious transition to EVs, a cut of approximately 20% of total miles driven will be required to meet carbon budgets targeting Net Zero by 2050. A greater reduction will be required in Newcastle because of its 2030 target and because urban areas are better suited for alternatives to car travel than rural areas.
• Walking and cycling, as well as being carbon neutral, take up less space. That freed-up space can be used for green infrastructure like sustainable urban drainage or street trees.

3. Attractive Neighbourhoods

• Street layouts should make walking and cycling the natural choice for local journeys in line with Government ambition. That means safe, direct, connected routes between homes and local services.
• Reducing traffic will address severance issues that prevent people from accessing local shops and services.
• Research has shown people walking or cycling spend more money locally, protecting local services and making neighbourhoods more attractive.
• Road layouts at district centres like Gosforth High Street need to fully prioritise walking and cycling to maximise access to shops and services for the local community in the catchment of the centre.

4. Employment Opportunities

• Good quality walking and cycling infrastructure enables better access to local employment opportunities, especially for those on a low income who cannot afford a car or taxis.
• Quality and accessibility of the street environment is a potential competitive advantage that will attract more employers to the city. Currently Newcastle is getting left behind as other cities invest in removing traffic from city centres and residential areas.
• Good quality walking and cycling infrastructure is also helpful for students who typically will not have access to a car, and makes Newcastle an attractive place to live for people who are able to work from home.
• Premium land currently used for roads or parking could be utilised in more economically beneficial ways.

5. Moving Around

• The Local Plan must ensure “new development promotes sustainable transport choices, patterns of travel, minimises the need for private car use and plan for new transport infrastructure to meet needs.” It needs to be a comprehensive plan though, not just a set of unconnected islands of development without the ability to travel sustainably between them.
• The Local Plan aim is to optimise the use of available space in the city to meet the overall aims. Walking and cycling support all the plan objectives, are low-cost, low-carbon, healthy, and use the least space per user compared to most other modes of transport.
• A network of safe, accessible, all age and ability walking and routes will be fundamental to achieving the Local Plan’s objectives. Ideally this should be in place even before the Local Plan comes into effect.
• The Local Plan needs to anticipate and prepare for an increase in electric-powered micro-mobility like eScooters and cargo-bike logistics.

6. Leisure, Culture, and Tourism

• Walking and cycling can be leisure activities as well as transport, with a significant amount of tourist spend relating to these activities.
• The nationally recognised C2C cycle route passes through Newcastle.
• Newcastle is ideally placed to attract visitors wanting outdoor activities given its proximity to the coast and open spaces in Northumberland, as well as more local attractions like the Town Moor and Jesmond Dene.
• Good placemaking, underpinned with high quality walking and cycling links, will also make the city more attractive for visitors.

7. Homes and Communities

• Low-car neighbourhoods can be denser, making it easier to provide better local services and an improved environment. See for example the ‘Merwedekanaal’ proposal from Utrecht.
• Good quality safe walking and cycling routes that children can use to travel independently will also make the city more attractive to families and would help reverse the trend for families to move out of Newcastle.
• Walking and cycling allow residents to benefit from “incidental sociability” improving the social fabric of communities.

8. Attractive and Safe Places

• Walking and cycling contribute to many of the ten characteristics of a well-designed place referenced in the consultation, including: efficient, healthy and sustainable, safe, social and inclusive, accessible and easy to move around.
• Road safety is a key factor in whether a place feels safe or not. Engineering measures can cut traffic levels and dangerous driving behaviours.
• Research has shown that Low Traffic Neighbourhoods also reduce non-traffic related crimes.

9. Protected Natural Environment

• Transport is a major cause of environmental degradation from air and noise pollution, carbon emissions, roadkill, and microplastics from tyres that are washed via the drains into local rivers.
• Enabling more people to walk and cycle more often through the creation of a network of safe all age and ability routes would substantially reduce the impact of transport on the local environment.

All this needs to be backed with a plan with SMART objectives, funding identified and an approach to build community support to achieve rapid change. It should not be passive shelf-ware only ever referred to as the starting point in a negotiation with developers.

These objectives should include:

• Pavements and crossings designed to a high standard to ensure they are accessible.
• Creation of a high-quality cycling network suitable for all ages and abilities that connects homes to local destinations and meets national standards.
• Traffic to be routed via the main road network, with local streets used solely for access.
• Targets for street trees and planting.
• Limits on sources of pollution and nuisance from traffic to ensure any new development doesn’t just minimise its impact but improves the situation compared to if that development didn’t happen.
• Targets for what services are available in a local area, ensuring that children will be offered a place at a school within walking distance and that services will be available when people move in.
• High quality standards for all the above that a development must achieve if it is to be approved. This should include a developer contribution to cover the cost of high-quality walking and cycling routes between the development and local services if not provided on site.

The Core Strategy and Urban Core Plan for Gateshead and Newcastle upon Tyne adopted in 2015, included many similar ambitions for sustainable travel, yet ten years on Newcastle is still dominated by vehicle traffic. Hundreds of millions of pounds have been invested in transport in the city, but most of this has been focused on the Western bypass with the effect of increasing traffic, counter to all sustainability objectives, and Newcastle Airport (the least sustainable mode of transport) continues to boast of increased passenger numbers.

Meanwhile, plans to enable more walking and cycling proceed at a glacial pace, if at all. Our local High Street in Gosforth still doesn’t achieve basic safety guidelines despite a full Council vote to this effect and Policy DM10 stating development should “Provide safe, convenient, attractive and continuous pedestrian and cycle links to key local facilities and services.” If the Council won’t stick to its own policy, why should it expect developers to do so?

So, while we support the ambitions, we remain sceptical that the new Local Plan will make much difference. As we said in our response to the Development and Allocations Plan “The Local Plan should not be limited to addressing issues though. It needs to show a city willing to compete internationally, to draw best practice from across the world, from Copenhagen, Amsterdam, Barcelona, Paris, Seville, London and New York, and our twin city Groningen, all of which are investing in the public realm, prioritising sustainable and active travel and investing in (and competing with each other on) liveability and accessibility. If Newcastle is to compete in this arena it needs a strong vision backed by robust policy to deliver that vision.”

We would also like to draw your attention to the following City Council Motions and ask that the draft version of the Local Plan be prepared to be consistent with these.

• Climate Emergency – City Council 3 April 2019
• Greater Focus on Cycling – City Council 2 October 2019
• School No Idling Zones – City Council 5 February 2020
• Use of E-Cargo Bikes – City Council 6 October 2021
• Investment in Roads and Pavements – City Council 12 January 2022
• Promoting Active Travel All Year Round – City Council 12 January 2022
• Gosforth High Street – City Council 2 November 2022
• Pavement Parking – City Council 1 November 2023

Further evidence, e.g. links to research, can be provided on request.

Yours faithfully,

SPACE for Gosforth.

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Newcastle in 2040?

Newcastle City Council has launched a consultation on the replacement to the current “Local Plan”. You can comment on CommonPlace up to 6 March 2024.

According to the Planning Inspectorate “Local plans are used to decide how much land should be set aside to build new homes, offices, factories, warehouses, shops and other things, usually over the next 10 to 15 years. They also show areas where development should be limited for some reason. The plan includes a map showing these areas and it will include policies that say what types of development are acceptable and what development should be like. The local plan is then used to make decisions on planning applications for individual development proposals.”

You can see Newcastle’s current local plan and timetable for the new plan on the Council’s website.The Council also has a planning policy map showing housing and employment sites, and classification of transport links.

It is often said that the best transport plan is a land use plan. That is because the location of shops, schools and other services compared to where we live dictates how far we need to travel. If the shops and service we use daily are within a fifteen minute walk then there would be less need for people to drive.

When it comes to making walking, biking & public transit not just practical, but ENJOYABLE in your city, remember that although smart infrastructure investment & design is critically important, the best transportation plan is a great land use plan. pic.twitter.com/4ncdOHss0t

— Brent Toderian (@BrentToderian) March 9, 2019

This consultation stage is called “Early Engagement” and the Council are asking for opinions on the following questions. In each case you can choose from a list of potential interventions to help the Council prioritise what needs to go in the plan. A further consultation will be held in 2025 on the draft plan once completed,

Consultation Questions

1. What steps can the Council take to support everyone in Newcastle to have healthier lifestyles and to improve their wellbeing?
2. How can the Council help address climate change and reduce carbon emissions in Newcastle?
3. What do you think is needed to improve the city centre and neighbourhood centres, and what would make you visit them more?
4. Does the city have the right employment sites (areas only used for businesses, factories, and other employers) in Newcastle and what opportunities should be provided for the future?
5. How can the Council support more people to actively move around Newcastle (by walking and cycling) and improve transport networks, helping to connect everyone better?
6. Where should the city’s leisure, cultural and tourism facilities be located, and how can the Council improve everyone’s access to the city’s open spaces?
7. What type of housing do you think Newcastle needs and where should new houses be built?
8. What is most important and makes Newcastle special for you?
9. How can the Council improve the natural environment including parks, woodlands, lakes and ponds and what would you like more of?

Please do respond to this consultation

You can comment on CommonPlace up to 6 March 2024.

Enabling more people to walk and cycle more often supports objectives to improve health, cut carbon emissions, and makes it easier for people to access jobs, leisure and the natural environment.

That is particularly important for the 37% of households in Newcastle upon Tyne who do not own a car. If there aren’t good alternatives to using a car and households who don’t currently own a car are forced to buy one then, as well as the personal cost, it will have an enormous impact on parking and traffic volumes. The fewer people who need to drive, the less congested the streets will be for those that do.

Having essential services within a fifteen minute walk or cycle ride is popular with the general public. A YouGov poll from March 2023 shows which services people want most in their local area.

Forget the conspiracy theories, 15 minute neighbourhoods are popular in Britain.

Here's what amenities do Britons want within a 15 min walk from their home

Bus stop: 90%
Post box: 87%
Pharmacy: 85%
GP surgery: 83%
Park: 81%

More in chart 👇https://t.co/9sHKzqhD1I pic.twitter.com/ZnlWS4nedS

— YouGov (@YouGov) March 6, 2023

The Council will be looking to create an evidence-base for the plan, so if you are aware of evidence for how walking and cycling can answer any of the consultation questions, please let us know via the comments below so we can include it in our group response.

Meanwhile, here’s one idea for the plan…

Here's an idea for @NewcastleCC's local plan consultation. https://t.co/F6GktGfF6l

— space for gosforth (@space4gosforth) February 10, 2024

12 thousand inhabitants, 0 car parking spots

In the new neighbourhood 'Merwedekanaal' Utrecht deliberately plans to make private cars superfluous. Everything will be on short walking/cycling distance. Also, the Utrecht train station!

Source: https://t.co/RiCZVUAN1k pic.twitter.com/qhRyJt0kS3

— Cycling Professor 🚲  (@fietsprofessor) January 9, 2020

You can comment on CommonPlace up to 6 March 2024.

The post Local Plan 2040 appeared first on SPACE for Gosforth.

Everyone is familiar with A roads, B roads and Motorways, the national road classification that determines how roads are designed and how they are used. Newcastle also has its own local road classification, which we explain in this blog.

What are road classifications for? 

Road classifications are used throughout the world as a way of specifying what roads are used for and therefore how they should be designed. They range from long distance high-capacity fast routes like motorways (freeways in the diagram below) that are designed for vehicles to travel safely at high speeds, to low-volume local streets designed mainly for access where vehicles are expected to travel slowly and where people should feel safe to walk and cycle without the need for special engineering measures.

The phrase Place vs Movement is often used to distinguish between streets that are important for people to meet, shop and socialise vs roads that are used for the movement of people, goods and services, which could be by car, bus, bike, van/lorry or walking.

By Belbury – Own work, CC BY-SA 4.0, https://commons.wikimedia.org/w/index.php?curid=128590751

DfT guidance states that “roads classification is intended to direct motorists towards the most suitable routes for reaching their destination. It does this by identifying roads that are best suited for traffic.” 

From a safety perspective, it is important to get vehicles away from local unclassified roads and onto the main road network as soon as possible as the injury rate per vehicle mile driven is much higher on minor roads than on main routes.

Newcastle’s road hierarchy

Newcastle’s road hierarchy is made up of Strategic Routes, Primary and Secondary Distributors, Public Transport Distributors and other non-classified local roads. These were specified and consulted on as part of the city’s Development and Allocations Plan (DAP) in 2018.

DAP Policy DM13 states the purpose to of the hierarchy is to “support the management of movement on the highway network and to ensure the safe and efficient movement of people and goods.”

These are the full definitions. 

To come up with these classifications Newcastle City Council produced a Road Hierarchy Justification Report, which was shared as part of the DAP consultation. 

Which roads are which?

The map below shows which roads in Newcastle are strategic and which are primary/secondary/public transport distributors. All other roads are unclassified.

Map of Newcastle showing the local Road Hierarchy

Newcastle City Council has created an online Planning Policies Map that can be zoomed and scrolled and also shows other local policies relating to transport and other areas like housing and nature conservation.

In the Gosforth area, these are how main roads are split by category.

 Managing Conflicting Needs

Nearly all roads have some elements of both Place and Movement. The Newcastle Road Hierarchy, like all road hierarchies, is intended to manage these conflicting needs to keep people safe and balance the needs of all users. 

• Strategic Routes enable the fast movement of traffic, managing risks by banning right turns and, in the case of motorways, by banning people walking and cycling.
• Primary and Secondary Distributors mitigate the risk posed to people from vehicle traffic using engineering interventions to separate people from traffic including formal crossings, pavements and protected cycle lanes.  Traffic lights are also used to manage conflicting vehicle traffic flows.
• Local unclassified routes generally don’t have these engineering mitigations, so must have lower speed limits and lower volumes of traffic to be safe.

Just as people walking and cycling are banned from some Strategic Routes, the DAP contains a specific intention to discourage through traffic on unclassified roads.

“The road hierarchy, as set out in Policy DM13, can also discourage through traffic, whilst maintaining local access for residents and businesses. This creates opportunities, particularly in those areas not included in the hierarchy, to improve conditions for pedestrians and cyclists, and create welcoming places that are safe and attractive to all.”

Local Neighbourhoods

As well as creating welcoming places, reducing traffic on unclassified local streets also contributes to decarbonisation of the transport network as well as “significantly reducing accidents, noise, and air pollution for local residents”.

Image from the Government’s 2021 Transport Decarbonisation Strategy

Currently, streets like Linden Road, Elmfield Road, The Grove, Regent Road, Moor Road North and South and Regent Farm Road are busy because they are used by non-local through traffic to avoid traffic queues on main roads. According to Government guidance, anything over 2,000 vehicles a day on a 20mph street will start to exclude some road users due to safety concerns.

This undermines the road hierarchy as, being unclassified, these streets neither have the investment nor traffic management to safely cope with higher volumes of traffic. Either they need to be redesigned as secondary distributors with controlled crossings and protected cycle lanes, or (SPACE for Gosforth’s preference) have modal filters installed to reduce traffic levels and ensure through traffic remains on roads that are properly designed for that purpose in line with DfT guidance. 

Gosforth High Street

One thing not recognised in the Newcastle road hierarchy, which SPACE for Gosforth asked to be added, is consideration of where main roads are also local destinations. Gosforth High Street, for example, is recognised on the policy map as a District Centre (outlined in blue in the map below) but only in the section of the DAP relating to retail.

Map of Gosforth showing the boundary of Gosforth District Centre

Retail destinations that are also on main roads present some of the greatest challenges for managing the conflict between Movement and Place. The SPACE for Gosforth view is that in this short section of road Gosforth High Street’s role as a local shopping street and community hub should take precedence over its role for moving people, goods and services. 

The current trial bus-priority layout prioritises Movement over Place, prioritises journey times over safety, and does little for the High Street itself. If you want to feed back to the Council on this trial layout you can do so at https://gosforthhighstreet.commonplace.is. The formal six month consultation period ends 21 September 2023.

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Newcastle City Council is consulting on its pre-submission version of the Development and Allocations Plan (DAP). Once confirmed, the proposed DAP will become part of the Local Plan along with The Core Strategy and Urban Core Plan, which will guide development in Newcastle up to 2030.

This is the follow up to the draft DAP which was consulted on in late 2017. SPACE for Gosforth submitted a response to the draft DAP consultation, including comments on Policy DM10 Pedestrian and Cycle Movement and on new policies to protect open spaces.

Comments on this final version of the DAP need to be submitted by 16 November 2018. Details of how to do this are on the Council’s website. The website also lists a number of consultation drop-in session at the City Library between 6 October and 10 November, and you can also leave comments at the DAP display stand at Gosforth Shopping Centre.

This is the last opportunity to make comments before the DAP is adopted. Following consultation, all comments received will be sent to the planning inspector appointed to consider the DAP at a public examination. The examination will be to find out whether the DAP is ‘sound’ and legally compliant. To be legal the DAP must comply with the conditions set out in the National Planning Policy Framework.

Our Feedback

The rest of this blog is made up of SPACE for Gosforth’s feedback to the draft DAP in 2017. We hope that this will be relatively self explanatory but if you have questions or observations on the SPACE for Gosforth submission and/or the pre-submission DAP please feel free to post them as a comment.

SPACE for Gosforth submission to the Draft Development and Allocations Plan Consultation – November 2017

Re: The Draft Development and Allocations Plan Consultation

Thank you for the opportunity to comment on the Draft Development and Allocations Plan.

The National Planning Policy Framework (NPPF) requires Local Plans to respond to the needs and priorities of the communities covered by those plans. For Newcastle, a relatively compact city with low car ownership but also with illegal levels of air pollution and some of the busiest and most dangerous roads and junctions in the North East, this means addressing those mobility, safety and environmental challenges but also addressing wider challenges related to lower than average health outcomes and poverty.

Walkability, and the ability to cycle safely, as well as improving mobility at low cost with minimal environmental impact, also have well documented positive benefits[1]on a range of physical and mental health issues, community cohesion, local economy and environment. Together these address a wide range of economic, social and environmental challenges impacting the people of Newcastle. As such we believe walking and cycling should be considered as a priority across all Newcastle’s Local Plan policies.

SPACE for Gosforth is a local residents’ group that seeks to promote healthy, liveable, accessible and safe neighbourhoods where walking and cycling are safe, practical and attractive travel options for residents of all ages and abilities. As such, our main focus in responding is in relation to Transport and Accessibility, Policies, Environmental Protection and Protecting Open Space. This feedback we have set out in Appendix A below. In Appendix B we set out some of the evidence that we have considered in providing this feedback.

The Local Plan should not be limited to addressing issues though. It needs to show a city willing to compete internationally, to draw best practice from across the world, from Copenhagen, Amsterdam, Barcelona, Paris, Seville, London and New York, and our twin city Groningen, all of which are investing in the public realm, prioritising sustainable and active travel and investing in (and competing with each other on) liveability and accessibility. If Newcastle is to compete in this arena it needs a strong vision backed by robust policy to deliver that vision.

With walking and cycling at the heart of these policies, Newcastle will be able to provide for all its residents young and old, attract families, help people improve their health and access jobs and services. Lowering the cost of travel and improving mobility options so people can access work more easily will help people to realise their full potential and make Newcastle more prosperous. Helping people choose active travel first will make Newcastle more sustainable and differentiate it from other UK cities.

We look forward to discussing these policies with you further and would welcome the opportunity to meet once you have had the opportunity to consider consultation feedback.

Yours sincerely,

SPACE for Gosforth

Appendix A. SPACE for Gosforth feedback on draft DAP Policies

 Policy DM1 Employment Sites

Policy DM2 Protection of Employment Sites

Policy DM3 District and Local Retail Centres 

Policy DM4 Retail and Leisure Impact Assessment

 No comment

Policy DM5 Housing Sites

Policy DM6 Adaptable and Accessible Housing

Policy DM7 Spacing Standards

Policy DM8 Specialist Accommodation

Policy DM9 Newcastle General Hospital Site

We don’t wish to comment on specific policies but have a number of general comments:

1. We would like to confirm that provision for Affordable Housing is included in the housing sites list in Policy DM5.

2. We would like to seek assurances that steps have been taken within the DAP to prevent developers avoiding requirements to building affordable housing on these sites. See for example: https://www.theguardian.com/cities/2015/jun/25/london-developers-viability-planning-affordable-social-housing-regeneration-oliver-wainwright

3. We would like the DAP to include assurances that the only open spaces that will be used for residential development in the Local Plan period are those specifically identified in Policy DM5.

4. More generally, best practice planning for walkable communities requires that development within an area is mixed-use so as to incorporate a range of homes, shops, services and workplaces all within close proximity.

This appears to be an approach considered suitable for the Urban Core and for the Newcastle General Hospital site. It is also mentioned specifically in the NPPF paragraph 69 as a way of promoting healthy communities so we are unsure why this same approach is not promoted for the wider city?

At Great Park for example, housing development and retail have been divided into separate ‘Cells’. If Newcastle is to make itself a place where people live, work and visit then we need well-linked communities and neighbourhoods, not a form of planning based on separation of inmates in penal institutions.

As an illustration of this, if you enter the post-code of Great Park Community Centre (NE13 9BD) into the www.walkscore.com website it states a Walk Score of 9 out of 100, which means  ‘Car-Dependent, Almost all errands require a car.’ Gosforth High Street by comparison has a Walk Score of 85.  The existing policies that enable the creation of car-dependent suburbs, which make it hard for people to choose other means of travel regardless of how they want to travel, why they are making their journey or where they wish to get to, need to be fixed as part of this Local Plan update.

5. On a similar basis it would be appropriate to include a further policy relating to density of housing in major developments, for example:

• Within 400m of local retail centres, strategic transport corridors, work-places and transport hubs: moderate to high density (>50 dwellings per hectare)
• Elsewhere: moderate density (>35 dwellings per hectare)
• Lower-density development will be permissible only in circumstances where moderate densities would be insensitive to context.

Policy DM10 Pedestrian and Cycle Movement

Policy DM11 Public Transport

Policy DM12 Parking and Servicing

Policy DM13 Road Hierarchy

Policy DM14 Mitigation and Highway Management

Policy DM15 Conservation of Heritage Assets

Policy DM16 Conservation and Enhancement of the Setting of Heritage Assets

Policy DM17 Archaeological Work and Preservation of Archaeological Work

Policy DM18 Building Recording

Policy DM19 Battlefield of Newburn Ford 1640

 No comment

 Policy DM20 Design

 Policy DM21 Shopfronts and Signage

Policy DM22 Shroud Advert Policy

No comment

Policy DM23 Residential Amenity

Policy DM24 Environmental Protection

Policy DM25 Flood Risk and Water Management

No comment

Policy DM26 Protecting and Enhancing Green Infrastructure

Policy DM27 Trees and Landscaping

Policy DM28 Protecting and Enhancing Biodiversity and Habitats

No comment

Policy DM29 Protecting Open Space

Policy DM30 Provision of New Open Space Sports and Recreational Buildings

Policy DM31 Green Belt Development

No comment

Policy DM32 Minerals Extraction and Reclamation

Policy DM33 Area of Search

Policy DM34 Recycling and Refuse Storage Provision

No comment

Policy DM35 Telecommunications and Digital Infrastructure

No comment

Appendix B. How have we reviewed the Draft Development and Allocations Plan?

SPACE for Gosforth has evaluated policies against SPACE for Gosforth’s objectives and against further Newcastle City Council policy and commitments as they relate to the SPACE for Gosforth objectives.

[1]The Case for Healthy Streets https://www.spaceforgosforth.com/cwis2017/

[2]Cycling Level of Servicehttp://content.tfl.gov.uk/lcds-chapter2-toolsandtechniques.pdf

[3]Gosforth High Street https://www.spaceforgosforth.com/high-street-walk/

[4]Salters Road Junction https://www.spaceforgosforth.com/zoe-the-guide-dog-reviews-salters-road-junction/

[5]RNIB on pedestrian crossings http://www.rnib.org.uk/campaigning-campaign-resources-my-street/crossings

[6]Traffic as a contributor to local air pollution http://www.rnib.org.uk/campaigning-campaign-resources-my-street/crossings

[7]Adverse effects of traffic http://www.rnib.org.uk/campaigning-campaign-resources-my-street/crossings

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2018 is an important anniversary for Newcastle upon Tyne as it marks 10 years since Air Quality Management Areas (AQMAs) were declared for the city centre (which includes parts of Jesmond and Heaton) and for South Gosforth in 2008.  The city centre AQMA replaced an earlier AQMA in this area.

Newcastle City Centre AQMA

Both Air Quality Management Areas were declared due to levels of the pollutant nitrogen dioxide exceeding legal limits.

Nitrogen dioxide has been linked to a wide range of diseases and other health conditions including cancer, low sperm counts, dementia and cognitive delay in children.

Newcastle City Council recently released figures for nitrogen dioxide levels in 2016, and these showed that a previous trend of nitrogen dioxide levels decreasing in Gosforth has halted and that nitrogen dioxide levels in Gosforth have once again risen to above legal limits.

The South Gosforth AQMA

Members of the public can obtain real time information about levels from pollution from Newcastle University’s Urban Observatory. SPACE for Gosforth has written several previous blogs highlighting high levels of nitrogen dioxide in both AQMAs:

• Black Friday, Smoggy Saturday… (on Gosforth)
• Black Friday Part 2 – Newcastle City Centre
• Pollution Update – February 2017
• The New Newcastle Air Pollution Plan
• Air Quality Update 2016

Air pollution monitoring in 2015

As well as nitrogen dioxide pollution, previous monitoring carried out by SPACE for Gosforth in 2015 suggested that there might also be a problem with particulate pollution on Gosforth High Street.

2018 will also be an important electoral date for the city of Newcastle upon Tyne as residents in all wards will have the opportunity to elect all their three councillors due to the boundary changes. 

Locations where Defra have ordered a reduction in emissions

At SPACE for Gosforth we believe that this election offers residents of Newcastle upon Tyne the opportunity to raise the issue of our filthy air with candidates of all parties and to ask how they would tackle this issue.

Poor air quality affects everyone who lives and works in Newcastle upon Tyne. It is not an issue that our elected representatives can ignore, as they have been ordered to take action by Defra to reduce air pollution on the key city arteries of the Tyne Bridge / Central Motorway, the A1 and the Coast Road. This was following the defeat of the Department for Environment, Food and Rural Affairs (Defra) in the High Court by the environmental law firm Client Earth.

Nitrogen dioxide levels on Blackett St last July – only legal when the road was closed to traffic!

Client Earth has launched further legal action against Defra this year, so it is entirely possible that as one consequence of this action Newcastle City Council may be required by the Government to do even more.  It is also worth noting that Newcastle City Council is currently controlled by the Labour Party, and Jeremy Corbyn, the leader of the Labour Party, has recently publicly stated that tackling air pollution is a national priority for his party should they form a government.

Air pollution monitor on Gosforth High St

The seriousness of this issue, both in its impact on public health and due to the legal obligations that are falling on Newcastle City Council, means that it is one which every candidate for public office in our city needs to understand fully.

In 2018 we hope to hear more from both elected councillors and candidates about what they will be doing this year to ensure that councillors, council officers and others in Newcastle take decisive and effective action to reduce levels of nitrogen dioxide in our city.

Ten years is too long for the health of the public to be put at risk in this way – our ambition for 2018 is that this tenth birthday for both AQMAs is also their last.

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As part of its draft Development and Allocations Plan, Newcastle City Council has set out the detail policies that it believes will help it achieve the objectives set out in The Core Strategy and Urban Core Plan, and which together will guide how the city is to be developed up to 2030.

In this second blog on the draft DAP we want to look at proposed policy DM10 covering pedestrian and cycle movement.

You can comment on the new plan on the Let’s Talk website until 20 November 2017. Our previous blog on the proposed policy for Protecting Open Spaces is here.

The Overwhelming Case for Walking and Cycling

In our post The Case for Healthy Streets we set out much of the evidence for why walking and cycling should be prioritised when considering new transport schemes, including the benefits to health and the economy, in creating more and better choices for how we travel and for children’s independence and safety. New policy should therefore require best practice for walking and cycling provision to ensure that maximum benefits can be gained for the city and its residents.

DAP policies also have to be consistent with the National Planning Policy Framework (NPPF) and other national legislation.  It also needs to be consistent with The Core Strategy and Urban Core Plan, which has already defined the strategic objectives  (S07, S08) and policy (CS13) that this more detailed policy is to support.

Getting this right is very important as we saw at Gosforth Business Park where a poor design would almost certainly lead to much more traffic passing through the South Gosforth Air Quality Management Area.

The SPACE for Gosforth Proposal

Broadly we support the new policy however we wish to propose some amendments in particular to ensure anyone can use new walking and cycling routes and to avoid conflict between people walking and cycling.

We have set out these changes below shown in red and underlined along with supporting evidence to show that the proposals are consistent with the NPPF and the Core Strategy.

1. Direct routes that also minimise conflict between walking and cycling.

The Newcastle Core Strategy Policy CS13 section 3(vii) requires that development “provides for direct, safe, secure and continuous pedestrian and cycling links.” Policy DM10 should therefore be updated to also require that routes are direct to support this.

NPPF Section 35 requires that developments be designed where practical to “create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter and where appropriate establishing home zones.” The NPPF is right to say that danger mostly comes from conflict with vehicles but routes should also be designed to avoid conflict between people walking and cycling.

Safety in this context means both from vehicle traffic and also ensuring people feel safe from crime. So, for example, unlit alleyways would not be appropriate.

2. Giving priority to walking and cycling

Section 35 of the NPPF also says where practical to “give priority to pedestrian and cycle movements, and have access to high quality public transport facilities;” Updating the policy to include this priority will help make walking and cycling viable choices for local journeys, where often design is currently an after-thought leading to long circuitous routes and long waits at multi-stage crossings.

This is also consistent with the Core Strategy Section 11.12, which states that “The aim of the Plan is to create sustainable communities, centres and new developments where priority is given to sustainable modes of transport. The hierarchy of sustainable modes of transport is: walking, cycling, public transport (including taxis), freight, car traffic.”

3. Ensuring walking and cycling routes are suitable for all ages and abilities

Section 1(i) of Core Strategy Policy CS13 requires the council to promote “sustainable travel choices including … improving equality of access to transport for everyone“. We wish to propose this addition as ensuring equality of access to transport is a key part of SPACE for Gosforth’s objectives.

As per those objectives ‘everyone’ includes “all ages and abilities.” and “residents or visitors with limited mobility and residents or visitors with disabilities or conditions for whom travel is a challenge.” For examples of how hard it can be to navigate some local streets see the SPACE for Gosforth blogs on Gosforth High Street and the Salters Road junction.

Core Strategy Policy CS14 – Wellbeing and Health backs this up by stating “The wellbeing and health of communities will be maintained and improved by … Requiring development to contribute to creating an age friendly, healthy and equitable living environment through: i. Creating an inclusive built and natural environment” and “ii. promoting and facilitating active and healthy lifestyles.” Core Strategy Policy CS15 Place-Making also requires development to create “safe and inclusive environments“.

Although a fairly weak statement, NPPF paragraph 35 requires that where practical developments should “consider the needs of people with disabilities by all modes of transport.” Also, one of the objectives of the Government’s Cycling and Walking Infrastructure Strategy (CWIS) is “better integrated routes for those with disabilities or health conditions”.

Much stronger still is The Equality Act 2010, which the RNIB summarise as follows. “It is unlawful for a public authority to discriminate in the exercise of its public functions. This includes highways functions. Section 20 (4) requires that where a physical feature (which includes increases in traffic) puts a disabled person at a substantial disadvantage in comparison to a person who is not disabled, an authority is required to take such steps as is reasonable to have to take to avoid the disadvantage.”

4. Clarifying a minimum list of local services

This policy is derived from NPPF paragraph 38 which mentions schools and shops: “For larger scale residential developments in particular, planning policies should promote a mix of uses in order to provide opportunities to undertake day-to-day activities including work on site. Where practical, particularly within large-scale developments, key facilities such as primary schools and local shops should be located within walking distance of most properties.”

As the purpose of the DAP is to expand on the objectives set out in the Core Strategy we wish to clarify what the minimum set of services that people can walk to should be. The full list we propose are from the SPACE for Gosforth objective 3: “There is good walking and cycling access to local community destinations including schools, shops, medical centres, work-places and transport hubs.” This should be the minimum for any new development.

5. Making walking and cycling the natural choice for short to medium journeys

We wish to propose this new paragraph to include a number of NPPF and Core Strategy objectives to maximise the use of walking and cycling in order to minimise the impact of the development on the wider road network and public health.

NPPF paragraph 17 states that one of the core principles for planning is to “actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable;” Only by making the fullest possible use of walking and cycling can the wider negative impacts be minimised.

Newcastle Core Strategy CS13 section 3(ii) supports this by “Ensuring development … minimises car trips, promotes and enhances public transport and for major development provides sustainable travel plans“. (Public Transport is covered in the DAP by a separate policy DM11.)

NPPF paragraph 110 states “In preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment.” This is very relevant to transport as it is both a significant contributor to local air pollution and to a number of other adverse effects including noise.

Consistent with all the above, the Governments’s Cycling and Walking Investment Strategy (CWIS) sets out “the government’s ambition to make cycling and walking a natural choice for shorter journeys, or as part of longer journeys“. Planning for new developments will be a key part of enabling this to happen.

6 Secure parking for cycles (not cyclists)

Our proposed change to section 6 is to provide cycle parking (in the same way as we have car parking and not motorist parking).

The full proposal is as follows. SPACE for Gosforth will be providing this response to the DAP consultation as well as commenting on other policies related to SPACE for Gosforth’s objectives.

Policy DM10 – Pedestrian and Cycle Movement (SPACE for Gosforth proposal)

Development will be required to:

1. Provide safe, direct, convenient, attractive and continuous pedestrian and cycle links to key local facilities and services that minimise conflict between traffic, cyclists and pedestrians;
2. Provide connections through developments that link to existing and planned wider pedestrian and cycle networks and ensure that those connections give priority to pedestrian and cycle movements;
3. Ensure that walking and cycling routes are suitable for all ages and for people with disabilities;
4. Demonstrate that major developments are within acceptable walking distances of key local facilities and services including schools, shops, medical centers, work-places and transport hubs;
5. Demonstrate that the development makes the fullest possible use of walking and cycling in order to minimise car trips and minimise pollution and other adverse effects on the natural and local environment; and
6. Provide employee changing and shower facilities and secure parking for cycles for major non-residential developments.

References to Planning from The Cycling and Walking Investment Strategy

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Newcastle City Council has just published its draft Development and Allocations Plan, which is the second part of the local plan that, with the first part The Core Strategy and Urban Core Plan, will guide how the city is to be developed up to 2030.

You can comment on the new plan on the Let’s Talk website until 20 November 2017.

The new plan sets out policies for Economic Prosperity, Homes, Transport and Accessibility, People and Places, Minerals and Waste, and Infrastructure and Delivery. One aspect of People and Places is Open Space and in this blog we want to look at the proposals for protecting Open Space.

“Surplus” Open Space can now be developed

In the old UDP Policies that include the current Open Space protections, there is a list of sites that are protected through the policies where the policies state development ‘will not be allowed’.

The new Open Space policy standards have ‘quantity standards’ which set out the amount of open space that should be provided per 1000 people. Anything over that will be considered surplus and therefore can be developed providing there is no conflict with other policies, for example relating to nature or wildlife. Using these standards for parks and for amenity green spaces, which are smaller more informal open areas, we have derived the following graph that shows how much surplus Open Space there is by ward according to the new standards. In total we believe approximately 93 hectares, equivalent to 130 football pitches, is at risk as a result of the new standards.

In fact, the area at risk is possibly larger than this as the above graph combines two categories, Parks and Amenity Green Space, and it is possible that development might be justified using just one category. So for example, Dene ward has less Open Space than the standards suggest is required for Parks and Amenity Green Space combined. The total for Parks by itself suggests that there is surplus and therefore current parkland in Dene could be built on.

As part of the assessment the Council’s consultants have drawn up plans of each of the City’s political wards to show where current provision exists. The map below is for East Gosforth but also shows Paddy Freeman’s Park, which is in Dene ward and under these standards could be built on.

Most of the green space in East Gosforth is shown in purple, which are school playing fields and therefore not open to the public. Light blue areas are private facilities such as the golf course just north of Garden Village. Amenity Green Space, what most people would just call greens and are open to the public, are coloured dark green and parks are in lime green, some with blue sports pitches. Also shown in dark red, within parks, are basketball courts and skateparks which collectively are called Youth Play Space, allotments in brown and Natural Green Space (The Town Moor and Jesmond Dene) in beige.

Open Space Standards 

Each of these classifications has its own standard both from quantity as well as access. The Access standard distance is given as a straight line and the times calculated based on walking at 3mph on a route that is 1²/₃ longer than the straight line route. For example 720m straight line distance = 1200m actual walking, which at 3mph will take 15 minutes.

Typical speeds at pedestrian crossings are calculated based on 1.2m/s = 2.7mph, but with guidance suggesting older people are more likely to walk at 0.8m/s = 1.8mph. That would make a nominal 15 minute walk in these standards more like 25 minutes. A similar issue would exist where parks are located near Metro lines and walking distances are actually much further than the1²/₃ times assumed.

The approach taken to coming up with these standards is described in the 2017 Newcastle Open Space Assessment, which is part of the evidence base for the draft Development and Allocations Plan. For Amenity Green Space, the assessment appears to be based on a city-wide average (0.83ha/1000people) and a survey that said 52% of people said more informal open space areas were needed and 43% felt there were enough. No results are given for whether anyone thought there were too many open space areas but if that was counted it would have been less than 5% of responses.

The assessment also mentions a Fields in Trust guideline suggesting 0.6ha/1000 people, so slightly less generous than proposed but with a much shorter walking (not straight line) distance of 480m. The proposed standard suggests a walking distance over twice this, which is counter to separate evidence that children’s independence is being ever more curtailed to a large extent due to danger caused by large volumes of traffic.

Separately in the evidence base for the new plan there are assessments, based on the new standards, to justify development on four existing green spaces. These are:

• Hartburn Walk in Kenton
• Hallow Drive, Throckley
• Thornley Road, Denton
• Somerset Place, Elswick

The guidelines for protecting Open Space are set out in proposed new Policy DM29. This sets out a presumption that Open Spaces are not to be built on but with the new exception 1(i) where there is a surplus over the quantity standard.

Development where there is no surplus

Arguably though, it is not clear what protection this new standard is going to give when planning assessments made by the Council so easily override stated policy based on a ‘material consideration‘ unrelated to Open Space, and when the Planning Committee appears unwilling in these circumstances to assert the priority of the Open Space policies the members themselves approved. Ultimately, unless clear guidelines are put in place to set limits on the use of material considerations to over-ride policies that protect Open Space, far more green space could be irreparably lost to future development.

If you wish to comment on these proposals now is your chance. You can see the proposed Development and Allocations Plan here, and submit comments here until 20 November 2017.

This blog is a very brief summary of the Open Space considerations for Newcastle. For anyone interested in Open Space in the city the 2017 Newcastle Open Space Assessment sets out all the previous policies for Open Space and how they have changed over time, and if you spot anything else interesting in the standards please let us know via the Comments section below.

The post Protecting Open Spaces – comments by 20 November 2017 appeared first on SPACE for Gosforth.

On 4 September, Newcastle City Council published a planning application to build on South Gosforth Green. This application, made on behalf of the Council’s Fairer Housing Unit, is for 7 bungalows in a courtyard arrangement with parking and an access road from Ridgewood Gardens to the north. 

The facilities proposed, to support people with physical disabilities and those with learning disabilities and/or autism, are undoubtedly a good thing. On the other hand, if approved, this development will lead to the irreversible loss of part of the green currently available and of benefit to the wider community. So while we support the creation of such a facility we do have concerns about the use of this location and the precedent this may set to allow building on other green space.

The benefits of having good quality green spaces within cities are well known. The National Trust, who are working with Newcastle City Council on its proposed Parks Charitable Trust have estimated for Sheffield that its parks and green spaces are an asset worth £1.2bn to the city including their very positive impact on physical and mental health for residents. Newcastle Council’s strategic objectives recognise this and include an objective to “Improve the function, usability and provision of our green 
infrastructure and public spaces by providing a network of green spaces and features which are connected and accessible for all.”

Recent history however suggests this objective to improve the provision of green space is no longer being pursued. In February the Council approved an application to build on Montagu Green in Kenton and in April we found the green in Grange where Alan Shearer learned to play football had also been earmarked for housing.

This raises a whole range of questions. Why has the Council chosen to build on community green space? How will the value of the new facility be weighed against the loss of green spaces? What criteria will be used to judge this and is the application compliant with these criteria? What happens when the Council is acting both as a developer and also as the planning authority? And what does this mean for the future of other green spaces in Gosforth and across the city? We thought we better have a look.

Why has the Council chosen to build on community green space?

The National Planning Policy Framework (paragraph 47) requires Councils to assess future housing needs and, where additional housing is required, identify sites that can be developed to meet those needs. For new housing to be developed in the next five years those sites must be immediately available, suitable for development and with a realistic prospect that housing will be built within the five year period. Given such criteria, parks and green spaces owned by the Council (or any Council) are going to be attractive targets if not given suitable protection.

That said, the most recently published assessment for Newcastle, set out in the draft 2016 Housing and Economic Land Availability Assessment (HELAA) and summarised in the interactive map below, does not include South Gosforth Green, nor the Park Avenue green. The Valley, by Newlands Road in High West Jesmond, is mentioned but as a site that has been specifically discounted, as is the former Sanderson Hospital site in West Gosforth.

Although not in the current site list for future housing, South Gosforth Green was in included in the Council’s 2013 Strategic Land Housing Availability Assessment. In this assessment it was recorded that this location would be “most suitable for development of a bungalow court” but that there was “no Council resolution to dispose of site for residential development” and that the main constraint to housing development there was the Council’s own Open Spaces policy.

While none of this would constrain a private developer from submitting a planning application for South Gosforth Green, it does seem surprising that the Council itself should choose a location it has specifically removed from its own development list and where previously it has noted non-compliance with its own policies. In these circumstances it seems reasonable to ask why the Council has submitted an application given its own plan shows sufficient sites for building without the loss of this green space.

How will the value of the new facility be weighed against the loss of green spaces?

Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that applications for planning permission must be determined in accordance with the Council’s statutory development plan unless material considerations indicate otherwise. The statuatory development plan for Newcastle consists of the Core Strategy and Urban Core Plan for Gateshead and Newcastle upon Tyne 2010-2030 and a number of reserved policies from the previous Unitary Development Plan including a number of policies relating to the protection of open spaces.

The Planning Statement prepared by the developer effectively admits that the proposed development is not in line with the development plan saying “it would still be difficult to justify development against UDP Policy OS1.5“. Policy OS1.5 along with OS1.4 are the key policies protecting open spaces. Policy OS1.5 sets a strong presumption against building on open spaces and lists four “exceptional circumstances”, none of which apply to the South Gosforth Green application. These four exceptional circumstances are the only circumstances where loss of open space would be considered acceptable according to the plan.

This does not automatically mean that the proposal will be rejected though. The approved application for Montagu Green was also assessed to be not in accordance with the development plan. The planning officer report (paragraph 108) stated that “none of the exceptional circumstances listed in policy OS1.5 are considered applicable in this case. As such, the proposal is a departure from the development plan.”

The Montagu report then goes on to say: “As such, consideration is required as to whether the loss of the open space would be outweighed by the benefits of the proposed development.” In effect, this reasoning appears to be second guessing the development plan as the development plan has already set out very clearly (in policy OS1.5) the specific circumstances in which the benefits of the proposed development should outweigh the loss of green space. Based on this, it feels quite likely that the recommendation given to the Planning Committee to approve the Montagu Green application was incorrect.

The South Gosforth application also states that “A separate ‘Open Space Assessment’ has been prepared which concludes that the development of the site for housing, would not result in overriding harm in terms of loss of open space functionality.” This conclusion also appears to be unjustifiable as Policy OS1.4 defines that “Harm includes loss of the space in whole or part.” and that “development which would cause demonstrable harm to any public open space… will not be allowed.” (underlined for emphasis). This same was true for Montagu Green however and that was recommended for approval despite the very clear harm (as defined by policy OS1.4) caused by loss of part of the green.

South Gosforth Green by Google Maps. Click Map to go to Google Maps

What criteria will be used to judge this and is the application compliant with these criteria?

As set out above, the South Gosforth application is not compliant with the local development plan and, if there are no material considerations to the contrary, should be rejected as required by the Planning and Compulsory Purchase Act.

Material considerations could include loss of privacy, traffic issues, lack of sufficient local facilities e.g. school places, impact on nature or layout and density of the design. Some of these aspects we wrote about in relation to a planning application at Gosforth Business Park and are for the most part reasons to reject an application rather than to approve a non-compliant application.

The National Planning Policy Framework is also considered to be a material consideration and the South Gosforth Application references paragraph 74 which also states a presumption against development on open space but in addition to the circumstances set out in policy OS1.5 also allows open space to be built on if “An assessment has been undertaken which has clearly shown the open space, buildings and land to be surplus to requirements.”

This circumstance is not included as an option in the development plan however policies OS1.4 and OS1.5 in effect confirm that the open spaces listed (including South Gosforth Green and Montagu Green) are (or were) required and are therefore not surplus to requirement.

The Open Spaces Assessment included in the planning application suggests an alternative view with a set of minimum “quality” standards that allow for the removal of green space even though Council strategic objectives and detail policy at the time of the application suggest this should not happen.

This leads to the following comparison of current green space vs the ‘quality standard’ which the developer asserts (we believe incorrectly) “clearly shows” the part of South Gosforth Green that is to be developed “to be surplus to requirements”. (quoted words from National Planning Policy Framework paragraph 74).

Based on the proposed Draft Development and Allocations Plan on the agenda for Council Cabinet on 18 September 2017 (table 1 p67), the Amenity Green Space ratio will be 1.0ha/1000 rather than 0.8ha/1000 stated above. This increases the requirement from 8.11ha to 10.14ha  and reduces the surplus to only 0.15ha so far less than the 0.44ha site covered by the application. If this application is approved then it will cause East Gosforth ward to be in shortfall for Amenity Green Space even with the new lower standards. These new ratios will not apply however until after public consultation which, if approved by Council Cabinet. will not complete until December 2017.

Measured against current policy the application is even less compliant. Policy OS1.2 states that when considering planning applications the appropriate measures are (a) that most households should be within 500m of a public park of 6 hectares minimum (not met at South Gosforth Green); and  (b) rates for local open spaces and spaces for outdoor sport set at 1.2 ha/1000 people and 1.1 ha/1000 people respectively (much higher than is available at South Gosforth Green).

There are a number of further issues with this assessment beyond the fact that it doesn’t appear to comply with Council policies  or objectives.

1. The developer cites the “over-provision” of Amenity Green Space as a reason for allowing the development to go ahead. While this is mathematically true based on the ratios provided with the application and for that specific category, if this assessment is made in respect of overall green space excluding allotments (i.e. locations where children can play) then even against these lower standards there is currently an under provision of 2.7 hectares, which will be made worse by this proposal.
2. The assessment states that Gosforth Central Park and Paddy Freemans are within a 15 minute walk of South Gosforth Green. While this may be true for a fit adult, the actual access standard is 720m which is not met as Gosforth Central Park is approximately 900m (see map below) and Paddy Freeman even further.
3. Walking routes to both these parks require the use of and crossing of busy main roads including Haddricks Mill roundabout, which according to analysis by The Chronicle is one of the 10 most dangerous roundabouts in Britain.
4. Just taking the distance from South Gosforth Green is too simplistic an analysis to judge distance as the 900m / 1100m would be incremental distance for anyone living north of South Gosforth green, in particular in Garden Village where contrary to its name there is a lack of usable open space.
5. The assessment scope covers the area enclosed by East Gosforth ward whereas people do not stick to political wards when choosing which park to go to. In this case, a large part of the Amenity Green Space for this ward is at the other end of the ward on the Little Moor, 1400m away.
6. Even if the 720m threshold was met, this doesn’t mean that children from South Gosforth would go (or be allowed to go) to these other parks. As a 2010 study observed “The distance our kids stray from home on their own has shrunk by 90% since the 70s; 43% of adults think a child shouldn’t play outdoors unsupervised until the age of 14“. So even if children don’t miss out as a result of this application it would create a significant additional time burden on parents escorting them to parks, where previously they did not need to. This is particularly important in light of the observation in the local development plan that Newcastle is “losing families and employed people to other districts.“

Google Maps walking directions from South Gosforth Green to Gosforth Central Park. According to the application 720m is the maximum distance anyone should have to walk to a park. Click to go to Google Maps directions.

What happens when the Council is acting both as a developer and also as the planning authority? 

This application has also highlighted a number of issues with the planning process itself.

1. The Council is acting in multiple roles which potentially conflict. As well as being the developer making the application, it is also the planning authority that assesses the application and the policy-setting body that creates the policy that the application will be assessed against.
2. The developer has been given access to unpublished (and possibly unapproved) Council  Open Spaces Needs Assessment, which suggests the planning department may have had a significant part in writing this key aspect of the application. This means in the final assessment the planning department could in effect be marking its own homework and potentially may not apply the proper scrutiny it deserves.
3. As developer, the Council appears to be over-relying on its role in policy-setting to interpret local plan policies in a way that may not have been intended when those policies were made.  Updating the Open Spaces Needs Assessment to vary the quality standards for open spaces could be seen in a similar light, as could an over-reliance on ward boundaries for assessing open space availability.
4. A similar potential conflict also exists for the Councillors that attend the Planning Committee, in that they are being asked to review their colleague’s application.
5. From a financial perspective, a further conflict exists in that if there is to be a developer contribution it would have to be paid by the Council. In the planning application it states “There is no scope, nor any requirement, for the development to make wider planning contributions.”  despite the loss of community green space. The National Planning Policy Framework (paragraph 204), on the other hand, states that planning obligations (including financial payments) may be sought in order to make the proposed development acceptable in planning terms. In this case that would be (as per policy OS1.5) the cost for the Council of providing an alternative of equivalent community benefit, which could be considerable.
6. There are also financial questions regarding future ownership of land e.g. will it be sold to Your Homes Newcastle and if so will the Council recover a fair market price for the land. Arguably, if this application goes ahead, any monies resulting from that sale should go to benefit the community that has lost the benefit of the green in addition to the developer contribution.

What does this mean for the future of other green spaces in Gosforth and across the city?

Parks and green spaces in Newcastle and in local authorities across the country face an uncertain future. When Council budgets are being cut then non-statuatory services such as parks will inevitably be affected.

At the same time cities across the world are striving to find ways to create more green space as they both understand the value to its residents and in attracting people, especially families, to come and live and work there. These include cities like Barcelona looking to double the number of trees and increase park space by two thirds , like Seoul where a highway has been turned into a public park and New York where the High Line park has been created from a former elevated freight rail line.

The applications at Montagu Green and South Gosforth Green should be a wake up call to anyone who values parks and green spaces in the city. By the time a planning application has been submitted it may well be too late. In many cases there will be friends groups already formed to look after parks that you can join and support, but if there isn’t it is never too late to start one. Whatever ratios are used to calculate under or over provision, green spaces that are cared for and well used by the local community will have a much better chance of survival than those that are not.

Comments on the South Gosforth Green planning application need to be received by 25 September 2017. There is also a Community Picnic planned on South Gosforth Green on 23 September.

The new reduced Open Spaces ratios proposed in the Development and Allocations Plan is due to be consulted on between 9 October 2017 and 20 November 2017.

UPDATE 28/9/2017

We wrote to the Council about the potential conflicts of interest referenced above. Whilst the developer clearly had access to documentation that has only just been made publicly available, we do have confirmation that “the  application was prepared by the Fairer Housing unit and did not have any involvement from officers in Development Management.”

The Council have also confirmed that “All applications need to be fully assessed against the adopted policies at the time of determination of the application.  All emerging policy are a material consideration and the weight to be applied depends to some degree on the stage of consultation.” We understand this to mean that the proposed lower levels of protection for open space can be taken into account in the assessment made by the Planning Officer but that these should be given lower weight as they have not yet been consulted on.

We also have confirmed that this will be taken to Planning Committee rather than to be made via a delegated decision. Agendas and papers for Planning Committees are available here. The next committee is planned for 13 October 2017.

In addition, the evidence base for the DAP is now available to view, which includes reference to the Newcastle Open Space Assessment 2016-2030 referred to in the planning application.

The Open Space Assessment states a ratio of 0.8ha/1000 people (section 6.3), which might explain why the planning application uses this figure rather than 1.0ha/1000people set out in the DAP.  The DAP however is the definitive policy document approved by cabinet to be consulted on and which could be cited as a material consideration (albeit of lower weight) for this application.

Based on figures set out in the Open Space Assessment there are 10,145 people in East Gosforth (section 1.4.3) and so based on 1.0ha per 1000 people there needs to be 10.15 ha of Amenity Green Space in East Gosforth ward.

Table 7 (section 5.2.2) of the Open Space Assessment says that there are currently 10.28 ha of Amenity Green space in East Gosforth so, under the yet to be consulted on ratios, a “surplus” of 0.13ha which means if the application was to go ahead it would result in a deficiency of 0.31ha in the ward and would not be compliant with the proposed new open spaces policy (Policy DM29 – see below). This confirms the analysis made in the original blog post.

UPDATE 7/10/2017 Planning Committee Report recommends approval

The Council has published its Committee Report and has confirmed this application will be on the agenda for the Planning Committee on Friday 13th October.

The Committee Report confirms that, as we outlined above, the application does not comply with UDP Policies OS1.4 and OS1.5 relating to Open Space provision [See References D below] and does not comply with Core Strategy Policy CS18 “Green Infrastructure and the Natural Environment” that requires open space to be protected and enhanced in accordance with agreed standards in line with national policy.

It also confirms that the application does not comply with NPPF paragraph 74 [See References B below] which sets out national standards for whether open spaces can be built on. Paragraph 74 could have applied in this case if an assessment had shown the open space to be clearly surplus to requirements but this has not happened.

With regard to the proposed Draft Development and Allocation Plan, which proposes to reduce open space protections for the city and which the developer appeared to be relying upon to suggest there was a surplus of open space in the East Gosforth ward, the report confirms that this has limited weight as it has not yet been through any public consultation. This is not mentioned in the conclusion and we therefore assume it was not a factor in the officer’s recommendation.

The purpose of the proposal, for affordable bungalows for people with support needs, is considered to be a material consideration in favour of the application. To quote the report “There is a lack of affordable housing in the area and the proposal would only build on a third of the area of open space.”

Paragraph 54 expands on this to say that “East Gosforth and the surrounding wards (West Gosforth, Parklands, Dene and North Jesmond) have the lowest supply of affordable housing in Newcastle at only 7%. The City average is 30% of the housing stock being affordable housing. Only 6 affordable house have been completed in these wards in the past 25 years (with none in the East Gosforth Ward).”

East Gosforth, and the other wards mentioned, also have some of the lowest proportions of parks & amenity green space in the city at 1.26ha/1000 people  compared to a city-wide average of 1.65ha/1000 people. [Figures calculated from the Council’s Open Space Assessment.]

The recommendation to the Planning Committee is that the committee should approve the application subject to conditions that include:

• Investigation of potential contamination and in respect of mining works.
• Implementation of open space enhancement works.
• Tree protection measures
• Provision of bat and bird boxes.
• Affordable housing only.

There is no planning condition in relation to the purpose of the housing to assist people with support needs.

The Planning Committee will have to assess whether it supports this recommendation  to prioritise the benefits of building affordable housing in this location over Council and National policy to protect green spaces from over-development.

If approved by the Planning Committee, details relating to appearance, landscaping, layout and scale will be considered once the developer has submitted a further application to confirm these elements.

UPDATE 15/11/2017

The Planning Committee approved the application at the 3 November meeting and the decision notice has now been uploaded to the planning website.

There are sixteen conditions associated with the approval. Most of these are generic e.g. to do with ensuring the final proposal (the “reserved matters” application) meets road design and environmental standards. Conditions specific to the final proposal include:

1. There needs to be “Investigation and Risk Assessment to assess the nature and extent of any contamination on the site”.
2. There needs to be “A scheme of intrusive site investigations for the shallow coal workings.”
3. There needs to be “a detailed scheme of enhancements of the retained area of open space abutting the southern and western boundaries.”
4. The proposal needs to include “details of bird and bat boxes”
5. “The development shall provide 100% affordable housing for and the dwellings shall meet the definition of affordable housing.” There is an accompanying note to say these are to be affordable housing for older people.

In the original application it stated that The facilities proposed were to support people with physical disabilities and those with learning disabilities and/or autism so the purpose of the housing appears to have changed.

REFERENCES

(A) Planning Applications

South Gosforth Green

• Save South Gosforth Green Facebook group
• Save South Gosforth Green Twitter account
• Planning Application – comments due by 25 September 2017

Montagu Green, Kenton – decided 3 February 2017

• Save our green – Montagu Estate Facebook group
• Planning Application and decision
• Planning Committee officer report and decision – see item 7
• The local battle which exposed the war against Britain’s green space – article in The Spectator Magazine about Montagu Green

(B) Planning Policy and the Local Development Plan

Newcastle City Council’s Local Plan (the Statutory Development Plan)

• Proposed Local Development Plan for 2017-2020 (item 3.2 Council Cabinet 18/9/17)
• Proposed Draft Development and Allocation Plan (Item 3 Council Cabinet 18/9/17) – includes updates to Open Space policies.
• Core Strategy and Urban Core Plan for Gateshead and Newcastle upon Tyne 2010-2030
• Unitary Development Plan – applies where policies (including relating to Open Spaces) have been reserved. (see below for Open Space Policies).
• Summary of policies relating to planning.
• Evidence base for the Development and Allocations Plan.
• Newcastle Open Space Assessment 2016-2030

Housing Needs Assessments for Newcastle upon Tyne

• The draft 2016 Housing and Economic Land Availability Assessment (HELAA). No final version has been published to our knowledge.
• Strategic Housing Land Availability Assessment 2013

Open Spaces Needs Assessments and related documents

• Policy OS1.2 (see copy below) sets out planning standards for how much open space is required as part of and as a result of planning applications.
• Planning Obligations Supplementary Planning Documentation 2016 (confirms OS1.2 still applies)
• Green Infrastructure Study – Evidence Base 2011
• Public Green Space, Sport and Recreation – Needs and Opportunities 2009
• Green spaces … using planning 2004
• The most recent draft Open Spaces Needs Assessment referred to in the application has not been released to the public. We requested this on 29 August and were told that this is part of a set of documents to be reviewed by Council Cabinet on 18 September.

National Planning Policy

• The National Planning Policy Framework Paragraph 74 refers to conditions for building on open spaces.

Proposed Open Spaces Policy as part of the DAP

Proposed DAP Policy DM29 – Protecting Open Space

1. Redevelopment of open space, sports, recreational buildings and land, including playing fields will only be allowed where an assessment has been undertaken in accordance with the Council’s open space standards which demonstrates:

1. there is a proven surplus of such provision and the proposed loss will not result in a current or likely shortfall in the plan period; or
2. any loss resulting from development will be replaced by the equivalent or better provision in terms of both quality and quantity in a suitable location; or
3. the development proposed is for alternative sports and recreation provision or green infrastructure, the need of which clearly outweighs the loss of the existing open space.

2. Development which would result in the loss of open space not shown on the Policies Map that contribute to the character and visual amenity of an area will not be permitted unless it can be demonstrated that the benefits of development clearly outweigh the loss.

3. Development of ancillary facilities on open space will be supported where:

1. it is necessary to or would facilitate the functioning of the open space;
2. it would be appropriate in scale;
3. it would not detract from the character of the site or surroundings;
4. it would not be detrimental to any other function that the open space performs; and
5. it would contribute positively to the setting and quality of the open space.

(C) Proposals for a new Newcastle Parks Charitable Trust

• Development of a Charitable Trust to Deliver Newcastle’s Parks and Open Spaces (see item 4). Note that South Gosforth Green is not currently included in the scope of this Charitable Trust.

Local park community groups include:

• Friends of Gosforth Central Park Facebook, Twitter.
• Friends of Havannah Facebook, Twitter.
• Exhibition and Brandling Park Community Trust Facebook, Twitter
• Friends of Leazes Park Facebook.
• Friends of Walker Park Facebook.
• Friends of Iris Brickfield Facebook, Twitter.
• Heaton and Armstrong Parks Facebook, Twitter.
• Greening Wingrove Facebook, Twitter.
• Friends of Jesmond Dene Facebook.
• Friends of Summerhill / Summerhill Bowling Club Facebook, Twitter.
• Scotswood Garden Twitter.
• Newcastle Parks Forum Facebook.
• Parks for People Gosforth Facebook, Twitter.
• Friends of the Valley and Little Dene (FOVALD) Website.

OS1.5 DEVELOPMENT AFFECTING AN OPEN SPACE SUBJECT TO POLICY OS1.4 [which includes South Gosforth Green] MAY ONLY BE ALLOWED IF ANY OF THE FOLLOWING EXCEPTIONAL CIRCUMSTANCES APPLY:

1. A. IT IS FOR RECREATIONAL PURPOSES RELEVANT TO THE USE OF THE SPACE; OR
2. IT IS FOR NEW OR IMPROVED ESSENTIAL LOCAL COMMUNITY FACILITIES FOR WHICH THERE IS NO SUITABLE ALTERNATIVE SITE; OR
3. THE ONLY MEANS OF RETAINING OR ENHANCING THE OPEN SPACE IS THROUGH DEVELOPMENT OF A SMALL PART; OR
4. ALTERNATIVE PROVISION OF EQUIVALENT COMMUNITY BENEFIT IS MADE AVAILABLE.

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At SPACE for Gosforth, we have learned that the planning system plays a vital part in our civic life.  At its best the planning process can improve a vibrant, healthy community – but bad planning can leave a legacy of problems for future generations.  

The planning process is also a system that is not always understood and is further complicated by the use of legal terms and jargon.

So SPACE for Gosforth is delighted to have permission to share Blue Kayak‘s Guide to the planning system (1) – as we believe the planning system is something that every citizen needs to understand.

A Busy Citizen’s Guide to the Planning System

As the title implies, this is not a detailed analysis of the planning system. Nor is it a guide for householders or business people wishing to carry out a development, or wanting to find out whether planning permission is needed for a given project – although excellent, bespoke advice and support from project planning to application is available from Blue Kayak at very reasonable prices. It is a brief for those who wish to have an input on matters relating to land use and built development, either with regard to a specific proposal or in more general terms.

What is the planning system, and why should we care?

19th century Gosforth – Gosforth developed rapidly at that time due to mining

For most of human history, if you wanted to build a house (say) and had rights over the intended site, you would simply do so. During the later nineteenth and earlier twentieth centuries, however, as the population expanded and the Industrial Revolution happened, concerns began to be voiced: firstly, about the growth of slums in the new industrial cities; secondly, about the extension of towns and cities into the surrounding countryside.

 

The solution – reached in 1947 with the passing of the Town and Country Planning Act – was simple and radical, and has essentially remained in force since then. Anyone wishing to build anything would have to seek permission from the relevant local authority. For its part, the local authority would have to produce a development plan stating what sort of development would be permitted, and where.

Great Park – a major greenfield development bordering on Gosforth and built by a consortium of developers

What has changed since 1947 is that local authorities in the UK do not, by and large, build very much themselves. Phrases such as “planners will be expected to deliver x houses in the next 10 years” or “planners wish to build a new shopping centre…” are often used but are shorthand for the process that actually exists, in which planners decide that, should a proposal to build the desired houses or shopping centre be made by a third party, it would be approved. They may, of course, discuss the proposals with developers, but have no power to make them carry them out.

Planning has become one of the key elements of local democracy. Local planning decisions are made in public, by elected politicians, throughout the year, in a forum where any citizen may attend and comment. The decisions don’t just affect what towns, cities and the countryside look like. They affect the way in which places function – whether they support social justice and environmental sustainability, whether enterprise can succeed, and whether people have access to accommodation and employment.

Policy: what decisions are based on

Indigo Park is another local development under construction

Theoretically, whether a development is permitted or not should depend upon whether it is in accordance with national and local policy.

National policy is summarised within a terse document called the National Planning Policy Framework, which falls within a web-based resource called Planning Practice Guidance. These can be accessed here.

 

Just about every new government makes changes to the way local planning policy is produced; since the process for producing it is lengthy and involves several stages of public consultation, this means that in terms of its format, it is nearly always out of date. However, a council’s planning policy – currently called, imaginatively, a Local Plan – always consists of a document or documents, accompanied by maps, describing the type, quantity and location of development that the authority would be willing to permit, over a given period of time (normally 20 years).

Newcastle City Council has published a number of documents which make up its Local Plan; the most important one is the Core Strategy, which can be accessed here.

Any factor which may be considered in a planning decision is called a “material consideration”; these may include things that aren’t specifically mentioned within local or national policy. However, certain things are “non-material considerations” which may not be taken into account. By and large, these involve effects upon a neighbour where it is only in his private interest, rather than the public interest, that his objection should be upheld. So a proposal may not be opposed on the grounds that it would devalue a neighbour’s house, or that a new business would compete with existing ones. (Since, however, obstructing light is a material consideration, whereas spoiling a view is non-material, the distinction may not always be obvious!)

The Application Process

Certain types of development – small extensions and garden sheds, for example – can be carried out without planning permission. These are “permitted development”; the easiest guide to what is and what is not permitted development can be found here.

La Sagesse in Jesmond includes both a John Dobson house and new build

Anyone wishing to build anything else must submit an application. The amount of information required will depend upon the scale of development, and its likely impacts – so a large housing development may be accompanied not just by site plans and drawings of the proposed houses but also by flood risk assessments, wildlife surveys, and so on.

The local authority must publicise planning applications – in general, all are publicised online and may be viewed at local authority offices; they may also be publicised via notices placed on the development site, letters to neighbours and other concerned parties, and/or advertisements in the local press.

La Sagesse development in Jesmond

A decision should be made within 8 weeks of a complete application being received – 13 weeks in the case of large or complex proposals. Theoretically, the decision rests with the Planning Committee – a group of councillors chosen for this purpose – but in practice most proposals, particularly less significant ones, are determined by planning officers and are therefore “delegated” decisions.

 

Appeals

If a proposal is rejected, the applicant may appeal against the decision. The proposal will then be re-examined by an independent inspector, who may either approve it or uphold the rejection. There is no third-party right of appeal against an approved proposal.

How you can get involved

New flats in an old street – Hawthorn Rd, Gosforth

There are two main points at which any citizen may get involved in the planning process: when a Local Plan is being put together, and when a specific application is being determined.

A Local Plan should be extensively publicised through online consultations, public meetings, exhibitions, etc. These should culminate in an Examination in Public – a series of meetings, chaired by an outside Planning Inspector, at which interested parties may speak.

Anyone may comment on a planning application for 21 days (often longer) after it is made public. In Newcastle, the easiest way to find out what applications have been received, and to comment on them, is to look online here.

You can also sign up to receive alerts if an application is made in your area.

An old building with a change of use – Woodbine Rd, Gosforth

If a proposal is determined at a meeting of the planning committee, objectors and supporters have a right to speak at the meeting. Generally, only a short amount of time will be allotted for this purpose, to be divided between all those who wish to speak on the same “side”; if there are many, it would be advisable to pick one or two people to speak for everyone.

You may, of course, appoint a planning consultant to object to a proposal in writing, and/ or to speak on your behalf at a planning committee meeting. The advantages of doing so are, firstly, that it saves you the trouble of having to go through the various documents yourself to determine where, and whether, the proposal accords or otherwise with local or national policy; secondly, a consultant will have a better idea of what factors should be emphasised in the submission.

Other consultants besides Blue Kayak are available, but they aren’t writing this article, and in any case would, I’m sure, fail to exhibit the same level of detailed analysis and expressive-yet-factual turn of phrase.

Closing remarks

A new development on Gosforth High Street

The planning system is supposed to serve the public good. It isn’t supposed to serve the narrow interests of those who wish to see no change at all in their area even if it means people are homeless, nor the narrow interests of housebuilders and landowners who wish to make money even if it harms societies and landscapes. Planners, of course, have a difficult job balancing up the competing requirements of different groups of people and of the environment; most of the time they more or less succeed; we tend to hear about it when they don’t.

We do not have a perfect planning system, but we do have a process which provides everyone with a real opportunity to comment on the way our towns and cities develop; and, theoretically at least, the more people do so, the better the places we create will serve us.

A few useful concepts

One of our members had this suggestion for a developer contribution

Developer contributions: these are sums paid by a developer to the local authority where the proposed development is thought to make certain social works necessary – things like highway improvements, schools and affordable (i.e. social) housing. By and large, developers will try to argue that they can’t afford them.

There are two main mechanisms by which developer contributions are paid:

• Section 106 Agreements – agreements made on a case-by-case basis between the local authority and the developer
• Community Infrastructure Levies (CIL) – a blanket fee levied on all applications which meet certain criteria. The advent of CIL was supposed to make things simpler, because setting up two different systems to do the same thing generally does have that effect.

Planning conditions: these are requirements set by the local authority when they permit an application. They may, for example, require a landscaping scheme to be submitted and approved before the development goes ahead.

Green Belt: this is an area around a town or city, specifically designated as a place where new development will not generally be permitted. The main purpose is to stop the outward growth of urban areas. Green Belts should not be confused either with “greenfield sites” – i.e. sites which have not been developed in the past – or the open countryside as a whole.

5-year land supply: local authorities are required to show, on a rolling basis, that there is enough suitable land within their area where they would permit housing if it were proposed, to meet the needs of the population for five years. This is important because, if the 5-year land supply doesn’t exist and a housing proposal is rejected, an inspector may approve it even if it conflicts with other policies.

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 (1)  We would like to thank Josephine Ellis of Blue Kayak for her kind permission to publish this post, originally published on the  Blue Kayak blog.

The post A Busy Citizen’s Guide to the Planning System appeared first on SPACE for Gosforth.