SUBMISSION RELATING TO BURY LOCAL PLAN IRO HOUSING, EMPLOYMENT, OPEN LAND, NATURAL ENVIRONMENT

Dave Bentley www.davebentleyecology.co.ukSeptember 2017V1

HEADLINE - It seems so weird that Bury MBC Planners and Labour Council members think they can have a public consultation into a local plan including topics relating to housing, employment, open land and the natural environment etc. YET, not consider these aspects in light of the worst impacts that proposed GMSF housing and employment sites will have on open land and the natural environment. It is imperative that the planners and councillors at Bury MBC see my concerns regarding the allocations for housing and employment and understand them. If they refuse to read and understand my concerns “because these are being dealt with by the GMSF” then they are refusing to understand the biggest threats to what they have painstakingly produced topic papers on. In any case the topic papers repeatedly refer to the GMSF.

So in one document I include my objections to Elton Reservoir, Walshaw, Northern Gateway, Holcombe Brook and Baldingtone. There is some repetition at the start of each but the reader will soon overcome this. Here goes:

See over

Elton Reservoir Housing Allocation (Bury) – Greenbelt removal – OBJECTION V4

David P Bentley Ecological Consultant www.davebentleyecology.co.uk

Representing – nature conservation and landscape

The open land between Bury and Radcliffe to be destroyed – 3460 houses

1The wrongly assessed Housing and Employment Need

1.1The well-loved countryside around Elton and Withins Reservoirs (from Pilkington Fold to Metrolink, from the Bronze Age Burial Site near Radcliffe Crematorium to Elton Sailing Club), and several other parts of the borough, is about to be destroyed on the whim of the local Labour Party. They claim it is the government’s fault. That is not true. Labour controlled Local Authorities hired the population forecasters. Labour chose the Accelerated growth option when they could have chosen a lower growth option. Labour decided to ignore the benefits of reduced migration that we will get from leaving the EU. Labour has 90% of the seats on the Greater Manchester Combined Authority and control Bury Council. This hated plan is Labour’s work. It is a political project divorced from actual housing and employment needs.

“Option 1 GMFM Baseline 2014: The standard baseline forecasts produced as part of the annual GMFM release in 2014 which draws on OE’s national and regional forecasts. This provides a level of growth and development consistent with GM’s existing land supply, as identified by the ten local authorities. The baseline is therefore a ‘policy neutral’ forecast.

Option 2 AGS-SNPP 2014: An Accelerated Growth Scenario providing a projection for the GM economy that is stronger than the baseline forecast, and reflects a future where the city plays a lead role in the development of a ‘Northern Powerhouse’. It also meets GM’s aspiration to provide additional employment opportunities to non-employed local residents. The scenario adopts demographic assumptions set out in 2012 sub-national population projections (SNPP).”

1.2The Labour Party chose Option 2. A political decision. In doing so they ALSO chose to ignore the end to the environmentally damaging effects of mass migration that will occur with Brexit. This is specifically cited in the background papers to the GMCA/AGMA Executive Meeting of August 2016.

1.3This is what the recent past tells us about Bury’s population increase since 1981. I did not need to pay population forecasters tens of thousands of pounds. I just checked the census totals for the Borough from 1981 to 2011. Here’s what they say and my conclusion.

Bury Pop 1981 175 459. No figs before then as no Bury MBC in 1971.

Bury Pop 1991 179 168. 371 rise in 10 years, 371 in a year average.

Bury Pop 2001 180 608. 1440 rise in 10 years, 144 in a year average.

Bury Pop 2011 185 060. 4452 rise in 10 years, 445 in a year average.

We can maybe put the recent rise down to immigration from the EU, given the rise of numbers of say Polish speakers in the Borough. This will cease on Brexit.

So the worst case scenario is that with a 445 person rise a year for next 20 years 8900 new people will live in Bury. That is assuming Free Movement will continue, which it will not. Assume 2.2 people per home – 4045 homes. I just checked my half of my street – it is 2.3 people per home.

So remain a member of the EU build 4045 homes. Drop to before the Eastern European nations were granted freedom of movement and it is 2880 new people in 20 years. At 2.2 people per home it is 1309 homes. THE GMSF FORECAST OF 12,500 HOUSES IS BEYOND RATIONALITY.

1.4Something we learned from the EU Referendum and aftermath is that a whole host of economic forecasters were totally wrong – doom was forecast from the moment the UK voted to leave. My opinion is that the Oxford Economics forecast as originally made for new homes, considering the above, is worthless.

1.5The Greater Manchester Strategic Housing Market Assessment Oct 2016 reports Bury MBC has existing supply of land for 4786 houses and a potential windfall of 1000 houses up to 2035. This is more than the requirement should we remain a member of the EU, and many times more than would be required on leaving.

1.6Now Bury has been allocated 12,500 houses. The sums of the Greenbelt deletion housing allocations are W 1250, B 60, S 135, H 100, E 3460, N 200 + 1000 + 3400 + 600 = 10,205. Given AGMA and Bury MBC considered it had non Greenbelt sites for 4786 plus 1000 windfall (making 5786) then, with these Greenbelt deletions, Bury will actually have space for 15,991 houses - which is ludicrously over any imagined ludicrous target. Clearly the GMSF has allocated fantasy allocations to Bury. The officers responsible should be dismissed. If this was some planner making a rational decision my comment might be out of order. It is not. This is a case of true incompetence which has caused massive financial cost and widespread emotional upset.

1.7The buffer the GMCA have applied to elevate Bury’s housing target is also unnecessary. Given that the GMSF target is so massively an over calculation there is no need to apply a buffer to allow for flexibility. The likelihood is that people will leave Bury if these plans are approved.

1.8The figures the GMCA use are based on an expectation of approximately 1.3 persons per dwelling. The 2011 census had a UK average of 2.3 persons per dwelling compared to 2.4 persons per dwelling in 2001. This therefore seems to assume that a lot more people will be living alone and households are getting significantly smaller, far more than the rate in the previous decade for which data is available.

1.9The mishmash of housing and urban edge the GMSF will create for decades as development proceeds on a slow scale will degrade the town’s landscape. It will blur the urban rural edge and lead to chaotic planning, and wholesale wildlife destruction as well.

2Lack of consultation

2.1The lack of consultation has been breath-taking. The process is contrary to Bury Council’s own guidelines – its Statement of Community Involvement - thus:

“How will the Council involve you?

“The following table lists some of the activities and methods the Council will consider using when undertaking consultation exercises in connection with the Local Plan. The methods used will be tailored to suit the scale and nature of impact of the decisions to be made and the particular needs of people being consulted:” THIS IS THE BIGGEST DEVELOPMENT PLAN THE COUNTY HAS KNOWN.

“Material made available on the Council’s web site, in Council offices at Knowsley Place Reception, Town Hall Reception and selected local libraries (see our Statement of Community Involvement web page on http://www.bury.gov/10738 for a list).” The ALLOCATIONS MAPS AND TEXT ARE NOT AVAILABLE ON THE COUNCIL WEBSITE. THERE ARE NO DISPLAYS, POSTERS OR LEAFLETS IN ANY COUNCIL RECEPTION IN THE BOROUGH; THE COUNCIL OFFICE IN KNOWSLEY PLACE HAS NOTHING, AND DIRECTS CALLERS TO A 15 MINUTE QUEUE AT THE TOWN HALL. AT THE TIME OF THE UDP THERE WERE PERMANENT DISPLAYS IN 3 TOWN CENTRE LOCATIONS.

“Send letters and emails to database contacts, including targeted consultation letters for key community groups. The Council may consider more targeted consultation where residents may be more directly affected by proposals.” NOT DONE (NOT TO ME!)

“Advertise via social media on Facebook & Twitter.” NOT DONE. I’M HEAVILY INVOLVED ON FACEBOOK AND HAVE SEEN NOTHING FROM BURY OR GMCA ON THIS MATTER.

“Where possible, place articles in:”

“Local newspapers;”

“‘Planzine’ - the department’s e-newsletter sent to a database of contacts and”

“Using other online news sources as appropriate.”

“Use posters on notice boards in prominent locations including town centres, civic suites, markets, leisure centres and public open spaces.” NOT DONE. EVERYWHERE HAS BEEN CHECKED. THE COUNCIL HAS DONE NOTHING IN THIS REGARD. THE BURY LIBRARIAN WAS ASKED WHERE THE POSTER WAS ON GMSF. HE SAID THERE WAS NONE, BUT THAT THE GMSF STUFF WAS IN A BOX BEHIND HIM.

2.2This consultation is contrary to Bury Council's Statement of Community Involvement, and is clearly UNLAWFUL. http://www.bury.gov.uk/index.aspx?articleid=10738. Furthermore at least one officer at Bury MBC has intentionally lied by writing to an official complainer stating that the council is in full compliance with the Statement. I expect that officer to be dismissed.

3Allocating SIX Sites of Biological Importance to Housing is illegal, gross negligence on the part of Bury Planners.

3.1This is not just a deletion from the Greenbelt. It is placing seven Sites of Biological Importance (Elton Reservoirs and ponds; Withins Reservoir and streamside; Spen Moor Ponds; Elton Goit; MBB Canal; Wetland near Radcliffe (Coney Green); Black Lane Ponds), which LPAs are required to protect in the planning process by numerous Central Government instructions, into a housing allocation. It is illegal. There are three other SBIs in the Elton basin habitat mosaic which will be compromised by the allocation/deletion (Daisyfield; Lower Hinds; Swan Lodge and Hutchinson’s Goit); and a further one just west of Pilkington Fold (Starling Reservoir and associated marshy meadow) which will also be compromised. The officers responsible for proposing this should be dismissed. The National Planning Policy Framework states (Para 110) “In preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment. Plans should allocate land with the least environmental or amenity value”…..IT DOES NOT STATE PLANS SHOULD ALLOCATE TO HOUSING LAND WITH SITE OF BIOLOGICAL IMPORTANT STATUS, or indeed SPECIAL LANDSCAPE VALUE STATUS. The Walshaw Allocation is illegal. The NPPF also states (para 116) “Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest…..” There is no exceptional need for this housing, certainly not “accelerated growth” and whilst in the Greenbelt the SBI is safe BUT the housing allocation/greenbelt deletion will certainly lead to the destruction of the SBI to make it developable. We have seen that happen to Bury’s SBI’s on several occasions – Edgar’s Field (most recently), Spen Moor, Pilsworth Bleach Works, Chapelfield Lodges and Townside Fields and on Features of Ecological Value at Openshaw Fold.

4Religious offence and widespread outrage

4.1In doing what they have done the officers responsible have caused in me harm and offence to my religious sensibilities, and across the borough they have caused widespread distress and outrage. Bury has never before placed a Site of Biological Importance within a housing allocation and, with good fortune, the officers who did this will be dismissed and expelled from the profession. It is an offence to my religion to put wildlife and landscape in peril like this, and, as a religious outrage, the allocation should be withdrawn, and the responsible people removed from office. I have just as much right to make these claims as anyone else, from any religion.

5Greenbelt Status

5.1The Elton/Withins allocation land has been assessed on behalf of AGMA as strong on all counts in terms of functionality as Greenbelt - “BU29: There is limited/no sense of encroachment with the parcel being generally free of urbanised built development. The landscape within this parcel remains largely unspoilt by urbanising influences located outside its boundaries. It has an intact and rural in character and displays characteristics of the countryside.” Of the inter Metrolink - Canal portion these words are included “The parcel plays a strong role in checking the unrestricted sprawl of Radcliffe. The Canal also potentially provides a barrier to the onward spread of sprawl beyond the parcel boundary to the west (and parcel BU29). The parcel plays some role in inhibiting ribbon development to the south and west of the minor roads to the northeast and along the minor internal access road… The parcel prevents the further physical coalescence or a clearly recognisable perception of merging that would further erode the separate identity of Radcliffe from Bury.” As far as Pilkington Fold goes the assessment includes the land between Bury and Bolton south of Ainsworth and scores strong on all counts in terms of functionality as Greenbelt.

5.2This area is strategic Greater Manchester Greenbelt allocated in the Greenbelt Subject Plan. Peel Estates challenged the Greenbelt designation for east Spen Moor and had the designation quashed in court. Bury attempted to reinstate this land in the Greenbelt at the UDP inquiry but this was not accepted by the inspector. Most of the disputed land is still undeveloped decades later.

5.3The Greater Manchester Structure Plan was adopted after approval by the Secretary of State in March 19819, and was later reviewed and superseded by a later version in 1986. The main themes of the 1981 Structure Plan were: 1 Urban concentration; 2 Redirection of development to the inner core; 3 Maintenance of the regional centre (linked to the regeneration of the inner areas of Manchester and Salford); 4 Resource and amenity conservation. These themes are still vital today and seem equally vital to the Northern Powerhouse ideals. You cannot grow and make strong and beautiful what you are seeking to destroy and squander and neglect. The GM green belt was designed to complement these efforts to regenerate existing urban areas.

5.4The National Planning Policy Framework (NFFP) states (Para 79) “The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.” It goes on to state (Para 83) “Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.”

5.5The UDP revised the Greenbelt boundaries at the time of the UDP (c1995). There were minor adjustments, additions and deletions, and the creation of a new strategic employment site at Bury Ground, which was removed from the Greenbelt. Bury Ground is still mostly empty 22 years later, with only the relocated Fire Station and police Station which their original bases are rotting in the town centre, standing derelict eyesores. This is what strategic removals from the greenbelt did to our town. Stole a country park and added dereliction. So are Bury planners fit to make such decisions like this again? I think not.

5.6There are no exceptional circumstances here. Bury MBC can meet its actual housing requirements using existing land supply without affecting the Greenbelt. The GMSF Policy on Greenbelt states the ‘Green Belt will be afforded strong protection in accordance with the National Planning Policy Framework.’ The only thing exceptional about this is the stupidity and indeed incompetence of those involved in the preparation of the framework, and the exceptional nature of the breach of the Bury MBC’s Statement of Public Consultation.

5.7Fundamentally the Greenbelt grabs in Bury are totally contrary to this main theme of Greenbelt – NPPF Para 80 “To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” We have seen that they would allow Bury to over supply housing without remediating and reusing any derelict land. We know from the Bury Ground experience (above) that it would encourage dereliction.

6The importance of the allocation’s Landscape Character

6.1In terms of Landscape Character Areas as defined by Bury’s abandoned Local Plan this is the largest and most visible and accessible “Canal & River Corridor” landscape area (The other such landscape is to the SW of Radcliffe – that contains “only” four protected wildlife sites, has no recreation focus and a poor footpath network and is split in half by the river, with no bridges).

6.2Allowing people to appreciate the distinctive Elton Reservoir area, the site is crossed with lanes and Public Rights of Way, Cycleways and a long-distance footpath. It has a Sailing Club, angling reservoirs, the canal and informal recreation areas. Buckingham Drive meadow is a large council-owned field, hay cropped and used for informal recreation (was once one of the Croal Irwell Valley Warden Service sites), whilst the canal and the field around it and the canal and towpaths belongs to the nation and the people of Bury via the Canal & River Trust. The area draws bird watchers from not just Bury, but the whole of Greater Manchester and indeed the North West. And it has a school cross-country route. Horse Stabling is provided in the eastern and western part of the site and the farm trackways in the area are used for horse-riding. The land west of Farcroft Avenue and Metrolink is used as an informal dog walking circuit.

6.3The farmed landscape supports Milk and Beef Cattle, Longhorn Cattle, Sheep, Horses and poultry, and sometimes maize is planted in one plot. It is important for children to see farm animals and gain some understanding of food production. These are VERY visible animals, especially given the immediate proximity of the informal recreation way and existing housing.

6.4Industrial heritage is represented by the reservoirs, the canal, the embankment of an ancient horse-pulled railway connecting with the canal, railwaylines - active and closed, the goits, and the ponds formed in old workings. There is a Bronze-age burial site in the field next to Radcliffe cemetery and crematorium - this is a landscape which our ancestors have cherished as a final resting place for thousands of years. A partially undeveloped Roman Road crosses the site. Metrolink passes the area and shows people entering the main town of Bury what a lovely green place the town is.

7The importance of the allocation’s Recreational value

7.1The land around Elton and Withins Reservoirs and the Canal (including the central grassland area) was proposed by the UDP (RT3/1/6 and RT3/3/6) for informal recreation protection and improvements to satisfy the needs of the population at the lifetime of the UDP (Not 3460 more houses). “Centred on Elton Reservoir, this site includes the MBB Canal, Withins Reservoir and a network of footpaths through surrounding farmland. The area is already popular but could be developed further to provide an important focus for informal recreation.” “Developed” in this case has nothing to do with housing. And the words “through farmland” are crucial - NOT through housing estates. The RT3/3/6 recreation area is a clearly defined area. These policies were carried forwards from the Croal Irwell Valley Local Plan of 1986, a multi-district project of the Greater Manchester Council.

7.2Allowing people to appreciate the distinctive Elton Reservoir area, the site is crossed with lanes and Public Rights of Way, Cycleways (on the railwayline and the towpath is National Cycle Route 6) and a long-distance footpath/sculpture trail. It has a Sailing Club, two angling reservoirs, the canal and informal recreation areas. Buckingham Drive meadow is a large council-owned field, hay cropped and used for informal recreation (was once one of the Croal Irwell Valley Warden Service sites), whilst the canal and the field around it and the canal and towpaths belongs to the nation and the people of Bury via the Canal & River Trust. The area draws bird watchers from not just Bury, but the whole of Greater Manchester and indeed the North West. And it has a school cross-country route. Horse Stabling is provided in the eastern and western part of the site and the farm trackways in the area are used for horse-riding. The land west of Farcroft Avenue and Metrolink is used as an informal dog walking circuit (This para copied from above).

8The importance of the River Valley and Green Infrastructure

8.1The UDP allocated a large part of the present allocation area to Protected River Valley (OL5/2). “The Council is keen to retain the open character of the river valleys by controlling development”…altered from an earlier draft which read “….by ensuring that there is a general presumption against most forms of development. So the still in force UDP designates all the land east of Black Lane, Radcliffe, North of Metrolink, west of the River Irwell, south of the former railwayline, and south of the track to Doffer Fold as protected River Valley. The boundary was carried forwards from the Croal Irwell Valley Local Plan of 1986 (which was in preparation from 1975) a multi-district project of the Greater Manchester Council. The current allocation is totally contrary to this protection.

8.2Green Infrastructure encompasses recreational spaces and areas of ecological value and these have a considerable role to play in promoting healthier lifestyles, adapting to the challenges posed by climate change, maintaining food production, protecting wildlife and attracting investment to an area. The emphasis nationally is therefore to maintain, improve and add to this resource by encouraging greater access and connectivity to deliver the above benefits across key areas in a strategic manner. Following a commitment in the 2011 Natural Environment White Paper, in October 2011 the Government launched a Green Infrastructure Partnership to facilitate the provision of local GI. Policy EM3 of the former North West Regional Strategy (2008) required local authorities to work together and with partners to conserve, create and enhance its green infrastructure. Later in 2008, AGMA commissioned TEP Consultants to assist in developing a green infrastructure framework for Greater Manchester. TEP were subsequently engaged to identify a more local network in Bury. The Greater Manchester GI Framework identified the Elton Reservoir area as a Green Infrastructure Asset. ALL of the Elton Reservoir allocation area apart from Pilkington Fold is included in “Bury’s Green Infrastructure Network.” It defined the Elton Reservoir area as part of Irwell Bank GI Action Area.

8.3The objectives cited in Bury for the Irwell Bank (Elton Res) are :

Safeguard and enhance existing assets in the network;

Safeguard and enhance the growth support functions that the network provides;

Ensure new development as a minimum maintains environmental quality and functionality of, and increases access to, the network;

Improve functionality of the network, specifically using the existing assets to increase the resilience of the Borough to the effects of climate change;

Address sources of pollution or blight which degrade the quality or perception of assets in the network;

Create new or enhanced assets where there is an existing deficit of access, environmental quality or functionality;

Partnership working to deliver major projects within the Borough and across boundaries.

8.4There is a mismatch between doing all of these lovely things to enhance Green Infrastructure, and building 3460 houses all over the area, destroying and damaging many of the assets in the process.

9The importance of the Habitat Mosaic

9.1The open space around Elton Reservoir contains 10 different council-designated Sites of Biological Importance and a river. This is the most concentrated and diverse group of wildlife sites in Greater Manchester. Present are large open waterbodies, small ponds formed in marlpits, brickpits, coal shafts and inundation areas, lowland streams - with cut off sections, a canal, a river and riverside habitats, mill goits, marshland, reedbed, berry-rich hedgerows, shrubland, woodland, wood pasture and moorland fragments at Pilkington Fold, hedgerow trees, vegetated industrial mineral workings, working farmland of improved dairy grazing land, and semi-improved grassland with for example hay-rattle flower, old farmsteads supporting bats and owls and other nesting birds.

9.2The following UKBAP Priority Habitats are present in the mosaic – Eutrophic Standing Water; Rivers and Streams; Ponds; Wet Woodland; Hedgerows; Lowland dry Acidic Grassland; Lowland Meadows; Floodplain Grazing Marsh; Woodpasture; Reed Beds; Lowland Fen; Open Mosaic Habitat on previously Developed Land (Lower Hinds orchid site).

9.3Here is what the National Planning Policy Framework states (para 117): “To minimise impacts on biodiversity and geodiversity, planning policies should:

● plan for biodiversity at a landscape-scale across local authority boundaries;

● identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation;

● promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan.”

9.4If you draw a line from the southern parts of Stockport across Greater Manchester to the north of Bury across a solidly built up conurbation there is only one substantial area of open water in a setting of grassland, woodland and hedgerows. That is this proposed Housing Allocation of Elton Reservoir. Gorton Reservoir is a large waterbody but it sits in a well-manicured golf course. The importance of the Elton Reservoir Housing Allocation for migratory wildlife, local wildlife and informal recreation cannot be over-stated. And Bury’s Labour Council seeks to trash it to pursue Labour’s choice of ACCELERATED GROWTH, which lies on top of faulty population growth statistics.

10The importance of Mammals in the Elton Reservoir Allocation Area and the undesignated Wildlife Corridor across Pilkington Fold/Spen Moor.

10.1The area supports a wealth of mammals including Roe Deer, Brown Hare, Rabbit, Badger (tracks seen and photographed 2016), Red Fox, Stoat seen on hinds lane between Elton Reservoir and Withins Reservoir, Weasel, Mink, Brown Rat, Short-tailed Field Vole, Wood Mouse, Grey Squirrel, Hedgehog, Common Shrew between Elton and Withins, Mole, and Otter, which is known from the adjacent River Irwell and also Roch in recent years (others and I have recorded it). Seven species of bats have been recorded. There are numerous deer sightings. They are resident. They also use the wildlife corridor across Pilkington Fold to move to and from the wider countryside.

10.2The Brown Hare has already been expelled from Spen Moor where records of it were unlawfully ignored in the planning process by Bury MBC. The Brown Hare is listed by the UK Government as a United Kingdom Biodiversity Action Plan Priority Species, given a 49% decline recorded between 1995 and 2002. This is now succeeded by the UK Post-2010 Biodiversity Framework (or “Biodiversity 2020”) and Priority Species are termed Section 41 species i.e. species “of principal importance for the purpose of conserving biodiversity” covered under section 41 (England) of the NERC Act (2006) and therefore needing to be taken into consideration by a public body when performing any of its functions with a view to conserving biodiversity. Concerns cited are the loss of roughs in farmland and the loss of mixed farmland and an increase in predation. The housing allocation seeks to effectively wipe out the farmland of this area, which mixed and non-intensive, as well as increase the population of dogs and cats in the area many-fold.

10.3The site supports Hedgehogs – which is listed by the UK Government as a United Kingdom Biodiversity Action Plan Priority Species, given a 20% decline recorded over 4 years prior to listing as a UKBAP species. Concerns cited are traffic density, fragmentation of habitats, need for hibernation sites, need for hedgerows and wide field margins.

10.4The importance of the undesignated wildlife corridor for mammals across Pilkington Fold between the wider countryside and Elton Reservoir allocation cannot be over-stated. It that area is closed then there is no other linkage. An earlier linkage was lost when Peel Estates closed the old railwayline in order to progress the building on land at Black Lane, Radcliffe. A corridor must be maintained across Pilkington Fold. A Wildlife Corridor must be designated.

10.5Seven protected Bat species have been recorded in the affected area. The South Lancashire Bat Group, in a 1.5km radius circle centred just north of Dofferfold Farm at Elton Reservoir, have recorded in recent times UK and European Law protected bat species Daubentons, Common Pipistrelle, Soprano Pipistrelle, Noctule and the Eurobat Priority species Nathusius Pipistrelle. Angela Graham has provided records of Brown Long-eared and Whiskered/Brandts Bat. The Noctule, the Brown Long-eared and the Soprano Pipistrelle are UK Biodiversity Action Plan Priority Species, i.e. “Species of principal importance for the purpose of conserving biodiversity” covered under section 41 (England) of the NERC Act (2006) and thus they need to be “taken into consideration by a public body when performing any of its functions with a view to conserving biodiversity.” For Noctules, which had a 21% decline over 6 years prior to UKBAP listing, the JNCC website shows a requirement to protect mature trees, wetlands, stream sides and other insect rich areas and boosting water quality – developing by streams and in the reservoirs and canal catchments of the allocation site will not help water quality. For Brown Long-eareds, which had a 20% decline over 7 years prior to UKBAP listing, the JNCC website shows a need to protect countryside buildings with roost potential as well as a landscape of woodland edges, hedgerows, small farm woodlands, deciduous and mixed woodland, and connectivity between these – the site is dotted with hedgerow trees and those associated with farmsteads. The advice specifically says this: “Ensure the retention and protection of older trees for roosts is included in land-use policies.” For Soprano Pipistrelles, which had a 42% decline prior to UKBAP listing, the JNCC website requires that the needs of the Soprano Pipistrelle are considered in agri-environment, planning, water quality, wetland creation …..policies. The Turley Peel Masterplan specifically shows they intend to destroy or encourage the destruction of the Elton Goit Site of Biological Importance in order to remove the wildlife value and remove the reasons preventing development – this is the largest area of marsh in the vicinity. The JNCC urges the creation, expansion and improvement of key habitats including wetland and features such as hedgerows and woodland edges. “Ensure adequate consideration of a landscape approach to the conservation of Soprano Pipistrelle.” Alas the housing allocation does quite the opposite - a landscape approach to the destruction of wildlife habitat and wildlife corridors.

10.6Recent data shows that Nathusius' Pipistrelle may be widespread but rare in Britain and Ireland. Nathusius' pipistrelle is considered to be vulnerable in the European context and is protected under the ‘EU Habitats Directive.’ Furthermore, this species is listed in the United Nations convention on the ‘Conservation of Migratory Species of Wild Animals’ (Bonn, 1979) via the EUROBATS agreement (London, 1991). At present, threats to the species include: Habitat Loss – all of which will happen due to the Elton Reservoir Housing Allocation; Maternity roost sites in buildings and trees can be disturbed, damaged or destroyed by inappropriate land management or development; Loss of hibernation roost sites in buildings, trees and underground sites can occur for similar reasons to those above; Destruction of habitats such as riparian, wetland, woodland and unimproved grassland has resulted in the loss of insect-rich feeding habitats; Land use Changes; Loss and decline of linear landscape features (e.g. tree lines, hedgerows, ditches) remove important flyways and flight line features along which bats hunt for insect prey; The trend for opening up land to produce large uniform fields has led to a decrease in habitat diversity, and consequently a loss of feeding habitat and decline of insect prey; May be effected by badly sited windfarms due to its migratory behaviour; Use of Pesticides and other chemicals - The widespread use of pesticides in both the garden and the wider countryside has led to a decline in the presence of insect prey; The use of inappropriate timber treatment chemicals at roost sites (i.e. those that are toxic and persistent) can be directly harmful to bats, and decrease the availability of roost sites. Elton Reservoir area contains a mosaic of habitats including 10 different Sites of Biological Importance, streamsides, hedgerows, and semi-improved grassland (with e.g. Hay Rattle) as well as improved pastureland.

11The importance of Birds in the Elton Reservoir Allocation Area and of the area for bird migration, both regional and international.

11.1Following is a list of birds from the Elton Reservoir housing allocation area. In this list are UK and EU Protected Species, Biodiversity Action Plan Priority Species, and species requiring conservation measures via the UK’s international obligations – the Bern Convention, the Convention on Migratory Species and the African-Eurasian Waterbirds Agreement. There are Birds of Conservation Concern Red List species, the most threatened UK bird species, whose conservation is of most concern, and BoCC Amber List species, whose conservation is also of concern. Four species are globally threatened and are listed by the IUCN. The remaining species are of Least Concern but are valuable part of this wonderful and vital ecosystem.

Total birds species recorded by contributors to this list186 species

Bird species fully protected by UK Law (W&CA Sch 1.1)39 species

Bird species fully protected in EU Birds Directive (Annex 1)27 species

Bird species designated UK BAP Priority Species27 species

Bird species recommended for protection by Bern Convention Appendix 271 species

Migratory bird species with unfavourable conservation status requiring

international conservation agreements via Convention on Migratory Species App 266 species

Migratory waterbird species that are endangered or with unfavourable

conservation status.CMS African-Eurasian Waterbirds Agreement - Annex II75 species

BoCC Red List species with severe population/range declines42 species

BoCC Amber List species with moderate population/range declines64 species

Bird species listed by the IUCN as Globally Vunerable i.e.considered

to be “facing a high risk of extinction in the wild.“ 1species

Bird species listed by the IUCN as Globally Near Threatened i.e.

which may become vulnerable to extinction threats in the future 3 species

Bird species listed by OSPAR Convention - seabirds birds which are

vulnerable to the threats posed by the many competing human uses of the sea. 2 species

11.2There are 42 Red List species, 64 Amber List species, and 80 other species. 39 of the bird species are specially protected birds under the Wildlife and Countryside Side Schedule 1.1. 27 of the bird species are UK Biodiversity Action Plan Priority Species, i.e. “Species of principal importance for the purpose of conserving biodiversity” covered under section 41 (England) of the NERC Act (2006) and thus they need to be “taken into consideration by a public body when performing any of its functions with a view to conserving biodiversity.” Patently the housing allocation devised by Bury MBC has ignored these species. This area is truly remarkable for birdlife. If you draw a line from the southern limits of Stockport to the northern part of the town of Bury there is only one single area of large waterbody set in a farmland landscape – the Elton reservoir area, with its mosaic of water, marsh, reedbed, streams, ponds, shrubs, hedgerows, grasslands, both improved and semi-improved, tall herbs, canal, river and vegetated mineral workings. The only comparable area of water with grassland is Gorton Reservoirs which is situated in an active golf course. I need to stress this list is important due to the whole habitat mosaic and not just one large waterbody.

11.3Table of Bird Species recorded by contributors in the Elton Reservoir Allocation Area

UK/EU LawS41BernMigratory SppBoCC4English Name + notes)

UKBPSREDArctic Skua P (PB) 26/12/2006

BD1BC2CMS2AEWA2AMBERArctic Tern P (PB) 2016 SH

BD1BC2CMS2AEWA2AMBERBarnacle Goose W (PB) 15/12/2016

WCA1.1BC2Barn Owl RB (PB) 2016 SH

BD1CMS2AEWA2AMBERBar-tailed Godwit W (SJ) 2014

WCA1.1 UKBPSAMBERBewick’s (Tundra) Swan W (SJ) Dec 2011

WCA1.1 BD1 UKBPSBC2AEWA2AMBER(Great) Bittern V (PB)

Blackbird RB (PB) 2016 SH

Blackcap SB (PB) 2016 SH

AMBERBlack-headed Gull R (PB) 2016 SH

WCA1.1BC2AEWA2AMBERBlack-necked Grebe P (PB) 2015 SH

WCA1.1BC2REDBlack Redstart P (PB) 2014 SH

WCA1.1 UKBPSCMS2AEWA2RED(NT)Black-tailed Godwit P (PB) 2016 SH

WCA1.1 BD1BC2AEWA2Black Tern P (PB) 2016 SH

BC2Blue Tit RB (PB) 2016 SH

WCA1.1Brambling W (PB) 2015 SH

UKBPSAMBER(Common) Bullfinch RB (PB) 2016 SH

CMS2(Common) Buzzard RB (PB) 2016 SH

Canada Goose RB (PB) 2016 SH

Carrion Crow RB (PB) 2016 SH

Chaffinch RB (PB) 2016 SH

Chiffchaff SB (PB) 2016 SH

BC2Coal Tit RB (PB) 2014 SH

Collard Dove RB (PB) 2016 SH

AEAW2AMBERCommon (Mew) Gull PW (PB) 2016 SH

BC2AMBERCommon Redstart PS (PB) 2016 SH

AMBERCommon Sandpiper P (PB) 2016 SH

WCA1.1 UKBPSCMS2REDCommon Scoter P (PB) 2016 SH

BD1BC2AEAW2AMBERCommon Tern P (PB) 2016 SH

AEAW2Cormorant R (PB) 2016 SH

AEAW2Coot RB (PB) 2016 SH

UKBPSRED (Common) Cuckoo PS (PB) 2014 SH

UKBPSCMS2AEAW2RED(NT)(Eurasian) Curlew PB (PB) 2016 SH

BC2CMS2AEAW2AMBERCurlew Sandpiper P (PB) 2016 SH

BC2AMBERDipper RB (PB) 2014 SH

BC2CMS2AEAW2AMBERDunlin P (PB) 2016 SH

BC2AMBERCommon Redstart PS (PB) 2016 SH

BC2AMBERDunnock RB (PB) 2016 SH

WCA1.1REDFieldfare W (PB) 2016 SH

WCA1.1BC2Firecrest V (PB) 14/11/2009

CMS2AEAW2AMBERGadwall PW (PB) 2016 SH

AEAW2AMBERGannet V (PB) 2010/13

Garden Warbler SB (PB) 2016 SH

WCA1.1CMS2AEAW2AMBERGarganey S 2015 SH & 22/8/2016

AEAW2AMBERGlaucous Gull W (PB) 2016 SH

BC2Goldcrest RB (PB) 2016 SH

CMS2AEAW2AMBERGoldeneye W (PB) 2016 SH

.BD1CMS2AEAW2Golden Plover W (PB) 2015 SH

BC2Goldfinch RB (PB) 2016 SH

CMS2AEAW2Goosander RB (PB) 2015 SH

UKBPSREDGrasshopper Warbler SB (PB) 2015 SH

AMBERGreat Black-backed Gull P (PB) 2016 SH

AEAW2Great Crested Grebe RB (PB) 2016 SH

CMS2AEAW2Great (White) Egret 2010 Man’r Birding

WCA1.1.BD1BC2AEAW2AMBERGreat Northern Diver W (PB) 2015 SH

BC2Great Tit RB (PB) 2016 SH

Greenfinch RB (PB) 2016 SH

BC2Great Spotted Woodpecker RB (PB) 2016 SH

WCA1.1BC2CMS2AEAW2AMBERGreen Sandpiper P (PB) 2016 SH

WCA1.1CMS2AEAW2AMBERGreenshank P (PB) 2016 SH

BC2Green Woodpecker RB (PB) August 2008

AEAW2Grey Heron RB (PB) 2016 SH

UKBPSREDGrey Partridge V (PB)

CMS2AEAW2AMBERGrey Plover P (PB) 25/5/14

CMS2AEAW2AMBERGreylag Goose RB (PB) 2016 SH

BC2REDGrey Wagtail BR 2016 SH

WCA1.1.BD1 UKBPSCMS2REDHen Harrier P (PB) April 2014

UKBPSAEAW2REDHerring Gull P (PB) 2016 SH

WCA1.1BC2CMS2Hobby S (PB) 2016 SH

BC2AMBERHouse Martin SB (PB) 2015 SH

UKBPSREDHouse Sparrow RB (PB) 2016 SH

AEAW2AMBERIceland Gull W (PB) 2015 SH

Jackdaw RB (PB) 2016 SH

CMS2AEAW2Jack Snipe W (PB) 2016 SH

Jay RB (PB) 2015 SH

BC2CMS2AMBERKestrel RB (PB) 2016 SH

WCA1.1. BD1BC2AMBERKingfisher RB (PB) 2016 SH

AEAW2RED (O)(Black-legged) Kittiwake P (PB) 2015 SH

CMS2AEAW2AMBERKnot P (PB) 2015 SH

UKBPSCMS2AEAW2RED(Northern) Lapwing RB (PB) 2016 SH

AEAW2AMBER(O) Lesser Black-backed Gull P (PB) 2016 SH

REDLesser Redpoll W (PB) 2016 SH

Lesser Whitethroat SB (PB) 2016 SH

UKBPSRED(Common) Linnet PS (PB) 2016 SH

WCA1.1 BD1BC2AEAW2Little Bittern 25/5/2014 SH (1st record in Greater Manchester for 45 years)

BD1BC2AEAW2Little Egret P (PB) 2016 SH

AEAW2Little Grebe RB (PB) 2015 SH

WCA1.1Little Gull P (PB) 2016 SH

BC2Little Owl RB (PB) 2015 SH

WCA1.1 BD1BC2AEAW2Little Bittern 25/5/2014 SH (1st record in Greater Manchester for 45 years)

WCA1.1BC2CMS2AEAW2Little Ringed Plover PB (PB) 2016 SH

BC2CMS2AEAW2Little Stint P (PB) 27/9/2009

WCA1.1 BD1BC2CMS2AEAW2AMBERLittle Tern P (PB) 2014 SH

BC2Long-eared Owl WP (PB) Winter 2014-15

WCA1.1CMS2AEAW2RED(V)Long-tailed Duck W (PB) 2015 SH

Long-tailed Tit RB (PB) 2016 SH

Magpie RB (PB) 2016 SH

CMS2AEAW2AMBERMallard RB (PB) 2016 SH

WCA1.1 BD1CMS2AMBERMarsh Harrier P (PB) October 2016

BC2AMBERMeadow Pipit RB (PB) 2016 SH

WCA1.1 BD1BC2CMS2AEAW2AMBERMediterranean Gull P (PB) 2016 SH

WCA1.1 BD1BC2CMS2REDMerlin W (PB) 2016 SH

REDMistle Thrush RB (PB) 2016 SH

CMS2AEAW2Moorhen RB (PB) 2016 SH

CMS2AEAW2AMBERMute Swan RB (PB) 2016 SH

CMS2AEAW2AMBERNorthern Pintail W 2014 SH

BC2Nuthatch RB (PB) 2015 S

WCA1.1 BD1CMS2AMBEROsprey P (PB) 2010 Manchester Birding

AEAW2AMBEROystercatcher PB (PB) 2015 SH

WCA1.1 BD1BC2CMS2Peregrine Falcon R (PB) 2016 SH

Pheasant RB (PB) 2016 SH

CMS2REDPied Flycatcher SP (PB) 2010 Manchester Birding August 2015

Pied Wagtail R (PB) 2016 SH

AMBERPink-footed Goose W (PB) 2016 SH

CMS2AEAW2AMBERPintail P (PB) 2010 Manchester Birding

CMS2AEAW2REDPochard PW (PB) 2016 SH

Raven R (PB) 2016 SH

CMS2AEAW2Red-breasted Merganser V (PB) 2015 SH

WCA1.1 BD1CMS2(NT)Red Kite P (PB) Aug 2016

REDRed-necked Grebe W (PB) 12/12/2005

UKBPSREDLesser Redpoll R 2015 SH

CMS2AEAW2AMBERRedshank P (PB) 2016 SH

WCA1.1 BD1BC2CMS2AEAW2Red-throated Diver WP (PB) 23/9/2004

WCA1.1REDRedwing WV (PB) 2016 SH

UKBPSBC2AMBERReed Bunting RB (PB) 2016 SH

Reed Warbler SB (PB) 2016 SH

UKBPSBC2REDRing Ouzel P (PB) 2016 SH

BC2CMS2AEAW2REDRinged Plover P (PB) 2016 SH

Ring-necked Parakeet P (PB) 2015-16

BC2Robin RB (PB) 2016 SH

Rock Dove R (PB) 2016 SH

BC2Rock Pipit P (PB) 2016 SH

Rook RB (PB) 2016 SH

CMS2Ruddy Duck P (PB) 1 in 2016

BD1BC2CMS2AEAW2Ruddy Shelduck V (PB) 22/8/2009

WCA1.1REDRuff P (RB) 2015 SH

BC2Sand Martin SB (PB) 2016 SH

BD1BC2AEAW2AMBERSandwich Tern P (PB) 2016 SH

BC2CMS2AEAW2AMBERSanderling P (PB) 2016 SH

WCA1.1 UKBPSCMS2AEAW2REDGreater Scaup P (PB) 2016 SH

Sedge Warbler SB (PB) 2016 SH

BC2REDShag V (PB) 23/8/2008

BC2CMS2AEAW2AMBERShelduck P (PB) 2016 SH

BD1BC2AMBERShort-eared Owl WP (PB) 30/9/2011

CMS2AEAW2AMBERShoveler PW (PB) 2016 SH

Siskin W (PB) 2016 SH

UKBPSREDSkylark RB (PB) 2015 SH

WCA1.1 BD1BC2CMS2AEAW2REDSlavonian Grebe W (PB) 12/11/2011

CMS2AEAW2AMBERSnipe RB (PB) 2016 SH

UKBPSREDSong Thrush RB (PB) 2016 SH

CMS2Sparrowhawk RB (PB) 2016 SH

UKBPSBC2CMS2REDSpotted Flycatcher S (PB) 2015 SH

UKBPSRED(Common) Starling RB (PB) 2016 SH

AMBERStock Dove P (PB) 2016 SH

Stonechat WP (PB) 2016 SH

BC2Swallow SB (PB) 2016 SH

AMBERSwift SB (PB) 2016 SH

BC2AMBERTawny Owl RB (PB) 2016 SH

CMS2AEAW2AMBERTeal PW (PB) 2016 SH

WCA1.1CMS2AEAW2Temminck’s Stint P 2014 SH 31/7/2014 record awaiting acceptance

BC2Tree Creeper RB (PB) 2015 SH

UKBPSBC2REDTree Pipit P (PB) 2016 SH

CMS2AEAW2Tufted Duck R (PB) 2016 SH

BC2CMS2AEAW2AMBERTurnstone P (PB) 2016 SH

UKBPSREDTwite W (PB) 28/10/2009

BC2AMBERWater Pipet P (PB)

AEAW2Water Rail RB (PB) 2016 SH

BC2Waxwing W (PB) 31/3/2013

BC2Wheatear P (PB) 2016 SH

WCA1.1CMS2AEAW2REDWhimbrell P (PB) 2015 SH

BC2REDWhinchat P (PB) every year 2016 SH

Whitethroat SB (PB) 2015 SH

BC2CMS2AEAW2White-winged Black Tern P 2014 SH

White Wagtail P 2015 SH

WCA1.1 BD1BC2CMS2AEAW2AMBERWhooper Swan W (PB) 2016 SH

CMS2AEAW2AMBERWigeon PW (PB) 2016 SH

UKBPSREDWillow Tit RB (PB) 2016 SH

AMBERWillow Warbler SB (PB) 2016 SH

CMS2AEAW2REDWoodcock W (PB) 2015 SH

Wood Pigeon RB (PB) 2016 SH

WCA1.1 BD1BC2CMS2AEAW2AMBERWood Sandpiper P (PB) October 2016

BC2Wren RB (PB) 2016 SH

Yellow-billed Pintail 2014 SH August 2014 presumed an escape.

AMBERYellow-legged Gull P 2016 SH 3-14 March 2015 and August 2016

UKBPSBC2REDYellow Wagtail S (PB) 2016 SH

Key to notes– R – resident; B - breeds; S – Summer visitor; W – Winter visitor; P – passage migrant; V – vagrant (very rarely seen). (PB) – from Peter Baron’s Elton Bird Report 10 years to 2016; (SJ) – Simon Johnson; SH – year of latest records from Steven Higginbottom; Some dates gleaned from Manchester Birding. This is not intended to be an exhaustive list of records. It is a list of bird species recorded over the proposed Elton Reservoir housing allocation in the last 10 years, with most recent years seen by one bird recorder; there may be more recent records. Farmland birds are still a major concern according to the British Trust for Ornithology. The list is what people have seen and should not be taken in any other way. Birds do not have to be seen by people to be present and visiting or migrating through.

Codes to protected/conservation status:

WCA1.1Bird species fully protected by the UK’s Wildlife and Countryside Act Section 1.1.

BD1Bird species fully protected by the European Union’s Bird Directive Annex 1. Birds which are the subject of special conservation measures concerning their habitat in order to ensure their survival and reproduction in their area of distribution.

UKBPSUK BAP priority species were those that were identified as being the most threatened and requiring conservation action under the UK Biodiversity Action Plan (UK BAP) – Now termed Section 41 species.

BC2Bird recommended for protection as a result of the Bern Convention Appendix 2 to which the UK is a signatory. Special protection (`appropriate and necessary legislative and administrative measures`) for the animal taxa listed, including all forms of deliberate capture and keeping and deliberate killing; the deliberate damage to or destruction of breeding or resting sites; the deliberate disturbance of wild fauna, particularly during the period of breeding, rearing and hibernation, insofar as disturbance would be significant in relation to the objectives of this Convention.

CMS2Convention on Migratory Species Appendix 2, to which the UK is a signatory. Migratory species having an unfavourable conservation status for which Range States are encouraged to conclude international agreements for their benefit.

AEAW2Convention on Migratory Species, African-Eurasian Waterbirds Agreement - Annex II, to which the UK is a signatory. Conservation of migratory waterbirds, giving special attention to endangered species as well as to those with an unfavourable conservation status.

REDStatus given by Birds of Conservation Concern 4. Uses several criteria - IUCN: Global conservation status. Species that are Globally Threatened (Critically Endangered, Endangered and Vulnerable, but not Near Threatened) under IUCN guidelines, as assessed by BirdLife International,

the IUCN Red List Authority for birds, in2015; Historical decline in breeding populations. Species judged to have declined severely between 1800 and 1995, from an assessment conducted by Gibbons et al. (1996a), and which have not recovered subsequently; Breeding population decline. Severe decline in the UK breeding population size (>50%) over 25 years or the longer term; Non-breeding population decline. Severe decline in the UK non-breeding population size (>50%) over 25 years or the longer-term; Breeding range decline. Severe decline in UK range (>50%) between the breeding bird atlases in 1988–91 and 2007–11 or 1968–71 and 2007–11 , as measured by the calculated change in the number of occupied 10-km squares; Non-breeding range decline. Severe

decline in UK range (>50%) between the wintering bird atlases in 1981–84 and 2007–11, as measured by the calculated change in the number of occupied 10-km squares.

AMBERStatus given by Birds of Conservation Concern 4. Uses several criteria - European Red List status; Historical decline – recovery. As described above, previously Red-listed for historical decline, followed by an increase of at least 100% over 25 years or the longer term period; Breeding population decline. As for Red-list criterion, but with moderate decline (>25% but <50%) over 25 years or the longer-term period; Non-breeding population decline. As for Red-list criterion, but with moderate decline (>25% but <50%) over 25 years or the longer-term period; Breeding range decline. As for Red list criterion, but with moderate decline (>25% but <50%) between 1988–91 and 2007–11 or 1968–71 and 2007–11; Non-breeding range decline. As for Red-list criterion, but with moderate decline (>25% but <50%) between 1981–84 and 2007–11; Breeding and non-breeding rarity; Species qualified as rare breeders if the UK breeding population was <300 pairs, and as rare non-breeders (WR) if the UK nonbreeding population was <900 individuals; Breeding and non-breeding localisation. Species were considered localised if more than 50% of the UK population was found at

ten or fewer sites in either the breeding the non-breeding season. Sites were defined as either Special Protection Areas or Important Bird Areas; Breeding and non-breeding international importance. Species were considered of international importance if the UK holds at least 20% of the European population in either the breeding or the non-breeding season.

(V)Globally Vulnerable to extinction threats per IUCN Threatened i.e. considered

to be “facing a high risk of extinction in the wild.“

(NT)Globally Near Threatened per IUCN i.e. which may become vulnerable to extinction threats in the future.

(O)OSPAR Convention conserved seabirds birds are vulnerable to the threats posed by the many competing human uses of the sea.

12The importance of Amphibians and ponds in the Elton Reservoir Allocation Area

12.1The Proposed Housing Allocation has many ponds and land habitats that support up to 5 species of amphibians – Common Frog, Common Toad, Great Crested Newt (GCN), Smooth Newt and Palmate Newt. Some of the ponds are centred on coal shafts, as can be seen by looking at the maps on the Coal Authority website. In my time other ponds have appeared meaning that the area is actively producing new ponds as the underground workings subside. Other ponds are appearing via impeded drainage. The amphibian breeding sites include field ponds, reservoirs, goits, the canal, marshland, cut-off sections of the River Irwell, quarry ponds and conservation ponds. The variety of types of ponds in a farmed grassland landscape make this a special area.

12.2Many of the ponds contain marshy habitats and swamps that may not have much open water in some years – they do however support interesting plants of conservation value – such as Bottle Sedge, White Sedge, Lesser Pond Sedge, Marsh Cinquefoil, Bog-bean, Marsh Pennywort and Sphagnum Bog-moss species, and for example the mollusc Twisted Ramshorn, which likes late successional ponds. A complete list of plant species was compiled by me for Bury MBC in their Great Crested Newt Survey of 2005-7.

12.3Great Crested Newts are fully legally protected by UK and EU legislation – but barely so in Bury.

12.4Bury Council – incompetent planners and land managers. Despite being a Site of Biological Importance the GCN population at Spen Moor was trashed around 2005 and later. The land managers ploughed one hedgerow base into the pond; another pond was drained completely into a neighbouring pond; the land managers let 3 further ponds to a new angling club who set about deepening a Great Crested Newt breeding pond and stocking this and two others with fish. They also set about building platforms for angling and walkways. Despite planning consent being required for this recreational infrastructure and change of use on an SBI, Bury MBC planners, to their great shame, refused to get involved. Subsequently the Environment Agency ended the fishery as they, under law, control the movement of fish in UK waters. But all this effectively destroyed the Great Crested Newt population in northern Spen Moor, a gift to Peel Estates. At Black Lane SBI in the west of allocation area, a piece of land was transferred to Bury MBC for Great Crested Newt conservation as part of a Section 106 planning agreement. For 8 years Bury MBC planners and recreational managers allowed an adjacent householder to squat on this land and turn it into a private garden.– year after year they ignored my pleas to throw the squatter off. These people are still at Bury Council - they are unfit to be involved in managing sites with wildlife interest. Eventually the matter came to a head after the squatter attacked me and the police became involved. Realising they had allowed a dangerous psychopath to attack a member of the pubic lawfully using the land for wildlife study AND make fools of them these unfit planners and land managers at Bury MBC finally threw the guy off - and used money they had been given by developers to manage the site, but had sat on, to fence him out. Other examples of Bury MBC Planning incompetence at Black Lane occurred when Peel gained outline consent. The pond area was to have a 3m buffer zone and a wide central linking area preserved for wildlife and this was given outline consent. When the developers sought reserved matters they and Bury MBC ignored the 3m buffer zone and this is now within private gardens. Indeed detailed measurement showed the garden fences have been placed within the protected area. The wide central area shrank to a narrow central area. Bury MBC refused to remedy the situation. Elsewhere in the SBI developers built hibernacula under a section 106 agreement and used asbestos sheets. These were deemed acceptable by Bury planners who then took them to the tip when they gained ownership of the land – so no hibernacula! Another example at this site is where another developer agreed to fence the buffer zone from the new house gardens as a planning condition, but sold the land within the buffer to the householders, who then set about relocating the fences to their ownership boundaries – a meaningless buffer zone. At Pole Lane, Unsworth, Bury MBC required a road upgrade to the new Golf Course and gave planning consent, without any mitigation whatsoever, for the road to be diverted through a Great Crested Newt pond they had on their records as a protected species site. In another part of Radcliffe Bury planning ran a derelict land scheme on some air-raid shelters and rough land where they intended to build units. They refused to do any mitigation whatsoever and flattened the site without clearing the newts. English Partnerships, the government land reclamation agency, rebuked the Council, leading to a mitigation scheme when the site was finally developed.

12.5Thus if the housing allocation were to require any planning agreements, planning conditions, section 106 agreement and land transfers to Bury MBC please note that the Local Planning Authority in Bury and the land management team are UNFIT to be involved. This makes mitigation and compensation an impossibility. An unrepentant Borough Council has never disciplined the guilty officers, never apologised, never admitted errors, and never made any attempt to set out how it would behave better. Would anyone actually trust Bury MBC planners to supervise a development in a wildlife area? No.

12.6There are Toads breeding in these reservoirs and ponds. They use the deeper waterbodies in this area as a metapopulation. They need to breed, disperse and find land habitats. Toads have a measure of protection in the planning system. The Common Toad is listed by the UK Government as a United Kingdom Biodiversity Action Plan Priority Species given “serious declines.” This is now succeeded by the UK Post-2010 Biodiversity Framework (or “Biodiversity 2020”) and Priority Species are termed Section 41 species, the “revised delivery method” for Common Toad conservation cited as “planning policies and control” (Gov.uk website). JNCC species Priority Species account also states “WIDER ACTION- PLANNING: This amphibian would benefit from recognition of its habitat and management needs at the wider landscape scale both aquatic and terrestrial. Taking account of/ or determining its presence during the early stages of local authority development plans, land allocation (particularly `brownfield sites`) and then development schemes.” The proposal will lead to a mass slaughter of Toads via massive habitat loss and getting trapped on kerbed roads, squashed on roads, falling into street grids - all totally contrary to government policy.

13The importance of the grassland and hedgerows in the Elton Reservoir Allocation Area

31.1Lots of Yellow Rattle marks some of these meadows as old semi-improved grasslands. The improved pastureland used for dairy cattle contains the worms eaten by Great Crested Newts. The Hawthorn hedgerows are berry-rich and great for overwintering bird flocks. Scattered in the hedgerows and around ponds, and alongside the streams are mature trees.

13.2Elton Goit Site of Biological Importance lies near the canal. Note the boundary has not been accurately drawn and the permanent wetland area extends beyond the SBI boundary. The SBI boundary must be revised to include all land of value. The SBI is a large area of unimproved grassland and marshland with willow carr and swamp and open water. It is a valuable bird habitat, supporting some uncommon species.

13.3As stated earlier the importance of this habitat mosaic cannot be over-stated. The proximity of grassland countryside next to large areas of water and marsh are what makes this site regionally special.

14The importance of Pilkington Fold for wildlife

14.1The area west of the Pilkington Fold farmstead and east of Starling Road is a piece of Pasture Woodland (Pasture Woodland is a UKBAP Priority Habitat), has areas of acidic grassland and is clearly part of the Cockey Moor. Presently it is horse-grazed. The site contains a stream with a reedmace marsh, and air photos show that the streams drains all of the area north of the farmstead. The water movement lines are quite clear on Google Earth. This stream becomes the stream in the council-owned Starling Wood. Council employed tree workers felled a tree in that wood containing an active owl nest. Can Bury’s land managers really be expected to play a part in managing sites that may be handed to them in compensation for wildlife losses? But why put Starling Wood in the housing allocation area? Starling Wood and Pilkington Fold form a massively important wildlife corridor between Elton Reservoir area and the wider countryside. It must be designated as such.

14.2Just to the west of Starling Road there is Starling Reservoir, a Site of Biological Importance and Toad breeding site. Given the countryside nature of Starling Road, Toads will scatter over the road and use land habitats on Pilkington Fold. Toads are a UKBAP Priority Species.

15Biodiversity Opportunity Areas/Sites

15.1In 2008 the Greater Manchester Ecology Unit was asked by AGMA to produce an Ecological Framework for Greater Manchester. They identified Biodiversity Opportunity Areas for Great Crested Newts in known ‘species hotspots.’ “At these sites policies encouraging relatively specific nature conservation measures applying to the specific requirements of great crested newts should be applied.” In the whole of Greater Manchester they identified just 9 Biodiversity opportunity Areas for Great Crested Newts. The area around Radcliffe containing Elton Reservoir area was identified as one.

15.2The GMEU also identified Priority Sites for Large-scale Habitat Creation and Repair. “The Technical Guidance concerning Ecological Frameworks prepared as part of the North West Regional Spatial Strategy recommends that Ecological Frameworks could incorporate sites for ‘large and visionary’ habitat creation schemes. The ten districts of Greater Manchester were asked to provide details of any such sites for their districts. Criteria used to select such sites included:

• Sites were regarded as being capable of ecological restoration in the short to medium term using identified resources and existing knowledge;

• Sites supported local concentrations of Priority habitats and/or species;

• Sites supported physical environmental factors suitable for recreation of Priorityhabitats;

• Sites were in part protected from inappropriate development by existing Policies in Plans.”

15.3Just 20 sites were put forwards in the whole of Greater Manchester. Elton Reservoir area with the area to the west at Coggra Fold were one of the sites having “opportunities for the creation/ improvement of open water and pond habitats.”

15.4What is the point in government spending money on such strategies and then having local authorities, besotted by some idea of political gain and grand projects decide, no, we don’t want wildlife, we want council tax-payers to fund our concrete utopia instead?

16Coal Mine, Mineral Extraction and Flooding concerns

16.1The Coal Authority Maps indicate shafts and horizontal workings across the allocation and reshaping the landform required by the development carries an environmental risk to hydrology and land stability including that of neighbouring residential properties.

16.2The Coal Authority map shows several ponds within 2 SBIs as actually being centred on coal shafts. This means the ponds have very exacting hydrology, and are possibly supported by upwellings of water from mine shafts, and again, should a horizontal mine working shatter during the development, the hydrology of the linked pond might be destroyed forever.

16.3It should also be noted that the All Sites Summary handout for Bury states “Policy GM25 is a generic policy that is applicable to all site allocations.” And “Development must ensure the extraction of any viable brickclay, sand and gravel, sandstone and/or surface coal resources in advance of construction, in accordance with the relevant policies of the Greater Manchester Joint Minerals Plan.”

16.4The Bury UDP records, because they are there, deposits of sand and gravel, in the eastern half of the allocation from Radcliffe Cemetery to what was the Farmer’s Arms (Benny’s), and also near Buckingham Drive. Policy GM25 of the GMSF requires that these areas are quarried prior to development. What is more worrying as to produce the Bury UDP all minerals identified in the GM Joint Minerals Plan that undelay Sites of Biological Importance were deleted, and now the GMSF ignores the beneficial aspect of the UDP and puts the GMJMP as the document relied upon. SBI’s are now fair game for mineral extraction under the GMSF, whereas under the Bury UDP it was simply not allowed. All one needs to do to extract minerals under the GMSF is to trash the wildlife first. There are plenty of examples above where developers do this to avoid planning requirements.

16.5Flooding has recently (winter 2015/16) occurred on the River Irwell at Redvales. Houses were flooded. There are concerns about the Council’s role in lack of supervision of the development of the hydroelectric plant on the weir. Particularly worrying is that the Council allowed the developer to infill Bealey’s Goit with material taken from the river, and the Council allowed the developer to raise the height of the weir. This meant that more water was held back, more water escaped around the hydroelectric plant, and more water had nowhere to go as Bealey’s Goit had been a useful channel for taking excess water. So do we blame the flooded homes on Bury MBC planners for allowing such a scheme? Are they competent to assess flood risk? The answer could be yes, and then certainly no.

16.6So at Elton the site will be first be trashed and the wildlife removed by removing tall ground vegetation and turf removal so there is nowhere for flowers to grow, birds to nest or wildlife to live; then the area will be excavated and there will be no topsoil. There will be massive flooding. The site will be tipped to restore levels, pile driven, and then covered in concrete. There will be massive flooding, and given the proximity of my home to the existing potential flood area it is probable that Bury MBC will flood my home. My property will be destroyed and I will be faced with thousands of pounds to alter my home; the insurance premiums will rocket. All because of incompetent, irresponsible and reprehensible people at Bury MBC and within the other 9 GM Districts and at AGMA /GMCA.

17The Turley Peel Masterplan

17.1Dated January 2016, this document displays Peel’s aspirations and intentions for the development of this area. It was submitted as part of the Call For Sites. On the front cover we are treated to a view of the Elton Reservoir area landscape with blocks of housing superimposed upon it. Most horrifying is that it shows Peel’s intent to destroy completely Elton Goit Site of Biological Importance, a site important for secretive water birds, and for a mosaic of unimproved acid and neutral grassland, marshland, swamp, carr and open water. The area of special interest is actually larger than the SBI due to mapping errors. One large deep pond near the canal is excluded. It must be included in the SBI.

17.2Para 1.3 is disingenuous. It talks of creation of an area of country park, when a country park already exists in all but name. The Canal & River Trust, on behalf of the people of Bury and the nation, manage and provide access to the Canal towpaths, Elton Reservoir, and the meadow and dam-side fringes of the reservoir. Bury Council owns and maintains for public enjoyment part of the railwayline as a cycleway, and the whole of the Buckingham Drive meadows. The Canal & River Trust have also heavily invested in the reservoir embankment recently and are stoning the existing soil pathway around the west bank. Public display boards have been erected. Neither Bury MBC nor the Canal & River Trust needed Peel’s help in providing these sites and amenities. Bury MBC maintains a series of Public Rights of Way across the farmland. Withins Reservoir is an angling reservoir with unofficial wider public access. The Reservoir has a Sailing Club and there is a public car park.

17.3On page 12 of the document a maps sets out the location of Sites of Biological Importance. Within the allocation area and the area identified on this map as Wildlife Corridor there are in fact TEN Sites of Importance. Is this exclusion deliberately deceitful, or merely outright incompetence? Whatever the case, I put it to the GMCA that the information provided to the Call for Sites was so wrong as to constitute a failure to correctly submit to the Call for Sites. The allocation should be withdrawn on that basis alone, if not others as well.

17.4So let’s look at “The Proposals.” These “Proposals” are copied from the document. My comments are in capital after:

“7.1 Elton Parkland seeks to create a new and useable publicly accessible park in a part of Greater Manchester where there is a gap in the provision. It seeks to be accessible to all ages and for a large range of uses and users, all centred on leisure and recreational pursuits.” THERE ALREADY IS A COUNTRY PARK IN ALL BUT NAME; THERE IS NO GAO IN THE PROVISION. THE PARK IS ALREADY ACCESSIBLE TO ALL AGES AND FOR A LARGE RANGE OF USES AND USERS, ALL CENTRED ON LEISURE AND RECREATIONAL PURSUITS. WHAT “THE PROPOSALS” WILL DO IS TO REDUCE OPPORTUNITUES FOR LEISURE – EG HORSE-RIDING, BIRD WATCHING, RAMBLING, DOG WALKING IN THE COUNTRYSIDE BY REDUCING THE AREA AVAILABLE TO DO THIS, REDUCING BIRD LIFE, AND AT THE SAME TIME ADDING THE HUMAN POPULATION OF 3460 NEW HOMES.

“7.2 The park could contain a unique range of landscape characters given its wetland and semi aquatic habitats and open grasslands. These habitats could be linked by a series of interconnected pathways – some upgraded existing and some new.” THE EXISTING PARKLAND AND COUNTRYSIDE INCLUDES A MOSAIC OF 10 DIFFERENT SITES OF BIOLOGICAL IMPORTANCE, ALONG THE SEMI-IMORIVED GRASSLAND, IMRVED GRASSLAND, HEDGEROWS AND UNDESIGNATED PONDS. THEY ARE ALREADY LINKED BY A SERIES OF INRERCINNECTED PATHWAYS.

“7.3 The park could be host to new Country Park facilities, car parks and open areas. The area’s rich history could be explained and interpreted. This could cover the natural flora and fauna, through to its man-made industrial heritage with the historic canals and rail line.” WELL, SPEN MOOR’S EXISTING NEW DEVELOPMENT IS BEING BUILT ON TOP OF THE LINE OF THE ROMAN ROAD. THE MASTERPLAN PLANS TO DESTROY ELTON GOIT SBI. THE WHOLE THING WILL DAMAGE FLORA AND FAUNA. THE CANAL & RIVER TRUST HAVE ALREADY BEGUN ESTABLISHING INTERPRETATION BOARDS. ANY OTHER INTERPRETATION COULD BE DONE BY EXISTING INITITATIVES AND DOES NOT NEED PEEL’S HELP.

“7.4 There is the potential for new habitat areas, regenerating wetland or sensitive grassland areas crisscrossed by pathways, where nature can be viewed easily and safely, close up and first hand by all.” THE EXSTING PARK AND ITS ADJACENT COUNTRYSIDE ALREADY OFFER THIS. ADDING THOUSANDS MORE PEOPLE INT THIS AREA WILL WRECK THE WILDLIFE HABITAT.

“7.5 Investment in Elton Parkland could further enhance the Irwell Sculpture Trail through increased activity and use of the trail linked to a wider set of green infrastructure investments.” WOW. IS PEEL GOING TO PAY FOR A SCULPTURE?

17.5“Section 9 Narrative Illustrated” shows the horor of what Turley Peel and (indeed Bury MBC) propose, and not even they know what they are saying. On the one had they show the Reservoir with areas of reedbeds and marsh where currently non exist, because the water is too deep, and on the other hand they show the same areas without reedbed and marsh but with hard decking and gravelled shorelines. The presence of Canada Geese illustratively added by Turley is telling – they are an invasive alien species that wreck habitats.

Increased pollution and hydrological impact

17.6The other thing that wrecks habitats is polluted water draining into them, and all these extra houses are certainly going to change the water quantity getting into the existing wetlands, via disruptions of centuries old field drain systems, and water quality, with all the extra storm surges that so many drains and areas of concrete create. Elton Reservoir for example is fed by a feeder goit, two other streams, sundry seepages from the surrounding fields, and the ponds on Spen Moor all have interlinked drains in and out and these issue to the reservoir and any development here will damage water quality.

18Wildlife Corridors

18.1At the Unitary Development Plan I presented as an objection to what had been proposed by the Council a revised set of wildlife corridors. The council hired an incompetent ecologist who had been negligent in numerous occasions on dealing with wildlife planning in Bury. The incompetent ecologist did not appear to even consider any of the additional corridors I proposed for Elton reservoir area. Thus I include them here. The GMSF must designate these as wildlife corridors. Corridors are linear chains of habitat of quality of landform. They include streams and river valleys, blocks of woodlands and canals and railways. Wildlife links are tracts of open space between built up areas that are not defined in such a way but are open in nature and allow larger mammals to passage between areas. In the included plans, from that inquiry, the additional corridors are numbered and edged by a black line with an arrowheads pointing inwards. Wildlife Links are shown by open circles and L3. The Council proposed Corridor of that time is shown hatched and the Links limited to the canal, Metrolink and the former Bury to Bolton and Radcliffe to Bolton Railwaylines. I proposed these become designated Wildlife Corridors and Links.

19Traffic

19.1The development of this site for housing will have a severe impact on traffic by massively increasing it.

20Quality of Life

20.1The development of this allocation for housing will massively impact on people’s quality of life for the reasons outlined above.

I hereby object to this allocation

David Paul Bentley Ecological Consultant - Aquatic Systems

Below are two plans:

Proposed Wildlife Corridors and Links

Proposed Wildlife Corridors and LinksDavid Bentley END

Walshaw Allocation (Bury) – Greenbelt removal – OBJECTION V5

David P Bentley Ecological Consultant www.davebentleyecology.co.uk

Representing – nature conservation and landscape

The open land between Bury and Walshaw to be destroyed : 1250 houses

1The wrongly assessed Housing and Employment Need

1.1The well-loved countryside around Walshaw, and several other parts of the borough, is about to be destroyed on the whim of the local Labour Party. They claim it is the government’s fault. That is not true. Labour controlled Local Authorities hired the population forecasters. Labour chose the Accelerated growth option when they could have chosen a lower growth option. Labour decided to ignore the benefits of reduced migration that we will get from leaving the EU. Labour has 90% of the seats on the Greater Manchester Combined Authority and control Bury Council. This hated plan is Labour’s work. It is a political project divorced from actual housing and employment needs.

“Option 1 GMFM Baseline 2014: The standard baseline forecasts produced as part of the annual GMFM release in 2014 which draws on OE’s national and regional forecasts. This provides a level of growth and development consistent with GM’s existing land supply, as identified by the ten local authorities. The baseline is therefore a ‘policy neutral’ forecast.

Option 2 AGS-SNPP 2014: An Accelerated Growth Scenario providing a projection for the GM economy that is stronger than the baseline forecast, and reflects a future where the city plays a lead role in the development of a ‘Northern Powerhouse’. It also meets GM’s aspiration to provide additional employment opportunities to non-employed local residents. The scenario adopts demographic assumptions set out in 2012 sub-national population projections (SNPP).”

1.2The Labour Party chose Option 2. A political decision. In doing so they ALSO chose to ignore the end to the environmentally damaging effects of mass migration that will occur with Brexit. This is specifically cited in the background papers to the GMCA/AGMA Executive Meeting of August 2016.

1.3This is what the recent past tells us about Bury’s population increase since 1981. I did not need to pay population forecasters tens of thousands of pounds. I just checked the census totals for the Borough from 1981 to 2011. Here’s what they say and my conclusion:

Bury Pop 1981 175 459. No figs before then as no Bury MBC in 1971.

Bury Pop 1991 179 168. 371 rise in 10 years, 371 in a year average.

Bury Pop 2001 180 608. 1440 rise in 10 years, 144 in a year average.

Bury Pop 2011 185 060. 4452 rise in 10 years, 445 in a year average.

We can maybe put the recent rise down to immigration from the EU, given the rise of numbers of say Polish speakers in the Borough. This will cease on Brexit.

So the worst case scenario is that with a 445 person rise a year for next 20 years 8900 new people will live in Bury. That is assuming Free Movement will continue, which it will not. Assume 2.2 people per home – 4045 homes. I just checked my half of my street – it is 2.3 people per home.

So remain a member of the EU build 4045 homes. Drop to before the Eastern European nations were granted freedom of movement and it is 2880 new people in 20 years. At 2.2 people per home it is 1309 homes. THE GMSF FORECAST OF 12,500 HOUSES IS BEYOND RATIONALITY.

1.4Something we learned from the EU Referendum and aftermath is that a whole host of economic forecasters were totally wrong – doom was forecast from the moment the UK voted to leave. My opinion is that the Oxford Economics forecast as originally made for new homes, considering the above, is worthless.

1.5The Greater Manchester Strategic Housing Market Assessment Oct 2016 reports Bury MBC has existing supply of land for 4786 houses and a potential windfall of 1000 houses up to 2035. This is more than the requirement should we remain a member of the EU, and many times more than would be required on leaving.

1.6Now Bury has been allocated 12,500 houses. The sums of the Greenbelt deletion housing allocations are W 1250, B 60, S 135, H 100, E 3460, N 200 + 1000 + 3400 + 600 = 10,205. Given AGMA and Bury MBC considered it had non Greenbelt sites for 4786 plus 1000 windfall (making 5786) then, with these Greenbelt deletions, Bury will actually havespace for 15,991 houses - which is ludicrously over any imagined ludicrous target. Clearly the GMSF has allocated fantasy allocations to Bury. The officers responsible should be dismissed. If this was some planner making a rational decision my comment might be out of order. It is not. This is a case of true incompetence which has caused massive financial cost and widespread emotional upset.

1.7The buffer the GMCA have applied to elevate Bury’s housing target is also unnecessary. Given that the GMSF target is so massively an over calculation there is no need to apply a buffer to allow for flexibility. The likelihood is that people will leave Bury if these plans are approved.

1.8The figures the GMCA use are based on an expectation of approximately 1.3 persons per dwelling. The 2011 census had a UK average of 2.3 persons per dwelling compared to 2.4 persons per dwelling in 2001. This therefore seems to assume that a lot more people will be living alone and households are getting significantly smaller, far more than the rate in the previous decade for which data is available.

1.9The mishmash of housing and urban edge the GMSF will create for decades as development proceeds on a slow scale will degrade the town’s landscape. It will blur the urban rural edge and lead to chaotic planning, and wholesale wildlife destruction as well.

2Lack of consultation

2.1The lack of consultation has been breath-taking. The process is contrary to Bury Council’s own guidelines – its Statement of Community Involvement - thus:

“How will the Council involve you?

“The following table lists some of the activities and methods the Council will consider using when undertaking consultation exercises in connection with the Local Plan. The methods used will be tailored to suit the scale and nature of impact of the decisions to be made and the particular needs of people being consulted:” THIS IS THE BIGGEST DEVELOPMENT PLAN THE COUNTY HAS KNOWN.

“Material made available on the Council’s web site, in Council offices at Knowsley Place Reception, Town Hall Reception and selected local libraries (see our Statement of Community Involvement web page on http://www.bury.gov/10738 for a list).” The ALLOCATIONS MAPS AND TEXT ARE NOT AVAILABLE ON THE COUNCIL WEBSITE. THERE ARE NO DISPLAYS, POSTERS OR LEAFLETS IN ANY COUNCIL RECEPTION IN THE BOROUGH; THE COUNCIL OFFICE IN KNOWSLEY PLACE HAS NOTHING, AND DIRECTS CALLERS TO A 15 MINUTE QUEUE AT THE TOWN HALL. AT THE TIME OF THE UDP THERE WERE PERMANENT DISPLAYS IN 3 TOWN CENTRE LOCATIONS.

“Send letters and emails to database contacts, including targeted consultation letters for key community groups. The Council may consider more targeted consultation where residents may be more directly affected by proposals.” NOT DONE (NOT TO ME!)

“Advertise via social media on Facebook & Twitter.” NOT DONE. I’M HEAVILY INVOLVED ON FACEBOOK AND HAVE SEEN NOTHING FROM BURY OR GMCA ON THIS MATTER.

“Where possible, place articles in:”

“Local newspapers;”

“‘Planzine’ - the department’s e-newsletter sent to a database of contacts and”

“Using other online news sources as appropriate.”

“Use posters on notice boards in prominent locations including town centres, civic suites, markets, leisure centres and public open spaces.” NOT DONE. EVERYWHERE HAS BEEN CHECKED. THE COUNCIL HAS DONE NOTHING IN THIS REGARD. THE BURY LIBRARIAN WAS ASKED WHERE THE POSTER WAS ON GMSF. HE SAID THERE WAS NONE, BUT THAT THE GMSF STUFF WAS IN A BOX BEHIND HIM.

2.2This consultation is contrary to Bury Council's Statement of Community Involvement, and is clearly UNLAWFUL. http://www.bury.gov.uk/index.aspx?articleid=10738. Furthermore at least one officer at Bury has intentionally lied by writing to an official complainer stating that the council is in full compliance with the Statement. I expect that officer to be dismissed.

3Allocating a Site of Biological Importance to Housing is illegal, gross negligence on the part of Bury Planners.

3.1This is not just a deletion from the Greenbelt. It is placing a Site of Biological Importance (Cyrus Ainsworth Nurseries and Parkers Lodges) which LPAs are required to protect in the planning process by numerous Central Government instructions, into a housing allocation. It is illegal. The officers responsible for proposing this should be sacked. The National Planning Policy Framework states (Para 110) “In preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment. Plans should allocate land with the least environmental or amenity value”…..IT DOES NOT STATE PLANS SHOULD ALLOCATE TO HOUSING LAND WITH SITE OF BIOLOGICAL IMPORTANT STATUS, or indeed SPECIAL LANDSCAPE VALUE STATUS. The Walshaw Allocation is illegal. The NPPF also states (para 116) “Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest…..” There is no exceptional need for this housing, and whilst in the Greenbelt the SBI is safe BUT the housing allocation/greenbelt deletion will certainly lead to the destruction of the SBI to make it developable. We have seen that happen to Bury’s SBI’s on several occasions – Edgar’s Field (most recently), Spen Moor, Pilsworth Bleach Works, Chapelfield Lodges and Townside Fields and on Features of Ecological Value at Openshaw Fold.

4Religious offence and widespread outrage

4.1In doing what they have done the officers responsible have caused in me harm and offence to my religious sensibilities, and across the borough they have caused widespread distress and outrage. Bury has never before placed a Site of Biological Importance within a housing allocation and, with good fortune, the officers who did this will be dismissed and expelled from the profession. It is an offence to my religion to put wildlife and landscape in peril like this, and, as a religious outrage, the allocation should be withdrawn, and the responsible people removed from office. I have just as much right to make these claims as anyone else, from any religion.

5Greenbelt Status

5.1The allocation land has been assessed on behalf of AGMA as strong to moderate in terms of functionality as Greenbelt - “There is a strong sense of openness….The parcel plays a strong roll in checking the further sprawl of Tottington, Woolfold, Bury and Walshaw”.

5.2This area has been Greenbelt since the adoption of the Local Plans for Tottington and West Bury. It is strategic Greater Manchester Greenbelt allocated in the Greenbelt Subject Plan. The production of these plans involved a trade off – some land allocated to new housing; other land allocated to Greenbelt. The change of all this land to housing means contempt for the trade-off that was agreed at that time.

5.3The Greater Manchester Structure Plan was adopted after approval by the Secretary of State in March 19819, and was later reviewed and superseded by a later version in 1986. The main themes of the 1981 Structure Plan were: 1 Urban concentration; 2 Redirection of development to the inner core; 3 Maintenance of the regional centre (linked to the regeneration of the inner areas of Manchester and Salford); 4 Resource and amenity conservation. These themes are still vital today and seem equally vital to the Northern Powerhouse ideals. You cannot grow and make strong and beautiful what you are seeking to destroy and squander and neglect. The GM green belt was designed to complement these efforts to regenerate existing urban areas.

5.4The National Planning Policy Framework (NFFP) states (Para 79) “The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.” It goes on to state (Para 83) “Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.”

5.5The UDP revised the Greenbelt boundaries at the time of the UDP (c1995). There were minor adjustments, additions and deletions, and the creation of a new strategic employment site at Bury Ground, which was removed from the Greenbelt. Bury Ground is still mostly empty 22 years later, with only the relocated Fire Station and police Station which their original bases are rotting in the town centre, standing derelict eyesores. This is what strategic removals from the greenbelt did to our town. Stole a country park and added dereliction. So are Bury planners fit to make such decisions like this again? I think not.

5.6There are no exceptional circumstances here. Bury MBC can meet its actual housing requirements using existing land supply without affecting the Greenbelt. The GMSF Policy on Greenbelt states the ‘Green Belt will be afforded strong protection in accordance with the National Planning Policy Framework.’ The only th