16th February 2023
Report from H.M. Planning Inspectorate re building on Greenbelt etc., received by GMCA on Wednesday 14th Feb.
2nd April 2023
Please see below letter sent to Daily Mail following an article they published recently
I am writing to you on behalf of the Littleborough Civic Trust, we need your help URGENTLY.
A planning application for 126 houses on the former Chemical Works/Oil Distillery, Coal Mine/Clay Mine site was granted on the 23rd of March, 2023 subject to a new location plan being submitted.
The application should have been withdrawn due to the red line boundary on the location plan being incorrect, Rochdale Council, no doubt you have heard of them, make up their own rules when it comes to planning.
The application number is 21/01146/FUL submitted 4 times by Vistry Partnerships jointly with Homes England. The Homes and Communities Agency bought the seriously contaminated site in 2016 for £10 million plus costs from Woodford Land Ltd who went bust 2 years later with no assets. The site was vacated in 2004 and numerous developers have failed to further their planning applications due to the complexity of the site. It was supposedly remediated to "industry standards" in 2009 however in 2020 RSK did a further site investigation for Vistry and found the "hard to dig layer" of 200mm of clean crushed stone placed across the site was "ingrained with asbestos", across the whole site. The case officer's report suggests it may have been due to fly tipping!
We [The Trust] suspect that is incorrect as there were discrepancies in the weigh bridge tickets for the removal of hazardous waste from the site, reported upon by RSK as a possible breach of contract but not investigated by the Council or Environment Agency when informed by the Civic Trust.
Chrysotile and Amosite asbestos fibres were identified as present on site as well as numerous other chemicals including dibenzo-ah- anthracene, a known carcinogenic compound. These same contaminants were identified on another (ongoing) building site, Birchinley Manor off Wildhouse Lane, Milnrow 1 mile away. This is now being built on (47 houses). The Council were aware of illegal tipping on this site but were unable to prosecute anyone as the company who owned the site kept changing Directors.
There are two underground watercourses crossing the Akzo Nobel site, the origins of which are unknown, The case officer, John Copestake, who will be leaving the Council shortly, stated at the planning meeting, that they did not exist. A Woodford Remediation Statement Plan" W 789 30 A " dated 16th Jan. 2008 clearly shows these watercourses and is annotated as of unknown origin.
The Planning Committee did not want to know. No doubt any mortgage provider or insurance company will want to know the exact location of these watercourses.
The above has been well documented for many years and a great deal of public money has been wasted. The infrastructure near to the tourist attraction of Hollingworth Lake Country Park and the centre of Littleborough village can not cope with traffic as it is. TfGM have stated that the road junctions are operating above capacity without any further development and Bloor Homes are intending to build 300 houses on land to the South of the site within the green belt. This is due to be determined for release under the Places for Everyone plan.
The residents at the Coppenhall Estate in Crewe, upon which you reported, may have a problem with the Council but it pails into insignificance when compared to the Akzo Nobel site.
The Civic Trust can provided detailed analysis of the site and this is available on line on the Rochdale Council's planning portal, but it takes a great deal of time to find it!
We desperately need some assistance to halt the "Decision Notice" from being issued as the Council rely on the facts that no one has the finances to request a "Judicial Review" and the public think the matter is another done deal.
The planning portal for 21/01146/FUL has a letter published on 13th March, 2023 which gives some details and, unusually, this is available for public inspection. This is the ONLY objection published by Rochdale Council. It is not their policy!
We have been raising these issues for many years with the Planning Department.
Formal complaints, regarding this and another planning application (22/00568/FUL; granted but now withdrawn by the applicant) have been forwarded to the Council are currently under investigation.
If any planning application and the activities of the planning department need exposing, it is certainly this one.
15th March 2023
We have been contacted directly this afternoon (15/03/23) by the Interim Head of Planning, Rochdale Council, with whom we have had numerous communiqués with re the proposed High Nets Activity Centre at the back of Hollingworth Lake.
We were informed that the application is being pulled, partly due to our efforts on behalf of affected nearby residents and businesses.
They are now considering relocating it somewhere else [as yet unknown] and will have to submit a totally different planning application.
To conclude; on the surface it would appear that if we make noises, then eventually, they listen.
Something to bear in mind when all the other proposals for residential developments come to the fore.
Within the same conversation we were also informed that the AKZO site will be on the agenda at the next Planning and Licensing Committee meeting; 6pm, Thursday 23rd March at No. 1 Riverside.
It will be interesting to see if they address the already ‘over-capacity’ traffic issues.
23rd December 2022
Yesterday evening 22/12/22, a member of the Trust attended Rochdale Council’s Planning & Licencing Committee to make representations regarding an application before them (21/00282/FUL) to approve/reject for 9 dwellings on Chestnut Way, Littleborough.
The application was made on 28/05/21 which is a point of note.
The Trust was given a very brief opportunity to speak and asked if the following would be taken into consideration.
Planning and Compulsory Purchase Act 2004 Part 2, Section 19, Paragraph. 1a states:
‘Development plan documents must (taken as a whole) include policies designed to secure that the development and use of land in the local planning authority's area contribute to the mitigation of, and adaptation to, climate change’. Do those documents exist on the application?
Upon inspection of the application on the Council’s Planning Portal no such document(s) are apparent.
The reply from a Council Planning Officer was that because the application was submitted before 15/06/22, when Part L Building Regs changed to take account of ‘Conservation of fuel and power’, then the climate change contingencies mentioned above did not apply to this application.
She pointed out that a flood risk assessment and also a drainage strategy/scheme was within the application then that was all that was needed.
She was then asked [by the Trust] that because of the date of the application we (the public) should ignore all what we are told about the Climate Change Conferences; COP 26; 27 etc.
She then laboured a point that she wanted specifics and was then given examples, such as type of water boilers; air source heat pumps; ground source heat pumps etc.
She refused to elaborate any further, again repeating that because of the date of the application none of it applied. Incredulous!
Especially given the fact that one of our local councillors; Cllr. Besford once stated he was the Council’s ‘climate change champion’.
After much debate about an existing dry-stone wall the application was eventually passed.
More load on the local infrastructure, albeit only 9 houses; it all adds up incrementally with each application.
The Council's activity around the businesses and properties on Hare Hill Rd., Victoria St., and Littleborough Railway Station, known as Littleborough Station SPD is again gaining pace
Remember Cllr. Blundell’s aspirations to ‘regenerate’ Littleborough Village Centre; Hare Hill Rd., Victoria St., Railway Arches etc, etc.?
Well, Rochdale Council are regurgitating those aspirations on the Littleborough Station SPD Masterplan by holding three so called consultation sessions. MEETINGS ARE AT L/BORO HISTORY CENTRE PLATFORM 2. Probably the smallest meeting room in Littleborough.
Tuesday 8th November: 12pm ~ 7pm
Friday 18th November: 10am ~ 4pm
Tuesday 22nd November 12pm ~ 7pm
Having attended the first one, these sessions are much the same as last time and not really consultation sessions at all. Another set of drawings, not even pinned up on boards on the wall. There isn't room, but laid out on tables.
No sit-down Q&A sessions and note the times; during the day when most of the population will be at work!
If you have any interest(s) please monitor the Council’s website as it should be online also as stated on a poster in the Coach House.
We rang the Planning Dept. on 3rd Nov. and got no real answers to our query. They couldn’t even find it, yet they produced the posters!
The SPD is probably long overdue insofar as most of the proposed developments have either been the subject of discussion at various levels for years or are fairly obvious opportunities. What has been lacking is an assessment of viability, co-ordination and focus.
Unfortunately, the document released for public consultation is not fit for purpose – it reads like a poorly composed initial draft and the proposals suggest a lack of “joined-up thinking”. In essence the development-led proposals cannot, given the Council's actions to date, be readily understood by the average resident, lack credibility as a consequence and are probably incapable of being implemented in the manner suggested. This has prompted local suspicion and conspiracy theories rather than reasonable appraisal and dialogue leading to an agreed way forward. Such a fundamental criticism of the Plan will be unwelcomed and can reasonably be considered invalid unless substantiated. Given that the SPD should provide a viable framework for future investment it seems worthwhile providing the detail set out below. (NB this was put together after reading the document and attending the public consultation events on 18/10 and 21/10 – this is not a knee-jerk reaction based on a glance at illustrative drawings.
Most of the identified development opportunities make sense as individual propositions. The problems arise when one considers the text and the difficulties relating to implementation. The latter is probably a more important issue – if it is accepted that we are discussing a draft SPD rather than attempting to consult on vague ideas that may or may not be viable and may or may not appear in a final version.
These boil down to either a failure to critically assess elements of the Plan or a failure to explain how the obvious constraints have been addressed and can be resolved. Two examples are relevant and both relate to transport which is a complex issue that gives rise to readily observable local problems including access, congestion, road safety etc.
The “failure” of the Plan in relation to transport etc is probably an inevitable consequence of its development-led focus – the author(s) seem to have used development as a starting point and expected traffic and public realm matters to be secondary issues whereas a better approach might have been to start with infrastructure/public realm.
The first example is the “partial pedestrianisation” of Hare Hill Road. The term itself is vague (no vehicles on a section of the Road? No vehicles at certain times? Service vehicles only?) and as a result local reaction has been speculative and mainly negative (if social media is anything to go by). There does not seem to have been any 'Highways’ assessment of whether redirected traffic flows will have any significant impact on other junctions – notably Whitelees Rd/A58 and Victoria Street/A6033 or whether adjacent streets would be likely to experience an unacceptable level of rat-running. It would also have been helpful if a Highways assessment had factored in significant local developments that will impact on traffic levels – such as the proposed High School - and the potential for works to improve public realm on Church Street without exacerbating existing issues (congestion, traffic flows etc).
The second example concerns the apparent failure to consider the cumulative impact of individual proposals.
Within the Plan the Station Focus Area proposals include the redevelopment of the Co-op site to accommodate a mixture of residential and business uses with parking; gap sites on Peel Street to be used as residential plots (most currently provide parking spaces) and the “decking” of the station car park to increase provision for rail users. The existing bus turn-around at the station is to be removed in favour of a “Plaza” and a “bus interchange with rail services” is to be provided at an undisclosed location. The area between the Wheatsheaf pub and the war memorial becomes an enhanced public space.
We suggest that the station focus area proposals do not make sense. Nationally we are likely to experience an increase in the demands on public transport and the Plan acknowledges the need for (and by implication the benefits of) a bus/rail interchange. However, the proposals simultaneously remove the only location where buses can turn around that is near the station whilst promoting development that is likely to increase traffic pressures on Railway Street from the Co-op site to the A58. Collectively this makes the proposed developments and a bus/rail interchange and improved public realm a difficult concept – if the station focus area proposals are viable then there should be some evidence that this is the case – otherwise it is probably inevitable that development will progress and proposed improvements to provide a sustainable transport network and/or improve public realm will be quietly abandoned.
NB. The provision for bus/rail service integration was questioned at both events on 18/10 and 21/10 – there seemed to be no understanding that bus services that go to the station would require a turn around area nor that double deck buses cannot pass under the railway bridge. Presumably someone has consulted TfGM/Network Rail on how best to achieve bus/rail integration over the 10-year lifespan of the Plan? Logically if the bus turnaround could be located safely in the Square along with traffic accessing current and proposed development then it would conflict with proposals to enhance that area as a public open space/function area/ “heart” of the village?
In summary, it is accepted that the detail of development proposals have yet to be established, however it is quite reasonable to expect that someone has thought through the collective impact and viability of the development proposals. We question the wisdom of the development-led perspective – the more sustainable approach would be to look at and use transport and public realm matters as starting point to inform a more sustainable view of development potential.
We have referred to the Plan as looking like a first draft – this may be too kind. A couple of typos would not be the end of the world but the text does not seem to have been proof-read and would benefit from rigorous editing. This is not a “nit-picking” issue – an amateurish document results in a loss of credibility and what we have at the moment is difficult to read, overuses of jargon, omits detail, seems to be composed from parent documents on a "cut and paste" basis and simply doesn’t get the message across because most would-be readers will give up .
To go through the document on a page-by-page basis would be tedious – a few of the “highlights” are given below:-
a) Cross referencing between text and illustrations is all over the place – illustrations are referred to as “Figure x” in several places and at least one of the references is in the wrong place (page 19 first sentence). Other illustrations are missing – the text on page 14 refers to “figure 8” which doesn’t appear. Similar problems occur with section headings – on page 20 the station area is “focus area 2” and on page 22 the Canalside area is also “focus area 2”.
b) missing and poorly described information.
The Plan focusses on 3 areas. Page 17 informs us that “ A fourth area behind the station has been identified of which consist (sic) of an existing residential area”. This area does not seem to be mentioned again.
A bus/rail interchange is proposed – location? (the bus layby that appeared on drawings at the public event is presumably not an “interchange” given that it is not accessible to double deck buses and to any service that needs space to turn around).
It is probably the case that most locals would not refer to the SPD area as “Littleborough Station” Calling the Plan “Littleborough Station” and having a “station and environs” focus area has already confused some who have pointed out that the Victoria Street proposal is referred to under “station” but is not within the station (focus) area. The title also results in statements that are technically correct but do not sound right “The overarching principle of this SPD is the creation of thriving, vibrant, sustainable communities in Littleborough Station”.
Missing illustrations/figures have already been noted.
“Decking” of the station car-park is not explained and might be anything from a minor provision for cycle parking to one or more storeys of additional vehicle bays (the latter is assumed to be the case and is causing concern re traffic flows etc) Given the high capital and revenue costs for a facility that is not going to pay for itself then a multistorey parking provision sounds unlikely - unless there is actual commitment then a better approach might have been to simply state that the Council and partners will look at ways to improve parking.
Clearly the Plan needs to use appropriate language, but the text tends to drift into jargon –such as settlement, movement and street “hierarchy”, “gateway experiences” and the favourite: “active travel”. An approach that used plain English would be more likely to result in a document that people were prepared to read and consider.
The draft Plan clearly references other studies, and some repetition is inevitable. However, the "cut and paste" approach can only be successful if it is selective and results in text that secures and retains the interest of the reader. Using three words when one would suffice is a general issue and editing to provide the same message in a more concise manner would be a benefit. As a specific example Page 3 goes into detail about current train services – surely of limited relevance in a document intended to co-ordinate development over the next decade?
On Wednesday 9th June we met, in person instead of Zoom, with Vistry, the chosen developers for the former AKZO site. On site were two architects and their Planning Development Manager and so we took the opportunity to show them around Littleborough, to enable them to get a ‘feel’ for the village and also show them how other recent building developments had been constructed ‘in keeping’ with the surroundings.
We provided them with a hard copy of the Littleborough Town Design Statement, but had previously made them aware of it via the Trust’s website where it can be found in its entirety. It is now recently classed as a Supplementary Planning Document, adopted by the Council in 2004.
We also imparted our local knowledge of various relevant issues; not least the traffic situation. As we stood at the site, around 11.30am, Hollingworth Rd traffic was extremely busy even at that time, and again we explained in vivid detail what it was like at rush hour. As mentioned previously, they [Vistry] intend to use the traffic survey done in 2011, which does not really fit the bill. But they state that post-pandemic traffic will be lighter. A fact we do not accept.
It also doesn’t include any weekend tourist traffic to/from Hollingworth Lake; plus, through traffic to/from West Yorkshire, which we stressed both are major factors.
Another point of note is that they informed us that, whilst they are willing to build much more, Rochdale Council’s Planning Dept. only want 15% of the development to be ‘affordable housing’, apparently preferring instead, 4/5 bed houses. We were asked to support them in their attempt to increase that percentage.
The Council do not publish objections or comments on planning applications and quote the General Data Protection Regulations as their reason for not publishing the text of any comments. The Developers were made aware of this and expressed their own concerns stating that other Local Authorities do not take that view. All that is required is redaction of any personal/medical data which could identify the individuals. The Trust have already, and will be making further representations regarding this and suggest that those wishing to comment should do the same.
Following close working relationships with Homes England (H.M. Govt. Housing & Communities Agency) since April 2018, on 28th May 2021 we met with the developers and their planning consultants who have been chosen, regarding the future of the former Akzo Nobel site Hollingworth Rd., Littleborough, who informed us that since they began enabling works for the site they clarified that they would be putting in a planning application in June 2021, but due to it having to be a totally new application they would be starting from scratch with renewed Coal Mining Risk Assessments, Traffic Assessments, water courses/sources and an Ecology survey of the site in the next few months.
No work is likely to commence until probably Spring 2022 the options to comply with the Local Planning Authorities policy on Affordable Housing.
They have committed to continuing to discuss the scheme with Littleborough Civic Trust to ensure community engagement during the planning and delivery process and further meetings with them are scheduled to ensure that as far as reasonably possible, the wishes and concerns of the residents of Littleborough are addressed.
They have taken heed of the Civic Trust’s information and concerns, including the Littleborough Town Design Statement, the link to which is on this page. A very substantial document (28mb), formulated by the Trust in 2004 and adopted by Rochdale Council at the time as 'Supplementary Planning Guidance'.
We have to recognise the fact that the majority it is actually a brownfield site but does impinge on a small area of green belt land. We did though stress very thoroughly that the roads and infrastructure are already at over-capacity levels. We suggested that any Section 106 monies offered by them go into improving what can be improved to the benefit of residents, instead of planting tress as a gesture. (A practice often used by some developers). They were acutely aware of the traffic situation due to the feedback they had received following their recent leaflet drop in the locality. We couldn't have stressed any more than we did, regarding the traffic situation
We are looking forward to maintaining a close working relationship with them prior to, and throughout the planning phase through to the construction of the development.