WHITTLE-LE-WOODS PARISH COUNCIL Ms Lisa Pickering Clerk to the Council 309 Brownedge Rd, , PR5 6UU Tel: 01772 304841 www.whittlelewoodsparishcouncil.org.uk [email protected]

Planning application 20/01347/OUTMAJ

Whittle-Le-Woods Parish Council Response Objection:

Whittle-le-Woods Parish Council is unanimous in its opposition to the above Application. This document will demonstrate why the proposed development is inappropriate and how it would create unacceptable risks for Whittle-le-Woods, its environment and people.

All our Parish Councillors have a wealth of local knowledge and life experiences. However, such is the importance of this decision; we have engaged professional opinions in the form of commissioned reports undertaken on ‘Honest Broker’ basis. These are included in the appendices and the full documents will also be available to other interested parties as appropriate.

We are calling for this application to be refused by Borough Council (and beyond if necessary). Our considered reasons are explained below: -

Contents

1. Summary of objection 2. Background & context 3. Site & location 4. Highways traffic & accessibility 5. Flooding and the proposed mitigations 6. Environment, Nature & Wildlife 7. Amenities 8. Development characteristics 9. Conclusion

List of Appendices

Appendix 1: Highways Technical Note - DTPC Northwest Appendix 2: Water Resource Associates - Review of FRA and associated documents - Town Lane Appendix 3: Table of recent flooding events, alarms and warnings Appendix 4: Wildlife species observations Appendix 5: List of Grade 2 listed buildings and structures

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1. Summary of Objection

Since being designated an ‘area of significant restriction’ in the late 1980’s the people of Whittle- le-Woods have been told this site is ‘Safeguarded’ until at least 2026. It is outrageous that it is even being considered for development in 2021 without transparent due process, and during the restrictions of a global pandemic. The application should be refused on these grounds alone if public trust in the planning process is to be maintained.

Highways & Traffic: The Applicant has failed to establish it is possible to deliver safe access for all users, either during construction or after occupation.

The characteristics of Town Lane include inherent risk for all road users on this semi rural lane. The Application does not demonstrate that adequate mitigations are feasible or even possible. (Please see Section 4 and Appendix 1)

Flooding: The proposed site impinges on a known (Level 3) Flood Risk residential area. Despite the developer having consulted regulatory bodies more than two years earlier the Application is lacking in detail, and has significant omissions. As a consequence it is impossible to scrutinise to a level that confirms feasibility. (Please see Section 5 and Appendix 2 & 3)

Ecology: The Ecology Assessment and the reports available are inadequate for any development, let alone over 30 acres of agricultural, undeveloped land known to be the natural habitat for many species.

It will be necessary for the developer to remove huge swaths of protected hedgerow to achieve adequate sight lines for cycle/footpath/emergency access; this must not be sanctioned. Further this access will permanently change the landscape making all the earthworks visible.

The Application fails to show any consideration for a deterioration in air quality due to, increased traffic levels, the loss of a ‘buffer zone’ between two motorways or the detrimental effects on occupation of the proposed houses – especially those in the “affordable homes” probably nearest to the M61.

2. Background & context

On 31st January 2020 the Parish Council hosted a public meeting for residents to consider the Central Plan (CLP) at its consultation stage. A few days later (11/2/20) the CLP team attended our Village Hall where people were able to view areas and discuss the plan. The subject site featured prominently in these discussions and as an area of particular concern.

Turnout across these events was significantly high and estimated to be more than 300. We are aware that a local Residents Association also held a public meeting with over 100 attendees. Unfortunately, we cannot say how many people actually responded to the consultation or what they commented because the CLP has not yet been published.

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We believe when public bodies engage with people, and seek opinions those people should be entitled to know that their views have not been brushed aside without due consideration. To bring forward ‘Safeguarded’ land for development now is unacceptable.

We would also contend that this land was previously designated as an ‘Area of Special Restraint’ in the late 1980s. At that time residents were told this afforded higher protection than Greenbelt status. The later change to ‘Safeguarded’ was largely unchallenged in the belief it could not be developed unless the designation changed again by way of the Local Plan process.

A crucial point here is that the above designations happened when the damages of climate changes and air pollution from motor vehicles were not widely understood. Similarly, flooding was not the perceived risk it is today.

If there is to be any change in the designation then this land should become ‘Protected’

It is understood that Chorley Borough has seen an increase in population much higher than the national average in recent years.

This increase can be attributed to new houses, for example, (some of which forms a part of the Parish), and Lucas Green, and soon Crostons Farm. Whittle-le-Woods has taken a large proportion of the new developments, almost exclusively at the expense of open green space without any significant improvement in infrastructure or amenities.

To echo the often-repeated voices of residents “enough is enough”.

3. Site & Location The proposed site comprises over 30 acres of undeveloped agricultural land. It occupies an elevated position above Town Lane to the South with the , running through the valley, to the North.

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At one time, the land included a cricket pitch. Whilst It is true that the area was affected by gravel extraction in the 1970s at the time of the M61 motorway construction, the healing effects of nature over the last 40 years are evident and it is now a pleasant green landscape enjoyed by residents and visitors who pass through and along by virtue of the public footpaths (Wellington or sturdy boots are recommended). The land is known to support a wide range of wildlife (See Section 6/Appendix 4) and is almost the last local undeveloped area before the M61 Green Belt boundary. Please note Redrow PLC is already building 53 new houses on the adjacent land, south of Town Lane (Crostons Farm).

North West of the site there is a commercial fishing lodge and down river to the North West is the Low Mill Industrial area. Beyond that is the residential area of Waterhouse Green and (lower) Town Lane, typified by stone cottages which are Grade 2 listed and the Roebuck Pub – also Grade 2 listed. (See Appendix 5)

Broadly on the eastern side of the site is the M61 motorway.

The only motor vehicle access point is onto Town Lane. Turning west (right from site) is downhill towards Waterhouse Green. East takes you towards the narrow canal bridge (grade 2 listed) near Johnson Hillock Canal Locks and onwards to St Chads Church & Primary School. This route is also typified by stone-built cottages and farm buildings.

4. Highways, Traffic & Accessibility

The Application includes a Transport Assessment (TA) prepared by SCP in Nov 2020. Its introduction claims “the benefit of knowledge of the local area” This seems very questionable especially to residents who live on or use Town Lane regularly. For detailed descriptions and technical comparisons, we invite the reader to also consider our Highways Report by DTPC in Appendix 1 to form their opinion.

Our own views are below with DTPC extracts in bold

The proposed single point of site access to/from Town Lane is near to a particularly dangerous section of road and we must assume this is the best option available to the developer. No mitigations are suggested and again we must conclude this is because there are no alternatives available.

For the developer to suggest a walking / cycling route through the estate will be a suitable alternative is unrealistic. This path will add to the hazards on Town Lane with access opposite Lady Crosse Drive at a point of restricted visibility. To achieve an adequate field of vision a large section of hedgerow will need to be removed (see also Ecology), estimated at 62 metres, and the retaining wall would also have to be removed.

“Substantial earthworks will be required, and this has not been set out or assessed as such in the absence of any detail the potential deliverability of the route is not proven and the scheme does not have a safe walk/cycle access route and should be refused.”

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We are advised the earthworks would need to include construction of a ‘meandering’ path and are concerned this might have an adverse affect in the underground water sources/flows for the adjacent Fishing Lodge. (See section 5)

Town Lane is classified as a ‘semi-rural’ lane by LCC Highways. It is enjoyed by walkers, cyclists and horse riders but it is becoming increasing hazardous as traffic volumes increase. In recent years it has become a short cut to/from the A674 and the A6 due to higher density housing and commuter journeys etc. There are certain risk characteristics, some of which combine, and these can only be magnified if vehicle traffic increased further for example:

- Narrow Sections - Sharp & blind bends - Steep short inclines - Single file yet two ways traffic (Canal bridge & on road parking with no alternatives) - Difficult junctions with limited visibility e.g. Copthurst Lane, Lucas Lane, Dark Lane, Low Mill Ind Est.

Dark Lane & Lucas Lane will inevitably become busier e.g. M61 access and they are entirely unsuitable for heavier traffic. (See Appendix 1) “The review sets a need to use the Public Right of Way (PROW) and Lucas Lane even though these are restricted in nature, poor surfacing and for Lucas Lane has conflicts with vehicles.”

It should be noted that the developers’ other site (under construction) at Crostons Farm relies on Lucas Lane for pedestrians leaving via its footpath. This can only exacerbate the potential for accidents & injury.

The TA correctly records Town Lane as an unsigned cycle route. However, it takes no account of the effects of the higher motor traffic which we believe will be a huge deterrent to cyclists if this development proceeds. Similarly, we would expect horse riders to feel particularly vulnerable.

The suggestion that walking will be preferred by new residents over short car trips is unlikely in the extreme. There are numerous limiting factors including; -

- Distance to amenities (See Appendix 1) - Narrow footways - Lengthy sections without footways - Necessity to cross back and forth to follow footways - The new proposed cycle/pedestrian access (Western end) is a danger in itself.

The risks to pedestrians, cyclist and horse riders are expected to increase in this area as and when electric vehicles become more popular, due to absence of sound on approach.

By way of simple example, we would not expect a parent/guardian to walk a child from the site to St Chads Primary School, especially during peak times. The risks are much increased if a pushchair and another child are factored in. Short car journeys will increase making walking less and less attractive.

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The Parish Council fully agrees with the conclusion statement by DPTC (Appendix 1), which is repeated here for the avoidance of any doubt.

‘The site has limited access for non-car modes, provides no mitigation for the constraints to non-car users on Town Lane and increase the risk of accidents occurring to a level where it is considered unacceptable in nature.’

“The overarching conclusion is that based on the details submitted the development would lead to unacceptable impact on safety and thus should be refused”

At the time of writing the Highways Department have been consulted by Chorley BC but has not yet responded. Should it be that no objections are raised we intend to challenge their finding with our own report. We will be particularly interested in the pre-application discussions with this developer and subsequent communications between them.

5. Flooding and the Proposed Mitigation

The areas of Waterhouse Green and lower Town Lane have been severely affected by flooding in recent times and the situation is not been helped by other new housing developments upstream. All of these were opposed by the Parish Council and many others.

Chorley BC is well aware of the issues and actually provides sandbags and equipment continuously restocked and available from a unit on Low Mill.

Local residents have formed a Flood Action Group (FAG) which also undertakes informal levels of maintenance along the river banks e.g., removing obstructions, branches etc. to alleviate the problems of flooding and protect their homes.

The Parish Council funded installation of a telemetry system installed on the River Lostock at Waterhouse Green in 2017.

Flood warnings and/or alerts are now a part of life for residents in this area.

20 Local streams 15 Telemetry 3 10 Telemetry 2 5 Telemetry 1 0 EA Alerts 2015 2016 2017 2018 2019 2020

Appendix 3 reports the numbers of events and the above graph illustrate the current and ongoing threats. We ask the reader to accept that every alert is a worry and even if flooding does not occur the disruption to peoples’ lives can be considerable.

The history with this developer serves to heighten concerns.

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When the Redrow/Lucas Green plans were eventually agreed residents were given assurances about attenuation systems, controlled water runoff etc. for the site. We have no evidence that what was promised was actually delivered, nor how it is maintained or monitored. In contrast residents can see surface water running through gardens and down the Redrow installed, supposed, cycle path. This is the natural flow from part of the estate to the bottom of the hill and gardens of Lady Crosse Drive (Cul-de-sac) houses.

Residents have similar concerns regarding the 's Farm Development (South of Town Lane) the effects of which are yet to be seen.

The subject Application includes a Flood Risk Assessment (FRA) and Desk Study Report by WaterCo.

Our Independent Report and Desk Top Analysis by Water Resource Associates (WRA) (Appendix 2) provide a critical assessment identifying numerous shortcomings and omissions, as summarised below...

1. Both reports are dated February 2019, and have not been submitted until a period almost 2 years after their completion.

2. Both reports are limited and lacking in detail which may be due to the current status of the proposals. It is expected that more detail will be provided in the FRA for the management of surface water at a later stage once ground investigations have been undertaken at the site (as recommended in the desk study) and the development layout has been finalised.

3. The FRA is lacking detail on the hydrology of the River Lostock and information on historical flooding.

4. The FRA proposed a stringent design in terms of restricting the surface runoff from the site to the 1-year greenfield flow. The associated storage volume with this flow restriction is given as 5,500 m3, adequate provision for this storage must be demonstrated and tested using drainage design software.

5. The FRA in its current format does not provide a robust SUDS design.

6. The FRA does not consider the issue of contamination and soil erosion during construction. This may be requested by the EA and included within another report if any environmentally sensitive areas are deemed to be at risk. The neighbouring fishing lodge should be highlighted as a sensitive area which is at risk of contamination and a major impact upon a local Business

7. The Desk Study Report is lacking attention to detail and has listed wrong values for the topography and incorrectly named the River Lostock the River Istock.

8. Photos of the site show wet areas and surface water indicating the risk of surface water flooding may be higher than stated on the EA maps.

9. Information on the geology is missing from the Desk Study Report and the FRA needs to be revisited to consider the risk of groundwater flooding once site investigations have been completed...

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We expect that Redrow will wish all these issues are be dealt with at a later stage. However, we believe this application is too important and too wide ranging for this to be allowed. We know from recent experience that if outline permission is granted eventual building becomes inevitable. Regrettably, we do not have faith that regulatory bodies have adequate resources to scrutinise and suitably monitor the development during the build or enforce thereafter.

It is clear that Redrow have had this site on their radar for a period of years. Yet the plans presented are vague and unconvincing. Their approach of ‘trust us’ to make it right must not be allowed.

We note that the Environment Agency have been consulted by Chorley BC and returned a ‘No Objection’ response within a few days. We find this both surprising and disappointing given the recorded history for the Level 3 Risk area.

At the time of writing the Lead Lancashire Flood Authority (LLFA) have not made comment, we intend to make our own reports available to them shortly.’

6 Environment, Nature and Wildlife

As mentioned earlier this land presents as a most pleasant green landscape with mature trees and hedgerows. It provides habitat for a wide range of wildlife (detailed in Appendix 4) We believe the Redrow ecological impact report is lacking in detail.

We simply cannot accept some of the statements in the Application (DAS) are evidenced in the plans put forward, examples include;

• ‘Creating new or enhancing exiting wildlife habitats’ • ‘Opportunities to enhance biodiversity’.

Any suggestion that existing wildlife can be adequately supported in the undeveloped areas between a housing estate and the M61 is illogical.

As with the flooding our experience of this developer’s record on Ecology in this area is unclear. When the Lucas Green development was agreed we believe conditions were imposed for the protection of the Biological Heritage Site (BHS) nearby. There is/was no evidence these were implemented or monitored.

Residents mourn the loss of green space and wildlife habitat in recent years. This is particularly poignant now as Redrow have been felling trees and removing hedges for the development on Croston’s Farm. This does not seem like progress, more like irrecoverable damage rather than engaging with the planning requirements of supporting biodiversity for conservation.

We can see that Greater Manchester Ecology Unit is the Statutory Consultee and has responded with no objection stating “There is currently no known reason to contradict the findings of the Report and the application can be forwarded to determination in respect of biodiversity without the need for any further work.”

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This appears to be based on a desktop review of two earlier one day visits the full details of which are not presented.

In contrast please also consider the views (in bold) from the Area Conservation office for The Wildlife Trust for Lancashire, Manchester & North Merseyside who have objected (02/02/21) – despite not having been consulted directly.

• 3.3.5 We note that breeding birds were surveyed on only one day, 15th September 2020. In our opinion this is an insufficient number of days. It is also outside the recognised UK bird breeding season (March to August inclusive). A usual technique to survey for breeding birds would involve establishing breeding territories of all species present through morning surveys between late March and the end of June at least, typically using an adapted form of the territory mapping or Common Bird Census (CBC) method (Bibby et al. 2000; Marchant, 1983).

• 3.3.17 The ESA reports that, "No signs of otter were detected and no records of otter are held for the wider area". Otters have been reliably recorded in recent years from the River Lostock; upstream, where it flows through the Chorley Borough sector of Valley Park. Given the considerable range of male otters, it is possible that they have and/or will visit the Whittle-le-Woods sector of the river.

• T4.2.2 Development of this, currently pastoral, agricultural land would result in some general habitat loss, including hedgerows, mature trees and improved and semi- improved pastoral grassland; but our main concern is in respect of the survival of the species-rich neutral grassland Biological Heritage Site (Local Wildlife Site, sensu Defra) that lies across Lucas Lane from the boundary of the application site. As you know, this is Lucas Lane Pasture (ref: BHS-52-SE-07).

On the subject of Otters, it is difficult to understand how an informed visitor would not take account of fencing around the Fishing Lodge specifically designed to keep Otters out.

We have grave concerns that the trees and hedgerow will not be adequately protected especially as hedgerows will have to be removed (estimate 50 metres) for access sight lines. (Please see also Section 4)

Birds and other species will be displaced and the benefits this area gives to our environment will be lost for future generations.

In recent times there have been many surveys and studies carried out to ascertain the effects of carbon dioxide and monoxide as well as nitrous gases and particulates. It is now accepted that this is a major cause of breathing diseases particularly in young children who reside within 500 meters from a major road or motorway. It is now understood that the lung capacity of children in the 10 to 18 age group can suffer from stunted lung growth.

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DTPC comment relating to increased traffic;

“The submitted documents do not include for an air quality assessment, this is unusual given the 250 units at say 5.5 trips per unit would generate in the region of 1375 two way, well above the 100 two way AADT threshold.”

The Parish Council asks for an AQA to be required.

7 Amenities

Schools – Whittle-Le-Woods boasts two Primary Schools – St Chads & Whittle-Le-Woods Primary School. The annual total intake for both schools totals 55 whilst applications last year were well over 150. The developers own reports forecast the new development will mean 76 additional primary school children. The need to transport young children to schools in the wider 2-mile radius catchment area, almost certainly by car, is unacceptable and should not be permitted.

Shops – The developers plan are out of date and suggest new residents will use a Londis that has been closed since 30 April 2018. The nearest convenience store will be at the Co-op 1.2 kilometres away from the site by road. The route suggested by the developer is via muddy paths and totally impractical. Almost all shopping trips will be by car to large supermarkets e.g. Buckshaw, Clayton Green or Chorley.

Doctors – Whittle surgery is oversubscribed and appointment times are under pressure. This surgery will relocate in 2022 to a larger site in Clayton–le- Woods, which is farther away from the site.

Dentists – There are none in Whittle-le-Woods which accept NHS patients.

Buses- We are advised that Stagecoach will not provide a service on Town Lane because of the highways issues already highlighted in this document.

Contrary to assertions made by the Applicant the routes, and distances to amenities will encourage car journeys rather than cycling and/or walking.

8 Development Characteristics

Redrow’s Application does not specify details of house styles but the site plan suggests, 4- bedroom detached properties for the most part, with smaller terraced blocks to the east/nearest to the M61. We consider it likely the smaller houses will be the ‘affordable’ homes mentioned. It follows that these are most likely to be the ones to suffer the worst effects of noise and air pollution from the motorway and be the furthest away from amenities.

The Application does not make any firm commitment to the drive for zero carbon emissions by 2050 which we assume will be within the lifespan of the houses. With this in mind we would have hoped to see references to: electric charging points, none gas heating, up to date and efficient solar panels etc.

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Although Redrow say the site will provide a ‘distinct identity’ this must be doubted based on experience in Whittle-Le-Woods where Redrow homes mirror many other Redrow Estates across the country. We are not saying a Redrow house is not attractive in itself but the volumes now being built in the village will change the village’s character forever. Any houses should be more in keeping with the stone fronted / slate roofed properties that were traditionally associated with Whittle-Le-Woods pre-Redrow developments.

A development on the scale proposed will all but destroy the very environment that attracted developers and their house buyers in the first place.

9 Conclusion

This opportunistic Application is unwanted by the overwhelming majority of Whittle-le-Woods residents. Whilst it is apparent we have been ‘in the sights’ of this developer for decades the Application fails to prove that a development on this scale is in any way feasible for the reasons detailed above.

The proposals offer virtually no benefits and considerable disadvantages to the local population who would be expected to take on the consequential risks without valid mitigations.

Whittle-le-Woods Parish Council respectfully ask for this application 20/01347 to be refused at the earliest opportunity.

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