Question 1 - Do You Consider That This Represents an Appropriate Response to the School

Salford City Council Supplementary Planning Document

Hot food take aways

Consultation Statement – November 2013

1.0 Introduction

1.1 This document sets out the consultation that has been undertaken in relation to amending the hot food take aways supplementary planning document (SPD) which was adopted in July 2007. It sets out the persons consulted when preparing the SPD and also includes a summary of the main issues raised and how those issues have been addressed in the revised document.

1 2.0 Statement of community involvement

2.1 The city council’s statement of community involvement (SCI) was formally adopted on 20 January 2010. The SCI aims to increase public involvement in planning processes. It sets out who will be involved, by what method and at what point in the process of document production or in the determination of planning applications. It gives more certainty to those wishing to get involved in the planning process.

2.2 The SCI sets the council's policy for community engagement in the production of formal planning documents. Below is a summary of the SCI guidance in respect of consultation at the different stages of SPD production:

Stage 1 – pre-production This stage is based around the gathering of evidence and asking people to identify issues and make suggestions in order to inform the preparation of the SPD.

Stage 2 – production A draft document is produced following the evidence gathering pre- production stage. Whilst the regulations simply require that draft SPDs are subject to a consultation period of at least 4 weeks, the SCI commits the city council to always consulting on the draft SPD for 6 weeks in order to maximise potential involvement. The city council will carefully consider any representations received during the consultation period and will update the SPD where it is considered necessary and appropriate.

Stage 3 – adoption The SPD will then be adopted. A summary of representations received and how they have been taken into account will be published at this stage.

2 3.0 Background to the hot food take aways SPD

3.1 Salford City Council has updated the previous hot food take aways supplementary planning document (SPD) adopted in July 2007. This is in order to ensure that the approach to determining planning applications for hot food take aways is as robust as possible.

3.2 The update particularly reflects experience in applying the 2007 SPD policies, recent appeal decisions, and widespread concerns regarding the health implications of hot food take aways. It seeks to balance the presumption in favour of sustainable development contained in the National Planning Policy Framework and the need to support local businesses alongside legitimate concerns regarding the potential impacts of hot food take aways for residential amenity, health and the vitality and viability of town and local centres.

3.3 Saved policy S4 of the Salford unitary development plan (UDP) provides the main policy basis for the SPD.

3 4.0 Scoping consultation

4.1 From Monday 9 July 2012 to Monday 20 August 2012, the city council sought the views of stakeholders and consultees on its intention to update the hot food take aways SPD (together with four other existing SPDs on design and crime, house extensions, telecommunications, and trees and development). The city council requested any comments that people might have on the existing SPDs and in particular whether any of the policies within them were still appropriate for use or whether they should be amended.

4.2 The city council consulted 288 consultees registered on its planning consultee database, including all statutory consultation bodies together with other consultees who the city council considered may have an interest in the production of the various SPDs. This included businesses, residents and community groups who had previously expressed an interest in or submitted representations on related planning policy documents. A list of all those consulted is set out at Annex A. A copy of the letter which was sent to consultees is set out at Annex B.

4.3 In addition, spatial planning officers ran a workshop with Urban Vision development management colleagues. Discussions were also held with Urban Vision’s environment team, the council’s environmental health and health and improvement teams, also Salford’s director of public health and health and wellbeing board. Details of the initial consultation were published on the city council’s website and an electronic version of the consultation documents were available to download.

4.4 A single representation was received from Barbara Keeley MP and was taken into account when preparing the both the draft and the adopted SPD. The Coal Authority and Network Rail also responded to say that they had no comments to make. These representations and the council’s response are set out in Annex E.

4 5.0 Draft SPD consultation

5.1 There was an eight week period of public consultation on the draft SPD from 10 May 2013 to 5 July 2013.

5.2 The city council consulted 342 organisations and individuals registered on its planning consultee database, including all statutory consultation bodies together with other consultees who the city council considered may have an interest in the revision of this document. This included: the city’s director of public health; all other Greater Manchester local authority directors of public health; Salford’s health and wellbeing board; the Salford BME forum; and BME network. Discussions were also held with Urban Vision’s development management and environment teams together with the council’s pollution control section. In addition all schools throughout the city were consulted on the proposed draft changes. Neighbourhood managers were contacted and letters were sent to every known hot food take away within the city (in total 244 outlets were contacted) seeking views on the draft planning policy document. A list of all those consulted is set out at Annex A. A copy of the letter which was sent to consultees is set out at Annex C.

5.3 Details of the consultation were published on the city council’s website1 and an electronic version of the covering letter and the draft SPD were available to download. Copies of all documents were also available to view at each of the city’s libraries. An article was placed in the June 2013 edition of Life IN Salford, available online2 and distributed to every home and business in Salford during the week beginning 3 June 2013. A press release was placed on the city council website on 28 May 20133 detailing the consultation. A clarification statement was then issued and published on the city council’s website on 30 May 2013. This clarified the draft policy approach to restrictions on operation of hot food take aways close to schools. There was an article in the Salford Advertiser and Manchester Evening News, five national newspapers also ran a story on the proposed changes, BBC online featured an article, in addition the children’s programme ‘Newsround’ also broadcasted an item on television. All articles published are set out at Annex D.

5.4 A summary of the main issues raised and submitted in response to the consultation on the draft SPD is set out below. Various comments were also submitted online on press publication websites in response to articles published. These again are summarised below.

5.5 The following 15 organisations and individuals submitted representations on the draft SPD:

 Anonymous  Mr P. Anastasiou  Mr P. Chamberlain  Mr J. Griffiths 1 http://www.salford.gov.uk/drafthftaspd.htm 2 http://www.salford.gov.uk/life.htm 3 http://www.salford.gov.uk/pr-13-3542.htm

5  Mr J. Harrison  Mr G. Sunbeam  Jan (no surname submitted)  McDonald’s Restaurants Ltd  Mr M. A. Mohmadi  Ms S. Miah  Mr D. Needle  Mrs M. Nugent  Mr W. Parkinson  Salford’s Health and Wellbeing Board  Mrs R. Steenson

5.6 The following 9 organisations responded to confirm that they had no comments to make:

 Coal Authority  English Heritage  Environment Agency  Highways Agency  Manchester Airport Group  Natural England  Network Rail  Oldham Council  United Utilities

5.7 A schedule of all representations received at the scoping stage and in response to the draft SPD, together with the city council’s response to how these have been taken into account in preparing the final version of the SPD for adoption are set out at Annex E.

Summary of representations submitted

5.8 Twenty four representations were received in response to the draft consultation, of these, eight statutory consultees together with one Greater Manchester council confirmed they had no comments to make.

5.9 In total 15 individuals or businesses expressed a view, and of these 12 objected whilst there were three representations offering support for the proposed changes.

5.10 Three hot food take aways formally responded to the consultation, including one national operator. The views of both the independent take away owners were that existing businesses should be protected and the opening of further establishments should be restricted where they could potentially negatively impact on existing operators. To summarise, the national hot food take away operator commented specifically in relation to the proposed restrictions near to schools, and expressed the view that they did not believe planning restrictions of this nature we an appropriate or proportionate

6 response to improve public health. Ultimately there must be flexibility for decisions to be made on a case by case basis.

5.11 Of the remaining representations, most comments related to the proposed restrictions on over the counter sales of proposed new hot food take aways. A number of these representations raised objections on more than one ground. Three individuals raised concern that the council would be unfairly restricting choice, three responses also objected on the basis that this would unacceptably impact on trading of new businesses and negatively impact on employment levels. There was a single objection to restrictions around schools given that chip shops are part of the British way of life/culture. A further comment received noted it should be the schools responsibility to ensure children undertake more physical activity. Another respondents’ view was that it should be the parents responsibility to ensure a child has a healthy diet and that chips or such like may be the only hot meal a child has in a day. A final objector suggested that there should not be an outright ban on over the counter sales before 5pm close to schools, but that hot food take aways should not be allowed to serve children unaccompanied by an adult.

5.12 All three of the respondents that offered support submitted comments in relation to the proposed new policy on restricting operation of hot food takeaways near to schools. Two of the respondents were members of the public whilst one letter of support was from Salford’s Health and Wellbeing Board. All three made reference to the importance of tackling obesity levels.

5.13 One representation also objected solely on the proposed change that would allow hot food take aways adjacent to residential properties subject to adequate odour and noise mitigation.

5.14 There were also numerous comments posted on press publication websites (both national and local) in response to articles written. Much of the extensive media coverage implied that this was a unique attempt by Salford to use planning to restrict hot food takeaways to help curb rising levels of obesity. This is misleading, as a number of other local authorities have however in the past few years introduced restrictions on new hot food take aways close to schools. Most local authorities have adopted a more stringent approach to Salford, placing an outright ban on further outlets opening close to schools, and in some instances extending this moratorium to parks, play areas and communities centres.

5.15 The large majority of comments made in response to the press articles were negative. Reviewing the content of the press articles, it may however be that some respondents thought that the council’s proposed approach to restricting hot food take aways applied to both existing and proposed businesses.

7 6.0 Previous consultations

6.1 In revising the SPD regard has also been had to comments received during the various consultations on the Core Strategy. At the pre-publication changes stage in summer 2011, NHS Salford raised concerns about the potential health implications of hot food take aways, particularly when they are located in close proximity to schools. Similar concerns were raised by the Salford Strategic Partnership Board in November 2008, but in relation to the proximity to education facilities more generally. The new policy HFTA 2 (hot food take aways and schools) addresses the issue of hot food take aways near to secondary schools.

8 ANNEX A – List of stakeholders consulted during production of the hot food take away SPD

CONSULTEE CONSULTED CONSULTED AT AT DRAFT SCOPING STAGE STAGE ACADEMY FOR RABBINICAL RESEARCH X X AGE UK X X ALDER KING X X ALDERBROOK INVESTMENTS LTD X X AMERICHEM X X ANCIENT MONUMENTS SOCIETY X X ARCHDEACON OF SALFORD X X ARMITAGE RESIDENTS ASSOC. X X ARMSTRONG BURTON PLANNING X X ARQIVA X X ASSOCIATION OF GREATER MANCHESTER X AUTHORITIES DIRECTOR’S OF PUBLIC HEALTH BANGLADESH ASSOCIATION X X BAO LTD X X BARRATT MANCHESTER LTD X X BARTON WILLMORE PARTNERSHIP X X BEECH FARM RESIDENTS ASSOCIATION X X BELLWAY HOMES LTD NORTH WEST X X BNP PARIBAS REAL ESTATE X X BOLTON METROPOLITAN BOROUGH COUNCIL X X BREEM CENTRE X X BRITISH WATERWAYS X X BROADWAY MALYAN PLANNING X X BROCK CARMICHAEL ARCHITECTS X X BUCKINGHAM BINGO X X BURY MBC X X BUSINESS CONSULTATIVE FORUM X X CA PLANNING X X CABE X X CARRINGTON PARISH COUNCIL X X CB RICHARD ELLIS LTD X X CBI - NORTH WEST OFFICE X X CENTRAL SALFORD URC X X CENTRE FOR LOCAL ECONOMIC STRATEGIES X X CERDA PLANNING X X CHESHIRE POLICE AUTHORITY X X CHESTERS COACHES X X CHRIS THOMAS LTD X X CHURCH OF ENGLAND X X CITY AIRPORT MANCHESTER LTD X X CIVIC TRUST NORTHERN OFFICE X X CIVIL AVIATION AUTHORITY X X CLA NORTH X X CLAREMONT COMMUNITY ASSOCIATION X X CLIFF WALSINGHAM AND CO. X X CLIFTON HAMLET X X CLIFTON OVER 60 X X COLLIERS CRE X X COLLIERS INTERNATIONAL X X CONTOUR HOMES X X COOPERATIVE GROUP PROPERTY DIVISION X X

9 CONSULTEE CONSULTED CONSULTED AT AT DRAFT SCOPING STAGE STAGE COPTHORNE HOTEL X X COUNCIL FOR BRITISH ARCHAEOLOGY X X COUNTRYSIDE PROPERTIES X X CPRE LANCASHIRE BRANCH X X CRAUNTON HOUSE ASSOCIATION OF TENANTS X X CTL ESTATES X X CULCHETH AND GLAZEBURY PARISH COUNCIL X X CUSSONS TECHNOLOGY X X DALTON WARNER DAVIES X X DANDARA X X DAVID WILSON HOMES X X DE POL ASSOCIATES X X DE TRAFFORDS RESIDENT ASSOC. X X DEGINSSA CC UK LTD X X DEPARTMENT OF TRANSPORT X X DEPT OF CULTURE MEDIA AND SPORT X X DISABILITY RIGHTS COMMISSION X X DIVERSITY LEADERS FORUM X X DORRIBO T/A REGIONAL MAP DISTRIBUTERS X X DPP X X DRIVERS JONAS X X ECCLES AND SALFORD MOSQUE X X ECCLES SAVINGS AND LOANS CLUB X X ELAN HOMES X X ELLESMERE ENGINEERING CO LTD X X ELLESMERE PARK RESIDENTS ASSOCIATION X X ENGLISH HERITAGE X X ENGLISH PARTNERSHIPS X X ENTEC UK LTD X X ENVIOLINK NW X X ENVIRONMENT AGENCY X X EVERGREEN X X F E BARBOR LTD X X FIRST PLAN X X FORESTRY COMMISSION NW X X FRAMPTONS X X FRIENDS, FAMILIES AND TRAVELLERS AND X X TRAVELLER LAW REFORM PROJECT FUSION X X GEORGE WIMPEY MANCHESTER LTD X X GL HEARN X X GM ARCHAEOLOGICAL UNIT X X GM POLICE AUTHORITY X X GM POLICE FORCE HQ X X GMP DESIGN FOR SECURITY X X GOVERNMENT OFFICE NORTH WEST X X GRAHAM BOLTON PLANNING X X GREAT PLACES X X GREATER MANCHESTER CHAMBER OF COMMERCE X X GREATER MANCHESTER ECOLOGY UNIT X GREATER MANCHESTER FIRE AND RESCUE X X GREATER MANCHESTER GEOLOGICAL UNIT X X GREATER MANCHESTER INTEGRATED TRANSPORT X X AUTHORITY

10 CONSULTEE CONSULTED CONSULTED AT AT DRAFT SCOPING STAGE STAGE GREATER MANCHESTER POLICE X X GREATER MANCHESTER WASTE DISPOSAL X X AUTHORITY GREENOAKS LTD X X GROUNDWORK MANCHESTER SALFORD AND X X TRAFFORD GVA GRIMLEY LTD X X HARLAND MACHINE SYSTEMS LTD X X HEALTH AND SAFETY EXECUTIVE X X HIGHAM AND CO X X HIGHWAYS AGENCY X X HILL STREET RESIDENTS ASSOCIATION X X HMP & YOI FOREST BANK X X HOLM COURT TENANTS ASSOCIATION X X HOME BUILDERS FEDERATION X X HOMES AND COMMUNITIES AGENCY X X HOURIGAN CONNOLLY X X HOW PLANNING LLP X X INSTITUTE OF DIRECTORS NORTH WEST X X IRLAM MEDICAL CENTRE X X IRWELL VALLEY HA X X J. FLETCHER (ENGINEERS) LTD X X JEWISH REPRESENTATIVE COUNCIL OF X X MANCHESTER JMP CONSULTING X X JOHN ROSE ASSOCIATES X X JWPC LTD X X KENYON RESIDENTS X X KING STURGE X X KING STURGE LLP X X KIRKWELLS X X KNIGHT FRANK LLP X X LAMBERT SMITH HAMPTON X X LANCS CIRCUIT OF JEHOVAH'S WITNESSES X X LIDL UK PROPERTIES X X MAGNESIUM ELEKTRON LTD X X MANCHESTER AIRPORT GROUP X X MANCHESTER CITY COUNCIL X X MANCHESTER DIOCESAN BOARD OF FINANCE X X MANCHESTER DOORS & CUBICALS X X MANCHESTER FRIENDS OF THE EARTH X X MANCHESTER JEWISH FEDERATION X X MANCHESTER SALFORD HOUSING MARKET X X PATHFINDER MANCHESTER SHIP CANAL COMPANY X X MATTHEWS AND GOODMAN X X MAWDSLEY BROOKS CO X X MILLER HOMES LTD X X MILLER METCALFE X X MISTER BLISTER LTD X X MOBILE OPERATORS ASSOCIATION X X MONCHEL PARKMAN X X MONTON GREEN RESIDENTS X X MORRIS HOMES (NORTH) LTD X X

11 CONSULTEE CONSULTED CONSULTED AT AT DRAFT SCOPING STAGE STAGE MORSTON ASSETS LTD X X NATHANIAL LICHFIELD AND PARTNERS X X NATIONAL FARMERS UNION X X NATIONAL FEDERATION OF GYPSY LIASION GROUPS X X NATIONAL GRID X X NATURAL ENGLAND X X NETWORK RAIL (INFRASTRUCTURE) LTD X X NEW PROSPECT X X NIMANS LTD X X NJL CONSULTING X X NORTH WEST CHAMBERS OF COMMERCE X X NORTH WEST REGIONAL LEADERS BOARD X X NOVEMBRE PROPERTIES LTD. X X NOVOTEL MANCHESTER WEST X X NPOWER RENEWABLES X X NW REGIONAL HOUSING BOARD X X NW STRATEGIC HEALTH AUTHORITY X X OFF THE RAILS LTD X X OLDHAM MBC X X ORANGE PERSONAL COMMUNICATIONS SERVICES X X LTD PARTINGTON HOUSING ASSOCIATION X X PARTINGTON TOWN COUNCIL X X PARTNERS IN SALFORD X X PAUL BUTLER ASSOCIATES X X PEACOCK AND SMITH X X PEEL HOLDINGS LTD X X PEEL INVESTMENTS LTD X X PEOPLE FIRST MANCHESTER X X PERSIMMON HOMES NW X X PLANNING POTENTIAL X X PLUSWORK LTD X X POST OFFICE PROPERTY HOLDINGS X X PRDS X X PRIMARY CARE TRUST X X RANDALL THORP X X RAPAR X X RAPLEYS X X RECLAIMING OUR COMMUNITIES X X RED ROSE FOREST X X REDROW HOMES X X REDROW HOMES (NORTH WEST) LTD. X X RIVERSIDE ISLAND TENANTS ASSOC X X RIXTON WITH GLAZEBROOK PARISH COUNCIL X X RMS INTERNATIONAL X X ROCHDALE MBC X X ROGER HANNAH AND CO. X X ROGER TYM & PARTNERS X X ROLAND BARDSLEY (BUILDERS LTD) X X RSPB X X SAFETY SYSTEMS UK LTD X X SALFORD’S BME FORUM X X SALFORD’S BME NETWORK X SALFORD CITIZENS ADVICE BUREAU X

12 CONSULTEE CONSULTED CONSULTED AT AT DRAFT SCOPING STAGE STAGE SALFORD’S CLINICAL COMMISSIONING GROUP X X SALFORD COMMUNITY NETWORK X SALFORD COUNCIL FOR VOLUNTARY SERVICE X X SALFORD CITY COUNCIL COUNCILLORS X X SALFORD CRIME AND DISORDER REDUCTION X PARTNERSIP SALFORD DEAF GATHERING X X SALFORD’S DIRECTOR OF PUBLIC HEALTH X X SALFORD’S DEPUTY DIRECTOR OF PUBLIC HEALTH X SALFORD DISABILITY FORUM X SALFORD DISABLED MOTORISTS ASS. X X SALFORD’S ENVIRONMENTAL HEALTH TEAM X SALFORD ELIM CHURCH X X SALFORD FORUM OF OLDER PEOPLE X X SALFORD HELATH IMPROVEMENT TEAM X SALFORD LINK PROJECT X X SALFORD’S HEALTH AND WELLBEING BOARD X X SALFORD’S POLLUTION CONTROL SECTION X ALL SALFORD NEIGHOUBOURHOOD MANAGERS X X ALL SECONDARY AND PRIMARY SCHOOLS WITHIN X SALFORD DETAILED AT http://www.salford.gov.uk/schoolfinder-results.htm AND http://www.salford.gov.uk/schoolfinder-results.htm SALFORD ROYAL NHS FOUNDATION TRUST WEIGHT X MANAGEMENT SERVICE SALFORD’S STRATEGIC DIRECTOR FOR CHILDREN’S X SERVICES SALFORD’S DEPUTY DIRECTOR FOR CHILDREN’S X SERVICES SALFORD YOUTH SERVICE X SALVATION ARMY X X SANDERSON WEATHERALL (ROYAL MAIL) X X SAVILLS X X SCOTT WILSON PLANNING CONSULTANTS X X SEDGWICK ASSOCIATES X X SEEDLEY AND LANGWORTHY PARTNERSHIP X X SHELTER (LONDON) X X SKILLS FUNDING AGENCY X X SOUTHGARTH RESIDENTS ASSOC. X X SPORT ENGLAND NW X X STEVEN ABBOTT ASSOCIATES LLP X X STEWART ROSS ASSOCIATES X X STOCKPORT COUNCIL X X STOREYS:SSP X X SUSTAINABILITY NORTH WEST X X SWINTON JUDO CLUB X X TAMESIDE MBC X X TARMAC CENTRAL LIMITED X X TAYLOR WIMPY UK LTD X X TESCO X X THE WILDLIFE TRUST X X THE BANK X X THE COAL AUTHORITY X X THE COOPERATIVE GROUP LTD X X

13 CONSULTEE CONSULTED CONSULTED AT AT DRAFT SCOPING STAGE STAGE THE DEVELOPMENT PLANNING PARTNERSHIP X X THE EMERSON GROUP X X THE LAWN TENNIS ASSOCIATION X X THE PLANNING BUREAU LTD X X THE SEEDLEY AND LANGWORTHY TRUST X X THE SPAB X X THE STABLES X X THE THEATRES TRUST X X THE TWENTIETH CENTURY SOCIETY X X THE WOODLAND TRUST X X THORN COURT TENANTS ASSOC. X X TRAFFORD MBC X X TRANSPORT FOR GREATER MANCHESTER X X TURLEY ASSOCIATES X X TYLER PARKES PARNERSHIP X X UK COAL HEAD OFFICE X X UNITED COOPERATIVES LTD X X UNITED UTILITIES X X UNITED UTILITIES PROPERTY SERVICES X X X X URBAN VISION DEVELOPMENT MANAGEMENT TEAM URBAN VISION ENVIRONMENTAL SERVICES X X VINCENT AND GORBING X X VIRIDOR X X WAINHOMES (NW) LTD X X WALTON & CO X X WARRINGTON BOROUGH COUNCIL X X WEASTE COMMUNITY WATCH X X WELLINGTON STREET WEST RESIDENTS ASSOC. X X WESTHOUGHTON TOWN COUNCIL X X WHITE YOUNG GREEN PLANNING X X WIGAN COUNCIL X X WILLIAM SUTTON HA LTD X X WRIGHTINGTON PARISH COUNCIL X X HAZEL BLEARS MP X X BARBARA KEELEY MP X X MR GRAHAM STRINGER MP X X PETER BALL X X MR DJ BANKS X X DEREK BUTTERWORTH X X L CHAPPELL X X RICHARD FEARNALL X X CHRISTOPHER GRAY X X GARY JAMES X X TERRY MANFORD X X MR NAZAR X X CM PATEL X X BERYL PATTEN X X R QURESHI X X K TAYLOR X X MR P TRAYNOR X X MRS P WALKER X X B WETHERALL X X

14 15 HOT FOOD TAKE AWAYS CONSULTED AT DRAFT STAGE BUSINESS NAME ADRESS Ackroyd's 217 Monton Road Adams Deli Ground Floor, 318 Great Clowes Street Albion Plaice 106 Seaford Road Ali Shaan 185 Littleton Road Ali's kitchen 86b Liverpool Road Alizak's Takeaway 172 Moorside Road American Southern Fried Chicken 6 Moorfield Parade Amigos Pizza 676 Bolton Road Andertons Fish and Chips 2 St James Road Balti Massala 579 Liverpool Road Barmpots 437 Chorley Road Barton Oriental 82 Barton Road Bo Wah 49 Russell Road Bon Appetite 220 Monton Road Bonnie Kitchen Hut 311 Lower Broughton Road Broughton Balti Massala 312 Lower Broughton Road Broughton Fish Bar 7 Basten Drive Buttered Muffin 522 Liverpool Road By the Slice Pizza Company 2 Chapel Street Caddy Fried Chicken 565 Liverpool Road Cadishead Charcoal Grill 192C Liverpool Road Captain Cod 189 Eccles Old Road Caribbean Flavas 187 Chapel Street Caribbean Nice Tasty 149 Eccles New Road Castle Chippy 67 Blackfriars Road Champion's Takeaway 674 Bolton Road Chandos Fish and Chips 102 Chandos Grove Chan's Chippy 70 Liverpool Road 18-19 King Edwards Buildings, Bury Old Cheetham Star Road Cherokee Chicken 348 Bolton Road Chicago Fried Chicken 177 Liverpool Road Chicken Cottage 10 Union Terrace, Bury Old Road Chilli 72A Broad Street China China 205 Chorley Road China Kitchen 438 Liverpool Road China Xpress 10 Standfield Shopping Centre Chinese Express 10 Lower Monton Road Chippy Tease 77 Eastham Way Chiu's Fish and Chips 323 Liverpool Road Chungs Chippy 19 Oldfield Road Cinnamon 285 Liverpool Road Clifton Cod 6 The Green Continental Pizza 118 Church Street Curry Hut 1 High Street

16 17 ANNEX B – Covering letter to consultees on scoping stage

18 19 ANNEX C – Covering letter to consultees on draft stage

20 21 22 23 Annex D - Press Articles http://www.bbc.co.uk/news/uk-england-manchester-22700415

BBC Online. Published 29 May 2013.

Daytime takeaway food sales could be banned near Salford schools

The new plan would ban the sale of hot food within 400m (1,300ft) of a school

Takeaways near schools in Salford could be banned from selling "hot food over the counter" before 17:00 to encourage children to eat healthily.

The ban would affect new outlets opened within 400m (1,300ft) of a school.

Data released by the National Child Measurement Programme in 2012 showed 35% of 10 and 11-year-olds in Salford were overweight or obese.

Councillor Margaret Morris said the changes would ensure new outlets do not have "a negative impact on the city".

The city council has proposed the ban.

Mrs Morris said that while planners "cannot control the food that is sold", the council would encourage new takeaways to "offer well promoted healthy alternatives, so people can have an informed choice about the food they eat".

She added "public health and helping to reduce obesity levels" was a "top priority" for the council.

"Takeaways create jobs and provide a service but these ideas are to make sure that they are opening in the right places."

The proposals - which could also limit the opening hours of businesses in "areas with problems of crime" -are open to public consultation until 5 July.

24 http://www.dailymail.co.uk/news/article-2333087/Takeaways-near-citys-schools-face-ban- serving-chips-5pm-bid-tackle-childhood-obesity.html

Daily Mail. Published 30 May 213

Takeaways near city's schools face a ban on serving chips before 5pm in bid to tackle childhood obesity

A city's takeaways could be banned from serving hot food during school hours under plans to tackle childhood obesity.

Chip shops, kebab houses and fast-food chains such as McDonald’s near schools would not be allowed to serve hot food to any customers – including adults – before 5pm in a shake-up of planning regulations put forward by Salford council.

Margaret Morris, the council’s assistant mayor, said: ‘Takeaways create jobs and provide a service, but these ideas are to make sure they are opening in the right places and not having a negative impact.

‘We don’t think they should be serving hot food before 5pm near schools, as children should be encouraged to eat healthily.

'Public health and helping to reduce obesity levels are a top priority, and while planners cannot control the food that is sold we would like every new premise to offer well promoted healthy alternatives so people can have an informed choice about the food they eat.

'Residents are encouraged to come forward with any comments or suggestions so they can be taken into consideration before a decision is made on the future of planning in our city.'

Last year, Salford officials announced they wanted a ban on mobile takeaway and ice cream vans near schools, but the new policy, which would apply only to new takeaways, extends this to permanent fast-food premises.

But Vas Felini, manager of Neil’s Fryery in Salford, said: ‘This is ridiculous. Nothing is more healthy than fresh fish.

'And chips cooked the right way are nutritious. It should be down to kids’ parents what they eat.’

Local residents were sceptical about whether the idea would work.

Nursery nurse Rebecca Hanlon-Jones, 23, said: 'I don’t think it will work. Obesity starts at home, and it depends much more on what the parents are feeding them the rest of the time.

'The ban would hit grown-up workers too - maybe that’s a good thing as some of them need it.'

25 The plans are not the first time a council has tried to tackle obesity by cracking down on takeaways – in 2011, Oldham council considered bringing in a £1,000 ‘fat tax’ on hot food traders, but the plan was scrapped.

26 http://www.express.co.uk/news/health/403654/Bid-to-ban-chips-in-school-hours

The Express. Published 30 May 2013.

Bid to ban chips in school hours

TAKEAWAYS could be banned from serving chips during school hours to combat child obesity.

Officials at Salford City Council want a “no chips before 5pm”

Officials at Salford City Council want a “no chips before 5pm” rule to stop pupils buying unhealthy lunches or nipping in for a snack on the way home.

Assistant mayor for health Margaret Morris said they wanted to encourage children to eat healthily.

But Vas Felini, manager of a local chippy, hit out at the plans.

He said: “What will they do next, ban newsagents who sell fizzy drinks and crisps? Nothing is more healthy than fresh fish”.

“And chips cooked the right way are quite nutritious.”

Two years ago the council failed in an attempt to impose a £1,000 “fat tax” on fast food.

27 http://www.huffingtonpost.co.uk/2013/05/29/ban-chips-before-five-to-tackle-obesity-salford- _n_3350864.html?utm_hp_ref=uk

Huffington Post. Published 29 May 2013.

Ban Chips And Hot Food Before 5pm To Tackle Obesity, Suggests Salford Council

Selling hot food, including chips, to school children before 5pm could be banned in controversial measures being considered by a council, in an effort to curb childhood obesity.

Any new takeaways, kebab shops and fast food restaurant such as McDonalds could all be banned from serving hot food over the counter during school hours, reports the Manchester Evening News.

Councillor Margaret Morris, assistant mayor for health at Salford council, told the newspaper: "Takeaways create jobs and provide a service but these ideas are to make sure that they are opening in the right places and not having a negative impact in our city.

“We don’t think they should be serving hot food over the counter before 5pm near schools, as children should be encouraged to eat healthily, so we have made this clear in our proposal."

But some local business owners in the area have described the proposals as "ridiculous".

Jazz Caur, the manager of Subway store next to a school on Hankinson Way, told the Huffington Post UK: "Would they rather not have our money and lose our business altogether? Most of these kids don't have breakfast and they come to my shop for a sausage butty. The kids tell me they just serve junk food at school anyway. We're probably healthier than that."

Andrew Crook, treasurer of the National Association of Fish Fryers told Huff Post UK: "Fish and chips aren't as unhealthy as people are led to believe.

"The majority of children pass by takeaways in the morning with sugary drinks and sweets having been to the newsagents. Are they going to ban Tesco Express and newsagents as well?

"We would definitely be in opposition to the proposals. This is something schools should be monitoring, not takeaways."

28 http://www.independent.co.uk/life-style/health-and-families/health-news/pupils-face- takeaway-ban-in-bid-to-fight-childhood-obesity-8636702.html

The Independent. Published 29 May 2013.

Pupils face takeaway ban in bid to fight childhood obesity

Restaurant owners in Salford hit out over proposals to restrict sale of hot food to children

Selling hot food to school children before 5pm could be banned in measures being considered by a town hall, in an effort to curb childhood obesity.

Any new takeaways, kebab houses, fish and chip shops and chains – such as McDonald’s and KFC – located close to schools would not be allowed to serve hot food over the counter during school hours under Salford council’s proposals.

The suggested regulations – open to public consultation until 5 July – are part of a nationwide trend of councils targeting growing rates of childhood obesity by bringing the fast food industry under tighter control. Several local authorities have already banned takeaways from opening close to schools, youth clubs and parks.

Waltham Forest, in east London, was the first to begin turning down applications from those who wanted to set up takeaways near schools – and since then scores of other councils have followed suit. Oldham Council also considered bringing in a £1,000 “fat tax” on hot food traders in 2011, before it was scrapped by Labour.

Andrew Cook, treasurer of the National Federation of Fish Friers, who owns fish and chip shops in Preston, said of Salford’s proposals: “This is penalising business unnecessarily. One of my shops is right next to a secondary school but the people who come in at lunchtime are all working folk, not school kids. Every morning I see children going to the newsagents next door and buying sweets, chocolates and pies – and that’s not healthy. But we’re an easy target.”

Professor David Haslam, chairman of the National Obesity Forum, said: “Just keeping fast food restaurants shut won’t make any difference to the obesity problem because children can still go down to the sweet shop and get a bag of crisps. I’m pleased that people are thinking about how to tackle the obesity problem, but on its own this is too little.”

The ban would affect new outlets opened within 400m of a school.

Councillor Margaret Morris, assistant mayor for health at Salford council, said: “Takeaways create jobs and provide a service, but these ideas are to make sure that they are opening in the right places and not having a negative impact in our city. We don’t think they should be serving hot food over the counter before 5pm near schools, as children should be encouraged to eat healthily, so we have made this clear in our proposal.”

But Vas Felini, manager of Neil’s Fryery chip shop on Salford’s Langworthy Road, was unimpressed. He said: “I’m against it. What will they do next, ban newsagents who sell fizzy drinks and crisps? Fish and chips is traditional. Nothing is more healthy than fresh fish. And chips cooked the right way are nutritious. It should be down to kids’ parents what they eat.” 29 http://www.manchestereveningnews.co.uk/news/greater-manchester-news/ban-selling- chips-before-5pm-4025795

Manchester Evening News. Published 29 May 2013

Ban selling chips before 5pm, say Salford council, in a bid to fight childhood obesity Chippies, kebab houses and chains such as McDonald’s would not be allowed to serve hot food over the counter before 5pm under the plans being proposed by Salford council.

Vas Felini, of Neil’s Fryery, says ‘chips cooked the right way are nutritious' Takeaways could be banned from serving chips during school hours – under new anti- childhood obesity rules being looked at by a town hall.

Chippies, kebab houses and chains such as McDonald’s would not be allowed to serve hot food over the counter before 5pm under the plans being proposed by Salford council.

It is one of a raft of new rules being considered in a shake-up of planning regulations, with Salford asking the for the public’s views before pushing ahead.

Under the changes, which would only apply to new takeaways applying for a licence, town hall officials also want to:

 Lift a ban on takeaways opening next to residential houses and flats because extractor fans have got better

 Oblige takeaways ‘not to worsen’ crime and disorder caused by drunken revellers

 Strike out a ‘healthy eating’ clause from the planning code, because the council says it is unenforceable.

The plans are not the first time a council has tried to tackle obesity by cracking down on takeaways.

Oldham council considered bringing in a £1,000 ‘fat tax’ on hot food traders in 2011, before it was scrapped by Labour.

Earlier this month, Salford announced a new one-to-one ‘health coaching’ scheme in a bid to cut soaring rates of diseases associated with alcoholism, binge eating and smoking.

It announced last year that it was thinking of bringing in a ban on mobile takeaway and ice cream van trucks near schools – but the new policy would extend this to permanent takeaways.

Coun Margaret Morris, assistant mayor for health at Salford council, said: “Takeaways create jobs and provide a service but these ideas are to make sure that they are opening in the right places and not having a negative impact in our city.

30 “We don’t think they should be serving hot food over the counter before 5pm near schools, as children should be encouraged to eat healthily, so we have made this clear in our proposal.

“Public health and helping to reduce obesity levels are a top priority, and while planners cannot control the food that is sold we would like every new premise to offer well promoted healthy alternatives so people can have an informed choice about the food they eat.

“Residents are encouraged to come forward with any comments or suggestions so they can be taken into consideration before a decision is made on the future of planning in our city.”

But Vas Felini, manager of Neil’s Fryery chippy on Langworthy Road, hit out at the plans.

He said: “I’m against it. What will they do next, ban newsagents who sell fizzy drinks and crisps?

“Fish and chips is traditional. Nothing is more healthy than fresh fish. And chips cooked the right way are nutritious. It should be down to kids' parents what they eat.”

You've got fat chance of selling this one to the people of Salford... It’s just more council bureaucracy. The kids aren’t allowed out of school round here anyway so what's the point? And most kids find a way of eating what they like whatever the rules.

Retired Jim Dylan, 77, of Manchester Road, Swinton

I don’t think it will work. Obesity starts at home, and it depends much more on what the parents are feeding them the rest of the time. The ban would hit grown-up workers too - maybe that’s a good thing as some of them need it!

Nursery nurse Rebecca Hanlon-Jones, 23, of Manchester Road, Swinton

As a mum, I just think kids will go further afield to find chips. It is nannying, really. It should be up to parents what kids eat. But it’s a tough one – some parents don’t feed their children well so what happens at school can make a difference.

Finance worker Sue Leigh, 44, of Deans Road, Swinton

What with the obesity epidemic, I would grudgingly say yes, it is a good idea. I think it could cut obesity, for sure. It’s definitely worth a try.

Order picker Robert Harvey, 36, of Station Road, Swinton

31 http://www.mirror.co.uk/news/uk-news/takeaways-banned-selling-chips-during-1919550

The Mirror. Published 29 May 2013.

Takeaways could be banned from selling CHIPS during school hours to tackle childhood obesity The plan would hit new chip shops, kebab houses and leading fast food chains such as McDonald’s – and has outraged traders.

Takeaway shops could be banned from selling chips during school hours under a council’s plan to encourage healthy eating.

The plan would hit new chip shops, kebab houses and leading fast food chains such as McDonald’s – and has outraged traders.

Local chippy boss Vas Felini said: “What next – a ban on selling fizzy drinks and crisps?

"Chips cooked the right way are nutritious. It should be down to parents what kids eat.”

And nursery nurse Rebecca Hanlon-Jones, 23, claimed the ban would also stop grown- ups buying chips.

Salford City Council said the public would be consulted.

A spokesperson added: “These ideas are to make sure takeaways are opening in the right places and not having a negative impact in our city.”

32 http://www.planningresource.co.uk/bulletin/planningdaily/article/1184362/salford-consults- fast-food-policy-changes/

Planning. Published 30 May 2013.

Salford consults on fast food policy changes

Measures to ensure fast food outlets serve food only after 5pm if they are located near schools are among a series of changes to Salford City Council's planning policy on hot food takeaways which have been put out for consultation.

The council is currently consulting on a revised draft of its existing hot food takeaways supplementary planning document (SPD). This is intended to update and replace the current document.

Salford said it considered it necessary to update the hot food takeaways SPD in order to reflect the National Planning Policy Framework and changes to legislation and guidance since the document was first adopted. It also said that recent planning appeal decisions in Salford had informed the need for revisions.

The key proposed changes to the supplementary planning document are:

 Inclusion of a new policy which places restrictions on the operation of hot food takeaways around schools to support and encourage children to make healthier eating options.  Inclusion of a new policy to ensure hot food takeaways do not worsen any existing problems of crime and disorder.  Deletion of a current policy on hot food takeaways and residential properties. The council said that this follows recent appeal decisions in which planning inspectors concluded that extraction equipment can adequately mitigate harm arising from odours even where there is an adjoining residential property.  The existing policy approach to odours has been altered to focus on unacceptable noise levels from odour control equipment where a residential property is adjacent to a proposed hot food takeaway.  Deletion of the council's current policy on healthy eating options. Salford said that as the current policy only 'encourages' takeaways to introduce healthier options, and is not a requirement, "there is no clear indication of how a decision-maker or applicant for planning permission should react. On this basis, it is considered more appropriate to include a section on healthy eating in the SPD but not as part of a policy".

Margaret Morris, Salford Council's assistant mayor for health and wellbeing, said: "Takeaways create jobs and provide a service, but these ideas are to make sure that they are opening in the right places and not having a negative impact in our city.

"We don't think they should be serving hot food over the counter before 5pm near schools, as children should be encouraged to eat healthily. So we have made this clear in our proposal.

"Public health and helping to reduce obesity levels are a top priority. While planners 33 cannot control the food that is sold, we would like every new premise to offer well promoted healthy alternatives so people can have an informed choice about the food they eat."

34 http://www.salfordonline.com/localnews_page/43208- call_for_comment_on_salford_takeaways.html

Salford Advertiser. Published 28 May 2013.

Call for comment on Salford takeaways

Salford City Council is calling for residents to comment on whether new takeaways should be restricted from opening near schools.

Only serving food over the counter after 5pm near schools is just one of the suggestions that Salford City Council has put forward to amend the planning rules in the city, which were last updated in 2006.

Other proposals include ensuring hot food takeaways do not worsen any existing problems of crime and disorder.

People have until Friday 5 July to have their voices heard. Comments can be submitted online here.

Councillor Margaret Morris, Assistant Mayor for Health and Wellbeing at Salford City Council said: “Takeaways create jobs and provide a service but these ideas are to make sure that they are opening in the right places and not having a negative impact in our city.

“We don’t think they should be serving hot food over the counter before 5pm near schools, as children should be encouraged to eat healthily, so we have made this clear in our proposal.

“Public health and helping to reduce obesity levels are a top priority, and while planners cannot control the food that is sold we would like every new premise to offer well promoted healthy alternatives so people can have an informed choice about the food they eat."

You can also email [email protected], or write to SPD Consultation, Spatial Planning, Salford City Council, Civic Centre, Chorley Road, Swinton, M27 5BY.

35 http://www.telegraph.co.uk/health/healthnews/10086060/Takeaways-face-chip-ban-during- school-hours.html

The Telegraph. Published 29 May 2013.

Takeaways face chip ban during school hours

Takeaways could be banned from serving chips during school hours under possible new rules aimed at tackling childhood obesity.

Takeaways could be banned from serving chips during school hours under possible new rules aimed at tackling childhood obesity Photo: AP

Chip shops, kebab houses and fast food chains such as McDonald's would not be allowed to serve hot items over the counter before 5pm under plans being proposed by Salford City Council.

The change is among a raft of new rules being considered in a shake-up of planning regulations, with Salford asking for the public's views before proceeding.

Under the plans, which would only apply to new takeaways applying for a licence, town hall officials also want to:

:: Lift a ban on takeaways opening next to residential houses and flats because extractor fans have improved;

:: Oblige takeaways “not to worsen” crime and disorder caused by drunken revellers;

36 ANNEX E: Schedule of representations submitted at the draft consultation stage

Key Representations submitted at the draft consultation stage (references: 001-024) Representations submitted at the scoping consultation stage (references: a-c)

Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) a Barbara Keeley Concern is raised regarding the potential impact of hot These issues are covered in broad terms in MP food take aways on local areas and local centres. In saved UDP policy S4. The revised SPD provides particular, there is a need to take into account: further details.

 the impact on residential areas; The previous policy HFTA 1 (hot food take  the potential for noise; aways and residential properties) is removed  the potential for rubbish and vermin; from the revised SPD, as decisions based on it  the concerns of residents; and have been overturned at five recent appeals.  the need to protect the quality of the residential Other policies in the revised SPD however seek environment. to ensure that residential amenity is given adequate protection. For example, new policy HFTA 3 controls hours of opening, new policy HFTA 4 (a revision of the previous policy HFTA 5) controls odours and noise, requiring appropriate extraction equipment and sound proofing, and a new policy HFTA 5 seeks to ensure that hot food take aways do not lead to any increase in anti-social behaviour.

New policy HFTA 1 in the revised SPD updates the previous policy HFTA 2, and seeks to ensure that there is no over concentration of hot food 37 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) take aways that would detract from the vitality or viability or town centres or local centres.

New policy HFTA 6 addresses disposal of waste products and seeks appropriate management of waste on site, whilst new policy HFTA 7 requires that litter bins are available for patrons of hot food take aways. b Network Rail Network Rail confirmed they had no comments to There are no implications for the SPD. make on the content of the previous SPD at the scoping consultation stage. c The Coal The Coal Authority confirmed they had no comments There are no implications for the SPD. Authority to make on the content of the previous SPD at the scoping consultation stage. 001 Anonymous You say you will stop all hot food being served in Research indicates that the most popular time certain stores/take outs during school hours to tackle for purchasing food from shops is after school childhood obesity when clearly children should be in and many secondary school children may also school during these hours, so really the only people leave school premises at lunchtime. you are stopping eating is the general public. Permitting hot food take aways to only serve I think a better plan would to have them still open for children when accompanied by an adult would the public, but state they should not serve to children prove extremely difficult to enforce from a without a parent. Surely that makes more sense than a planning point of view. full ban? The restrictions on the operation of hot food take aways (new policy HFTA2) will not apply retrospectively to existing hot food take away businesses, only new businesses. 38 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable)

Following on from the draft consultation changes have been made to new policy HFTA 2. The restrictions on over the counter sales will only apply to locations close to secondary schools Monday to Friday. This is considered to be a reasonable approach and the basis for changes are: there would seem to be insufficient evidence at the present time to suggest primary school pupils have the same degree independence as secondary school children in terms of travelling to and from school; and it would seem unnecessary to apply the policy on a Saturday and Sunday given children do not attend school on these days.

Overall the final policy approach is considered to be an appropriate balance between protecting the health of children and enabling new businesses to become established.

002 Mr P. Anastasiou The council is not supporting existing small Competition between similar uses is not a businesses, despite this being central government material planning consideration. Policy HFTA 1 policy. Another hot food outlet has now opened up and in the revised SPD updates the previous policy couple of doors down despite only recently a food HFTA 2, and seeks to ensure that there is no outlet opening on the opposite side of the road and over concentration of hot food take aways that another within the hospital. would detract from the vitality or viability or town centres or local centres. An area of land previously used for customer car 39 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) parking has also now been taken over by the council Regarding the use of the adjacent land by the and is now primarily used by those visiting relatives at council, any issues regarding land ownership are the hospital. not within the remit of the planning system.

003 Mr P. In some ways I can see that there are too many take New policy HFTA 1 updates the previous policy Chamberlain aways spring up, but who is at fault? Well no need to HFTA 2, and seeks to ensure that there is no look far, for the answer lies with the council planning over concentration of hot food take aways that department. would detract from the vitality or viability or town centres or local centres. In the 1970s there could not be the same type of shop with in a certain distance from each other but pubs was The restrictions on the operation of hot food take the only thing that there was more of. In my day we aways (new policy HFTA2) will not apply went from one school to the other for lessons and retrospectively to existing hot food take away there was one chippy which worked with the school businesses, only new businesses. back then. Also shops closed on Wednesday afternoon, not today and also some fast food leaflets The draft policy has now been amended, we get in Eccles already are only open from 4pm so applying the restrictions only to secondary they get no dinner trade. schools Monday to Friday. This is considered to be a reasonable approach and the reasons for If you decide to force this nanny state (big brother) on changes to the policy are: there would seem to us and take aways not open till 5pm how many people be insufficient evidence at the present time to are going to be unemployed? suggest primary school pupils have the same degree independence as secondary school Unfortunately I see big business forcing some children in terms of travelling to and from school; problems on you. They would pay a fine that you would and it would seem unnecessary to apply the enforce on them and just carry on regardless. Lets policy on a Saturday and Sunday given children have a look at something you could try bring big do not attend school on these days. business to the high street and not build large stores, 40 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) take for example Tesco. Overall the final policy approach is considered to provide an appropriate balance between Tesco want every 3 miles a store in place so protecting the health of children and enabling Superstore Irlam Small Extra in Monton and Petrol new businesses to become established. Station Extra Eccles. Now you gave permission to have large superstore in Eccles (West One) they say In response to other issues raised, that they will have 400+ parking which in a way are concentrations of supermarkets within the city is already there so that's wrong and they have a outside the scope of this supplementary superstore in Salford Pendleton you need to sort this planning document, and the positioning of first. double and single yellow lines is not within the remit of the planning system. Getting business back on the high street and slowly you would get rid of take aways, but to do this you will need to remove yellow lines this killed the High Street.

Also can I just say how are the council workers at Swinton (town hall) going to survive, because they walk into Swinton town centre and go to fast food establishments. So no Greggs, Subways, Geenhaighs, Morrisons Sandwiches, small bakeries selling cakes and pies, also in that case no Pubs sell fast food either.

You need to look at school food first and that way you could educate the next generation.

Remember no fast food companies no employment, council tax, or investment in the area.

41 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) 004 Coal Authority The Coal Authority confirmed they had no comments There are no implications for the SPD. to make on the content on the draft SPD.

005 English Heritage English Heritage confirmed they had no comment to There are no implications for the SPD. make on the content of the draft SPD.

006 Environment The Environment Agency confirmed they had no There are no implications for the SPD. Agency comment to make on the content of the draft SPD.

007 Mr J. Griffith What a ridiculous idea to not sell hot food during the The restrictions on the operation of hot food take day. The British chip shop has been part of our lives aways (new policy HFTA2) will not apply for generation after generation, now there is a retrospectively to existing hot food take aways, suggestion they should not open at lunchtime. Surely only new businesses, and will only affect a small obesity is more likely to be caused by people eating area of the city in locations close to secondary takeaways etc. later in the evening? Not having a schools Monday to Friday. traditional British meal at lunchtime. Scrap this idea now. Since there are approximately 250 existing hot food take away businesses in the city, the policy is unlikely to unduly restrict access to popular food choices such as fish and chips.

008 Mr J. Harrison There are some good takeaways near schools that are The restrictions on the operation of hot food take used by adults, for lunch, and a few that only open for aways (new policy HFTA2) will not apply lunch. By restricting opening time, you are depriving retrospectively to existing hot food take aways, some people, like drivers, and losing people working in only new businesses, and will only affect a small takeaways their jobs. area of the city in locations close to secondary schools Monday to Friday.

Since there are approximately 250 existing hot 42 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) food take away businesses in the city, the policy is unlikely to unduly restrict access to these popular and convenient food choices.

009 Highway Agency The Highway Agency confirmed they had no comment There are no implications for the SPD. to make on the content of the draft SPD.

010 Jan (no surname I am sorry but your taking peoples’ choice away, it is The restrictions on the operation of hot food take provided) up to the person what they eat and whether its aways (new policy HFTA2) will not apply reference to food or anything else this country is fast retrospectively to existing hot food take aways, becoming a police state, I work in the health service only new businesses, and will only affect a small and I know there is a problem with obesity, but you area of the city in locations close to secondary cannot take peoples’ choice away it’s up to them want schools Monday to Friday. they want to eat, drink smoke whatever, I'm sorry but this will not be popular at all. Since there are approximately 250 existing hot food take away businesses in the city, the policy is unlikely to unduly restrict access to these popular and convenient food choices.

011 Manchester Manchester Airport Group confirmed they had no There are no implications for the SPD. Airport Group comment to make on the content of the draft SPD.

43 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) 012 McDonalds McDonalds Restaurants support the aim of this policy McDonalds Restaurants Ltd views have been Restaurants Ltd to improve health but object on the basis that they do considered. The city council has also reviewed not believe planning restrictions of this nature are an other councils (emerging) policies and inspector appropriate or proportionate response to improving comments referred to in the representation. public health, as there must be flexibility for decisions to be made on a case by case basis. Each of the councils referred to by McDonalds are unique in the particulars of their case and The reservations of three planning inspectors to other policy approaches vary to that proposed by planning authorities emerging 400 metre moratorium Salford. Nonetheless, it is recognised that a policies are highlighted. These being Newham core proportionate approach should be taken to the strategy4, also South Ribble5 and Chorley6 allocations problem of obesity. and development management policies development plan documents. All three inspectors raise concern in Following on from the draft consultation changes respect of the evidence base. The Newham inspector have been made to new policy HFTA 2. The also noted that any approach should be proportionate restrictions on over the counter sales will only to the problem. apply to locations close to secondary schools Monday to Friday. This is considered to be a It is requested that if the council does wish to pursue reasonable approach and the basis for changes this policy, there is a need to justify the exclusion of A1 are: there would seem to be insufficient and A3 use class retailers, or to include them in the evidence at the present time to suggest primary policy. It is also requested that a similar approach to school pupils have the same degree the London Borough of Hackney’s Publication independence as secondary school children in Development Management Local Plan7 where terms of travelling to and from school; and it proposed policy DM12 sets out: Proposals for hot food would seem unnecessary to apply the policy on take-aways (A5 uses) that sell food considered to be a Saturday and Sunday given children do not

4 Report to London Borough of Newham Council, 13 January 2012, Geoff Salter Planning Inspector, The Planning Inspectorate 5 Letter to South Ribble Borough Council, 29 April 2013, Susan Heywood Planning Inspector, The Planning Inspectorate 6 Letter to Chorley Borough Council, 1 May 2013, Shelagh Bussey Planning Inspector, The Planning Inspectorate 7 London Borough of Hackney Development Management Local Plan, Publication Version, July 2013 44 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) unhealthy may not be granted planning permission if attend school on these days. proposed within 400 metres of the boundary of a secondary school, excluding locations in the Borough’s The final policy approach is considerably less shopping centres. Applicants are required to submit restrictive than the moratoriums imposed by information detailing the nutritional content of food to some other local authorities and is thought to be sold, and cooking practices employed. If A5 uses provide an appropriate balance between striving are permitted, conditions will be applied to regulate the to protect the health of children and enabling change in nature of A5 uses to ensure that businesses new businesses to become established. selling food considered to be unhealthy do not operate from the premises. It is recognised that the provision of unhealthy food is not the sole preserve of hot food take aways. A1 and A3 uses do sell a wide variety of goods and it is true that some of the goods that they sell are not conducive with healthy eating. This however tends to be a far smaller proportion of the goods on offer and it would seem unreasonable to restrict their operation on this basis.

Most businesses falling within the ‘A’ use classes in the first instance are directed to defined centres through national policy but there are clear benefits in terms of locating for instance, some small scale convenience stores within residential areas to cater for local needs and top up shopping. By applying the policy to A1 uses, this could be perceived to be an unjustified restriction on access to day to day services. 45 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable)

It would seem logical to assume that children do not visit restaurants during school lunchtimes given they are unlikely to be affordable. Cafes may sell unhealthy food at a price which is attractive to children but it is likely that they will also sell a wider range of healthier options. Furthermore, any restrictions imposed on cafes would also affect restaurants given they fall within the same use class.

Hackney’s proposed approach has not yet been subject to examination. The policy approach as it stands would seem somewhat difficult to enforce in terms of ensuring healthy food continues to be sold from the premises. Furthermore, at the onset it would seem difficult for the decision maker to make a judgement on at what point the type and /or proportion of unhealthy food deems the proposal to be unacceptable. The policy would also seem to be contrary to the guidance in the NPPF (paragraph 153) which sets out “only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plans”.

013 S. Miah I am writing in regards to the planning documents for Competition between similar uses is not a 46 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) 306 Lower Broughton Rd which I have received from material planning consideration. Policy HFTA 1 Salford council. I decline on giving planning permission in the revised SPD updates previous policy for a hot food takeaway. My reasons being there are HFTA 2, and seeks to ensure that there is no too many takeaways within the area, taking the over concentration of hot food take aways that economy into consideration business are really low would detract from the vitality or viability of town having another food place won’t help. It’s already hard centres or local centres. to keep the business going, There is around 5 -6 hot food place on street alone so I hope you take my The revised SPD does not directly address the request into consideration. issue of concentrations of hot food take aways outside of defined centres but saved UDP policy S4 addresses the cumulative effect of such uses whether in or out of defined centres.

014 Mr M. A. We have 5 schools around us and hot take away food Comments noted in relation to schools and hot Mohmadi is an unhealthy option for our children. More take food take aways. aways will increase the existing problems of crime and disorder in the Monton area. In response to comments on crime and disorder, it is not to suggest that hot food take aways are inherently problematic in generating disturbance. Nor is anti-social behaviour an inevitable consequence of such premises. Nonetheless hot food take aways can often attract a gathering of people, which particularly at night can exacerbate existing problems of crime and disorder.

Where there are existing concerns over crime and anti-social behaviour in an area, an applicant may be required to provide or 47 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) contribute to deterrent measures, alternatively hot food take aways may be limited in their opening hours. Any restrictions/financial contributions will be imposed based on the advice from Greater Manchester Police.

015 Natural England Natural England confirmed they had no comment to There are no implications for the SPD. make on the content of the draft SPD.

016 Mr D. Needle It is the parents’ responsibility to ensure their children Parents, schools and health services all have eat appropriately, and there are many ways of doing responsibility to encourage children to eat this without limiting trading hours. Even if a school healthily and when more calorie rich food is child were to eat 'hot food' from a take away most days consumed this should be part of a balanced diet of the week for their lunch this could form part of a and eaten in moderation. reasonably healthy diet if the parent's provided adequately for breakfast and dinner. Limiting trading Hot food takeaways do not directly cause hours would likely have a huge effect on the potential obesity but the majority of premises offer food revenue of a takeaway, limit choice of available food which is energy dense and nutritionally poor, for local residents, and is an unnecessary intervention. which can contribute to obesity. Hot food If this amendment is to be included it requires serious takeaways within easy walking distance to thought and clarification as not all 'hot food' from a schools provide an attractive and affordable food takeaway is detrimental to health. For instance, jacket option for pupils and could be a contributing potato, poached egg sandwiches and properly cooked factor to unhealthy eating habits in children and fish are all healthy choices that could be available from rising levels of childhood obesity. a hot food takeaway. These choices would, I assume, also be restricted. Furthermore, particularly through Some children who consume unhealthy food winter months, it may well be beneficial for school from hot food take aways could have a relatively children to eat a hot lunch - even if it is chips. Some of balanced diet and may be consuming healthy 48 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) these children may well not eat breakfast or be food choices for all other meals. Conversely, for provided with a nutritious hot dinner. To combat child some pupils the school lunch may be their only obesity the focus should be on suitable parenting. nutritionally balanced meal of the day. By restricting access to hot food take aways close I do not agree that the Council should impose to secondary schools, this should not deny regulations that inhibit free choice for the sale and children of a hot meal as it would be expected purchase of hot food. that, especially during the winter months, schools should be providing hot (and nutritious) food as a lunchtime option.

Influencing types of food sold by a hot food take away is outside the remit of the planning system and would prove difficult to enforce. It is recognised that hot food take aways are not the only means of accessing unhealthy food choices, and some may provide healthier options, most do however predominantly sell unhealthy foods.

The restrictions on the operation of hot food take aways (new policy HFTA 2) will not apply retrospectively to existing hot food take aways, only new businesses, and will only affect a small area of the city in locations close to secondary schools Monday to Friday.

Since there are approximately 250 existing hot food take away businesses in the city, the policy is unlikely to unduly restrict access to these 49 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) popular and convenient food choices to the majority of the city’s residents.

017 Network Rail Network Rail confirmed they had no comment to make There are no implications for the SPD. on the content of the draft SPD.

018 Oldham Council Oldham Council confirmed they had no comment to There are no implications for the SPD. make on the content of the draft SPD.

019 Mrs M. Nugent Superb idea. I think this whole outlook, policy change Comments noted. is excellent. As a nation we can no longer afford to support obesity through our NHS. Obesity is dangerous, it cannot be seen as curvy and big is beautiful. It is dangerous. Salford is making a brave stance on thus and other authorities should follow.

020 W. Parkinson A ridiculous idea. What about adults who want hot food The restrictions on the operation of hot food take and sometimes chips for dinner. It is a free country and aways (new policy HFTA 2) will not apply surely adults have the right to decide what they want to retrospectively to existing hot food take aways, eat!!! only new businesses, and will only affect a small area of the city in locations close to secondary schools Monday to Friday.

Since there are approximately 250 existing hot food take away businesses in the city, the policy is unlikely to unduly restrict access to these popular and convenient food choices to the majority of the city’s residents.

50 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) 021 Mrs R. Steenson Initially I was not going to bother to comment on this The previous policy HFTA 1 (hot food take latest ill thought out scheme until I read in the aways and residential properties) is removed Advertiser that one of the proposals was to lift a ban on from the revised SPD, as decisions based on it takeaways opening next to residential houses - really have been overturned at five recent appeals. how much misery are you prepared to inflict on Salford Other policies in the revised SPD however seek residents - as an inner city resident on the to ensure that residential amenity is given Charlestown/lower Broughton boarder, we already live adequate protection. For example, new policy in a hell hole with far too many takeaways - if salford HFTA 3 controls hours of opening, new policy council gave a rats about healthy eating they would not HFTA 4 (a revision of the previous policy HFTA allow such a concentration, and as for extractor fans 5) controls odours and noise, requiring being 'better' a takeaway has opened on Cromwell appropriate extraction equipment and sound Road (rumour has it the licence was granted in Bristol!) proofing, and a new policy HFTA 5 seeks to and the sickening greasy smell that pervades my ensure that hot food take aways do not lead to home, which is in the next street, is lowering the quality any increase in anti-social behaviour. of life even further. What is your aim? to heap even more misery on to already put upon residents - let's face it, if we could move away we would, you have either no comprehension or no interest in residents, you are a shower of self-serving opportunists and have turned Salford into a city where people just exist, not live.

022 Salford’s health In summary Salford’s health and wellbeing board Comments noted. and wellbeing commented as follows: board Reducing childhood obesity levels is a top priority for the health and wellbeing board because overweight and obese children are more likely to become obese adults, and consequently have a higher risk of illness, 51 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) disability and premature death.

A number of studies have found that takeaway food outlets are often located in areas of higher socioeconomic deprivation. The National Obesity Observatory (NOO) has found that there is a strong association between deprivation and the density of fast food outlets. With the most deprived areas having more fast food outlets per 100,000 population. There is a similarly strong relationship between the prevalence of obesity and deprivation, women and children in lower income groups are more likely to be obese than those who are wealthier. It would be simplistic to suggest a cause and effect relationship ie more takeaways leading to higher rates of obesity but there is clearly an association between the two.

Salford as a city with significant areas of deprivation is inevitably doubly challenged by both higher rates of both childhood obesity and takeaways supplying high calorific foods. Young people are particularly susceptible in this environment. Therefore the draft SPG is to be welcomed, any measures which potentially control the availability of fast food to children outside of parental supervision is a positive contribution to managing the environmental factors which contribute to obesity.

023 Mr G. Sunbeam I blame Margaret Thatcher....she sold off the playing It is recognised a joined up approach is needed 52 Ref Individual or Representation Council response and implications for SPD organisation (and agent where applicable) fields of the non-fee-paying schools in England, so the to encourage healthier lifestyles combining school-kids couldn't even do the one afternoon of physical activity alongside a healthy balanced Games that they used to do; plus Gym, once a week, diet. Parents, schools, the health service and of course. other organisations all have responsibility to encourage healthy living amongst children and At Boarding school u do Games 5 afternoons a week. young people. It's compulsory and it gets u fit, so u need the food to build yr muscle-mass. With Gym once a week, too. [6th afternoon was Combined Cadet Force {CCF}, which is marching and charging in a synchronized way; and Sunday was free].

I know the truth of the above, for I went to both sorts of schools; so I speak with knowledge.

What to do now?....find new playing fields, max the use of those that are still there, do Gym more often, curse Margaret Thatcher every day at morning Assembly.

Cut the CCF, and the 5-days-a-week day schools could then do games every afternoon. Except, the teachers would now do a full day's 8-hours of work; so there'd be strikes immediately. It's hard enough for them not being bored lifeless during the school holidays.

024 United Utilities Network Rail confirmed they had no comment to make There are no implications for the SPD. on the content of the draft SPD.