Burnley’s Local Plan: Proposed Submission Document Consultation Statement under Regulations 19 and 17(d)

Burnley Borough Council: April 2017 Burnley Local Plan: Regulation 19 and 17(d) Consultation Statement

Contents

1. Introduction ...... 3 2. Consultation Requirements ...... 3 3. Summary of Consultation Stages ...... 3 4. Early Engagement ...... 5 5. Consultation on Issues and Options ...... 7 Consultation ...... 8 Responses ...... 9 6. Consultation on Issues and Options Additional Sites ...... 11 Consultation ...... 11 Responses ...... 12 7. Supplementary Consultation...... 13 8. Preferred Options Consultation ...... 13 Consultation ...... 13 Responses ...... 14 Main Issues Raised ...... 17 Consideration of the Comments ...... 19 9. Ongoing Consultation ...... 20 Appendix 1: Issues and Options Consultation Letter...... 22 Appendix 2: Issues and Options Additional Sites Consultation Letter ...... 23 Appendix 3: Preferred Options Consultation Letter ...... 24 Appendix 4: Preferred Options Consultation List ...... 26

Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

1. Introduction

1.1 The purpose of this Consultation Statement is to set out details of the consultation undertaken in the preparation of the Burnley Local Plan. It has been produced in order to meet the requirements of Regulation 19 and 17(d) of the Town and Country Planning (Local Planning) (England) Regulations 2012 as amended. 1.2 It sets out high level summary details of the responses made during the three stage Regulation 18 consultation. It highlights the main issues raised and outlines how these have been addressed in the Local Plan that is proposed to be submitted to the Secretary of State.

2. Consultation Requirements

2.1 Regulation 18 of the Town and Country Planning (Local Development) (England) Regulations 2012 as amended requires that in preparing a Local Plan (1) A local planning authority must— (a) notify each of the bodies or persons specified in paragraph (2) of the subject of a local plan which the local planning authority propose to prepare, and (b) invite each of them to make representations to the local planning authority about what a local plan with that subject ought to contain. (2) The bodies or persons referred to in paragraph (1) are— (a) such of the specific consultation bodies as the local planning authority consider may have an interest in the subject of the proposed local plan; (b) such of the general consultation bodies as the local planning authority consider appropriate; and (c) such residents or other persons carrying on business in the local planning authority’s area from which the local planning authority consider it appropriate to invite representations. (3) In preparing the local plan, the local planning authority must take into account any representation made to them in response to invitations under paragraph (1). 2.2 Regulation 18 stage is flexible and need not necessarily comprise a single event. 2.3 The Planning and Compulsory Purchase Act requires the Council to produce Statement of Community Involvement (SCI). This explains what the Council will do to involve the community and other stakeholders in the preparation and revision of local development documents (including the Local Plan) and how the community will be consulted on planning applications. Burnley Borough Council adopted its initial Statement of Community Involvement (SCI) on 5th September 2007. This was updated in July 2015 to reflect the reality of the Council’s revised planning staffing and financial resources and changes in legislation, plan-making procedures and community structures. It was adopted by Council’s Executive on 14 July 2015. 2.4 The SCI sets out how the Council intends to comply with the statutory requirements and consult at Regulation 18 and other plan stages. The 2015 SCI revision took account of comments made on the consultation process at the Issues and Options stages of the Local Plan’s Development.

3. Summary of Consultation Stages

3.1 The Council opted for a multi-stage approach to the Regulation 18 consultation in broad alignment line with the approach of its earlier SCI when such stages were a statutory requirement of plan-making. It undertook an Issues and Options, Issues and Options Additional Sites and Preferred Options consultation.

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3.2 The following table sets out the plan-making and consultation stages identified in the SCI and the dates they were undertaken. Table 1: Plan and Consultation Stages and Dates

Stage Process

1. Pre-production Collect evidence and establish wider 2012 Onwards policy framework

2. Involvement Informal consultations may be carried Early Engagement: out and the nature/extent of these will 2012-2014 be determined by the specific Informal and early requirements of evidence gathering or engagement the subject matter Issues and Options:

Consider issues and alternatives 17 Feb to 31 March 2014 Issues and Consult on the Scope of the SA/SEA Options Issues and Options Additional Sites: 26 August to 7 October 2012

3. Consultation Consult over six week period in line with Regulation 18 Preferred Options: Council to consider the comments Preferred Options 15 July to 26 August 2016 made*

4. Publication Statutory stage where a minimum of 6 weeks is provided to make Proposed Submission Consultation: ‘representations’ on the plan, its Publication of sustainability appraisal and supporting Proposed evidence (Regulations 19 and 20) 12 April 2107 to 26 May 2017 Submission These ‘representations’ will be Document and (Statutory 6 weeks plus 3 extra days considered by the Inspector at the SEA/SA Report for because of bank holiday) Examination final representations

5. Examination Main issues raised in the representations at Regulation 19/20 Submission proposed - July 2017 summarised and made publicly available Submission of Examination to Start - July 2017 Plan submitted to Secretary of State for Plan for independent Examination in line with Hearing Dates - tbc Independent Regulation 22 Examination Independent Examination (notice given 6 weeks in advance to people who have requested to appear - Regulation 24)

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Examination likely to involve public Hearing Sessions Planning Inspector issues Report

6. Main Optional Stage - if the Council agrees, tbc Modifications the Inspector can propose changes or ‘main modifications’ to the plan (including to add ‘omission sites’, i.e. additional sites put forward by objectors to the DPD) to avoid it being found ‘unsound’ Inspector considers representations on main modifications The hearings may be re-opened

7. Adoption Plan adopted by the Council if agreed as Anticipated March 2018 ‘sound’ by Inspector (Regulation 26)

8. Monitor & Monitor Plan to make sure it is Review achieving its objectives Plan may be reviewed where necessary

* It is important to note that any comments made at this stage will not be carried forward to the Independent Examination. If anyone is not satisfied that their comments have been taken on board, they must comment again on the Proposed Submission Document in order to have their comments considered by the Inspector

4. Early Engagement

4.1 The first Local Development Scheme (LDS) adopted by Burnley Council in 2004 set out a plan to produce a Core Strategy DPD, Development Management Policies DPD and 5 Area Action Plan DPDs. The 2004 Planning and Compulsory Purchase Act required local planning authorities to prepare a Core Strategy with which other Development Plan Documents and Supplementary Planning Documents had to be in conformity. This is no longer the case and it is now possible to produce a single planning document incorporating strategic policies along with site allocations and development management policies. The Area Action Plan documents were to have provided a detailed planning framework for the regeneration of three neighbourhoods and the Town Centre. The proposed submission versions of these plans were published for comment in November/December 2010, but work on them ceased before their formal submission to the Secretary of State. 4.2 Some early work on the Core Strategy was also undertaken including a Housing Issues and Options consultation in 2009. The aim of this consultation was to inform the production of the Core Strategy, helping the Council to get a clearer idea of the housing situation in Burnley as a whole and setting the context for the Purposed Submission Area Action Plans which were being prepared. This consultation also included a list of housing site options from the Council’s emerging SHLAA work following an earlier Urban Potential Study and ‘call for sites’. 4.3 The LDS 2012–2015 proposed to move to the production a single development plan document, the Burnley Local Plan. This would not only set out strategic planning policies but would identify site specific allocations and detailed development management policies.

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4.4 Work began immediately and drew on the earlier work undertaken. A new information leaflet was produced advising of the new Local Plan and inviting people to register on the consultation database. 4.5 The early work included engagement with key stakeholders to support the new Local Plan and the preparation and commissioning of new evidence.

SA Scoping Report 4.6 In 2012, a draft Sustainability Appraisal/ Strategic Environmental Assessment (SA/SEA) Scoping Report was produced by LUC on behalf of the Council and a 5 week consultation with the three ’SEA Consultation’ bodies required to be consulted by regulation was carried out. The final Scoping Report, which addressed the comments made was published in July 2012. Details of this consultation is set out in the Proposed Submission Sustainability Appraisal Report.

Stakeholder Workshops 4.7 In 2012, three days of stakeholder workshops were held at Nelson House, Burnley to discuss the issues and challenges that the Plan would need to address along with stakeholders’ ideas about options for future growth. The three events were aimed at:

• Mon, 24th Sept 2012: Statutory bodies/local authorities/town and parish councils Attendees included:

• The Environment Agency • United Utilities • Pendle Borough Council • Canals and Rivers Trust • Forest of Burnley • Lancashire County Council • Regenerate Pennine Lancashire • Rossendale Borough Council • Cliviger Parish Council • CPRE • Lancashire Police • Calderdale MBC • Lancashire Joint Health Unit • Ribble Rivers Trust • East Lancashire PCT

• Tues, 25th Sept 2012: Businesses, bondholders and the development industry including RSLs Attendees included:

• Keepmoat • Gleeson • Great Places • Pettys • Kirkwells • Globe Enterprises • PLACE • Trever Dawson • Taylor Weaver

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• Lancashire County Council

• Wed, 26th Sept 2012: Residents groups/local interest groups/etc Attendees included:

• Historic England • Burnley and District Chamber of Trade • Project Padiham • Pyramid Group • Ramblers Association • Groundwork • Burnley Wildfire Conservation Forum • Friends of Towneley Park • Burnley and Pendle Council for Voluntary Services • Building Bridges • Pennine Lancashire Community Farm • Piccadilly Moving Community Association

• Any session: BBC councillors 4.8 Each day’s workshop followed the same format with presentations and workshops on a draft Vision of the Plan, Issues and Opportunities, Options for development, Travel Plans and Green Infrastructure.

Infrastructure and Service Provider Meetings 4.9 Meetings were held in 2012 and 2013 with key infrastructure and service providers including: • Network Rail • Transdev Transport • East Lancashire Clinical Commissioning Group • Lancashire County Council • Public health • Environment Agency • Highways England • NHS Property Services • Environment Agency • United Utilities • Canals and Rivers Trust • Internal Burnley BC Officers 4.10 These meetings were attended by Council officers from a range of services. 4.11 Email exchanges also took place with Electricity North West and National Grid.

5. Consultation on Issues and Options

5.1 Building on the early work, an Issues and Options Plan was prepared in 2014. This highlighted the relevant issues that had been identified and invited comment on these and set out a number of options for how the plan might address them, including through a number of potential housing, mixed use and employment and one potential Gypsy and Traveller site allocation. Its purpose was to stimulate discussion and debate about the issues that the Plan should address and the options for dealing with them. It sought to stimulate comment through a series of Questions (119 in total).

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5.2 The Issues and Options Plan was accompanied by a Sustainability Appraisal Report and a Habitats Regulations Assessment, which were not requirements at this informal stage. 5.3 An Infrastructure Delivery Plan (IDP) Baseline Report was also prepared which summarised the key social, economic and environmental infrastructure the borough. It provided an opportunity for interested parties to comment and share early views on infrastructure provision. Consultation 5.4 There was a six week consultation focused on these 4 documents that ran from 17 February to 31 March 2014. 5.5 Letters/emails were sent to all those on the Local Plan consultation database. The letter on the Plan is attached at Appendix 1. 5.6 This letter indicated that the 4 documents were available online and available for inspection and that comments were invited. 5.7 The Issues and Options Plan, all of its additional reports and IDP Baseline Report were published online on the Council’s website where people could both view and download the documents. 5.8 To help inform other interested parties, press releases were issued in December 2013, January and February 2014. Front page articles appeared in the Burnley Express newspaper (17/01/14) with a follow up article on the 21/01/14 and the Lancashire Telegraph (09/01/14) with a follow up article on the 10/01/14, highlighting the issues and options covered and the consultation period. The Burnley Express also ran a story on 14/02/14 publicising the consultation events which would be running the following week. 5.9 People were also able to request copies from the Council, or call into ‘Contact Burnley ‘ the Council’s contact centre at Parker Lane for copies or advice if necessary. 5.10 Additionally, copies of the Issues and Options, Sustainability Appraisal, Habitats Regulations Assessment, Infrastructure Delivery Plan Baseline Report, maps and comments forms were made available, along with promotional material, at Burnley Central Library and Padiham Library. 5.11 Specially designed comments forms were made available and people were able to comment using externally hosted online software (Objective). 5.12 During the consultation period the Council held 4 drop-in sessions to allow members of the public to view and discuss the documents and maps with Council staff. Copies of the Issues and Options plan and maps and IDP Baseline Report were available to take away, and other evidence base documents in were available to view and discuss with Council staff. In the week before the events the Council publicised them with a display in the Charity Arch in Burnley Town Centre and by handing out leaflets from the Council’s Trailer in Tesco car park in Padiham and on St James’s Street in Burnley. Event locations and attendance figures were as follows: Table 2: Issues and Options Drop-in Events

Date Time Location Approx. Attendees 11am – 2 pm 11/02/2014 Linkbridge Community Centre, Swinless Street 12 4:30 – 6.30pm 11am – 2 pm 18/02/2014 Pop up shop, 4 Burnley Road, Padiham 7 4:30 – 6.30pm 11am – 2 pm 19/02/2014 Howard Street Medical Centre 6 4:30 – 6.30pm

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11am – 2 pm 21/02/2014 Belmont Community Centre, Belmont Grove 2 4:30 – 6.30pm Total 27

5.13 In addition to the drop-in sessions, the Council held three stakeholder sessions on the 25th – 27th February 2014 and the University Technical College on Trafalgar Street and East Lancs Voluntary Resource Centre on Yorkshire Street. A total of 67 people attended these sessions which included presentations on the Issues the Borough faces and the Options put forward to address these issues including group activities exploring growth options, spatial options and site options. Representatives from statutory bodies, local authorities, town and parish councils, infrastructure providers, developers, businesses, agents, residents groups and local interest groups were invited to these sessions. A follow up session was held for Parish Councils on the 19th March 2014 at Burnley Town Hall to which 16 people attended. Responses 5.14 In total 1,018 responses were received on the Issues and Options from 165 consultees. There was also a petition on the Gypsy and Traveller site option at Spa Wood Farm. 11 responses were received to the IDP Baseline Report from 9 consultees. 3 comments were received on the SA 5.15 The key issues raised in relation to the Issues and Options report were: • Growth Options A range of responses was received supporting one or more of the three of the proposed growth options.

• Spatial Options As with the growth options, a range of responses was received supporting Spatial Options 1 – 3 and /or a combination of these options. No comments were in favour of the Option 4 i.e. to have no Local Planning Framework.

• Core Policies and Site Allocation Options – Population and Housing A number of responses were received considering questions related to the delivery of affordable housing and delivering a mix of housing types and tenures, but the largest response received was to the provision of new housing on sites across the Borough and to the identification of a Gypsy and Traveller site. Respondents raised a number of concerns with the proposed developments, outlining reason why sites should not be progressed. A number of sites were also put forward as alternatives.

• Core Policy and Site Allocations Options – Economy and Employment In relation to employment development a number of responses were received concerning questions related to the expansion/improvement of business premises, the loss of employment premises and economic improvement areas; but the largest response was to the provision of new employment land on sites across the Borough. Respondents raised a number of concerns with the proposed developments, outlining reasons why sites should not be progressed. A number of sites were also put forward as alternatives. In relation to Town centres and retail, a number of responses were received considering questions related to an appropriate response to proposals for town centre development and the boundaries, the role and function of all centres within the Borough’s and the retail hierarchy.

• Core Policies and Site Allocations Options – Climate Change, Renewable Energy and Flood Risk

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A number of responses were received to questions concerning the important issues of dealing with the challenge of climate change and mitigating the impacts of development, promoting low carbon and renewable energy and flood risk.

• Core Policies and Site Allocations Options – Natural Environment A number of responses were received to questions concerned with biodiversity, green Infrastructure, local wildlife sites and local nature reserves, the Green Belt and the rural area. There was support for an overarching policy on green infrastructure and continued protection of the Green Belt from development. Whilst there was support for development in and around rural settlements, there was also concern over development in the rural area and the potential impact of such development.

• Core Policy and Site Allocations Options – Built Environment A number of responses were received to questions concerned with the Borough’s heritage assets (listed buildings, conservation areas, historic parks and gardens, ancient monuments), design in new developments, local distinctiveness and environmental protection. There was considerable support for the protection of the borough’s heritage assets which were seen as irreplaceable. An overarching design policy was seen as the most appropriate policy response to promote good design and reinforce local distinctiveness.

• Core Policy and Site Allocations Options – Transport and Other Infrastructure A number of responses were received to questions concerned with the requirement to submit Travel Plans and Transport Assessments, encouraging the use of public transport, walking and cycling, the protection of playing pitches, public parks, informal recreation areas, major open areas, and play areas, other areas of open space and allotments, the protection and provision of community facilities

• Core Policy and Site Allocations Options – Development Management The development management chapter asked questions on a number of themes including housing density and design, open space in new housing developments, residential conversions and extensions, small businesses and local shops, hot food take-aways, rural diversification and agricultural worker’s dwellings, telecommunications, protecting and enhancing biodiversity, outdoor sports and equestrian development, advertisements and shopfronts, the transport hierarchy and taxi booking offices and parking standards. 5.16 The key issues raised in relation to the IDP Baseline Report were: • The potential for future housing development impacting on infrastructure • The need for continued liaison with infrastructure/service providers • A rise in the number of good jobs to enable access to better shops, education and aspirational housing • To encourage and facilitate cycle routes • Reference to the riverine environment • A positive strategy for the conservation, enhancement and enjoyment of the historic environment • Burnley sewage treatment works • Flood risk/defences • Provision for GI assets • Reference to cultural infrastructure 5.17 The Council used these consultation responses as a basis for further discussions with a number of agencies and stakeholders to inform the formulation of the Preferred Options.

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5.18 The comments received were summarised and responses set out in a schedule which accompanied the Report to Council’s Executive seeking approval of the Preferred Options draft of the Local Plan for consultation in July 2016

6. Consultation on Issues and Options Additional Sites

6.1 In response to the Issues and Options consultation, the Council had invited and received a number of suggestions for additional and alternative sites for development. It decided that it would seek comment on these prior to preparing its Preferred Options. Consultation 6.2 Consultation on these additional sites took place over a 6 week period from 26 August to 7 October 2014. 6.3 There were 16 sites consulted on: 12 for housing, 1 for employment development and 3 for Gypsy and Traveller sites. 6.4 Letters/emails were sent to all those on the Local Plan consultation database. The letter is attached at Appendix 2. This letter indicated that the Issues and Options Additional Sites Report along with a Sustainability Appraisal of the sites was available for consultation and available to view online or at Contact Burnley, Burnley Central Library and Padiham Library. Specially designed comments forms were made available and people were able to comment online using the externally hosted software (Objective). 6.5 The Issues and Options Additional Sites Report and Sustainability Appraisal were published online on the Council’s website, where residents could both view and download the documents. To help inform other interested parties, a press release was issued on 12th August 2014. There were a number of articles published in both the Burnley Express and Lancashire Telegraph both during and after the consultation period highlighting the three proposed traveller sites, housing sites and employment sites. 6.6 Copies of the Issues and Options Additional Sites, Sustainability Appraisal, maps, leaflets and comments forms were made available Burnley Central Library and Padiham Library. Information and copies of all the documents were available on the Council’s website. People could request copies of the documents from the Council, or call into the Council’s contact centre - Contact Burnley on Parker Lane for copies or advice if necessary. 6.7 The Council held eight drop-in sessions during the 6 week period, to allow members of the public to view and discuss the documents and maps with Council staff. 6.8 To actively promote the Issues and Options Additional Sites consultation and the drop-in events, leaflets and posters were produced and distributed door to door by Council staff throughout a number of locations across the borough, including South West Burnley and North Burnley, Worsthorne, Burnley Wood and Padiham. Notice boards in all wards of the borough also contained a poster showing the times and venues of the drop-in sessions. 6.9 At the drop-in events, copies of the Issues and Options Additional Sites, Sustainability Appraisal, maps and comments forms were available to take away, and other key evidence base and national policy documents were available to view and discuss with Council staff. Event locations and attendance figures were as follows:

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Table 3: Issues and Options Additional Sites Drop-ins

Date Time Location Approx Attendees 12-2pm and 29/08/14 Cliviger Village Hall, Burnley Road 50 4:30-7pm 12-2pm and 02/09/14 Linkbridge Centre, Swinless St, Burnley 62 4:30-7:30pm 03/09/14 4-6pm Terracefields, Springfield St, Burnley 30 12-2pm and 04/09/14 Howard St Community Centre, Burnley 39 4:30-7:30pm 12-2pm and Worsthorne Reading Rooms, Ormerod Road, 09/09/14 109 4:30-7pm Worsthorne 12-2pm and 11/09/14 Hapton Methodist Church, Whitefield St, Hapton 46 4:30-7:30pm 12-2pm and 12/09/14 Ballroom, Padiham Town Hall, Burnley Road 56 4:30-7:30pm 12-2pm and 02/10/14 Burnley Town Hall, Manchester Road 101+ 5-7pm Total 493+

6.10 In addition to this, two public meetings were held in the evening, to allow Council officers to present key information about the consultation, followed by an open question and answer session: Table 4: Issues and Options Additional Sites Public Meetings

Date Time Location Attendees 29/08/14 7:30pm Cliviger Village Hall, Burnley Road 49 09/09/14 7:30pm Thornton Arms, Brownside Road, Burnley 100+ Total 149+

Responses 6.11 In total 1,186 responses were received from 664 consultees. Eight petitions were also received in relation to site options for Gypsy and Traveller sites; three for Heald Road, two for Marlborough Street and three for Lawrence Avenue. 6.12 The majority of comments were regarding the housing sites within and around Worsthorne and the Gypsy and Traveller sites with the main material issues raised being:

• Access, parking, traffic and highway safety • Impact on the character of Worsthorne and the Conservation Area; landscape and the scale of development • Impact on infrastructure/amenities including schools, public transport and health facilities; • Impact on wildlife and ecology • Greenfield site development • The need for development • Noise/light nuisance • Impact on ongoing regeneration efforts • Impact on house values; • Costs associated with developing sites

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• Fear of crime/anti-social behaviour • Social Integration • Overlooking and visual impact

7. Supplementary Consultation

7.1 Following the two rounds of Issues and Options consultation the decision was taken to discontinue with the externally hosted online consultation software that had been used at the earlier stages and to develop an in-house consultation database. This allowed for some data cleansing which highlighted that letter/emails to a small number or recently formed successor bodies including some identified as specific consultees had been sent to old names/addresses. The decision was taken to resend letter/emails to these consultees to give them a further opportunity to respond before the Council drafted its preferred options. No responses were received. These were:

• The Showman’s Guild • The Traveller Movement • The Gypsy Council • East Lancashire NHS trust • The Police and Crime Commissioner Lancashire • The Police and Crime Commissioner West Yorkshire • The Clinical Commissioning Group • NHS England 7.2 Further consultation took place in early 2015 and in 2016 with Lancashire County Council Highway Engineers who had responded to the issues and Options sites; in particular to seek advice on a number of new and alternative SHLAA/Plan sites.

8. Preferred Options Consultation

8.1 The Preferred Options document was approved for consultation by the Council’s Executive on 5 July 2016. This document was the culmination of the previous plan stages, and presented the Council’s preferred strategy for meeting the needs and demands of the borough to 2032. Consultation 8.2 The Preferred Options consultation ran over a six week period between 15 July and 26 August 2016. 8.3 Letters (551) and emails (903) (see Appendix 3) were sent to the organisations listed in Appendix 4 along with any businesses or individuals who had requested to be informed (not listed). Correspondence notified these consultees about where the Preferred Options and its associated documentation could be viewed and invited comments during the six week consultation period. 8.4 To help inform other interested parties, press releases were issued in July 2016 to the Burnley Express, Lancashire Telegraph, Radio Lancashire, 2BR, BBC NW TV and Granada TV. Front page articles appeared in the Burnley Express (01/07/16) and the Lancashire Telegraph (27/07/16), listing all the preferred housing sites and consultation events. Information was included in the annual Council magazine in March both in 2015 and 2016, sent to every household in the borough. 8.5 People were also able to request copies from the Council, or call into Contact Burnley on Parker Lane for copies or advice if necessary. 8.6 Additionally, copies of the Preferred Options Plan, maps, Sustainability Appraisal, Habitats Regulations Assessment and comments forms were made available, along with promotional material at Burnley Central Library and Padiham Library. These documents and the plan’s evidence base were

13 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement published online on the Council’s website to view and download. 8.7 Copies of the preferred options, maps, comments forms and promotional materials were also made available to Parish and Town Councils. 8.8 During the consultation period, the Council welcomed comments on any aspect of the plan, its evidence base or associated documentation, as well the consultation itself. The Council provided comments forms at every event as well as an electronic comments form on its website which could be filled in and emailed or downloaded and posted. This was in addition to libraries, Contact Burnley and Parish Councils having comments forms available. People were also able to comment online through the Council’s website. 8.9 The Council held seven drop in sessions, to allow members of the public to view and discuss the proposals with Council staff. Copies of the Preferred Options and site allocation maps were available to take away, and other documents in the evidence base were available to view and discuss with Council staff. Event locations and attendance figures were as follows: Table 5: Drop-in Events

Date Time Location Approx Attendees 19/07/2016 4:30 – 7pm St Leonards Primary School, Slade Lane, Padiham 17 20/07/2016 2 – 7pm Parkside Methodist Church. Cog Lane, Burnley 40 21/07/2016 2 – 7pm Hapton Methodist Church, Hapton 17 27/07/2016 2 – 6:30pm Cliviger Village Hall, Cliviger 38 Stoneyholme and Daneshouse Youth and 09/08/2016 2 – 6:30pm 9 Community Centre, Daneshouse Road, Burnley 11/08/2016 2 – 7pm Worsthorne Primary School, Worsthorne 63 22/08/2016 2 – 7pm Burnley Town Hall, Burnley 52 Total 233

8.10 In addition to this, two public meetings were held in evenings, to allow Council officers to present key information about the consultation, followed by an open question and answer session: Table 6: Public Meetings

Date Time Location Attendees 20/07/2016 7pm Parkside Methodist Church. Cog Lane, Burnley 64 11/08/2016 7pm Worsthorne Primary School, Worsthorne 79 Total 143

Responses 8.11 In total, the Council received comments from 446 individuals and organisations, as well as two petitions (67 signatories and 21 signatories respectively). 8.12 Consultees commented on many different parts of the plan raising 1,247 separate comments across a variety of topics. A breakdown of these topics and the respondent type (as set out in the Council’s SCI) is provided in Tables 7 below:

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Table 7: Number and Type of Respondents – Non Site Specific Comments

Specific General Individuals, Subject/part of Plan Other Consultation Consultation Agents and Total commented on Organisation Body Body Companies Consultation 1 1 2 72 76 General 9 2 6 10 27 Other 4 0 3 8 15 Introduction 0 0 2 2 4 Spatial Portrait 2 0 5 1 8 Vision & Objectives 3 0 7 3 13 Strategic Policies 11 5 16 57 89 Policies 29 2 35 39 105 Monitoring 2 0 2 0 4 Sustainability Appraisal 4 0 0 11 15 HRA 1 0 0 0 1 Site Allocation Policies - not 2 0 1 3 6 site specific Total 68 10 79 206 363

8.13 In total 887 comments made were on site allocations. 8.14 There were 743 on housing sites (including two petitions) 93 on employment sites, 3 on the town centre site TC4/1, 3 on the gypsy and traveller site HS1/7 and 6 general comments (these last 12 are included in the above table under Policies). A break down on the housing and employment site comments against each site and by the type or respondent is set out in Tables 8 and 9 below. 8.15 There were also 20 comments putting forward ‘Omission Sites’ i.e. objections to sites not being included in the Plan or suggestions for new sites. Two of these have now been included in the Proposed Submission Plan. There were also 22 responses commenting on ‘omitted sites’ i.e. sites that were not actually in the plan some supporting their omission and some made in error. Table 8: Housing - Site Specific Comments

General and Site Owner Petition/ Individual Other Promoter/ of other Resident’s (General Site Ref Name Specific Body Owner Councillor site(s) Group Public) Total Former Hameldon HS1/1 0 2 1 2 0 0 6 11 Schools Sites

HS1/2 Hollins Cross Farm 1 2 1 0 1 1 34 40

Former William HS1/3 0 2 0 0 0 0 1 3 Blythe Site Land at Rossendale HS1 /4 1 1 2 0 0 1 12 17 Road (housing) Former Baxi Site HS1/5 2 3 0 0 1 0 2 8 (housing) HS1/6 Lambert Howarth 0 1 0 0 0 0 0 1

HS1/7 Ridge Wood 0 3 0 0 0 0 10 13

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General and Site Owner Petition/ Individual Other Promoter/ of other Resident’s (General Site Ref Name Specific Body Owner Councillor site(s) Group Public) Total New Hall HS1/8 0 0 0 0 0 0 0 0 Street/Barden Lane Red Lees Road, HS1/9 2 3 1 1 0 0 12 19 Cliviger

HS1/10 Higher Saxifield 1 3 1 2 0 0 20 27

Land at Burnley HS1/11 0 0 0 0 0 0 2 2 General Hospital HS1/12 Former AIT Site 2 0 0 0 0 0 0 2

HS1/13 Peel Mill (housing) 1 1 0 0 0 0 0 2

HS1/14 Waterside Mill 2 1 0 0 0 0 0 3

Former Heckenhurst HS1/15 2 2 1 1 1 0 187 194 Reservoir

HS1/16 Tay Street 1 0 0 0 0 0 0 1

HS1/17 Former Gardner Site 2 0 0 0 0 0 0 2

HS1/18 Former Ridgewood 0 3 1 0 0 0 0 4 High School Coronation Avenue, HS1/19 1 0 0 0 0 0 0 1 Thompson Street

HS1/20 Gordon Street Mill 3 2 0 1 1 0 153 160

HS1/21 Livingstone Mill 1 1 0 0 0 0 0 2

HS1/22 Lawrence Avenue 2 0 0 0 0 0 0 2

Perserverance Mill, HS1/23 2 0 0 0 0 1 1 4 Padiham HS1/24 Land NE of Sycamore 1 0 1 0 0 0 0 2 Avenue

HS1/25 Ridge Avenue 0 4 0 0 0 1 22 27

Land adjacent 2 HS1/26 1 2 1 0 0 0 5 9 Queens Park Road

HS1/27 Former Dexter Paints 1 0 0 0 0 0 0 1

Land to rear of Bull HS1/28 1 2 0 0 0 1 12 16 and Butcher Land at Oswald HS1/29 0 1 0 0 0 0 0 1 Street Brampton House, HS1/30 0 0 0 0 0 0 0 0 500 Colne Road Land adjacent 250 HS1/31 3 2 0 1 1 0 152 159 Brownside Road Clevelands Road HS1/32 1 1 0 1 0 1 4 8 (South)

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General and Site Owner Petition/ Individual Other Promoter/ of other Resident’s (General Site Ref Name Specific Body Owner Councillor site(s) Group Public) Total

HS1/33 Whalley Road 0 1 0 0 0 0 1 2

George Street Mill HS1/34 0 0 0 0 0 0 0 0 (EMP1/11) Total 34 43 10 9 5 6 636 743

Table 9: Employment - Site Specific Comments

Site Individual General/ Promoter/ Owner of (General Site Ref Name Specific Other Body Owner Councillor other site(s) Public) Total EMP1/1 Rossendale Road (North) 0 2 0 0 0 5 7 Burnley Bridge Business EMP1/2 1 3 1 0 0 0 5 Park EMP1/3 Vision Park 2 3 0 1 0 0 6

EMP1/4 Widow Hill Road 0 1 0 1 0 0 2 Land South of Network EMP1/5 2 1 1 1 0 0 5 65 EMP1/6 Balderstone Lane 1 1 0 1 0 0 4

EMP1/7 Westgate 0 0 0 0 0 0 0 Thompson Centre Car EMP1/8 1 0 0 0 0 0 1 Park (Mixed Use) EMP1/9 Innovation Drive 0 2 0 1 0 0 3

EMP1/10 Widow Hill Rd South 0 1 0 0 0 0 1 George St Mill (Mixed EMP1/11 0 0 0 0 0 0 0 Use) EMP1/12 Burnley Bridge Extension 2 2 1 1 0 3 9 Shuttleworth Mead South EMP1/13 (aka Eaves Barn Farm, 5 6 1 1 1 33 47 Padiham) EMP1/14 Stoneyholme Gas Works 1 2 0 1 0 0 4

Total 15 24 4 8 1 41 93

Main Issues Raised

Site Comments 8.16 Unsurprisingly for a single local plan which includes site allocations, the majority of comments (over 70%) were on sites. Almost all of these were objections. There was some support for individual sites, including from site owners, and some technical observations and suggestions e.g. from the Environment Agency. 8.17 The main (material) issues raised in the site objections were: • Loss of greenbelt (employment sites only) • Development of greenfield sites

17 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

• Development in the countryside (moving the current urban boundary) • The scale of development in and around Worsthorne (many were opposed to all development here) • Transport and traffic infrastructure concerns • Flooding of and from sites • Coal mining legacy/subsidence • Contamination from adjacent sites e.g. former landfill site • Lack of educational and health infrastructure • Biodiversity impacts

Policy Comments 8.18 The second most popular subject was the policies in Section 5. The main (material) issues raised were:

• A number of comments were made on the housing policies in Section 5.1, generally by developers who felt they were too prescriptive • View on the sites allocation policy approach i.e. not to simply have red lines and numbers, received a mixed vresponse but in general it seems whilst residents may have objected to specific sites, they did support having specific requirements for the allocations. Natural England also welcomed this approach • There were few objections to the Natural Environment Policies in Section 5.5 but were some specific suggestions for revised wording • Historic England asked for some policy wording changes to the Historic Environment Policies in Section 5.4 • There were a small number of comments on the town centre policies including the town centre boundaries in Burnley and Padiham; and a strong objection to the Shopfront and Advertisement Design Policy TC8

Strategic Policy Comments 8.19 The third most popular subject was the strategic policies in Section 4, in particular : The housing requirement set out in SP2

• Residents tended to think this was too high with a number feeling there was no need for new house building and /or that all or much of the new capacity should be met through the filling of vacant properties

• Developers/site owners either supported it or requested a slightly higher requirement figure and a some considered that the allowances for filling empty and /or windfalls should be excluded and further sites allocated The spatial strategy of SP4

• A large number of residents who responded did not support the release of any greenfield sites outwith the current urban boundary; some did not support the release of any greenfield sites at all and most of the responses from residents in and around Worsthorne did not support any development in and around the village or at nearby Brownside

• A number of comments were made by developers who felt the requirements for greenfield sites were too onerous Policy SP5

• The were some expression of support for and no objections to the Key Gateways concept

18 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

• A number of comments were made by developers who felt the requirements were too onerous

Consultation Process 8.20 The fourth most popular topic was the plan consultation process • Most comments received on this were critical of the consultation process feeling that each household and business in the borough should be individually notified at each plan stage

• Other criticisms e.g. the timing of consultations and drop in sessions were considered to be unfounded

Omission Sites

• 20 ‘Omission Sites’ were put forward i.e. objections to sites not being included in the Plan or suggestions for new sites. Any new sites suggested were considered through the Strategic Housing (and Employment Land) Availability Assessment. Two of these sites are now included

Evidence Base

• A number of residents and residents’ groups felt there was insufficient evidence, in particular:

• Site walkover, ecological and investigatory surveys • Traffic surveys

Other

• A number of residents and residents’ groups felt there was insufficient clarity and commitment to put in place the infrastructure to support the plan and felt this should be put in place before any sites were allocated

• Highways England requested updated assessment/modelling of the impact on the strategic road network of the higher level of housing growth than had been set out in the Issues and Options Plan. No objections were received for the County Council (The Local Highway Authority) Consideration of the Comments 8.21 The comments reflected the fact that the Preferred Options Plan had been the first chance consultees had had to see fully drafted Local Plan with all the sites and policies set out. The comments made were carefully considered and a number of changes to the plan were made in response to them, including:

• the addition of two omission housing site at Lodge Mill HS1/35 and Butchers Farm HS1/38 • the removal of the large housing site at Ridge Wood HS1/7 and its replacement with a much smaller site and the proposed protection of the remaining land as Open Space under Policy NE2,

• a reduction of housing numbers at some sites to allow for greater GI including for SuDS and biodiversity mitigation

• additional site specify policy requirements added to the Housing Site allocations, in particular with respect to ecological surveys and updated flood risk information

• Additions to policy wording e.g. NE5 in response to the Coal Authority’s comments

19 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

• Changes to the Historic Environment Policies • Changes to the Shopfront Advertisement and Design Policy TC8 to meet part of the objection made

• In response to Highways England’s comment it was decided that it would be appropriate to re-test the previously proposed interventions set out in the Burnley–Pendle Growth Corridor Study. The Council, in partnership with Lancashire County Council commissioned Jacobs to undertake updated Highways Impact Assessment, in consultation with Highways England, to assess the impact of the proposed new housing and employment development identified in the Preferred Option on both the SRN and LRN. The HIA concluded that a number of key junctions, even accounting for proposed interventions, could not accommodate the level of proposed growth. The Council worked with LCC, and Highways England to identify and agree further requirements over the plan period. Highways England has committed to develop a micro simulation model of the SRN between Junctions 8 and 10 to assist LCC and BBC to fine tune proposals, to assist monitoring and to inform future iterations of the Infrastructure Delivery Plan

• Some sites – the new sites and some of the earlier Issues and Options Additional Sites that had not been surveyed, has walkover protected species/phase 1 habitats surveys undertaken.

• No response had been received from the County Council on archaeological matters and so a Rapid Archaeological Desktop Assessment of the Plan sites using the County’s HER was commissioned in part to address the comments of Historic England and also to investigate some information on potential archaeological features raised by residents 8.22 The comments received and recommended responses were presented to the Council’s Executive and Full Council in March 2017 with recommended responses set out. This formed an appendix to the Report seeking approval of the Proposed Submission Local Plan for Publication under Regulation 19. 8.23 Following publication of the Executive and Council agendas a number of residents exercised their right to speak to address the Executive and /or Council before the decisions were made. 5 residents spoke at Executive and 6 at Full Council. All raised objections. At Full Council, members were also presented with a late email form Habergham Eaves Parish Council in relation to flooding concerns and late letter a petition relating to the proposed Gypsy and Traveller site at Oswald Street (HS7). No reason was stated in the petition other than a stated lack of awareness of the proposal and a perceived lack of opportunity to comment previously. The petition has many names and addresses/partial addresses but few signatures.

9. Ongoing Consultation

9.1 Throughout the plan’s development, consultation with a number of specific and Duty to Cooperate bodies has been undertaken – see also the separate Duty to Cooperate background paper. 9.2 Prior to finalising the Preferred Options, the Council had tried largely unsuccessfully to arrange meetings with the County Council (other than with the highway engineers). Following Preferred Options and given that only a single response has been received from Lancashire County Council to the Preferred Options consultation (from the Education Team) a series of meeting were successfully arranged with County Council with officer s from education, public health, transport and highways to discuss the Plan moving forwards. 9.3 Separate to these discussions, discussions and meetings were also held on the emerging evidence base. These included with the County Council as LLFA and the Environment Agency in

20 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement finalising the Council’s SFRA and in respect of the design of a Flood Alleviation Scheme for Padiham, and in commissioning and carrying out of the updates highways impact modelling in discussion with Highways England and County highways.

21 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

Appendix 1: Issues and Options Consultation Letter

22 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

Appendix 2: Issues and Options Additional Sites Consultation Letter

23 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

Appendix 3: Preferred Options Consultation Letter

24 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

25 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

Appendix 4: Preferred Options Consultation List Residents, local businesses Developers, agents and landowners who were sent letter/emails because they were registered on the local plan consultation database (not listed here)

Specific Consultation Bodies Altham Parish Council Blackshaw Parish Council Briercliffe Parish Council Brierfield Town Council Calderdale Metropolitan District Council Cliviger Parish Council Dunnockshaw Parish Council East Lancashire Clinical Commissioning Group EE Electricity North West Habergham Eaves Parish Council Hapton Parish Council Heptonstall Parish Council Higham Parish Council Highways England Historic England Homes and Communities Agency Hyndburn Borough Council Ightenhill Parish Council Lancashire County Council National Grid Natural England Network Rail Infrastructure Limited NHS Commissioning Board (Lancashire Area Team) Padiham Town Council Pendle Borough Council Police and Crime Commissioner - Lancashire Police and Crime Commissioner – West Yorkshire Reedley Hallows Parish Council Ribble Valley Borough Council Rossendale Borough Council Simonstone Parish Council The Coal Authority The Environment Agency Todmorden Town Council Trawden Forest Parish Council United Utilities Vodaphone & O2 Wadsworth Parish Council Whitworth Town Council

26 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

Specific Consultation Bodies Worsthorne – with – Hurstwood Parish Council

General consultation bodies

Belmont Community Association Friends of Memorial Park Big Local Gannow Friends of Padiham Greenway Brunshaw Action Group Friends of Scott Park Brunshaw Estate Management Board Friends of Thompson and Queen’s Park Building Bridges Burnley Friends of Towneley Burnley & District Chamber of Trade Friends of Towneley Park Burnley & District Society for The Blind and Partially Friends of Worsthorne with Hurstwood Sighted Burnley Civic Trust Hapton Heritage Burnley Historical Society Jinnah CDS Burnley Lancashire Facebook Jinnah Community Centre Burnley Lane Residents Action Group Masjid Ibrahim Burnley & Padiham Over 50's Forum Middlesex Avenue over 50s Club Burnley & Pendle Ramblers Association Near Neighbours Burnley, Pendle and Rossendale Council for Neighbourhoods United Voluntary Services Burnley Wood Community Centre Over 55's Group Howard Street Community Centre Burnley Youth Council Padiham Community Action Burnley Youth Theatre Palace House and Woodbine TRA Canalside Community Association Pennine Lancashire Community Farm Caring Accrington Road Residents Piccadilly's Moving Community Association Central Briercliffe Road Action Group Project Padiham Coal Clough Lane Community Association Pyramid Group CRACA Cliviger Regeneration and Community Red Lees Action Group Association Eastern Avenue Tenant Group Rosegrove Action Group East Lancs Chamber of Commerce Rosehill & Howorth Fold Residents Association East Lancashire Deaf Society Rotary Burnley Pendleside East Lancashire Service User Network Stonemoor Bottom Residents Group Eliza Street Action Group Stoops and Hargher Clough Community Association Elm Street Business Park Association Thursby Gardens Community Action Group Forest of Burnley Trees for Burnley Fraser Street Project Trinity Action Group Friends of Bank Hall Visually Impaired Persons Group Friends of Ightenhill Park Weavers’ Triangle Trust

Other consultees Accent Housing Group The Lawn Tennis Association Age UK NFU North West Ancient Monuments Society The National Federation of Gypsy Liaison Groups

27 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

Other consultees Association of Inland Navigation Authorities National House Building Council (NHBC) Blackburn with Darwen Borough Council National Housing Federation National Market Traders Association British Horse Society National Trust British Sign and Graphics Association National Trust Gawthorpe Hall British Toilet Association Newground Burnley College NHS Property Services Burnley Police Station North West Transport Activists Roundtable Burnley Wildlife Conservation Forum Office of Rail Regulation Calico Housing Ltd Offshoots Permaculture Project Campaign for Better Transport Open Spaces Society Campaign for Real Ale Outdoor Media Centre Canal & River Trust Padiham Police Station Civil Aviation Authority Participation Works Commission for Architecture and the Built Pennine Prospects Environment (CABE) Confederation of British Industry Places for People Consortium of Local Medical Committees Planning Inspectorate (PINS) Community Rail Partnership - East Lancashire Line The Prince’s Foundation for Building Communities Council for British Archaeology Rail Future CPRE Regenerate Pennine Lancashire Country Land & Business Association RenewableUK Cyclists Touring Club Ribble Rivers Trust Defence Infrastructure Organisation Support the East Lancashire Line Association SELRAP (Skipton and East Lancashire Rail Action East Lancashire Hospitals NHS Trust Partnership) Equality and Human Rights Commission South Pennines Local Nature Partnership Forestry Commission Royal Society for the Protection of Birds (RSPB) Freight Transport Association Royal Town Planning Institute Friends of the Earth Society for the Protection of Ancient Buildings The Garden Trust Sport England Geo Lancashire Group Sure Start South West Burnley Children's Centre The Geological Society Sustainability Action Partnership Georgian Group Sustrans Government Equalities Office Taywood Nursery School Great Places Housing Group The Showman’s Guild The Gypsy Council Theatres Trust Health and Safety Executive Towneley Branch Labour Party Heritage Trust for the North West Traffic Commissioner Home Builders’ Federation The Traveller Movement Home Office UK Rainwater Harvesting Association Home-Start Burnley University of Central Lancashire Lancashire Constabulary Victorian Society Lancashire Probation Service West Lancashire District Council Lancashire Wildlife Trust The Woodland Trust

28 Burnley Local Plan Regulation 19 and 17(d) Consultation Statement

Other consultees Lancashire Youth Association Your Eaves Brook Lancashire Local Enterprise Partnership Yorkshire Metropolitan Housing Association Lancashire Environment Forum - Lancashire Local

Nature Partnership Lancashire Fire and Rescue Service Lancashire Gardens Trust Lancashire Pennine Local Medical Committee

29 Burnley Local Plan: Regulation 19 and 17(d) Consultation Statement