Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination...

51
Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To: Planning.Policy Mr D & I O'Malley, Re :Cowling Farm Gypsy And Traveller Preferred Option• Dear Sir /Madam, having resided in the cowling area for over 10 years we are concerned with the lack of consultation and information with regards to the proposed site for the Gypsy and Traveller community. Having moved to the Cowling area for the picturesque views, quiet location and community environment we feel that this is now under threat and therefore we object to the Chorley Planning proposal to use Cowling Farm as their preferred site for the Gypsy /Traveller community for the following reasons: Although several sites have been identified, Chorley planning report appears to be biased towards the Cowling site compared to other sites and we feel that the assessments completed on all sites are not up to date information in relation to bus service, education, traffic and also conflictions in relation to green belt. We strongly recommend that Chorley planning review there processes and procedures and look to sites more suitable for the Gypsy /Travelling community on existing brown field sites and or more accessible sites with nearby facilities that fit the criteria. Yours sincerely D & I O'Malley

Transcript of Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination...

Page 1: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

Ib3~7tgl

Katherine Howarth

From:

Sent: 15 July 2014 21:11

To: Planning.Policy

Mr D & I O'Malley,

Re :Cowling Farm Gypsy

And Traveller Preferred

Option•

Dear Sir/Madam,

having resided in the cowling area for over 10 years we are concerned with the

lack of consultation and information with regards to the proposed site for the Gypsy and Traveller

community. Having moved to the Cowling area for the picturesque views, quiet location and

community environment we feel that this is now under threat and therefore we object to the

Chorley Planning proposal to use Cowling Farm as their preferred site for the Gypsy/Traveller

community for the following reasons:

Although several sites have been identified, Chorley planning report appears to be biased

towards the Cowling site compared to other sites and we feel that the assessments completed on

all sites are not up to date information in relation to bus service, education, traffic and also

conflictions in relation to green belt.

We strongly recommend that Chorley planning review there processes and procedures and look to

sites more suitable for the Gypsy/Travelling community on existing brown field sites and or more

accessible sites with nearby facilities that fit the criteria.

Yours sincerely

D & I O'Malley

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Katherine Howarth

From:

Sent: 151u1y 2014 22:17

To: Planning.Policy

Subject: Gypsy, Traveller &Travelling Show People Preferred Options Documen

Hello,

Please see my comments regarding the potential Gypsy, Traveller &Travelling Show People Preferred

Options Document and the Yarrow Bridge, Bolton Road, Chorley PR7 4AB.

believe the Bolton Road Site is unsuitable for the following reasons:-

1. A bus stop is located directly in front of the entrance to the site. This will cause issues regarding traffic if a

bus is blocking the entrance and a vehicle is turning into the site. Due to the increase in house building in the

area the traffic has considerably increased during peak hours it is not uncommon for traffic to be backed up

from Chorley or from Heath Charnock so any additional traffic will have an adverse effect.

Due to the bus stop also being located near two schools it could increase the possibility of an accident as the

site access will be in use at all times.

2. The site is on Green Belt land which should be preserved as per Government guidelines.

3. There has been three large housing developments off Little Carr Lane, Pilling Lane &off Myles Standish

Way. This has increased the demand on local services especially the primary schools which are already over

subscribed.

4. Due to the sites location to the river further developments could increase the possibility of flooding

hope you take my comments into consideration.

Kind Regards

David Byrne

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1~5C~ Tt$3

Katherine Howarth

From: Graeme Wright <

Sent: 15 July 2014 22:52

To: Planning.Policy

Subject: Objections to Travellers site @Crosse Hall Lane

would ask for the following are taken into consideration for the proposed travellers site at Crosse Hall

Lane.

1. This land is actually on Howarth Road rather than Crosse Hall Lane.

2. The land is almost half the size of the stated minimum size required (0.4 hectares), and would

require a second site in order to meet the minimum 5 households - at additional cost to the council

tax payer.

3. The site would not be in-keeping with the Iocal street scene, and would be visible from the road.

4. Should this site be used, it would not allow any future expansion of St James' Primary School, which

understand is nearing over capacity - as schools are not allowed to build on their playing fields.

5. The road is very busy - especially at school time, causing a danger to pedestrians and other road

users. This additional building will increase traffic volume.

6. The cost of this site is prohibitively expensive, in comparison to the preferred Cowling Farm site.

7. The consultation has not taken place in a fair manner to existing residents living in surrounding

areas to proposed sites. Residents have not been informed directly by letter. One article has

appeared in local press, and the planning documents have not been placed in a prominent position

on the council website. This has limited our opportunity to investigate our options and legal

position, and to respond within the allotted consultation period.

8. The site is located on an unadopted road - it is therefore not in control of the council, and it being

maintained at the cost of the local Morris homes development. This additional traffic will cause

wear and tear (especially given the size and weight of a large caravan. The expense of repairs

would be borne by local Morris homes residents until such a time as the Council is in a position to

adopt the road. As residents, we have no control over this travellers' development, and the type of

vehicles that will be used on the site. In addition, this road is not gritted and therefore is likely to

be unsafe in winter conditions, for private cars, let alone large caravans and mobile homes.

9. The existing Rivington View site has only one access road (Howarth Road), leading to circa 200

homes. Should this be blocked for any reason, this causes a real safety problem, given the size of

the vehicles which could use the road. We have particular concerns regarding access for emergency

and refuse vehicles.

10. The palisade fencing will not screen the proposed travellers' development from view. Given that

this would be a highly visible site from the road, it would be not in keeping with the local

surroundings and street scene.

Many thanks

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i bb

G~('1$ ~-

Katherine Howarth

From: BURTON MACLEOD

Sent: 15 July 2014 22:47

To: Planning.Policy

Subject: Chorley local plan - Gypsy, traveller Preferred Options

I would like to oppose the planned consideration of using the Former Depot at Yarrow Bridge,

Bolton Road, Chorley PR7 4AB on the grounds that the proposed site is within the Greenbelt and is

in an area of natural beauty and wildlife. The erection or allowance of any habitation would put this a

risk and would not be in keeping with the local area.

I would also like to object on the grounds of the increased disruption that this site would cause to one

of the main arterial routes into Chorley. The new lights at Myles Standish Way have already created

traffic flow problems particularly at rush hour, and should this site be selected together with the road

widening and carriageway crossings being suggested by the highways agency it would compound the

problem and adversely affect the traffic flow. Coupled with this, having a site entrance in close

proximity to a bus stop, given the size of the vehicles entering the site, would create a hazard to

anyone alighting the bus at this location.

I believe that on these grounds this site should be removed from the list of proposed locations.

Kind regards

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1 ~ ̀l

4'T~gSKatherine Howarth

From: Heather Laughton

Sent: 15 July 2014 23:04

To: Planning.Policy

Subject: Objection to proposed permanent gypsy and traveller site on Cross Hall

Lane, chorley.

Dear sir/ madam,

am a resident of the rivington view estate chorley. It has recently come to my attention that there are a

number of proposed gypsy /traveller sites in my local area.

am therefore emailing you to express my objection to the proposed permeant gypsy and traveller site on

cross hall lane, chorley for the following reasons:

the site does not appear to provide the required size to support the gypsy /traveller community as

requested e.g. Regarding accommodating size of pitches /trailers; the site is attached directly to a school

preventing expansion requirements considering the increase of potential attendees from the rivington view

estate; road safety may bean issue considering the access road is currently unadopted, especially at peak

times when parents drop /pick up children from school.

believe that the alternative proposed sites provide more satisfactory accommodation than the one on cross

hall lane e.g. Cabbage hall fields, cowling farm and yarrow bridge depot (if removed from the Green Belt)

and should therefore be considered for development.

Kind regards,

Sent from my iPad

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Chorley Local Plan 2012-2026~~~~~~~Gypsy and Traveller and Travelling Showpeople

Preferred Options (June 2014)C o u n c~ 1

Ref Number:

Representation Form G TI$(~Official use only

4 JUNE to 16 JULY 2014

Chorley Council is seeking comments on the Council's preferred location for the provision of a minimum of 5 permanent Gypsy

and Traveller pitches (Chorley Local Plan 2012-2026). The Council has also considered and discounted a number of

alternative sites and welcomes views on these. A Schedule of Proposed Further Modifications which includes a proposed

policy on Gypsy and Traveller and Travelling Shopwpeople (Policy HS11) to the Local Plan has also been produced.

This consultation is intended to invite comments on the sites (and whether the document is a) legally compliant and b) sound.

Further guidance on this is provided at the back of this form).

The Council is not inviting views on whether this proposed allocation is sufficient to meet the permanent and transits needs of

the Gypsy, Traveller and Travelling Showpeople Community as this issue is being considered in a separate Development Plan

Document (DPD —taken fornrard December 2014).

If you have any views on the Preferred Options document, please use this form. Copies of the Preferred Options document

along with all accompanying information can be viewed at:

■ The Council's website www.chorlev.gov.uk/planninq

■ Local libraries and Post Offices in villages without a library (paper copies). The documents are available for inspection

during normal opening hours. The times of opening can be viewed on the Council's website_

■ Chorley Council Offices at Union Street, Chorley —open Monday to Friday 8.45am — 5.00pm.

Please complete this form and email it to planning.poticvCa~chorlev.gov.uk or post to Planning Policy, Civic Offices, Union

Street, Chortey, PR7 tAL.

For more information please call: 01257 515151

Please note the deadline for responses to be received is 16 July 2014, by 5pm at the latest. If responses are

received after this deadline unfortunately they will not be considered. Please allow for postage delivery times.

Please note that your comments cannot be treated as confidential (see below).

Data Protection StatementThe information you provide will be held and used by Chorley Council, in accordance with the Data Protection Act 1998, to help

in the preparation of the Local Plan. Please note that all responses received will be available for public inspection and wi II be

placed on the Council's website. This will include your name but the remainder of your personal details will remain

confidential. Anonymous representations will not be accepted.

Inappropriate, offensive or racist comments will not be accepted.

Thank you for taking the time to complete this form

Please fill in your details below, or if an Agent has been appointed, their details.

Tick as appropriate (~): Personal Details [~j Agent Details ~

Title Mr

First Name Paul

Last Name Walton

Organisation(where relevant)

PWA Planning

Job Title/Position

Director

Address Line 1

Address Line 2 ~~~

Town ~■~~ Telephone number

Post Code a~~ Email address

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This consultation seeks views on the suitability of sites and not the principle of

allocating sites. Please fill in your comments below. Please use a separate

form if you wish to make comments on more than one site.

To which part of the Preferred Options document does this representation re{ate? (please state)

Site Ref No/ Cowling Farm Paragraph Number

Location

FurtherProposedModificationNumber

1. Do you have any evidence or information about this site which will help the Council to

demonstrate that this site is available, suitable and achievable for Gypsy provision?

See attached document.

2. Do you agree that the Council's preferred site at Cowling Farm should be taken forward as

a formal allocation?

Yes ~

No ~

3. Do you have any other comments on the Preferred Options document?

See attached document.

Please use a separate sheet if required but indicate Site Reference No/Location.

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4. Do you consider the Preferred Options document is: (please tick one box only per

representation)?

(1) Legally Compliant Yes ~ No 0

(2) Sound* Yes ~ No ~

*The considerations in relation to the Local Plan being ̀ Sound' are explained in the

National Planning Policy Framework in paragraph 782.

5. Do you consider the Preferred Options document is unsound because it is not: (please

tick box one box only per representation)? Explanations of these terms can be found in the Guidance

IVotP_s.

(1) Positively prepared ~

(2) Justified 0

(3) Effective ~

(4) Consistent with national policy ~

6. Please give details of why you consider the Preferred Options document is not legal)

compliant or is unsound. Please be as precise as possible. If you wish to support the lega

compliance or soundness of the Preferred Options document, please also use this box to se

out your comments.

See attached document.

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7. Please set out what changes) you consider necessary to make the Preferred Options

document legally compliant or sound, having regard to the test you have identified above

where this relates to soundness. You will need to say why this change will make the

Preferred Options document legally compliant or sound. It will be helpful if you are able to

put forward your suggested revised wording of any policy or text. Please be as precise as

possible.

Please note your representation should cover succinctly all the information, evidence and

supporting information necessary to support /justify the representation and fhe suggested

change. After this stage, further submissions will only be at the request of the Inspector, based

on the matters and issues she identifies for examination.

See attached document.

8. If your representation is seeking a change, would you like to participate at the oral part of

the independent examination due to take place on 23 and 24 September 2Q14? (please tick

box).

No, I do not wish to participate at the oral examination 0

Yes, I do wish to participate at the oral examination ~

9. If you wish to participate at the oral part of the independent examination, please ou#Fine

why you consider this to be necessary:

Please note the Inspector will determine the most appropriate procedure to adopt to hear

those who have indicated that they wish to participate at the oral part of the examination.

It is essential that we are able to participate at the examination to :-

(i) ensure that the views of interested parties are properly represented to the Inspector;

(ii) ensure that we have adequate opportunity to question the LPA's assumptions in arriving

at their preferred option site;

Signature:

Date: 15/07/2014

Chrley~oU~~~~

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Chorley Local Plan 2012 — 2026

Gypsy and Traveller and Travelling

Showpeopie Preferred Options -June 2014

Representations on behalf of

Moorland Gate Business Park and Cowling Action Group

July 2014

P4VA_34_079_06J01

RTPI

PacE Viaitan dssxiates and PWA Ftanrin~ are trzGing names of Paut Wal:on Associates Ltd, a company registered in England ;na. 8605106)

Ribble Saw Mill

Paley Road

Preston PR1 8LT

01772 369 669

01772 887 022

[email protected]

www. pwa pla n n ing.co.0 k

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Chorley Local Plan 2012 — 2026

Gypsy and Traveller and Trevelling Showpeople Preferred Options (June 2014)

1. BACKGROUND

1.1 PWA Planning is retained to advise the owners of Moorland Gate Business Park and the Cowling

Action Group and in particular to submit representations to the Chorley local Plan 2012-2026

'Gypsy and Traveller and Travelling Showpeople Preferred Options' document dated June 2014.

1.2 Our clients have requested PWA Planning to prepare a summary document to consider the

manner in which Chorley Borough Council (CBC) has concluded that, of the various sites

considered within the 'Gypsy and Traveller and Travelling Showpeople Preferred Options' (GTTSP)

report, the Cowling Farm site is the Preferred Option.

1.3 The following report identifies why we believe that CBC have incorrectly undertaken the site

comparison in the GTTSP; have rejected site for inappropriate reasons and consequently have

made the wrong choice of preferred option. We ask the Inspector to therefore conclude that this

element of the Chorley Local Plan (CLP) is unsound. .

NATIONAL PLANNING POLICY FRAMEWORK (NPPF): EXAMINING LOCAL PLANS

1.4 The following is an extract from the'Communities and Local Government: National Planning Policy

Framework — Examining Loca! Plans':

"The Local Plan will be examined by an independent inspector whose role is to assess- whether the

plan has been prepared in accordance with the Duty to Cooperate, legal and procedural

requirements, and whether it is sound. A local planning authority should submit a plan for

examination which it considers is 'sound'— namely that it is:

• Positively prepared —the plan should be prepared based on a strategy which seeks to

meet objectively assessed development and infrastructure requirements, including unmet

requirements from neighbouring authorities where it is reasonable to do so and

consistent with achieving sustainable development;

• Justified —the plan should be the most appropriate strategy, when considered against

the reasonable alternatives, based on proportionate evidence;

• Effective —the plan should be deliverable over its period and based on effective joint

working on cross boundary strategic priorities; and

• Consistent with national policy —the plan should enable the delivery of sustainable

development in accordance with the policies in the Framework."

1.5 This report will demonstrate that CBC have not undertaken the GTTSP Preferred Options Plan in a

manner consistent with the requirements of the NPPF. The assessment therefore does not comply

with national policy guidelines and hence the plan is considered to be unsound.

Page ~ 1

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Chorley Local Plan 2012 — 2026

Gypsy and Traveller and Travelling Showpeople Preferred Options (June 2014)

2 FACTORS WHICH CONTRIBUTE TOWARD THE PLAN BEING CONSIDERED UNSOUND

2.1 The paragraphs below describe how it is considered that the Preferred Options document does

not comply with the NPPF (as detailed above) leading to the Preferred Options document being

'unsound';

Positively Prepared

2.2 It is considered that there has been a distinct lack of adequate consultation with the settled, and

indeed the traveller, community and certainly a lack of meaningful public engagement prior to and

during the selection and recommendation of a Preferred Option. Despite the commentary within

the Regulation 22 (1)(c) report, it is clear that adequate prior consultation, particularly with the

settled community, has not occurred. The Statement of Consultation Supplement Paragraphs 1.2 —

1.5 makes it clear that there has been no previous engagement or informal consultation with the

settled community on the issue of a specific land use allocation to meet the needs of the gypsy

and travelling community. All references within the statement of consultation relate to the much

earlier call for sites, which occurred from 2005 — 2010 and which were simply requests for

potential site allocations. None of these ̀ consultation' period actually tackled directly the issue of

allocations to meet the needs of the gypsy and traveller community. Accordingly it is not surprising

that large sections of the settled community were surprised to learn of a 'preferred' option having

been determined, given that they were not even aware that there were any options being

considered.

2.3 It is considered that this lack of adequate engagement with interested parties, renders the

preferred options document inconsistent with the requirements of the NPPF, and hence unsound.

2.4 Moreover there are a number of gaps in the information provided in the GTfSP, which appear to

be because the authors of the report have not had adequate time to compile or simply do not

have the information; have made assumptions which are not supported by evidence, or the

evidence is not in the public domain. By failing to substantiate assumptions or facts which have

influenced the choice of a preferred option, the Council have failed to prepare the plan positively.

It seems evident that there has been a lack of rigorous assessment of contributory factors that

would impact the selection of a Preferred Option. For example there is yet to be a full assessment

of the highway authority and other statutory undertaker's concerns regarding the Cowling Farm

and other sites, with ̀ comments awaited' on many of the considered sites. This suggests that the

plan has been prepared in haste, without full knowledge of the impacts and effects of particular

proposals on particular sites. This lack of up to date information and evidence reinforces the fact

that the plan has not been ̀ Positively Prepared' and hence is unsound.

Justified

2.5 It is considered that the manner in which CBC have assessed the alternative sites is flawed, both in

terms of the assessment criteria used and more particularly the manner in which the preferred

option has been chosen.

2.6 The Council have used a relatively 'standard' Sustainability Appraisal (SA), which of itself is clearly

better suited to assess potential housing or similar allocations, as opposed to potential sites for

Gypsy and Travellers. A number of the sustainability criteria are not particularly relevant to an

objective assessment of a site's suitability to provide a sustainable site for gypsy and traveller

Page ~ 2

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Chorley Local Plan 2012-2026

Gypsy and Traveller and Travelling Showpeople Preferred Options (June 2014)

communities, who tend to have different needs as outlined in the Planning Policy for Traveller

Sites (PPTS). The Council seem to acknowledge this fact within the preferred options document,

but it is not at all clear how the sustainability appraisal has been weighted or scored. It is

considered that a more appropriate set of assessment criteria would demonstrate more clearly

that sites other than Cowling Farm are most suited to such an allocation.

2.7 Even accepting the criteria chosen, and without any clear understanding of how the Council have

weighted the various criteria and hence arrived at the ranking that flows from this scoring, it

seems apparent that the Council have arrived at the wrong choice of site. The table reproduced at

APPENDIX 1 to this statement provides a comparison of the preferred options site against three

alternative sites, each of which we believe outperform the preferred option by some considerable

margin, using the Council's own criteria.

2.8 It can be seen that by reference to the Council's own sustainability matrix that each of the three

alternative sites indicated outperform the Cowling Farm site by a considerable margin. Indeed the

Cabbage Hall Fields site scores significantly better than Cowling Farm and it is therefore extremely

surprising to note that the Council have identified all of these sites within the same "sustainability

appraisal banding". It seems quite clear that, if the Cowling Farm site is banded "B" then the

Yarrow Bridge site and certainly the Cabbage Hall Fields site should be banded as "A" if the scoring

is to have any meaning. Of course such a differential banding would not then support the Council's

preferred option. Ultimately regardless of the banding, it is clear that the sustainability appraisal

does not in fact support the Council's choice of preferred option and that the Ackhurst Road,

Yarrow Bridge and in particular the Cabbage Hall Fields site should be ranked above the current

preferred option.

2.9 Turning then to the Council's site ranking assessment, which appears to incorporate the

sustainability appraisal, reproduced at Pages 10-14 of the report, there continues to be a distinct

lack of transparency and indeed logic in so far as the criteria which have resulted in the Council's

choice of preferred option. Again by comparison to the other sites previously referenced (all of

which are set out a pages 10 & 11 of the report), each of the sites are identified as being of

sufficient scale to accommodate the intended use and each is said to be potentially a candidate for

HCA funding. In terms of estimated costs, the Cowling Farm site is marginally the most expensive

with the Cabbage Hall Fields and in particular the Ackhurst Road sites being markedly less

expensive to develop.

2.10 The Yarrow Bridge site is marked down by the Council due to its location within the Green Belt and

moreover its location outside of the key service centre. It is not entirely clear that being located

within the key service centre, as opposed to being close to key services, is a key criteria. Indeed

the Council acknowledge that the relevance of being located in such urban locations is in fact the

proximity and availability of services. To this end, it is clear that in sustainability terms, the Yarrow

Bridge site outperforms the Cowling Farm site and is better located in relation to the range of

services and facilities. Accordingly it seems entirely inappropriate to reject or mark down the site

due to its location outside of the urban boundary. Moreover the Council appear to have argued

that the Yarrow Bridge site is unsuited to an allocation due to its location within the Green Belt.

Again this argument seems to contradict various other indications within the Council's preferred

option document as well as the national guidance. Such guidance acknowledges that the plan

making process is the correct time to consider making an exceptional alteration to the Green Belt,

Page ~ 3

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Charley Lotal Plan 2012 — 2026

Gypsy and Traveller and Trevelling Showpeople Preferred Options (June 2014)

so as to exclude the proposed gypsy site from the Green Belt. Furthermore whilst national

guidance makes it clear that gypsy sites are inappropriate uses within the Green Belt, the fact that

the site is acknowledged to be previously developed means that the site ought to be considered

against Paragraph 89 of NPPF, which permits ...

"limited infilling or the partial or complete redevelopment of previously developed sites (brownfield

IandJ, whether redundant or in continuing use (excluding temporary buildings), which would not

have a greater impact on the openness of the Green Belt and the purpose of including land within it

than the existing development".

This exception criteria must apply equally to gypsy sites as it would for housing or other

commercial uses (all of which are equally inappropriate uses in the Green Belt), provided the

impact is no greater than the existing. It does therefore appear that the Green Belt argument is

somewhat erroneous and that, either by way of specific exclusion of the site from the Green Belt

or through redevelopment in accordance with NPPF Paragraph 89, there should be no reason to

preclude the consideration of the Yarrow Bridge site due to its Green Belt location.

2.11 Similarly in the case of the Ackhurst Road site, the Council appear to have marked down the site

simply on the basis that it provides existing car parking to a number of local businesses. It is not

considered that this is a substantive reason to reject this site, as the impact of the loss of parking

will not be significant if alternative parking can be provided. It does however indicate that there

may be some delivery issues with this site, given that there is a long lease to a third party which

could preclude its development in the short term. The site does however perform reasonably well

in all other respects and could provide a very adequate reserve site.

2.12 Taking into account the above matters it seems that by any logical assessment of the evidence, the

sites should be ranked differently to that produced by the Council. The table below reproduces the

Council's table on Page 10 of the preferred options document, but revises and re-orders the

ranking and hence the preferred option based on an objective assessment of the criteria and

taking account of the comments raised above.

SITE Location Area Capacity Conformity with Core Sustainability HCA Funding Ownership Estimated

RANK (Ha) Strategy Banding Cost

1 Cabbage 0.6 5+ Policy 1 —In confarmity A Potentia€ly Charley fA84,000

Hall with poEicy, wifhin Key Council

Fields Service Centre of

Charley Town (triterion

b)

Policy 8 —all of criteria

could be satisfied.

2 Ackhurst 0.49 S+ Policy 1— Inconformity with B Potentially Charley E440,000

Road policy, within Key Service Council

Centre of Charley Town

(criterion b)

Policy 8 —The site does not

have very good access to a

number of services under

criterion (a~.

3 Yarrow 0.63 S+ Policy 1— Outside urban B Potentially Charley E550,000

Bridge boundary but well located Council

Depot, in relation to Key Service

Charley Centre of Charley Town.

Brownfield site within

Green Belt.

Policy 8—All of the criteria

could be satisfied

Page ~ 4

Page 15: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

Chorfey Local Plan 2012 — 2026

Gypsy and Traveller and Travelling Showpeople Preferred Options (June 2014)

4 Cowling 9.5 5+ Policy 1— Inconformity with B Potentially Charley E560,000

Farm, policy, within Key Service Council

Charley Centre of Charley Town

(criterion b)

Polity 8 -All of the criteria

could be satisfied

Table showing revised site ranking.

2.13 Based on the Council's own evidence, without adjustment, it is clear that the preferred option site

should clearly be Cabbage Hall Fields, followed by Ackhurst Road, with Cowling Farm at least

fourth ranked or worst. When adjustments are introduced to properly reflect the sustainability

scoring of Cabbage Hall Fields in particular, as well as using a more reasonable assessment of the

need for the site to fall within the urban area, the preferred option and the second choice

(reserve) site become even more apparent.

2.14 Taking all of the above into account, it is clear that the Council have failed to identify the correct

site as the preferred option and hence that the plan does not represent the "most appropriate

stratepY when considered against the reasonable alternatives" and hence that the plan is unsound

for this reason.

Effective

2.15 Delivery is a key issue in terms of the identification of any land use allocation, in particular the

allocation of a gypsy and traveller site allocation. Where there are known constraints to

development, these should be identified. In this respect it is understood that there are specific

issues associated with the Cowling Farm site, whereby the proposed access, which itself is

proposed to include land within the Green Belt, is subject to restrictive covenants which would

preclude its use to provide a means of access to the wider site. Furthermore based on the

response from the highway authority, there is some considerable doubt about the delivery of a

safe and convenient means of access to the Cowling Farm site. Pages 17 and 18 of the GTTSP

identifies a possible objection to the proposal to develop Cowling Farm from Lancashire County

Council (LCC) Highways. It is stated that in respect of Cowling Brow ...

"there have been no less than 10 recorded slight personal injury traffic accidents in the past 5

years at different locations of its length. Two of these accidents were recorded as serious.

"if the accident review cannot be undertaken and the additional safety measures implemented

then, Highways would seek io object to the proposed site".

2.16 Evidently there is some considerable doubt as to the delivery of a safe. and convenient access from

Cowling Brow and the impact any development would have on the local and strategic highway

network. This itself casts further doubt on the decision to identify Cowling Farm as a preferred

option, particulary as such constraints to delivery (by way of access) do not affect the Cabbage Hall

Fields site, where it is stated that "there are no highway objections".

Z.17 It therefore considered that the decision to identify Cowling Farm as the preferred option will not

render the plan effective as there is considerable doubt about the delivery of the scheme and such

doubts do not affect other sites, particularly those which, in our opinion, out-perform the

Council's preferred option site. For this additional reason, the plan is considered to be unsound.

Page ~ 5

Page 16: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

Chorley local Plan 2012 — 2026

Gypsy and Traveller and Travelling Showpeople Preferred Options (June 2014)

3 SUMMARY AND SUGGESTED AMENDMENTS

3.1 In summary and for the reasons identified in the body of this response, it is considered that the

GTTSP fails the tests of soundness on a number of grounds due to considerable flaws in the

evidence base and more particularly in the choice of preferred option for the identification of a

gypsy and traveller site.

3.2 In particular it has been demonstrated that the plan :-

(i) not been "positively prepared", as it has not been subject of appropriate community

engagement and there are significant gaps in the evidence base;

(ii) is not justified, as it is plainly not the most appropriate strategy when considered against

the reasonable alternatives;

(iii) is not effective, in that there are considerable doubts about the delivery of the preferred

strategy, which do not affect other alternatives.

3.3 It is therefore considered that the plan is unsound.

3.4 It is recommended and suggested that the Council review and reconsider the preferred option as

set out in the GTTSP and identify the most appropriate site, based on a more thorough and

rigorous evidence based assessment. We consider that there is one site which is clearly the most

suitable site and which outperforms the others -the Cabbage Hall Fields site. This site should be

identified as the most suitable option and a further round of consultation should be undertaken

based on this proposal.

Page ~ 6

Page 17: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

Chorley Lo

cal Plan 2012 — 2026

Gypsy and Tra

vell

er and Travelling Showpeople Preferred Options (Ju

ne 2014)

S.A Obj

Indicator

Cowl

ing Farm (CF

)

Distance to ra

ilwa

y st

atio

n1.

61 to 2.4km

Rail

ser

vice

fre

quen

cy

Distance to near

est bu

s st

op

Bus se

rvic

e frequency

Dist

ance

to se

rvic

e centre

0.81 to 1.6km

Distance to A Road jun

ctio

n0.

81 to 1.6km

51

Distance to motorway jun

ctio

nOv

er 3km

Distance to supermarket

0.81 to 1.6km

Distance to convenience store

0.41

to 0.

8km

Distance to Post Office

~ ~~,~~,~~~„~~,~, ~

0.41

to 0.8km

Distance to Primary Sc

hool

Distance to Secondary Sc

hool

0.81

to 1.6km

S2

On a cycle rou

teNo

Distance to cycle route

Distance to GP sur

gery

2.1 to

5km

Distance to NH5 gen

eral

hospital

Distance to pu

blic open spa

ce/park

, . ~

, __

`l1p

to " km'

Dist

ance

to lo

cal centre

1.2~

. Go~~:.6km

Desi

gnat

ion of

lan

d_~ Key Servfce:Cni +re

Area

of Separation

Outs

ide

AONB

- -

- Ou

ksid

e T

Outs

ide

SS51

Biological/ Geological Heritage Site

~ Ou

tsid

e T

Agricultural cla

ssif

icat

ion~

Grade 3

APPENDIX 1

Yarrow Bri

dge (YB)

0.81 to 1.6km

0.81 to 1.6km

R~'~

V`~ $

4~KY

L1;

Over

3km

0.81 to 1.6km

0.81 to 1.6km

? 1 to 5km

u~., t~~

0 4km

0.81 to 1.2km

.~.~

Qut>

ide

~' Outs

ide

Outs

ide

QULSIC~~

Grade 3

Cabbage Hal

l Fi

elds

(CHF)

0.81 to 1.6km

2-5/hour /direction

0.81 to 1.6km

0.41

to O.8km

0.41 to 0.8km

0.41 to 0.8km

0.41 to 0.8km

,~~'~~,

~{~<~

~ ~J~

~~4

_.~ __

.0.81 to 1.6km ~~

~

0.41

to 0.8km

~~1)pto(7.4krri

0.4"

I to 0 Skm

Kcy Service ~er~tr~~

__.__----Qu

tsi~

I;~ --

........

..

Uutside

O;itside

__._

___ Gu

rsid

e ~---

~~!o~e

Ackh

urst

Road (ARj

Highest scoring

1.61

to 2.4km

YB/CHF

1.61

to 2.4km

0.41

to O.Skm

Over3km

0.41

to O.Skm

0.81

to 1,6km

0.81

to 1.6km

No

2~tokm

~ Ip '; O.

~±~~r.

1 ?,

i t:

C. ~..6K(Yt

5cry

~ (~ ~ r

~~

it~t~[sic~et

_.

:.),

Sl_I

GL_

__ __

.. __

.:

.CS JC

~,

YB

CF/YB/CHF

YB

CHF

CHF / AR

YB

CHF

YB/CHF

YB

CHF

CHF

CHF

CHF

CF/CHF/AR

CHF

Page 18: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

Chor

ley Lo

cal Plan 2012 — 2026

Gyps

y and Traveller and Travelling Sh

owpe

ople

Pre

ferr

ed Opt

ions

(June 20:14)

APPENDIX 1

High

est sc

orin

g

SA Obj

Indicator

Cowling Farm (CF)

Yarrow Bri

dge (YB)

Cabbage Hal

l Fi

elds

(CHF)

Ackhurst Road (AR)

site

Conservation Are

a~~"

~u` do

(~Eit7~ci

Outs

ide

~Qt.tside

=

Ancient Monument on sit

e~

~U

~r~

t~~`

6

EN2

Registered Park or Garden

~~ a s

:r':~

~Ci

utsF

drC}

utsi

dr

~,_

~u~5

1 ~~

_

~~

List

ed Building on site

:.__

__.

......

_..~

__..

_._

i._._

..._..

h~o

. _.

._.m

____

_.~

.._~_

_.._..

._y.

_.. ___.

No

_...__

..... _

~

....

...

~~

-- _ .

_...._..

__-' _.__...

_.---

'~-- ---- -

---

(

~`~,

c':i

I- ----1-_

~

_Nd

Nr~

__--~—

_ ...

N~

_ _ ____ .~

._ _ __

.__ _

._w:

Loca

lly Li

sted

Building on sit

e

EN3

Curr

ent/

form

er land us

ePart Brownfield/Part Gre

enfi

eld

Gr~.ent'ieid

L~rau~ i~"~

IU~

AR

EN4

Flood Zone are

a

Contaminated land

~.

,.t~~~

~~. "-

Nc>

!sK

Part Zone 2

Medium Risk

~.

~1l(

,~p~

~ 1

h ~~

aF.,

Medium nsk

F~II

Z?ne 1

Z~ltdlum i

isk

CF/CHF/AR

CF

.

ENS--

With

in 3km of a co

nges

tion

spo

t---

- --

~ es

lJ~,

cc u.

bkrn

_. _

-- ----;

~~ m~._

No

I 1 21 to 1 6km

--

__ _ _

--__

_~

Yes

i

Up to 0.8km

!__

..

~

_ ~.._.

No

U,~ to C).8km

_ _

_

~ YB/AR

CF/CHF/AR

Dist

ance

to employment sit

e

Acce

ss to Broadband

ECl---

~ 's

Yes

iYe

s ~

~ e

EC2

Dist

ance

to further/hi

gher

l.Gi ~o ~ ~I:m

Over'Skm

~L 61 to 3.2km

~lJp to ~.Gkm

AR

education

---

----

— _ ----

-.._

._ ..~_._._~_~._.~._

~_....

~.....

,~..~

.-

--

._

_ _

i_ -----

- __..

_._.

. _.

Acce

ss to sewer system

---

Ye ~

~Yes

Ves

_.

Yes.

~,o

Acce

ss to water

~

_._.

____

___.

___

_ ~

_~~~ ~

T~_,__~

—___~___—

Ye s

Yes

Yes

_'

Acce

ss to gas

Yes ~

Yes

~_.~._._ Yes

.. ____

~ _ _~~_.

~~E'

s

~ ~

Acce

ss to electricity

~__

~~E %~~-

_.___

Yes

~

Yes

Ye'

-

', YB/CHF/AR

Existing road ac

cess

~!~

'"Ye

sYes

___

___._

Yts

__ ._-

-- ~. _. _—

v_._

____ ~ .__.~_.__~.~

____

__~.

~vAt

ris

k from hazardous ins

tall

atio

ns~

.+lo

Nq

No

No

*entry adj

uste

d to bet

ter reflect st

atem

ents

in detailed appraisal

Key

Site

Number of in

dica

tors

uvh

ere site

sco

res tap or

joint top

(exc

ludi

ng those where all sit

es are

equ

al) (ou

t of

38)

CHF

Cabbage Hall Fields

15

YB

Yarr

ow Bridge

9

AR

Ackhurst Roa

d8

CFCowlin

g Farm

4

Page 19: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

i f~qG ► 1 ~~

Moorland Gate

Cowling Brow

Chorley

PR6 9EATel: 01257 226635

Fax: 01257 469309

11/07/2014

Chorley Local Plan 2012-2026

GYpsv and Traveller and Travelling Show people Site — Preferred Options June 2014

Cowling Farm

Dear Sirs

write on behalf of FDC Holdings Ltd to express my concerns from a Local Business perspective to

the proposed Gypsy, Traveller and Travelling Show People site in the Cowling area of Chorley.

FDC Holdings owns Moorland Gate Business Park immediately adjacent to the proposed site. The

feedback I am receiving from our Tenants on site is that if the proposed site does go ahead they will

o;±hoc o~f.,r~P rhP hrPak clause in their leases when they fall due or they will not renew the lease at

the end of the term, whichever comes first.

Whether this could be viewed as discriminatory I do not know, I have nothing against the travelling

community, I only know that this is what the Businesses on site are telling me — it is fact. It goes

without saying that this outcome would seriously damage our business resulting in some job losses

or worst-case scenario the business would cease trading altogether.

We have owned the Moorland Gate site for 10 years and have worked extremely hard to build a

successful business and attract other businesses to the area. The site currently has a very high

occupancy and the site employs in the region of Z00+ people. We have plans to expand the site in

the near future however this would now appear to be extremely unlikely as we feel we would not be

able to attract other businesses to our site.

All goods carried subject to RHA terms and conditions, and all goods stored subject to RHA storage conditions...— - .. .... .~.n inn D..,.;,. «...-...I :.. C..,.I.....J O.\A/.I.... /"'....____.. D__ n1_ ]'~'1~n1]i

Page 20: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

Clearly the mixing of Gypsy and Travellers in a mixed residential and business area will also have a

severe impact on both the Councils revenue for the sale of the prime land and the value of the

Moorland Gate site. This would severely affect FDC Holdings' future borrowings and ability to

expand the business. I fear that if the proposed site does go ahead it will be the beginning of the end

for Businesses in the Cowling area.

also attach letters from two independent Commercial Property Agents which confirm their fears

that Moorland Gate Business Park will no longer be able to attract new Tenants should the proposed

sit go ahead.

Yours Sincerely

_~

Stephen Allen

Director

Page 21: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

1)urlL.~i`. C'U13.(~11 ~hartcrad SurvercxsC'ert~mereial Pi~}x:ity Consultants

Yuur Kef

.•St~~~r Allen LaqFi~C' (Hulclin~st I_imiicd ~.-.__..._ __ __... ,..~4ati~i M2rtin (Lanes} Limited.

h1c~~rlancl <Tate Rusin~ss i'ark ~ ~' ".:s ..- t! ~,L ••~; ; .'._ iBurlinQton Hausc.

('E7~+ lin~> ltvacl ~ -- +_ }U- I ~ Ribb[e~dale Place.

C~'d~`.-_`.~~'(,.l`r.; _~~ ;Preston PRI 3tiA

C'4~~~riz~ ~ ~ r ~:.i' ; n.;

PKG NFE ~elephone: Q17'72 56

~ ; , ̀ '` ~ ~ ~ .~ ~ ~ ~ ~.a' ~ email: tnai. mure2nmaRin.cn.uk

_._........__..a~.,..E

I'~m~ Ste►°c ~ : .. _~'

CH()~I.E1' — ►7~wriancl (..ttC I~t1S1tItSS Par.Ic, Coss~lin~ l3rc~~~+

1 refer tt* ~iur r~eent ctiu:vs:ic~~~s re~~rc#i~~~ tl~~ prc~4~;rcl ~itin~~ ~~i' the ~~ ps~~ ~itr can thr acij~cent

C'E1~ lip_} f=au3.

Ai prr~,nt ~L~to~~rl~~AUf (ial: is.}~e►~~te:s H~ .~ si~ce~~stut titisines, I'~i-k ~~ith a cli~~r~c mi.~ c~(' hirsiii4s~;~x,:upyi~~~~ the iiyai~;. ,1s 1 t~izdrr,ia~~d. at ~re,rajt. tine site i, liilly.uceu{~ieti »itt~ a ~~7ucl demand I~i~r

unit; t~ hca: Lhe~ di► hc:ci~me ~.~cant.

From ~n~- e~periciu~ bu;i~~2s~;t~~ ire siiancwl~at \~i11'S t)I I(~tTtlll~~ ~3(I)T~CI1C Ell. i)1' CItaSC 1t~ ~*~'~5y ~}ill'k~,

~1'1t11E1~1~~ idle C4 ~tl'U►'lll' ISSItt'ti I~klt tITISC.

iirnil~ bc.lictic: that die ar~•i~at ot'~~ich si sits aclj.~cfitl t.~ ?11o~~rlantl f.iaEt' ~ti:i~ttld up~iuubtedt~ h~~e qua

adrrrc c~~IlCt ill IeYnis cs1~

• E;?~kSlill,! U~:~tt~1C1"5 ~iF1'i311{l~ Clll' SIIC BHt~ I'k'Il7l':111l1L c:~~C\t~121'l

s %allf3~1117L 8t[~i~ /Ki:U~tlll:ti (L) 1~1C f:CC

G~ nt} t~pitiioti uih a use ~i~i~ultl n~~t he Ii,catcd in an area such ;L: Coy;limy 13n~n ati ur4J~;i~btedl~ it

~~il1 nyean that ~•ou ~tiiU IkYV~ c1if~1'~tult4 Jintlipr ~~cupicrs tier v,,ui• sit< ~!uim~. tiar~v~irci~. 1 ~lottld.

tlurclore, reet~n3me»c~2d ti~at y.ou Irangh i>hje~t Ic.z the planninL ~}~}~(icFt~it~~~ t~iat is l~eii~~_ ubn~ittc:d.

Ye~urs >i~~eerel.

C I) 13e11

~.

. ;;f,; rl . /icrrlr ::; glft f(dg1qU3.1/Ai L r',.1i6

■\~~~

Page 22: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

eck~rs eC01'~'~r"i('rf~2.: )?'Opc•r$./ S~iEaYici'15F

Our Ref MAC/CF

Date 14 July 2014`~'>>~k~f ~: ,:j~~~ r ; _ . _ ;<;:~..=:r=;:]. S:.arki- ~t: ear' F ! ~ _ '7. 8^n75~12

~r.,5t~~~~ $ i. ~!Lc'r ~~r:r:gf=: C'y';~ _;~:..r:y t~:~:_.F

_7SI IGBSF.S'F

To Whom It May Concern~~~T-• ~~==~`t ~~ ~~ ~ y

Dear Sir/Madam

...._=..e _. __.- -- .. ..

-''~ ̀ ̀'

GYPSY AND TRAVELLER SITE PROPOSALS_ _ ._.............,_.. _- -.-.--..-.

MOORLAND GATE BUSINESS PARK, CHORLEY

refer to the proposals to locate a gypsy and traveller site on Cowling Farm off Cowling

Road adjacent to Moorland Gate Business Park.

The development which was previously occupied Scottish &Newcastle Breweries was

acquired by FDC Holdings to develop, refurbish and establish a secure and accessible

business park offering a mix of office, industrial and open storage accommodation in an

attractive, yet accessible, setting for local and regional businesses and in the process

creating a notable and now well established local employment site.

The business park has attracted numerous notable occupiers including Fedex, Carillion and

the Stagecoach Group along with local businesses in total employing in excess of 200 staff

many from the local community.

The business park has and continues to prove attractive within the commercial property

market place which is demonstrated by its high occupancy rate.

It goes without saying that such a development adjacent is expected to have a detrimental

impact upon market demand and may prejudice its sustainability as a thriving employment

hub and major employer within the general Chorley area.

~~--~- ~~--a ~ ~~~~~~~ ,yuyo ai~Aa~~ in~iir_.ata~1 that should such an adjacentVVe UCIICYC a iat Scvci of viv~,p.~ ~

development progress, it would be their intention to seek to relocate elsewhere; which is

obviously of great concern to the Landlords and could threaten the viability of the park and

their ongoing investment and expansion ambitions.

Yours faithfully

;r

Mark Clarkson MRICSEckersley

~r~ ~~~~,~..~7.v..-..~M_.w .~:xas.:%~~;a~r.>:at a~Ya~:alrtim Ei.hE.r.lN~•;f~F lyd.Fnkm:nkcF.r

,(:rrs~wpa~'i;C•a.:lY:rSa,~•;errC.E.x;~a~df •ii;I :i~I+::c~(~?7.';!%r.

x';HSx Nif ~ fY9H

Page 23: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

~~a~ T~$S

A. R. Yarwood, DipTP, MRTPI,Planning Officer

~~~Nauona1FPa~aho~° National Federation of Gypsy Liaison Groups

of GypsyLiaeon Groups Unit 3, Molyneux Business Park

.~ - Whitworth RoadMatlock,DE4 3HJ

01629732744

Planning Policy,Civic Offices,Union Street,Chorley,PR7 1 AL.

16 July 2014

Dear sirs,Gypsy and Traveller and Travelling Showpeople Preferred Options

comment on the above document on behalf of the National Federation of Gypsy

Liaison Groups. Whilst the plan may be legally compliant it is not sound and, in

our view, has not been positively prepared.

The consideration given to the sites listed in appendix 2, suggested by the

Traveller Community at Hut Lane is superficial and in stark contrast to those

selected for consideration. All the sites listed in appendix 2 which are in the

Green Belt are dismissed solely on the grounds of their location in the Green

Belt, yet several sites suggested by the Council within the Green Belt have been

given detailed consideration.

The dismissal of a site suggested by the Traveller Community at Hut Lane simply

because the Council could not be bothered to locate it also suggests a

discriminatory approach.

Site 9, with temporary permission at Hut Lane, should be allocated. It has too

easily been dismissed. The fact that it cannot easily accommodate 5 pitches

does not meet it cannot contribute to Traveller provision.

Yours faithfully,

A, n, yarwv6d

A. R. Yarwood,

The National Federation is a Company Limited by Guarantee registered in England and Wales. ~p

Company No: 6983027. Registered Charity No: 1136730 lC~~.SU i

Also funded by The Esmee Fairbairn Foundation ~"""T" " "̀R"

:~~~,.~.,~3v.,..~ ~ss,~.«,

Page 24: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

r~►G ~~$9

Katherine Howarth

From: Cllr Paul Walmsley

Sent: 16 July 2014 10:07

To: Planning.Policy

Cc: Cllr Beverley Murray; Cllr Alistair Bradley

Subject: Fwd: Former Depot at Yarrow Bridge

please not the comments from Mr Haslam

Cllr Paul Walmsley

Chorley South East Ward

Begin forwarded message:

From: Derek Haslam

Date: 15 July 2014 22:18:35 BST

To: <paul.walmsle~(a~chorle~ og v.uk>

Subject: Former Depot at Yarrow Bridge

Hello Paul, could you please forward my comments on the above as the allocated

form on Chorley BC website is ridiculously complicated. ie — in PDF format which

needs converting before its usable.

think the above site for a permanent Gypsy travellers home is unsuitable for the

following reasons:

1 It would be accessed by lorries etc to and from a very busy main road.

2 It is very close to two School playgrounds, one of which is used by small children

and on full view from the footpath.

3 It backs on to the River Yarrow which has been the subject of a major clean up in

recent years and inevitably there would be pollution from the site.

4 It would be next to one of our bigger residential Premier inns and would have an

adverse effect on economic growth and could in fact cause its demise.

Many thanks Paul, Derek Haslam,

Page 25: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

112GTIgO

Katherine Howarth

From: Jayne Gouldthorpe

Sent: 16 July 2014 10:31

To: Planning.Policy

Subject: Gypsy and Traveller Preferred Options Consultation

am writing with my concerns regarding the proposed permanent site fora 'traveller' site for travellers who

are going to be permanently resident.

As an aside comment: The format of your consultation is not accessible to all as you are expecting a pdf form

to be printed out, then completed and scanned in to email back to you. The pdf cannot be typed into and

not only do people not have these facilities the form is not easy to understand. I am therefore emailing my

comments.

My first point is that if people want to live permanently in an area then there is accommodation available to

rent or to buy. There seems to be a lot of money going to be used to create a gypsy and traveller site which

could be spent elsewhere.

Secondly, I do not think that greenfield sites should be used for this purpose. It is destroying the natural

beauty of places within Chorley and having an impact on the natural habitat and ecology of the area.

am writing with particular opposition to Site 2 Yarrow Bridge Depot. It is not a good location for a

permanent site for the following reasons:

It will have an adverse impact on the natural environment, there is a lot of wildlife in this area with deer,

foxes, badgers, herons, squirrels being seen there.

It is out of keeping for the area which consists of woods, Duxbury park, the canalside, the river etc, low

density housing, semi-rural.

The nearest primary school is a Church of England school which requires regular church attendance and is

always oversubscribed. Other primary schools are some distance away.

There has recently been a housing development (Arley Homes) which has put increased pressure on services

in the area including the school.

There are no shops nearby.

There is no GP surgery nearby.

There is no chemist nearby.

The entrance to the site is where there is an existing bus stop —this is an issue for safety.

The stretch of road here is particularly busy and the traffic lights created by the Myles Standish Road have

created bottlenecks at rush hour. Having large vehicles coming and going is going to be hazardous. It is a

known stretch for accidents and fatalities.

In the past the school (St Georges) has requested the services of a lollypop person to help people across the

road and this was refused. So why can money now be spent on crossings for 5 potential families?

The area has issues for flooding and creating a site could aggravate the drainage issues.

am not as familiar with the proposed site at Cowling Farm. However, some of the reasons (eg greenfield

site) I have used above are likely to apply to this proposed site and I do feel that there are probably more

suitable brownfield site which could be used if explored further.

hope that my comments can be taken into account even though I have not used your form.

Mrs Jayne Gouldthorpe

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1~3

CT19 !

Mr &Mrs Eckersley

Thursday 16th July 2014

Planning PolicyCivic OfficesUnion StreetChorleyLancashirePR7 1 AL

Re: Gypsy and Traveller and Travelling Showpeople Preferred Options June 2014

CC: Chorley Borough Council

Dear Sir or Madam,

I am writing this letter in respect of the Gypsy and Traveller and Travelling show people

preferred options (June 2013) document. The majority of the households oppose the proposed

"Crosse Hall Lane" site described in the Gypsy and Traveller and Travelling Showpeople

Preferred Options June 2014 report. The following arguments opposing this site have been

developed giving a strong and coherent reason for the site not being suitable.

Reasons for not adopting Crosse Hall Lane as a Gypsy and Traveller site

Design and Location of Gypsy and Traveller sites

The following information is taken from Central Lancashire's Joint LDF Officer Team

Report, dated 26 March 2014, sections 26, 27 and 28:

In addition to the provision of hot and cold water and electricity, there should be space on the

site for the provision of a separate community building and community open space and

grazing. The average Trailer size is 15 metres but some are as long as 25 metres.

The study is based on Leighton Street, Preston. The site covers an area of 0.3 ha (3000 sqm)

where five pitches have been installed each measuring 15 metres by 11 metres.

Using the above information the total area for five pitches would equate to 825 sqm; All other

amenities, therefore, are housed on 2175 sqm.

If provision had been made for the larger trailers, which are approximately 25 metres by 11

metres, and area of 1375 sqm this leaves only 1625 sqm to house all other amenities; This

would not be enough space.

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The Crosse Hall Lane Site4

- ~

Applying fie Preston cri,~eria to the Crosse Hall Lane site which is 0.23 hectares (2300 sqm),

then fivaptehes at 15 riietres by 11 metres, 825 sqm, would only leave 1475 sqm, ~9% less

than the Creston site, wi~h'not enough room for the recommended other requirements.

In a worst case scenario, providing room for the larger trailers, only 1245 sqm is available for

communal activity. This is a smaller area than the total of the pitch bases. In conclusion the

Crosse Hall Lane site is unsuitable as a permanent Gypsy/Traveller site.

Other Considerations

A case could be made for a site with fewer than five trailers. However, the relative costs of

providing two or more sites far outweighs that of a single site, especially as the local

taxpayers would possibly be asked to help foot the bill. Additionally, it would be

advantageous to the Gypsy/Traveller families to have a single site this is especially important

where children are concerned.

The use of palisade fencing against the backdrop of the Rivington View estate is not in

keeping with the general aesthetic of the surrounding area, and therefore does not meet

criterion d of Central Lancashire Publication Core Strategy Local Development Framework

Policy 8.

Finally, when preparing the site initially, some provision could be made to accommodate the

larger trailer. The Chorley Local Plan 2012- 2026 published in February 2012 states that the

total 14 year requirement for pitches is five. Taking a longer timeline there is the possibility

that more pitches may be required. This helps the case for looking at a larger site where the

infrastructure can easily be extended.

I await your response regarding our objections.

Yours faithfully,

Mrs Stacey & Mr Alex Eckersley

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i~~C1I92

i

Email:

Direct line: 01695 554917

Date: 16th July 2014

Dear Peter McAnespie,

Chorley Local Plan 2012-2026: Gypsy and Travellers and Travelling Showpeople

Preferred Options Document Consultation

The NFU is a professional body which represents the interests of approximately 75% of all

farmers and growers and has 2000 members in the county of Lancashire. We have

compiled the following comments in response to your consultation on your Gypsy and

Travellers and Travelling Showpeople Local Plan Consultation. Our views are on behalf of

the farming and land management sector in general. We do make our comments in the

knowledge that the Council is under a duty to assess the need for Gypsy and Traveller sites

in its area and is under pressure to plan for sites over a reasonable timescale.

Our primary concern is that the consultation document does not include enough information

on how these sites would affect local infrastructure and the nearest settled community.

The local farming community must be fully consulted on sites and given access to

information on site selection. It must be remembered that farmers are running businesses

on their land and that they also have long term plans for the future. Sites must be selected

so that they take consideration of the practical aspects of running a farm business for

example by avoiding sites with close proximity to livestock units, or opposite busy farm

entrances. They should avoid using quality agricultural land.

hope that you find our contribution to the consultation useful. If you require further

information or clarification of any of the points raised in the response please do not hesitate

to contact me.

Yours sincerely

Alice UnsworthEnvironment 8~ Land Use Adviser

NFU, Agriculture House, 1 Moss Lane View, Skelmersdale, Lancashire WN8 9TL

Tel: 01695 554 900 Fax: 01695 554 901 Web: www.nfuonline.com

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Katherine Howarth

From: Andrew Barton

Sent: 16 July 2014 11:10

To: Planning.Policy

Subject: Objection - Crosse Hall Lane Gypsy/Travellers planned site

Good morning,

1~5C~T19~.

Please accept this email as a notified OBJECTION to the planned Gypsy/Travellers site location at

Crosse Hall Lane in Chorley.

must draw your attention to the following concerns:

Land Use: this planned development is on one of the last few open spaces in this local area. By

building on this greenbelt location will only be a detriment to the surroundings. Developing this

small greenbelt location for the plans indicated will be unsightly, and be out of keeping with the

rest of the local area, given the more suitable locations elsewhere.

Land size (space): the space for this development is much too small to meet the criteria set out in

the Council planning document, and does not fit the needs of the development.

Congestion: There is a school next to this plot, and at school peak times in the morning and

afternoon, the area is already heavily congested. To consider manoeuvring caravans and larger

vehicles into or out of such a small space next to the school is potentially dangerous.

Local Services: The plan does not meet the most important of criteria, which is the proximity to

local GP services. Nor is it close to motorway junctions. The increase in larger vehicles not only

impacts the area around Crosse Hall Lane, but also the roads between the motorway junctions and

the planned development.

It must also be drawn to your attention that the residents of Rivington View have committed (legal

covenants and financially) to maintain the high standard of the local area as developed by Morris

Homes. This site plan will be highly visible at the top of the Rivington View development, be

unsightly -and potentially goes against the agreements of the hundreds of surrounding residential

properties. (It is worth highlighting that all of the residents of Rivington View have signed an

agreement NOT to park/display any caravans/mobile homes etc that they may own on their

properties so as to detract from the local environment)

By your own planning document statements, this location is simply not fit for purpose. It is highly

unsuitable for the requirements indicated, and ultimately will provide no benefits to either

travellers wishing to base here, or to the existing residents in the surrounding area.

do hope that the planning department will see the inappropriateness of this location's size, and

reject Crosse Hall Lane from the siting list.

Kind Regards,

Andrew Barton

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i~ ~~T194-

Mrs K Brophy

Jennifer MooreHead of planningPlanning Policy,

Civic Offices,

Union Street,

Chorley,

PR7 1AL.

15th July 2014

Dear Sir/ Madam

RESPONSE to - Chorley Local Plan 2012-2026 Gypsy and Traveller and

Travelling Showpeople Preferred Options June 2014

wish to object to Chorley Council's decision to name Cowling Farm as the preferred site for

allocation as Gypsy and Travelling and strongly abject to this site being taken forward as a formal

allocation.

There are a number of reasons why 1 believe there are serious flaws in the performance site

indicator, that other sites listed are better options and why Cowling Farm is clearly not the best

choice on a number of criteria as detailed below:-

The document "Chorley Local Plan 2012-2026 Gypsy and Travelling Show People Preferred

Options Sustainability Appraisal Supplement" (referred to as the document herein after)

states there are no identified negative economic effects in developing this site.

However this site is the most expensive site proposed. Utilising the site in this way will limit

the use for housing and extension of the industrial estate already agreed, impacting on

employment opportunities for the area. Also the mixing of Gipsy and Travellers with

residential and business use will have a severe impact on the Council's revenue from sale of

prime Council owned land, and it is extremely unlikely that best market prices will be

achieved where the mix is as defined in the plan.

Other sites could be developed at lower cost and without loss of opportunity for other use.

The area identified is too big and this could easily encourage large numbers of the travelling

community to settle illegally, developing a Dale Farm nightmare scenario for Chorley Council

to contend with. The environmental damage caused by unauthorised encampment has been

witnessed on many Traveller invaded sites across the country. The Council should look to

the recommendation of limiting site size and quite clearly ability to do this at such a large

site is severely restricted. This would also place undue pressure on local infrastructure and

services, if large numbers are able to settle in this area.

Other sites are more appropriate in size, limiting the risk that unauthorised expansion

could occur, placing additional demands on Chorley BC and local infrastructure.

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Cowling Brow is already a traffic blackspot with the roundabout and area close to the Prince

,,of Wales pub frequently congested by parked cars with lorries unable to pass. Once past the

speed bump "chicane", the road becomes a race track and there have been a number of

accidents, including one fatality in recent years. Approaching from Adlington along Long

,+.~~ Lane is equally precarious, with a very narrow road, no pavements and a single track bridge

and hairpin bend at Limbrick. In winter the icy roads are treacherous and prone to severe

conditions. Snow is not cleared and in recent winters the road has been impassable. Other

sites are located closer to main routes and do not carry the traffic risks and problems.

• The proposed access across Green Belt land should not be allowed as this is inappropriate

use of the Green Belt. We need to preserve the beautiful green belt countryside around

Chorley and promote the gateway to the Pennines, and not allow these areas to be snatched

in any way. If the Site at Hut Lane is to be rejected on these grounds then this should equally

apply to the Cowling Site. The Local Plan refers to "Protecting the Green Belt from

inappropriate development and strictly limiting new Traveller sites in the open

countryside, away from existing settlements or outside areas allocated in the local plan".

Other sites are outside greenbelt and do not impact greenbelt areas in any way. Yarrow

whilst identified as a greenbelt is already in use by the council as a depot, and has

already been tarmacked and therefore has surely already been effectively reallocated as

Brownfield.

• The document states that "Cowling Brow is a bus route and there is a bus stop within the

recommended 400m walking distance of the site and located about

60m south east of the junction of Cowling Brow and Moorland Gate". This is a very

misleading statement as the bus service is extremely limited, is not regular or efficient

with just two buses a WEEK, one in each direction. This can hardly be classed as a

sustainable service. Othersites lie on main bus routes with direct routes to further/higher

education.

• The document refers to "Higher Education located within 1.6 — 3.2km." If this is the case

and I am not sure it can be, then this must be similar for both the Yarrow and Crosse Hall

Sites — Yarrow is certainly closer to Runshaw and lies on one of the many bus routes to this

college, whilst Cowling Farm does not. See above.

• This is a heavily undulating site with very poorly drained land, and not suitable for caravans.

Again other sites have better landscapes suitable for travelling communities.

• Cowling Farmhouse is Grade II listed. Any development in the vicinity of a grade II listed

building should have respect to the building and its surroundings. A gypsy site is likely to

detract from this, and not respect the heritage of this building. Not a factor for other sites.

• The Central Lancashire Core Strategy Policy 1: Locating Growth sets out where

development should be located in the Borough. It favours well located Brownfield sites. This

site at Cowling is greenfield, in open countryside and if located in the southern area as

appears to be intended, will be in full view from the roadside .Again not a factor for other

sites.

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Finally The Localism Act 2011 requires Councils to both notify and consult local communities

in respect of this type of development before publishing proposals. I have not been able to

see how CBC has satisfied this requirement. Applicable for the whole process.

believe there are at least two other sites in the performance schedule which are more appropriate

for this use than Cowling — eg Yarrow and Cabbage Fields, which will have less effect on the

surrounding locality whilst meeting the criteria required better than the Cowling Site, as shown by

the sustainability measure and I urge Chorley Council to take my comments into full consideration

when reviewing the allocation further, and drop Cowling Farm from the site option list completely.

Yours faithfully

Kathy Brophy

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Ili

~~T1q~

Katherine Howarth

From: S. Robinson < >

Sent: 16 July 2014 12:49

To: Planhing.Policy

Subject: Chorley Local Plan - Gypsy, Traveller and Travelling Show people Preferred

Options Document

Dear Sirs,

am writing to you about the proposed provision for a permanent Gypsy and Traveller Site within the

borough of Chorley.

reside on the Duxbury estate and am writing to ask you to note my comments in respect of the former

depot at Yarrow Bridge, Bolton Rd., Chorley, PR7 4AB as a resident in the area, I am not writing in a

professional capacity.

have no objection at all to a permanent site being found in Chorley and don't object, out of hand, to the

proposal to the use of the site at Yarrow Bridge.

My only observation would be traffic safety in light of the fact that the A6 is a very busy road already in that

area especially since the building of Myles Standish Way. Within a short distance you would have traffic

joining the A6 from a number of junctions starting with Carr Lane, then Hogs Lane, the proposed site, the

public house, Taylor's Garage, Springwood Drive, Myles Standish Way, Duxbury Park (people often park

outside the park entrance}, Worcester Place and then Wigan Lane. There are also a number of properties on

the A6, which access onto the A6 directly.

am not sure if it would be safe to introduce another form of access to the A6 at that site and given that the

land is surrounded by existing properties and the canal it's hard to see how safe access and egress could be

achieved in light of the existing traffic issues in that area. My observations are made with everybody's

interests in mind and strictly from a road safety point of view, I have no objection in principle to a

permanent site being found for travellers in Chorley.

Regards,

Simon Robinson.

Kevills Solicitors5 Park Road

ChorleyPR7 1 QS

Tel: 01257 265711Fax: 01257 266925

www.kevills.co.ukwww.lawyersontheweb.co.ukVAT number 155 3473 63

Follow me on Twitter: @SiChorley

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X- - --

Skype Address SiChorleyq

Partners: SA. Robinson LL.B (Dip PI Lit}, Vicky K. Nicholson LL.B.

Regulated by the Solicitors Regulation Authority#00060398

e-mail transmission

This e-mail may contain confidential information or be privileged. It is intended to be read and used

only by the named recipient (s). If you are not the intended recipient (s) please notify us immediately

so we can make arrangements for its return. You should not disclose the contents of this e-mail to

any other person, or take any copies unless stated otherwise by an authorised individual, nothing in

this e-mail is intended to create binding legal obligations between us and opinions expressed are

these of the individual author.

Regulated and authorised by the Solicitors Regulation Authority #00060398

Partners: SA. Robinson LL.B (Dip PI Lit), Vicky K. Nicholson L1.6.

www.kevills.co.uk

www.lawyersontheweb.co.ukVAT number 155 3473 63

Page 35: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

Chortey Local Plan 212-2026Gypsy and Traveller and Travelling ShowpeopiePreferred Options (June 2014]

Representation Form

4 JUNE ts~ '16 JULY 2014

~~-~ r1e~Co~.~ncil

Ref Number:GTi9

offlaiat use only

Chortey Courcii is seeking comments on the Gouncil's preferred iacation fcr the provision aF a minimum of 5 permanent Gypsyand Traveller pitches (Cttodey local Plan 2(112-2026}. The Council has also considered and discnunteci a number ofaftemativa sRes and welcomes views an these. A Schedule of Proposed Fu[ther Modifications which includes a proposedpolicy an Gypsy ar~d Traveller ar~d Trave111ng Shopwpeop[e (Policy HS11} to the Lora! Ptan has also been produced.

This consu#tation is intendsr3 #o invite commen#s on the sif~s (and whether the ciacumant is a j [egaCiy campfiant and bj sound.Further guidance an this is provided at the back of #his form}.

The Council is not inviting views fln whether this proposed atfrrcation is suffici~en# to mee# the perrnanent and transits needs offire Gypsy, Traveller an~i Travelling Shawpeopie Carnmunity as this issue is being considered in a separate (3evelopment PtanDocument (t3PD —taken fo~xard L~ecemR~er 2014).

Ef you have any views on the Preferred Options document, please use this #o~rn. Copies of the Preferred Options documentalong with ati accompanying inforrtaation can be viewed a#:

The Council's website va~v°v~r_chor~ey_g~av_ukl~ta*~nfLocal libraries and Posk Qffices in villages v+fiihaut a library {paper cap'ses). The documents are availabfe [or inspectionduring normal apenirtg hours. The limas of opening can be viewed on the Council's webs te.Charley Council {Jffices at Union Street, Ghorley —open Noonday to Friday 8.4~am — S.aQpm.

Please complete this form and email ~t to g~nniczc3-~1icy~a?~hc;rl~~r.gov.~:k ar past to Planning Policy, Civia £Nfiaes, UnienStrset~ Chorley, PR7 1A#_.

For rr~or~ irrfotma#ion please call: ~i12'~7' S1Si5t

Pfease note the deadiir~e for responses to E>e reeetved is 96 July ZOid, by 5pm at tine Lafasf. Ef responses arereceived after this deadline unfortunately they will not be considered. Please ai{ow far postage delivery times.P4ease note that your cammunfs cannot be treated as confidential {see below}.

Data Protection S#aternentThe information you provide vriR be held end us~ti by Choriey Council, ir. accordance v~~ith the Data Prat~ction Rci '! 998, tc, helpin the preparation of the l.acaS Pfian. Please note that all responses received wit! be available #or public ins~ecfion and +rtitl tieplaced on the Council's ivehsite. This vrill include your name but the ~rrEainder ofi your ~ersanai cfaiaiis will remainconfidential. Anonymous representations will not be accepted.

lnapprcpriate. of#ensive or racist comments ;+~+ li not be accepted.

Thank you for taking the time fo com~#ete this form

Please fill in yc~ut details below, or if an Agent has #peen agpoir~ted, their details-

3'~ck as ~~ rc~priat~ ~~ . P~r~c~r~a~ t#~e#ails ~" Agent aet~~~s ~

Title <,,,.i[~; r'rry ~;,~ ; _ ~ ~ ~ ._____

Fret Name ~tt~,fi-c ~'s,r'v~ .~~;J!~~~~c~~~?

Cast Name ~t,~e~tcL._E~~'

organ~sattc~n(where relevanfj

_ _.._f

{ Job Ti#leiPosition

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Address Line 1

Tele hone numberAddress Line 2TownPost Code Email address

Page 36: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

This consultatson~ seeks views on the sui#abiEity of sites and no# the principle of

all+~~ating sites. P~e~se fill 1n your c+amments b~lc~w. Phase use a separate

form if you wish to make comments nn more than one si#e.

Ta which part of the Preferred i~ptions document foes this representation relate? (please state}

Site Fief Nol 31~n~;,,,~~~r~ ~,~~.;~ ParagrapF► NumberLacatian ~ ~►-~~,~^, ~.~ 4~

FurtherProposedMoc3~ficatiaNumber

1, 0o you gave any evidence crr information abou# #hts site which w 31 I~eip tt~e Council to

demeans#ra#e that this site is available, suitable and achievable for Gypsy provision?

°-

~. Dc~ you agr~€~ that the ~Coun~i#°s pre~erret! si#e at C~wting Earrn shQUld be taken frrrward as

a #orma! attt~cation?

Yes ~

Na

3, Do you have any other cornrr~ents on the Preferreri dptions document?

~ ~- ice,-, ~~- ~..~ ~~a F %.v~}~ ~~ ~r~``~ m~ ~ ~..s h~~ ~irtr~~~~ r.~ u~.- v ~~te~~•

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Ptease use a ss crate sheet if _aired but indicate Sate Reference No/l.vcation, ~~

Page 37: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

~Y~3`°~ t~'1C~ ,~~,..t`?''iYli Tt.+r— t~Vt°1~~C~

pal ~~-~. 1c~ ~ v~ ti s~ ~,r ~~ ..~J ~

a ~~1E.. €~-#"'~tch►n ~t~'!~ l.S ~if~~1 ~ ~~ ~ i't~~"~ tJt~~~. "~ur- CJ~~~t -►~-

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Page 38: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

4. t}o you consider the Preferred Op#ions document is: (please tick one box only perrepresentation)?

~1} legally C~mp~i~nt Yes ,;V ~ C~t~ ~ }~.> e ~,: }-~,4~ ~~~,~~,

(2) Svun~i~ Yes ~~ Na

*Tire c~tnsi+dera~ons i,~ r~Ia~ivn to the Luca! P/are 6efn~ ̀Sound' arcs ~e~plalrred ~n theNational P#arming Pcadlcy ~tarrrsrnr~tirk in para~ra~ir 'i82.

~. Do you consider the Pre#erred Options document is unsound because it is not: (pleasetick box one box only peC r~pre~en#atiott}? Explanations of these terms can be #ouncl in the GuidanceN»tec

('3? Pc~s~tiv~ly prepared ~..~

(2} Justified

(3} E~~ctiv~

~4) ~~nsi~ter~t with national policy

6. Ptease give details of why you consider the Preferred Ctp#ions document is not legaltcompliant or is unsound. Please be its precise as possibl$. tfi you wish to support the tsgacomptianGS or sa~r~dness cif the Pref~~ed Uptiflns document, please also use #his boy to seo~# dour common#$,z _

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Page 39: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

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Page 40: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

7, Please set out what changes} you cansicier necessary to make the Preferred Options

dacumen# iegaily compliant or sound, having regard to the test you have identi#ied above

where this reia#es t4 soundness. You will need tc~ say why this change will make the

Preferred Options documen# t~gally compliant ~r sound, It wilE be helpful if you are able to

put forvvard your suggesfed revised urording of any policy 4r tex#. Please be as precise as

possible.

Please nofe yt~ur rep~esentatfon should cover sctcc ncfly a!! the information, evidence end

supporting information necessary to support / jusfify fhe representation and the suggested

change. After this stage, furfher submissions wit! only be at the request of the Inspecfor, based

on the matters and issues she td~ntifies for exat»ination.

~o~- (v ~°l"L

S G"~ ~''~'- Y~I~~itCra ~ ~c~°v~r~3~~;t't;5c.~}1

'~ P~ ~~' ~ ~/ ~ ̀ ~ ~ ✓f ~ ms's S.3 ~ C'~G~ ~- ~ t'1

~C%~" '~-3'I .'"s- C~'~ f

8, If your cepresentation is seeking a chan~e~ wcsuld you 1ik~ to ~aartici~ate at the oral part of

th+~ independent examination due to talcs place on 23 and 24 Sepdember 241 ? (please tick

bax~.

No, i dti not wish to participate at the rxral examination (~~'

Yes, I do wish to participate of the ara! exarr~inaticrn

~. If you wish to participate at the Arai part of the ndepe~dertt examina#ian, prase outline

why you consis~er #his to be necessary:Please note the Inspector vuill determine the most appropriate procedure to adap# to hear

these w~a ha~re indicated that they wish to participate ~t the oral part of tine exam~nat~on,

r ~" /'t ~°

Signature;

~~~~`~Gc~unCil

Page 41: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

i~~

Choriey Loca{ Plan 2012-202#1Gypsy and Traveller and Travelling Shawpeople ~ ~ ~ ~ f ~~~

Preferred Options (June 2f1'14) C o u r~ c i

Ref Number:

RepresentatEOn Form G TIg7O~c3al use isnly

4 JUNE to ~6 .JULY 21114

Choriey Council is seeking comments on the Cauncii's preferrarf location far ttYe provision o(a minimum of 5 pemranent GYPSY

and Traveller pitches {Chorley Local Flan 2 12-2028}. The Council has also considered and discounted a number of

aite~`riative sites and welcomes views on #here. A Schedule of Proposed Further Modifications which includes a prc~ossd

policy on Gypsy and Traveller and Travelling Shopwpeople (Policy HS1 T} to the Coca! Plan has also been produced.

This consultation is intended to invite comments on the si#es {and whether fhe document is a) legally compliant and b} sound.

further guidance on this is provided at the back of #his form}.

The Gouncl is not inviting views on wrhether #iis proposed altocatiort is sufficient to meet the permanen# and transits needs of

~~ ~Yp~Y~ T~ve1ler and Travelling Showpeo~le Commu~ifi} as fhs issue 'ss b$ing cans~ered in a separate [}eve!opmenf Plan

Qo~umeni (DPB -~ taken forward December 2014}.

!f you have any views ors the Preferred Op#ions doctttr~ent. pease use lhis (orm. Copies of the i'referred Opiigns doGUtnent

along with alt accorriparrying inforrnafion can be viewed at:

■ Ths Counc~`s watrsite www,ci~o~iev.gov.~k_glae~ni~:a

• Local 4 braries and Pali ~ffic~s in villages without a library (paper copies)_ The documents are available #or inspection

during nrnmaE opening hours. The times of opening can 4e vsewed on fha CounciYs websife.

• Ghorley Council C3it'~s at Union Street, Chorley —open Monday to Friday $.45artt — S.flOprtt.

Please camptefe Skis form and email if to ptanni~so.ct~licvac~crE~3.~ay.uk or Rost to Planning Policy, Civic Offices, Union

Street, Chortey, F'i27 iAL.

For mare informat{art pease c~aif: 01257 515151

Please note Fhe deadline for responses to be received is 46 3uly 2414, by 5pm at the latest. If responses are

received after this deadline unfortunateEy they will not be consitier~d. Please aEiow for postage delivery times.

Pisese note chat your comments canr~o# be treated as confidentia{ (see below},

Dafa Protacti~n StatementThe information you provide w#II be held and used by Choriey Coureif, in accordance with the Data Protection Act 1998, to help ~

in the preparafion of the Lacai Piaa. Please Hale that atI responses received will be available for public inspection and uriii be ~

placed on the Council's websi#e. This will include your name twt the remainder of your personal deiaiis will remain i

confidential Anonymous representations will not be accepted_

Inappr~pria!e, offensive or racEst comments will Hat be accepted.

Thank you for taking the time to complete this form

Pteas~ fill ia~ your details below, or i# an Agent has teen ap~flin#eel, their details.

~`ic~c as at~prQpriate (~}: Personal Details (~1 At~~nt Cletaits C

T(t!e ~ t\ ~ "~ ~~'~ ~ c;

First Name r~'l~(~'t-r ~~~U.~ '~.-ZE~~~~~~'t~'

Last Name ~;; ~c.~

Organisation _ __where relevant

~ Job Titlel ~ ._~.,~.PositionAddress Line 1

Address Line 2

E TOWt1 BIB ~1QC1E CIUR'13}~(

Post Code i Email adt~ress~~.,,,~-

Page 42: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

This consultation seeks views an the sui#ability of sites and not the princip3e ofa![ocating ~i#es. Please fi11 ire yrsur ~ommen#s below. P[~~se use a separateform i# yQU wish to make comments on mare than ane site.

'To which part of the Preferred Options dr~cum~nt doss this representation relate? (please state)

S(te Ref No/ -~"~~~~s~~.. ~ ~~ ~~ Paragraph NumberLocation ~1~~ G`€-{~~z.~,~~

FurtherProposedMadificatioNumber

9. Do you have any evidence or inforn~tatio~ abouf this site which wi![ help the Ct~uncil to

deman~tra~Ee t3~at this si#e is available, sui#able and achievable for GYp~Y Provision?

2. Do you agree that the Council's preferred site at Ct~wling Farm should be #aken forward asa forma! allocation?

Yes

No

3. Do you E~ave any other comments on the Preferred ~ptiQns document?

!_.-E' ` ~y 'q('+~ j $ y~/~}

{.~i.~~ 4!V~ I V'~ ~.. ir`V l_.~~ ~ ~~~ '~~

C.~s`✓1 YT ~~ I • J

f

~~ ~ ~

~~- -~ < ,~

~~ C~~►~"► v1 t,~ ~c:~ c~ etch r.~ ~i cwt ~ .'~'~~.~ j ~ • ~` .

'tease use a se crate sheet if re ui~$tl but indicate ~i#e Reference NolLoca#ian.

Page 43: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

t„~~~ ,,j

~'C:~. '►~'1E:~'~~~ ''cif` t~r1 ~r~ ~ ~ '1 (~~~~.~~~

~ ~ ~ cam~ ~ ✓~ °~ ~...r

..~}c- ~c s tit :~. t~- t~v1S~ z~+ ~ ~ ~' ~,~►~:~ ~ c~ rs ~'.~r~

~ ~,~

~ ~ c~ ~`~ ~c~ ` rte` `~ ~ ~ ~ Urt`~- ~°̀~ °`'

~.; ~~~~.

~~~ ~~~ C`v~5 ~~~~ k

Page 44: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

4. Do you consider the Preferred Options document is: {please #ick one box only p+~r

representation)?

(1} ~.egally Compliant Yes ~~"'] No (~ t'`e ~`a ~ ~

t2} Sounr~* Yes ~ No

The conside~ratlons fn relatfvn to the Luca/ 'Ian being °Sound' are exp/atn~d fn the

Nationaf Plar~ning Policy Framework In paragraph 182.

5, Dc~ you ec►nsider the Preferred Qptinns documen# is unsuunc~ k~ecau~e it is nnt: (pleastick box one box onty pet represetltatlon)? Fxpfanations of these terms can be found in the Gui~fance

lVnt~c

(1 } Posit veiy prepared

~2} Jusiifed ~y

(3} Ef#e~ve

~4) Gc~nsistent with natiorta( poficy [~

6. Rlease give tfe#alts of why you consider the Preferred Options document is not legalf

c+~mp[iant or is unsr~und, Ptease be as precise as possible. If you wish to support the iega

compliance or soundness of the Preferred t~ptians document, ~alease alsfl use this hQx to se

+~u# your comments.

~, Wit,.

,~ -

Page 45: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

7, Please set out what changes} you consider necessary try make the Preferred Options

document legally compliant or sound, having regard t4 the test you have identified above

where this relates to soundness. You wi![ need to say why this change will make fhe

Preferred Options document legally compliant or sound. It wil! be helpful if you are able to

pu# forward your suggested revised wording of any policy or #~xt. Please be as precise as

possible.

Please note your representation should cover succinctly all the information, evidence and

supporting information necessary to support / jusfify fhe representafion ar~d the suggested

change. After tf~is stage, further submissions will only be a# the request of the Inspector, based

on the maffers and issues she idenfr~es for examination.

~~ ~1~-

$. 1# your representation is seeking a change, would you like tc~ participate at the oral part of

the independent examinatian due to take place on 23 and 24 September 2014? (please tick

box}.

Riv, f dc~ not wish #a parkicipate at the oral examination ~~

Yes, 1 da wish to participate at the oral examination

9. !f you wish to participate at the oral part of the independent axart~ina#icon, please outline

why you consider this to be necessary;Please note the Inspector wilt determine the most appropriate procedure to adopt #o hear

those who have indicated that they wish to participate at tt~e oral part of the examination.

t',rffjS

t

1

Sig~natur~:

date: i 5~~~~~ c ~ t~..,~

~l~f~~~ou~~i~

Page 46: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

About yvu

Cl~otiey ~Q~nci1 is com~it#ed t~ m~ic ng sure that it takes into acct~unt the views of everyone in the. t~oro~agh,Pieass answer the fr~~lowi~tg questions. You des r~o~ hive to ~t~swer these c~e~~stions bu#~ if you ~o, your~nsur~r~ will be used to rna(ce sure tit tiur service are be ~tg accessed equally. ~veeything you felt ~s ispr~~ate and confidential and wi~E nofi be stared,

Q'~ Gan yt~u please cr~n rr your ful# Post Code?(l'~. A~~ WRITE FULL f~~~~(3DE !t~ BC}X e.g. PR71CiP}

t~~ Are yvu, {F'I.ER~E T#CK ,~ C3~2E BMX C3~L'Y}

Male .,....... ,~"~J Fema#e ............. ❑ 7ransgender .,...~,...... ~ Pr~f~r not #o ansvHSr ...,......... CJ

Q3 What r~ras pour age on y~~r last bi~fhday?4~.~~s v~~~~r~ ~t~ st~x} :~ ~ dears

Q4 Are you an $mployee or Counc~llctr crf C~~r~ey Council? {~€,EAS~ T1~ ✓ ~~1E BOX ~3 ~.Y)

Employee..._.__.... ~ GounciCtor ............. ~ Neither cif these; .......,.,....~

Q~ ~3~ you have any tong-standing it~n~ess, di~agt`ti~r ur infi~nity~ ~ ~ng•stanclang ►Weans~nr~hing that has tr~ubl~d yr~u aver a ~srioci ~f t rr~~ ter ~ha# is i~kety to affect you over apetic~d of time) {PLEASE TICK ~' ~3NE BtiX C}tVLY}

Yes .................... ❑ hFa..........................~Prefe~ rso# t~ answer......,..,,,.,....<,~..............._....

Q6 Tt~ which of these ~gro~aps do you cc~ns~der y~c~ beit~ng~(PL€ASE TICK ~ ONE EOX ~N~.Y~

Y11hit~

Ertgish/~/VeishlScottishltUartnern irshlBritish.........

Chinese..._......, ............. .... , . ...<., .. ~

frish......................................................................,... ~

gypsy or Irish Travelfer ........ ......... ....................

Any oEher White background.,.;.... ......:...:..........,:..,.......~~PCEASE V4+RlTE B~LOV~!}

AA~xedlMu3tbp4~ ethnic Grt~ups

WWhite & 8fack Car€bbean ......... ............ .. ,.. ❑

Wh~t~ &Mack African .................................................

Any other Mixed ethnic background .....:....:............ !~

(PLEASE WRITE 6Ei.~YVj

Arab..............................~.............,..................

Prefer nc~k to answer ...........................................

~~AsianJ Asian Bri~fs~s

Banglades#~i.............,..,....... .................................. ~

fr~dian ........... ........ ..........~ ..., ..,.....,...., ❑

€~akistani... .............................................................. D

~y tither Asian ba~kgro+snd ................................. ~

(PLEASE V~IRITE B~Lf}4M1i~

St~ck~Afri~anlCaribbeanlBi~ck 8ritlsh

Afr€can .....................................~..... ,.......,.........,

Garibtsean..............................................................

Any tither BiackfA#€canlCaribbe~r~ background......

(PLEASE WRITE SfLt3W}, '

tiny other et~,nic Group ...................................... ~(PLEASE t~JR[TE BELCl~t1~)

Page 47: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

Bibb s Farm Scout CamY p,,; ~`~„~`,,,,,~r~'- ' and Activity Centre

f~~ p~r~,~c~rr~~t

Date 16th July 2014

Planning Policy Civic Offices

Chorley Local Plan 2012 —2026 Gypsy and Travellers and Travelling Show People

Preferred option Document, June 2014- Consultation

Dear Sirs

1~9

G~TIq~

am writing on behalf of Bibbys Farm Scout Camp and Activity Centre. The campsite provides facilities

for: Scouts, Guides and children from both schools and churches from Chorley and Bolton. The age

range of children visiting Bibbys Farm is from 6yrs to 18yrs but the majority of children are between the

ages of 6yrs to 13yrs. The average annual attendance is in access of 4000.

Our Centre is located across the motorway adjacent to the proposed Gypsy and Traveller and Travelling

Show people's site at Cowling Farm. A public footpath crossing the motorway via a footbridge links the

two sites and continues through our Centre along side camping areas and activity facilities. The route of

the path through the site makes it impracticable for it to be fenced. We have had problems in the past

ensuring people using the footpath adhere to it and do not take alternative short cuts through the camp

sites and associated buildings. We have also had people illegally camping in the woodland area of our

site. If the proposed travellers site is located at Cowling albeit only initially for 5 pitches, which we

believe will grow, it will only exacerbate our concerns associated with safeguarding and security

commitments.

We trust you will give due consideration to our concerns /objection in selecting Cowling Farm as a site

for Gypsy and Traveller and Travelling Show people .It would be tragic to loose the confidence of

parents, which is so easy to do in this current child protection climate, and hence stopping their children

attending Bibbys Farm, which is providing an excellent service for the young community of Chorley.

Yours Sincerely

Brian DaviesDirector of Bibbys Farm Campsite and Activity Centre

T

Page 48: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

~ r~o

~ C~Tig9

The CoalG T Zo 1

Authority~ t Zo2~ ~ zoo

Chorley Local Plan 2012 — 2026: Gypsy and Travellers and Travelling Showpeople

Preferred Options Document - Consultation

Consultation Deadline — 17/07/2014

The following contact details are the only ones you need for planning related matters, therefore

please amend your database if necessary.

Contact DetailsPlanning and Local Authority Liaison Department

The Coal Authority200 Lichfield LaneBerry HillMANSFIELDNottinghamshireNG18 4RG

Planning Email: planningconsultation~coal.gov.uk

Planning Enquiries: 01623 637 119

Person Making CommentsDeb Roberts M.s~.Graduate Planning Liaison Officer

BACKGROUND ON THE COAL AUTHORITY

The Coal Authority is allon-Departmental Public Body sponsored by the Department of Energy

and Climate Change (DECC). The Coal Authority was established by Parliament in 1994 to:

undertake specific statutory responsibilities associated with the licensing of coal mining operations

in Britain; handle subsidence claims which are not the responsibility of licensed coalmine

operators; deal with property and historic liability issues; and provide information on coal mining.

The Coal Authority set up a Planning and Local Authority Liaison Department in 2008 to re-engage

with the three planning systems across England, Scotland and Wales. The main areas of planning

interest to the Coal Authority in terms of policy making relate to:

• the safeguarding of coal in accordance with the advice contained in The National Planning

Policy Framework in England, Scottish Planning Policy in Scotland, and Minerals Planning

Policy Wales and fe1TAN2 in Wales; and

ensuring that future development is undertaken safely and reduces the future liability on the

tax payer for subsidence and other mining related hazards claims arising from the legacy of

coal mining in accordance with the advice in The National Planning Policy Framework in

England, Scottish Planning Policy in Scotland, and Planning Policy Wales and MTAN2 in

Wales.

Page 49: Ib3 ~7tgl Katherine Howarth - Borough of Chorleychorley.gov.uk/Documents/Planning/Examination news/Gypsy and Tr… · Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To:

Coal mining legacyAs you will be aware, the area within the district of Chorley has been subjected to coal miningwhich will have left a legacy. Whilst most past mining is generally benign in nature, potential publicsafety and stability problems can be triggered and uncovered by development activities.

Problems can include collapses of mine entries and shallow coal mine workings, emissions of minegases, incidents of spontaneous combustion, and the discharge of water from abandoned coalmines. These surface hazards can be found in any coal mining area, particularly where coal existsnear to the surface, including existing residential areas.

Within the administrative area of Chorley there are 376 recorded mine entries and around 55 coalmining related hazards have been reported to The Coal Authority. Mine entries may be located inbuilt up areas, often under buildings where the owners and occupiers have no knowledge of theirpresence unless they have received a mining report during the property transaction. Mine entriescan also be present in open space and areas of green infrastructure, potentially just under thesurface of grassed areas. Mine entries and mining legacy matters should be considered byPlanning Authorities to ensure that site allocations and other policies and programmes will not leadto future public safety hazards.

Although mining legacy occurs as a result of mineral workings, it is important that newdevelopment recognises the problems and how they can be positively addressed. However, it isimportant to note that land instability and mining legacy is not a complete constraint on newdevelopment. It would be far preferable for appropriate development to take place in order toremove these public liabilities on the general tax payer. The Coal Authority would therefore notwish to suggest that any of the alternative sites should be excluded from the assessment on thegrounds of former coal mining legacy issues.

We defined a data set (Development Risk Areas) where these legacy issues have been recorded.This data set has previously been supplied free of charge to Chorley Council (06/08/2010;24/09/2010; and 08/03/2011). This data was supplied to assist both plan making and in thedetermination of planning applications. It should help to determine whether or not there may beissues on sites within your administrative area where former coal mining activity has left a legacy.

According to our records the updates made to this data since 2011 which have been madeavailable to Mr Paul Sudworth (Information Manager) at Chorley Council, have not beendownloaded. Your evidence base therefore is not using the latest data set. Since 2011 there havebeen two updates to our data with a further update scheduled for July /August 2014.

SPECIFIC COMMENTSHaving reviewed the Gypsy and Traveller and Travelling Showpeople Preferred Options, June2014, whilst we have no objections to the principles of the document the comments andlorchanges which The Coal Authority would like to make or see in relation to the above document areset out as follows:

Representation No.1 -Site 1 Council Preferred Site Land at Cowling FarmComment —This site is not within the defined Development High Risk Area and is instead located

G~~°9 within the Low Risk Area. As such there are no recorded risks within the site that newdevelopment will need to take into account.

Representation No.2 — Unstable Land on Sites 4, 5, 8 and 9

CiT~:a Four of the eight alternative sites have been subjected to coal mining which has left a legacy.~;';' ~.o:~ Sites 4 (recorded mine entry); Site 5, 8 and 9 (probable shallow coal mining).

G T ~~~`I 2G3

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Whilst these coal mining hazards would not deem these sites to be automatically unsuitable;

should the preferred site not be taken forward and an alternative site chosen, these risks should be

identified as part of each of the sites constraints.

Whilst it has been acknowledged that Site 4 does not identify that the site contains former coal

mine workings, it does highlight that a detailed site investigation would be required in advance of

any development. The LPA must ensure that these site investigations include locating the mine

entry and provide a remediation strategy on how the mine entry will be treated.

In relation to Sites 5, 8 and 9 there is no indication that site remediation will be required even

though our information confirms that coal mining legacy may have led to ground instability.

Change requested —Table 1

Site 4 "Policy 8 — A detailed site investigation is required under criterion (c) as there is potential

ground contamination due to the historic land uses on the site. This site also has recorded coal

minin_q le_gacv and the site investi_gation will need to locate and assess the recorded mine

entry to establish its current condition and the remedial works required to ensure that anv

development activity within the vicinity will not be at risk~from this existin_q feature.

Change requested —Site Information and Site Appraisal (Site 4 Land off Westhoughton Road,

Heath Charnock)

Contamination: Risk from contamination is unknown - detailed site investigation would be required

in advance of any development. This site has a recorded mine entry, the current condition is

unknown. if this site were to be developed then a site investi_gation should include fhe need

to locate and assess the recorded mine ent►7~ to establish its current condition and theremedial works required to ensure that any development activity within the vicinifv will not

be at risk from this existin_q feature.

Change requested —Site Information and Site Appraisal (Site 5 Land at Ackhurst Road, Chorley)

Contamination: The site is historically classified as part of the sewage works. There is a potential

for ground contamination. Former coal minin_q activity has left a le_gacy of unsfab/e land which

will need to be assessed and appropriate remedial works undertaken prior to site

occupation.

Change requested —Site Information and Site Appraisal (Site 8 Safeguarded Land BNE3.2

Harrisons Farm, Adlington)

Contamination: No known contamination issues. There is low likelihood of any potential

contamination. Former coal minin_q activity has left a le_gacy of unstab/e land which will need

to be assessed and appropriate remedial works undertaken prior to site occupation.

Change requested —Site Information and Site Appraisal (Site 9 Hut Lane, Heath Charnock)

Contamination: There are currently no known or suspected contamination issues at this site.

Former coal mining activity has left a le_gacy of unstable land which will need to be

assessed and appropriate remedial works undertaken prior to site occupation.

Reason - In accordance with local planning policy BNE7 of the Chorley Local Plan and the NPPF

guidance (paras. 109, 120, 121 and 166), this would ensure that the policy that allocates potential

development sites identify the necessary remediation or stabilisation prior to development.

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CONCLUSIONThe Coal Authority welcomes the opportunity to make these comments. We are, of course, willing

to discuss the comments made above in further detail if desired and would be happy to negotiate

alternative suitable wording to address any of our concerns. The Coal Authority also wishes to

continue to be consulted both informally if required and formally on future stages. The Coal

Authority would be happy to enter into discussions ahead of any examination hearing process to

try and reach a negotiated position if this were considered helpful.

Thank you for your attention.

For and on behalf of:

Miss Rachael A. Bust B.Sc.(Hons), MA, M.Sc., LL. M., AMIEnvSci., MlnstLM, MCMI, MRTPI

Chief Planner /Principal Manager