Ms Susan Slamon
8 Greenhalgh Lane
Anderton
Chorley
PR6 9PH
Representor: 48
28th
February 2013
MIQ 4: Policy HS1.29 Land at Babylon Lane, Adlington
Specific issue in relation to Matters:
4.2 - does the most up to date evidence confirm that the proposed scale of housing provision
remains appropriate? What is this evidence? Some of the evidence presented in the
Sustainability Appraisal Detailed Site Assessment is factually incorrect
4.4 – what were the criteria that were applied in the site selection process? Because the
evidence in the detailed site assessment is incorrect, it’s overall scoring may be
incorrect. This site should be perhaps be in a lower banding, not ‘C’
4.5 – does the CS target of 70% of new housing development being accommodated on
Brownfield land remain appropriate? Will the allocations achieve this target? No
4.7 – do the locations of the allocated housing sites reflect the most sustainable options and
the location strategy of the CS? No – detailed reasoning/evidence of this is provided
below
‘S1’ - Social indicators
Distance measurements are incorrect. This land is not bounded on all sides by existing
development.
There is not, as stated, “general agreement that the land should remain safeguarded for
development”. It should be safeguarded from development.
From the most southerly (closest) point, at this site, to the railway station it is over 1km.
Also, in reality, this is an awkwardly shaped site which is unlikely to have access allowed
from its most southerly corner, and this fact would increase distances to all local services.
Note should also be paid to the fact that this is in Heath Charnock (outside of Adlington). It
is uphill from bus stops from service centres and supermarkets, with no North/South
Adlington bus service. So in reality, people living here will predominantly have to use cars,
assuming they have them.
Distance to the closest 125 (regular) bus stops is over 400m, not „up to‟.
Distance to the closest „A‟ road junction is over 400m, not „up to‟.
Though supermarket performance has been correctly stated, in reality, if a supermarket were
to be developed at the bottom end of Adlington at Fairport, (bringing this social indicator into
a more sustainable banding) people without cars would still travel to Chorley due to the
difficulty they would have carrying shopping back uphill. Assuming they are able to park
when they get there, traffic journeys would increase locally, as people drive up and down
Babylon Lane and Railway Road, to get to this new supermarket. In comparison, the local
centre at the A573/Railway Rd/Babylon Lane junction, at which local centre functionality and
resilience should be strengthened, is over-crowded with small businesses already, with no
space for further development. People do not use these shops as much as they might
however, as there is no space for parking and they cannot get a full weekly shop here. We
have lost any remaining local shops e.g. Bowen‟s butchers and Burgess‟s green grocery
store in recent years, as a consequence. Small businesses, and local food suppliers and
outlets should be encouraged back to the top end of Adlington as it has the infrastructure of
a small town. Supermarkets are out of character and cannot be accommodated in this
locality.
Post office/convenience stores are both also over 400m from this site.
Though there is a small doctor‟s surgery on Babylon Lane, just within 400m, the closest
medical centre is at Granville House – this is 650m+ from the closest point on this site.
North and south M61 motorway junctions are over 7.5km in distance– though correctly
stated as over 3km, this has been put in the yellow colour band. What is the threshold for
moving up into orange/red bands?
Additional road congestion will make for further traffic issues on this narrow B road. There is
a primary school on Babylon Lane. It is already a busy, dangerous route, partly due to
insufficient existing parking for existing terraced properties. Heavy traffic uses this route to
get to Cowling industrial/commerce parks. It is proportionally more dangerous for those
traversing the route to/from the local centre and/or to Rivington, e.g. by disabled vehicles,
bikes or horse riders. Particularly at weekends, this is a heavily used recreational activity
through-route to Rivington for non-motorised users. The Sustainability Appraisal says a
Transport Statement will not be required for developments less than 50 houses.
EN2: Conservation area – though this site is not protected, there are mature trees on this
site. The trees on this specific site perform the function of taking up some of the ground and
surface water that naturally occurs on this land. Bats are often seen in spring and summer
the vicinity of the trees on this specific site. They are also used by owls. It has not however
been stated that there are Tree Preservation Orders on these trees (and we have evidence
that there are). Please note these are situated at the southern section of this site (where all
distance measurements have been taken from). These trees should remain, as they provide
numerous, including ecological functions.
In combination impacts
Due to the high levels of residential development in recent years, there are no longer any
high suitability ranking Sustainability Appraisal sites in Adlington – Other recent Adlington
developments e.g. Fairview and Grove Farm have encroached into remaining Greenfield,
riparian corridors and areas of biological interest e.g. around ponds and wetlands - note,
CH0180 is about to do the same. Though perhaps not significant alone, in combination
these developments are resulting in a combined adverse impact. Sustainable development
must focus on the remediation of Brownfield sites first – however relatively less attractive
that might be to developers.
EN4: Flood zone area. We do not consider the consequences of 18 new houses may be
managed on this site. Though this is strictly correctly stated as flood zone 1 (green band),
we have evidence of localised surface water drainage issues here already and believe this
should be a material consideration. The underground watercourse becomes surface water
in times of heavy rain. Groundwater flushes are common in this field which effectively
functions as a „SUDS‟ for other existing properties in the area. The field‟s name –
„Washacre‟ is appropriate. Please see photo below; this shows the unmaintained field
boundary and looks into the field toward two naturally occurring springs/sinkholes. The
smaller of the two has recently been cordoned off. The larger is a few meters downstream
from this in the middle of the photo. (The photo also shows an existing in use building on the
site).
In times of heavy rain, groundwater up wells from these features to meet water flowing
through the site. I have also attached a short (8 second) video of this brook in spate in times
of heavy rain. When this upwelling occurs, surface water flows down the field and
percolates back into ground adjacent to no. 18 Greenhalgh Lane.
As such, this land provides essential „ecosystem services‟ functions for existing properties in
the locality – especially the bottom half of the field. In my/our opinion it should continue to
do so. The owner, Mr Sinker has attempted to dry this raised land out in recent years by
installing drains but this hasn‟t worked. Surface water flushes are common in this general
area. The normally underground watercourse joins a combined sewer outside of existing
properties (including mine) at the junction of Greenhalgh Lane and Babylon Lane. We have
already experienced development of a pot hole around this junction. Surface water runoff
along with heavy traffic is (I believe) implicated in this. Bringing new water supplies, along
with heavy traffic into this locality to construct and serve new housing requiring and using
more water will only make matters worse. The construction period would be particularly
risky as this is a raised, sloping site and as such, much earth movement would be required
in order to make it developable. Silt would find its way into this watercourse/combined sewer
pinch point via runoff.
Due to the relatively small size of this proposed development, we are worried Chorley
Council will not consider the potential flood risks here fulfils the criteria requiring a full Flood
Risk Assessment/sequential test as per Planning Policy Statement 25 practice guidance.
Flash flooding, as opposed to the existing percolation and detention of rain and groundwater
can be, in my opinion, expected as a result. If this does occur, on and off site downhill
impacts are likely. Implications for existing adjacent properties should receive no less
consideration than on site impacts. Note: even if technical solutions could be found, in our
opinion, underground water storage tanks would not be considered an ecologically
sympathetic solution.
EC1 distance to employment site
What is the ratio of people to local jobs? This section states there are employment
opportunities, but there are far fewer jobs than there are people. The majority of people
travel out of Adlington in order to work.
Summary:
This land is not appropriate / should not be safeguarded for housing development. Various
housing unit quantities - up to 60 units have been suggested as appropriate for this land.
The Sustainability Appraisal has made the assessment based upon a potential number of 18
units.
However, this wet, raised walled site is not considered to be readily developable. It is an
awkward shape, has fluctuating topography and has a watercourse running through the
middle of it. There is also an existing in use building on site (the Rivington and Adlington
Brass Band practice house), and mature trees with TPOs.
However, these concerns have been raised already - a lot of those 300+ „comments‟ (hand
delivered) to Chorley Council were really objections to this specific development for these
reasons. I would hope the inspector would deem it fair and reasonable to treat them as
such. We are saddened that landowners with interests in future development planning here,
but who do not actually live here, appear to be heard over all of these other voices.
I urge you to please consider the above material facts as evidence in making your decision
in relation to „soundness‟.
Please also see appended below, my relevant comments made in response to
12/00895/FULMAJ „Full‟ planning application, 3rd October 2012, as HS1.29 boundaries have
now changed from previous.
12/00895/FULMAJ ‘Full’ planning application response
I object in principle. How can the 12/00895/FULMAJ planning application go through before the
Housing Allocation Strategy has been out to consultation, accepted and adopted?
This specific housing developer has only submitted an Energy assessment. I expressed concerns to
the LDF with regards to the lack of sustainable housing. The Council response to my LDF comments
refers me to sustainable resources DPD and SPD – I would suggest this type of development which
uses traditional materials; primarily „reconstituted stone‟ (concrete) and cement, is not a sustainable
per say. The only beneficiaries are the developer, the contractor and their associated suppliers. I do
not consider the continued building of large carbon footprint houses to be examples of long term
sustainable development. Builders of any new housing should be local. Materials used should be
locally sourced. Locals should be able to afford new housing built.
The developer should not be able to appeal this decision as this is not an „affordable housing‟
planning development proposal.
Other related comments/observations
a)
b)
c)
d)
e)
f)
g)
h)
Housing Allocation CH0036 1.2 Land at Babylon Lane (lower end), and CH0283 - 0.8 Land at
Babylon Lane (top end). HS1.29 incorporates both of these LDF Housing allocation site
suggestions.
The original housing site allocation proposal was made by Mr Sinker who‟s original proposal
was for 50-60 smaller affordable housing units on his land adjacent (below) this. This housing
unit figure was then dropped to 36 over a wider area including land relevant to this planning
application. The current 12/00895/FULMAJ planning application is for 14 large houses
(8no.x5 bed/6x4 bed) within HS1.29 boundaries; a site that has been supposedly put on the
backburner until at least 2021 - I understand this doesn‟t necessarily automatically stop
applicants from making proposals for that land.
Mr Sinker would appear to be neither the applicant nor landowner in relation to this specific
land development proposal. Hence, may I ask what this means for the rest of the HS1.29
site? e.g. are another 22 houses (or other) still deemed as suitable in principle, for placement
on the lower „Washlands‟/‟The Wash‟ field? I believe a recent decision is to allow this specific
land allocation to remain as „safeguarded‟ for the time being. I personally believe this land to
be unsuitable in principle for housing, and would implore Chorley BC to re-examine their
decision to keep the remainder of the HS1.29 site as „safeguarded for future development‟.
I would imagine Mr Sinker is unhappy that Chorley have not taken his site suggestion forward
at this time. If we cannot rely on Chorley Planning refusing this on „in principles‟ alone, or
other applications on this land, what is to stop Mr Sinker from also putting in a planning
application for houses on his land? If we disagree with development on HS1.29 and wish to
object to further development here, do we have to check the planning applications put forward
every other week?
Would it be appropriate to ask whether we may positively influence activities in the
Washlands field? E.g. can we request/demand maintenance of the boundary wall (a public
Health and Safety issue) and/or biodiversity enhancements within the field? i.e. invasives
treatment, further tree planting and installation of bat and owl boxes? I would imagine that if
Mr Sinker expects he will eventually get planning permission for houses on this land that he
will continue to refrain from any positive management activities here. Hence, I can only see
the stone wall maintenance/H&S issues getting worse.
Without action, the non native invasive Japanese Knotweed on HS 1.29 land will continue to
be spread as it is adjacent to a private road (it spreads vegetatively). It is an offence to
spread JK under the Wildlife & Countryside Act 1981.
(Note: Japanese Knotweed is also growing through the stone field wall at the top of Babylon
Lane – fragments are broken off by cars and spread into the wider environment / brought
down the lane by flood waters and wind). With no action, this will become a problem much
harder to tackle in the future.
LDF Policy BNE 2.5 Safeguarded Land (on adjacent land) – there are already properties and
a watercourse within these boundaries. A relatively small proportion – 40%? of this area is
developable.
i)
j)
k)
l)
m)
n)
o)
p)
Flooding/drainage: I accept United Utilities responses to the Housing Strategy and the lack of
specific comments about this particular site. As previously advised however, UU comments
are with regards to known problems/issues. For instance, as Washlands has always been
vegetated land, and has generally coped with the amount of water it receives. Relatively little
information is available with regards to the flooding of non main rivers and surface water
(road) runoff often is a relatively large contributing factor. I am concerned with the impacts of
built development and the long term sustainability of placing storage water tanks in the
ground (which development of this scale here would be considered likely to need). Note:
holes have previously appeared in the road at the corner of Babylon Lane and Sutton Lane,
related to surface water, and the combined sewer. Is this not a sign of exceeded capacity /
threshold?
Comment further to Housing allocations LDF counter response ref /01/218. Growth: The
Council response was that growth was required within Urban Local Service Centres (e.g.
Adlington) as this is a Core Strategy Policy. In practice however, settlements originally built
for a small number of people have limited core infrastructure and hence there are difficulties
in successfully adapting to accommodate a significant population growth. Who decides what
the overall total projected housing units figure should be for Adlington? An increasing number
of Adlington residents consider housing developments here to be growing at a rate
detrimental and disproportionate to other sectors and infrastructure (e.g. building of schools),
and growing much faster than other Lancashire Villages. Infrastructure is suffering as B
roads are forced to accommodate large numbers of car driving residents, commuters and
parked cars. There are also large vehicles that use Babylon Lane as a route through to
Industrial premises at Cowling. These pressures have also helped force local shops to close.
Supermarket chains are the only winners in this situation as they are now successfully
encroaching into the high street buying up closed failed businesses e.g. the Ridgeway Arms,
and helping fast growing conurbations like „Greater‟! Adlington to lose their individual
identities and community hubs.
I recognise the need for better local resilience and investment in true regenerative
development e.g. by giving more people the option to shop and work within walking distance.
Why are some developments e.g. change of use – „industrial use‟ to „residential‟ (e.g. Grove
Farm) given permission and just done?
Would not a publically open visioning exercise where locals are encouraged to give their
views and take an active part in the future development planning process be better than a
„decide and defend‟ approach? Maybe there were/are alternative options for a new „shopping
centre‟ at the bottom end of Adlington? This latest change however will likely polarise retail
infrastructure in the Town.
Will the public have a say over which outlets go in the new „shopping centre‟? By definition, a
multi-national supermarket corporation cannot be a „local centre‟. Accepting one of the top
four at this location would in my opinion, thereby further deteriorate Adlington‟s diminishing
local identity.
In order to meet the needs of the old and infirm, this will require a good public transportation
service to the top end of Adlington, Anderton and Heath Charnock if we are to keep traffic
problems already experienced, within tolerable limits. The current bus service up Babylon
Lane is not frequent enough to encourage people to use it.
The „safeguarded land‟ term is misleading – most people assume this to be followed by „from‟,
not „for.‟