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Public Comments on the Churnet Valley Options Report – Meeting at Moorlands House, Leek, 7pm Wed 18 July 2012

The results of the public consultation on the Churnet Valley Master Plan Options Report are to be presented in an officer report to the District Council at 7pm on Wednesday 18th April 2012 at Moorlands House, Stockwell Street, Leek.  Members of the public may observe from the public gallery.

The officer report summarises the 3695 individual comments made by the 226 respondents to the five options for tourism development in the Churnet Valley identified by the council.  The officer report is viewable on the district council’s website via the following link:

Support for the five development options was as follows:-

Refusal to select any of the District Council options                                         26%

Option A Minimal Development                                                                         44%

Option B  Dispersed Development                                                                       6%

Option C Northern Focus                                                                                     12%

Option D Froghall Focus                                                                                        7%

Option E Southern Focus                                                                                       5%


The next step is for the officers to write a draft Churnet Valley Master Plan that will need to conform to the council’s Core Strategy (yet to be finalised) and the new National Planning Policy Framework (NPPF).  The meeting at 7pm on Wed 18 July 2012 at Leek presents an opportunity for you to listen to how the council receives the officer report.


District Council Core Strategy

Your Representations on the Core Strategy – closing date 13 July 2012


You may have missed the plans of SMDC to re-consult on the Authority’s plans for Staffordshire Moorlands until 2026.

Representations have to be with SMDC by 13/7/2012 and WAG urges you not to miss the opportunity to have a say in the future of your community.

The test to be met is that the Core Strategy is Legally Compliant and ‘Sound’.

Since representations were made in the period that ended in January 2012 the planning laws and guidelines have changed and it is now necessary to show that ‘Legal Compliance and Soundness’ must now be measured against the provisions of the Localism Act 2011 and the National Planning Policy Framework.  These new provisions are complex and contain many as yet untested concepts.
If any of you would like help in structuring any response that you intend to make to the Core Strategy Document you may find help in the following list of instances of non-compliance identified by WAG:-



In this submission CSD means the Core Strategy Document that is the subject of this submission.

NPPF means the National Planning Policy Framework introduced by the Localism Act 2011.


Any paragraph numbers referred to herein are those used in the NPPF 2012.    Because of the format, space and time restrictions placed upon this response and a lack of access and the opportunity to verify the contents of all documents that do or might constitute the CSD the following points, are not in this document, fully argued although some are briefly referred to by way of indication only.  With appropriate time and access to all the evidential base and expertise more detailed submissions can be made.



  • The CSD at the date of this submission is neither legally compliant nor sound for the reasons stated in previous submissions by WAG members and it is not compliant with NPPF 2012.
  • Large parts of the CSD fail to meet the criteria set out in the NPPF regarding “sustainable development”.
  • The CSD contains proposals for change which do not meet the criteria that it is “for the better”.
  • The CSD contains proposals that are not “essential to our well-being”.
  • The CSD contains elements that are not “economically  sustainable” as required by the NPPF. For a development to be economically  sustainable it must make a profit and the CSD contains no provision to show how that is to be determined. It therefore fails to meet the criteria as required in the NPPF.
  • The Governments “requirement” is that the CSD is  “relevant”, “proportionate”, and “necessary”. The CSD contains no or no credible and objectively assessable evidence that it meets the requirements of Paragraph 1.
  • The CSD fails in a number ways to promote EU obligations and statutory requirements. For reasons set out above a full recital of the nature and extent of those failings cannot be set out here, but broadly they encompass environmental enforcement legislation, greenbelt issues, toxic waste issues, a failure to support proposals with objectively      assessable evidence, a failure to disclose evidence that relates to a  clear change of policy during the preparation of the CSD arising out of  and as result of private assurances given to “Key Stakeholders” and despite formal and entirely proper and appropriate requests under the Freedom of Information Act [FOI].
  • The CSD fails to use a clear and logical matrix to assess such evidence, if any, that might have been obtained.
  • The CSD fails to comply with the legal provisions set out in the decision making framework set out in the Planning Act 2008.[See   above and later with regard to private assurances given to and the identification of “Key Stakeholders”.]
  • The CSD fails to meet the criteria of “sustainable development” as set out in Resolution 42/187 of the United Nations General   Assembly or the United Kingdoms “Sustainable Development Strategy Securing   the Future”.  In particular it does not demonstrate the “ five guiding principles of sustainable development viz.,

                                     1. Living within the planets environmental limits.

                                     2. Ensuring a strong, healthy and just society.

                                     3. Achieving a sustainable economy.

                                     4. Promoting good governance.

                                     5. Using sound science responsibly.

A few examples of these failings are:-

  1. Lack of consultation with those who are at danger from  contamination and the  removal  of heavy metals from sites where they are known to exist.
  2. The CSD as currently drawn makes no proper provision to remove or reduce the risk to residents from certain specified dangerous sites despite expert evidence that spells out its dangers to publi  health.
  3. MDCs failure to adhere to its own consultation protocol  means that the CSD does not meet the criteria relating to a “just society”.
  • SMDCs failure/ refusal to disclose the evidence of itsconsultation with and any commitments it has made to “Key Stakeholders” in regard to the specific amendments to the CSD that have been made to meet those commitments demonstrates that it is not committed to “promoting good governance” and is therefore not compliant with NPPF.
  • The CSD appears to demonstrate a complete absence of the use of “sound” science.
  • The CSD fails to comply, in some cases at all, with      paragraphs 18-219 NPPF inclusive.
  • The CSD cannot demonstrate that it is “economically sustainable” as it is required to do. For any development to be      economically sustainable it must “make a profit” otherwise it is      demonstrably not sustainable. The CSD contains no provision for showing  how any particular development will meet that criteria. It is submitted  that a combination of the legal doctrines of “Restraint of Trade” and “Commercial Confidentiality” will render the CSD inoperable when any attempt is made to assess whether and if so how any particular development meets the criteria of “economical sustainability”
  • As local communities were not consulted [in some cases a all] and/or in compliance with SMDCs best practice guidelines on the preparation of the CSD it cannot be shown to meet the criteria to “ reflect the communities needs and support its health, social and cultural well-being”. The Leader of SMDC has very recently gone on public record      saying “A Councillors job is to make decisions for the community, no  follow public opinion.” Such an approach underpins the reality that loca  communities are not being consulted properly and/or at all.
  • The CSD demonstrates in specific areas that it does not “  contribute to protecting and enhancing [the] natural, built and historic environment, improve bio-diversity, use natural resources prudently, minimise waste and pollution and mitigate and adapt to climate change including moving to a low carbon [local] economy”. Examples are an  existing failure to manage/mitigate pollution, a failure to demonstrate how it is to move towards a low carbon economy, a failure to produce/ promote/operate traffic management policies that might help achieve these aims.
  • The CSD fails to meet the NPPF requirement that “economic,  social and environmental gains” are being “ sought jointly and  simultaneously”.

The CSD does not contain any objectively assessable evidence of a commitment to “ improve peoples quality of life”

  • The CSD does not demonstrate how it will move from “a net loss of bio-diversity to achieving net gains for nature” or what matrix  will be employed to objectively measure same.
  • The CSD contains no matrix for establishing what constitutes “poor design” and “better design”.
  • The CSD contains no matrix for establishing what constitutes “improving the condition in which people live, work, travel, and take leisure”.
  • The CSD does not demonstrate how it complies with S.38 of  the Planning and Compulsory Purchase Act 2004 and S.70 Town and Country Planning Act 1990.
  • The CSD does not demonstrate that it has “an up to date Local Plan” in place.
  • The CSD does not demonstrate compliance with S.19 of the Planning and Compulsory Purchase Act 2004.
  • The CSD is substantially out of date, is based on time  expired data and does not meet “objectively assessed needs and displays a lack of flexibility”.
  • The CSD fails to demonstrate that it can or will restrict development that may endanger sites protected under the Birds and Habitat  Directive Paragraph 119 and/or SSSI, land designated as Greenbelt, Local  Green Spaces, area[s] of Outstanding Natural Beauty and Designated  Heritage Assets.
  • The CSD fails to demonstrate compliance with the requirement to be “genuinely plan-led” and that it “empowers local people to shape their surroundings”. Further in its preparation the CSD has failed to demonstrate “joint working and co-operation with the local community and has expressly refused to allow the public to question the CSD in what was purported to be “village or local conversations/consultations”. Further on he 15th November 2011  at a Cabinet meeting of SMDC an elected represented wrongly represented  those “conversations/consultations” as providing the evidence base upon  which a planning policy document was to be released for discussion on a restricted number of options. When challenged on this matter SMDC refused  to ensure an accurate and balanced record of the representations appeared in the minutes of that meeting.[* see also the quoted remarks of the Leader of the SMDC above]. These matters and others referred to above demonstrate an authority that is unwilling and/or unable to meet the criteria requiring them to “ promote good governance”.
  • The CSD fails to take any or any proper and proportionate account of the roles and character of different areas affected by the CSD  and it is not in any objective way evidence-led or evidence based. In particular it contains provisions specifically written in at the request      of and in order to permit “ Key Stakeholders” the opportunity to damage the Greenbelt contrary to the provisions of the NPPF, such alterations i the then draft CSD being made without consultation of any kind with the      local community.[Documentary evidence exists to support this assertion.]
  • The CSD does not “contribute to conserving and enhancing the natural environment and reducing pollution”. Rather it contains  positive proposals that will, objectively assessed, damage the natural environment, pollute it and/or fail to ensure that pollution is safely removed.
  • The CSD fails sufficiently and in some cases at all to develop policies that encourage the re-use of Brownfield sites and land of      lesser environmental value.[eg insufficient emphasis on locating  development in the “gateway”  towns of Leek, Biddulph and Cheadle and using the power to give “business rate holidays” to help start up small new businesses]
  • The CSD contains few if any significant proposals as to how it will meet its obligations under the provisions of the NPPF to make  use of “ public transport in areas which are or can be made sustainable”.
  • In so far as the CSD contains any statement of “a clear economic vision and strategy” [and it is submitted that it does not in any  objectively assessable way] it is based on purported evidence that is now  substantially out of date and should not be relied upon. Further the brief prepared for the agency that produced the report upon which this aspect of      the CSD relies was such that it predicated the conclusions reached and cannot properly be regarded as “evidence”.
  • The CSD does not contain provision for it to apply the “sequential test” to planning applications.
  • The CSD appears not to contain any or any sufficiently clear and tightly drawn requirement for an “impact assessment” in those situations where one would be required.
  • The CSD contains no logical or enforceable policy to  ensure compliance with the authorities duty to “respect the character of      the countryside”.[In a planning application determined locally only days  before the provisions of the NPPF came into force the Authority purported to apply the principle shortly due to come into force in the Localism Act and the NPPF  namely applying the “presumption in favour of granting” the application before it. Yet it      acted inconsistently and partially by failing to apply the   principles relating to traffic issues and the adverse effects of excessive car usage in an area where there  existed an evident and longstanding nuisance that has “adverse effects on      the character of the countryside”. Neither was there any attempt to promote the principle of moving to a low carbon economy by measures aimed at reducing the impact of motor vehicles.  No attempt was made to promote  or manage the road environment or to promote bio-diversity and no assessment  was made to assess whether the development met the criteria of “economic   sustainability”.  The “pick and mix approach” to the above mentioned  application used by SMDC demonstrates further evidence that the Authority in developing the CSD is not equipped to properly apply the “ Wednesbuy Principles” to the issues of reasonableness and objectivity in so far as  it applies to the criteria set out in the NPPF.
  • The CSD does not demonstrate any or any sufficient and objectively assessable commitment to the NPPF requirement that it must  assess what constitutes “severe residual cumulative impacts”.
  • The CSD fails to demonstrate any or any significant commitment to prioritise pedestrian and cycle movement and is therefore  not compliant with NPPF.
  • The CSD fails to ensure that any sustainable development  is supported by an objectively assessable Travel Plan or to determine what matrix will be used to assess same.
  • The CSD contains no or no significant commitment to mee “the overall need to reduce the use of high-emission vehicles” an  contains no definition of such vehicles and is thereby not compliant wit NPPF.
  • The CSD contains no up to date, evidence-based andobjectively assessable need for “market” and “affordable” housing in relation to distinct and specific local communities as predicated by the scheme of development set out in the Localism Act and the NPPF. Rather SMDC has determined in advance that named communities must accommodate a  pre-specified number of “market” and/or “affordable” homes within a set time frame that has no regard to or survey of existing and available unoccupied properties within specified local communities.
  • The CSD fails to identify and has not annually up-dated  register of “specifically deliverable” sites for development and to make      the details of such a register available to scrutiny by local residents.      Further the following criteria is not met, namely, specifically deliverable sites must “offer a suitable location for development “ now,  and be achievable with a realistic prospect that housing will be deliverable on the site within five years and in particular that      development of the site is viable”. The CSD contains no definition of  “viable” or how such a concept will be compliant with NPPF.
  • The CSD fails to demonstrate a “five year supply of deliverable housing sites” in a way that complies with the scheme and statutory intent of the Localism Act and the NPPF.
  • The CSD fails to demonstrate that SMDC has “work[ed] with  the support of their local communities” in a way that fits with the intent and the scheme set out in the Localism Act and the NPPF. Rather SMDC has expressly  denied local communities “the opportunity to provide the best way of  achieving sustainable development” by misrepresenting the nature of village/local conversation/consultations and denying members of those communities access to such meetings as were held.
  • The CSD contains no “robust and comprehensive policies that set out the quality of development that will be expected in the area”  and which fits within the scheme and intent of the Localism Act and the NPPF.
  • The CSD contains no “understanding and evaluation of its[the separate local communities] defining characteristics”.
  • The CSD in being prepared has failed “to involve all sections of the community in the development of Local Plans”.
  • The CSD contains no provision to ensure a “positive and collaborative approach to the new “Community Right to Build Orders” and is  thus not complaint with NPPF.
  • The CSD contains no provision to “protect public Rights o Way and access to land”. Further and in so far as the national Government has set up a Cabinet Committee to receive evidence and submissions concerning the perceived need to “get rid of red-tape” and that the said  committee has as yet set no date to deliver a report and that national      bodies such as The Ramblers, The National Trust and the CPRE have   expressed concerns to the Cabinet committee about the proposals made by      organisations representing the interests of private land owners, that if      adopted, would remove/reduce the publics access to land, it is imperative  that the CSD contains a clear and unambiguous commitment to “Protect      public Rights of Way and access to land and incorporates in the CSD  documentary evidence of all current and planned Rights of Way and intended access to land under the “right to roam” legislation so as to protect  present and future generations right of access.
  • In specified areas the CSD is not compliant with Government policy on Green Belt and does not meet the provisions of the NPPF.
  • The CSD contains few [if any] plans to “positively enhance the beneficial use of the Green Belt” and is thus not compliant with NPPF.
  • The CSD fails to comply with the NPPF with regard to Mineral extraction.
  • The CSD fails sufficiently and/or at all to “protect and  enhance valued landscapes, geological conservation interests, fails to  recognise the wider benefits of ecosystems, fails to minimise impacts on  bio-diversity at specific sites and to provided for net gains of      bio-diversity and fails to establish coherent ecological networks that are      more resilient to current and future pressures”.
  • The CSD fails to meet, in any objectively assessable way, the duty of SMDC to “minimise pollution and other adverse effects on the  local and natural environment” and is thus not compliant with NPPF.  At specific sites the authority is in breach of its duty to protect the publics health.
  • The CSD demonstrates few if any criteria based policies to protect against developments that would or might affect protected wildlife or geo-diversity sites or landscapes. Further it fails to incorporate the guidance contained in circular 06/2005. It is not compliant with NPPF.
  • The CSD fails to show how it will comply with its duty to ensure that its effects meet the obligation to operate “across local      authority boundaries” and is thus not compliant with NPPF.
  • The CSD fails sufficiently, or at all, to “promote the  preservation, restoration and re-creation of priority habitat, ecological      networks and the protection and recovery of priority species populations      linked to national and local targets and to identify suitable indicators      for monitoring biodiversity. It is thus not compliant with NPPF.
  • The CSD fails to identify sufficiently, or at all, how and      in what circumstances it will meet the “primary objective of conserving or enhancing biodiversity” and is thus not compliant with NPPF.
  • The CSD contains no provision, commitment or scheme to show how and in what circumstances it will adhere to the principles set      out in Part 11A of the Environmental Protection Act 1990 and is thus not compliant with NPPF.
  • The CSD contains no provision or mechanism to identify and protect “areas of tranquillity” and it thus not compliant with NPPF.
  • The CSD contains no or no sufficient and “positive  strategy for the conservation and enjoyment of the historic environment      including heritage assets most at risk” and does not comply with the Planning [Listed Buildings and Conservation Areas] Act 1990.It is not  therefore compliant with NPPF.
  • The CSD is not compliant with the provisions of paragraphs 142-149 of the NPPF.
  • The CSD is not compliant with the provisions of paragraphs  150-157 of the NPPF.
  • The CSD is not compliant with paragraph 158 of the NPPF as   it is not based on up to date and relevant evidence of economic, social      and environmental characteristics and prospects of the area.
  • The CSD does not demonstrate how it has complied with its duty to co-operate with neighbouring authorities, public, voluntary, and private sector organisations in a way that meets the criteria of  sustainability set out in the NPPF and is therefore not compliant.
  • The CSD fails to demonstrate its compliance with      paragraphs 163,165, 166 of the NPPF. The refusal of SMDC to say how and by  what criteria it identified “ Key Stakeholders” and the rejection of  requests of individuals and organisations to become “ Key Stakeholders” in the process of planning for the future of local communities demonstrated an unwillingness to commit to the then emerging principles of the NPPF.
  • The CSD fails to demonstrate how it will comply with      paragraphs 173-177 inclusive of NPPF
  • The CSD fails to demonstrate how it will meet its duty to  comply with paragraphs 178-181 inclusive of NPPF.
  • The CSD fails to demonstrate compliance with paragraph 182 of NPPF relating to its duty to co-operate with and observe the legal and  procedural requirements and to show how it meets the obligations of “soundness”.   It is not in any objectively measurable sense “Positively prepared,  Justified, Effective, or Consistent” with national policy.
  • The CSD is not compliant with paragraphs 183, 184, 185 of      NPPF. Officers and elected representatives have misrepresented the      mechanisms, purposes and objectives of processes they have used in      developing the CSD and so have failed in the duty to “put forward a shared  vision of sustainable development” in the local communities within the      schemes and intentions set out in the Localism Act and the NPPF.
  • The CSD is not compliant with paragraphs 188-195 inclusive  as evidenced by the following;
  • Officers have engaged in secret meetings with “Key Stakeholders” during which they have given commitments to prepare the CSD in a manner that furthers the commercial interests of those “ Stake Holders” and have failed to keep any or any accurate notes of such  meetings and/or have failed to disclose the fact of those meetings and the      contents thereof despite proper requests to do so by local residents under  the FOI Act.
  • Reworked the CSD to ensure no obstruction is placed in the way of the commercial interests of those “Key Stake Holders” in bringing  forward plans for developments upon which local communities have been positively denied an opportunity to comment or view any evidence upon  which such commitments have been made.
  • rejected requests from the local community to be considered   “key stakeholders” in the process of preparing the CSD.
  • demonstrated an unwillingness to commit to “ open  governance”
  • The CSD is not compliant with paragraphs 203-207 of NPPF.      The public record demonstrates that SMDC has failed to use its planning      enforcement powers to properly and to adequately protect the historic built environment [e.g. Cotton College]


                  For All the reasons set out above and many more too numerous and detailed to set out herein it is submitted that the CSD is not legally compliant or sound.

WAG Supported by the Campaign to Protect Rural England.

WAG Supported by the Campaign to Protect Rural England.

Following the submission of the Whiston Action Group Alternative Master Plan to Staffordshire Moorlands District Council supportive comments have been received from a national body, The Campaign to Protect Rural England.

Local villagers from Whiston Action Group, are critical of the District Council for failing to adequately consult with residents in the Churnet Valley.   Council proposals to significantly increase tourism through the development of a series of tourist attractions along the valley do not sit comfortably with local people, who feel the proposals are excessive in scale for the sensitive nature of such a small compact valley.   Nick Cresswell, the actions group’s communications officer said that:-

 “Residents are concerned that the valley is going to be exploited for commercial gain. We are particularly opposed to proposals for Moneystone Quarry along Whiston Eaves Lane between Whiston and Oakamoor, where the imposition of 640 holiday lodges and a 100-120 bed hotel is  totally outrageous in such a confined area.  The scale of the proposals is driven solely by commercial interest with no regard for residents.  If these excessive developments were allowed to go ahead there would be a severe impact on local residents in terms of traffic and degradation of what at present is a beautiful quiet country lane with great views and wildlife.  To impose such a level of development would destroy the area’s peace and tranquillity that we should be conserving for future generations to enjoy.”

 Whiston Action Group has responded to the recent Staffordshire Moorlands District Council public consultation by presenting a 50 page evidential document expressing concerns and demanding  a new more inclusive consultation where the needs of local people are given greater consideration.  Other groups from the valley have also expressed opposition to the council’s proposals during a recent consultation exercise.  The district council’s website currently shows 184 pages of comments from the public on the master plan, the vast majority expressing views in opposition to the council’s proposals.  Nick Cresswell said,

“The sheer weight of the public response must surely prompt conscientious district councillors to question the very basis of these commercially led proposals that are not in the interests of residents.  They cannot help but see that the people of the Staffordshire Moorlands are not happy with what is proposed.  They should require the planning officers to conduct a complete review, from a starting point of full public consultation.”

He went on to explain that the growing disquiet amongst residents across a wide area has now attracted the attention of a nationally respected campaign body, The Council to Protect Rural England.  Nick Cresswell highlighted the recognition Whiston Action Group has received from the national body, saying:-

“Following our submission to the district council The Campaign to Protect Rural England has congratulated Whiston Action Group on its work, with the opinion that it represents the best kind of local involvement over the whole field of planning. CPRE considers it compliments and reflects much of CPRE’s countryside work, especially current concerns over the District Council’s Local Development Framework where it views with dismay the minimal regard being paid to changing social, economic and environmental conditions forecast to occur over the 20 year period of the plan.  CPRE has made it clear to Staffordshire Moorlands District Council its views concerning the value scenically and environmentally of the Churnet Valley and its conviction that the Churnet Valley Master Plan must be environmentally driven.”

“Whiston Action Group is encouraged by the CPRE comments and will continue to vigorously press home our perfectly reasonable demand that the beauty and tranquillity of the quiet country lane between Whiston and Oakamoor be conserved for future generations to enjoy.”




Moneystone Quarry

Moneystone Quarry mature pond & valuable scrub habitat

Moneystone Quarry

  • Disused sand quarry between Whiston and Oakamoor at risk of excessive development.
  • Older parts of the quarry workings have already naturally regenerated into valuable wildlife habitat.
  • There is an existing restoration plan obligation on the owner to return the quarry to its natural green state for the benefit of the environment.  Staffordshire County Council is the enforcement authority.
  • The current owners want to impose 640 tourist lodges and a 100-120 bed hotel, excessive development that would damage the environment and disrupt local communities.
  • Access along the narrow and winding Whiston Eaves Lane would be unable to cope with traffic from the proposed development.
  • Additional concerns relate to the safety issues on Carr Bank, Oakamoor, from traffic travelling from the development to and from Alton Towers.

At the time of the preparation of this submission a state of much uncertainty and anxiety exists within the area centred upon Moneystone Quarry and which includes Moneystone, WhistonVillage, Oakamoor and Cotton.

The former owners of the site ceased to operate Moneystone Quarry at the end of December 2011 although it is understood that it retains freehold title to the Laboratory Complex on the site and with it presumably a right of ingress and egress. Currently the quarry site is being cleared of redundant plant and machinery.

Moneystone Quarry - settling lagoon, valuable lapwing roost

The formal position is that the site owners in 1996 when applying for the permission to extract silica sand deposits were made the subject of binding written conditions as to the nature and extent of the  restoration of the site. This became officially adopted policy and the restoration of the site to meadow land remains a planning condition.[Planning permission 96/935 refers].WAG are pressing the enforcement authority Staffordshire County Council to ensure and insist upon the full honouring of that restoration and have received written assurances to that effect. [Letter of Paul Wilcox SCC dated 30/6/11 refers].

It is known that the new owners of Moneystone Quarry Laver Leisure {Oakamoor} Ltd. are in discussions with Staffordshire County Council with a view to altering the restoration conditions. WAG representatives continue to monitor the situation in an attempt to ensure that the protection promised to the site is not diluted.

A representative of WAG was able to meet with Mr, Peter Swallow Managing Director of the new owners in August 2010.  He sought and received assurances about the plans for the future use of the quarry site.  It is now a matter of record and of public knowledge that virtually none of the assurances given in August 2010 were demonstrated in the public presentation given at Whiston Village Hall in February 2011.  There have been subsequent attempts to ‘spin’ the reaction of concerned residents and put a positive gloss on the event in the local media.  It very quickly became clear that the proposals had created a great deal of local opposition.

Moneystone Quarry - valuable scrub habitat for migrant birds

The record shows that the public pronouncements Laver Leisure [Oakamoor] Ltd. have made have at times been contradictory and often lacked clarity.  On past assurances residents have every reason not to trust what they are told.  To that end members of WAG and a separate group of residents in Oakamoor prepared, circulated and collated a detailed survey of all residents to discover what, if any, support there was for Laver Leisure [Oakamoor]Ltd. proposals. The results of the survey, detailed in appendix D, and show a virtually unanimous opposition.

The commitment which was incorporated in the extant planning conditions requiring restoration include:


  • Restoration of existing and proposed quarrying areas.
  • To include the recreation of a variety of habitats using locally sourced   native and rare species.
  • A comprehensive conservation management plan.
  • Woodlands, hay meadows, wetlands, heath land, hedgerows and the construction of dry stone walls.
  • Restoration to blend in with the surrounding landscape.
  • Creating a variety of new habitats for plants and wildlife.
  • Bat Cave.
  • [That] Environmental promises will be kept [and] overseen in THE PUBLICS INTEREST by S.C.C. [and be] monitored by the Environmental Agency.
  • That there would be a conservation management plan developed for the site.

[source Planning permission SM 96/935; Moneystone Quarry News Sept. 1996]

Laver Leisure {Oakamoor} Ltd. [LL{O} Ltd. Company number 06982054 is a Private Limited liability company incorporated in 2010.   It has a share issue of 100 shares. It therefore has a limited liability to the people or organisations with which it does business of £100.

Assurances have been received by WAG from the previous owners of Moneystone Quarry, SibelcoUK, that LL{O} Ltd. have inherited full responsibility for executing the restoration of the quarry site in accordance with the existing planning conditions.  The duty to ensure that the restoration conditions are met is that of S.C.C. Again WAG has received written assurances from S.C.C. that they will enforce the restoration conditions.  It is entirely unclear what redress, if any, S.C.C. would have in the event that LL{O}Ltd. defaulted in meeting its obligation to restore the site in accordance with the existing conditions.

Given that the full extent of the present owners legal liability to meet the cost of restoration is £100 it is to be hoped that Staffordshire County Council has exercised ‘due diligence’ in ensuring that such an eventuality, however remote it might be, has been covered.  It is not known if Staffordshire County Council has taken a bond payment ‘up front’ to protect the public purse.

Once it became clear in early 2011 what proposals LL{O}Ltd. had in mind for the redevelopment of Moneystone Quarry a team of WAG representatives began a detailed analysis of the public record to establish the nature and extent of contacts, discussions,  offers, commitments etc., there had been between it or its agents and SMDC planners and/or elected representatives of the authority. To that end a series of Freedom of Information Act   applications were submitted.

Despite an unsolicited commitment to ‘open government’ given by Council Leader Councillor Sybil Ralphs at the Cabinet Meeting on 15th November 2011, and her assertion that ‘this authority does not do deals behind closed doors’, all FOIA requests have been rejected and/or ignored and/or failed to disclose the information requested.

Textual analysis of such documentation as WAG members have been able to discover tends to show that representatives and/or agents of the new owners have been in discussions with SMDC officials, well before residents of Whiston or Moneystone, knew of their existence or their proposals for the development of Moneystone Quarry.

A representative of WAG was able to meet with Mr Peter Swallow, Managing Director of the new owners at 3.10pm on the 11/8/2010. He sought and received detailed assurances about LL{O}Ltd’s plans for the redevelopment of Moneystone Quarry.

It is now a matter of public record that virtually none of those assurances have been met. Indeed the consultation exercise held at Whiston Village Hall in February 2011 illustrated many of the features Mr Swallow had expressly ruled out. Subsequent attempts to ‘spin’ the reaction of residents in the media have served only to harden local resolve to resist them. Any degree of goodwill towards LL{O}Ltd. was destroyed by the mismatch between the assurances given and the actuality of the details displayed at the public consultation.

To ensure that WAG was able to democratically represent the views of residents in any future consultations about the proposed developments for Moneystone Quarry a detailed questionnaire was prepared and distributed to every residence in Whiston and Moneystone. The completed forms were then collected and collated. The findings are shown in appendix D.  It was evident that there was overwhelming opposition by residents to the proposals of LL{O}Ltd.

 Issues of disclosure of Information directly relating to the proposed development of Moneystone Quarry.

In the face of refusals/failures by SMDC to be open with residents of Whiston and Moneystone about the nature and extent of any discussions and/or commitments etc., given by either SMDC or LL{O}Ltd. concerning the proposed development at Moneystone Quarry WAG has had to rely upon the very limited material only very lately put into the public domain in an attempt to shape its response to the Churnet Valley Masterplan Options Report of January 2012.  It is noted that residents have barely a month in which to absorb the details of the ‘options’ and their implications for their community, let alone attempt to match the purported ‘evidence’ said to support those options and then submit a coherent response. SMDC on the other hand have had and taken years to produce the document.

Freedom of Information Act (FOIA) requests remain outstanding regarding SMDCs obligation to comply with all legal and procedural issues in the preparation of the CVMP Options Report.  What follows is a necessarily abbreviated analysis of such documentary evidence and/or policy which bear upon the future use of Moneystone Quarry.:-

  • The Department for Culture Media and Sport [DCMS] March 2011 Government Tourism Policy [page 14] is built upon a projected growth in national tourism numbers of 3.5% per year for each year up to 2020 [See Delloitte  Forecast].In the new reality of a prolonged market recession such expectations are now shown to be unsustainable across that time scale [a requirement of government policy and the Localism Act].  Current GDP growth for the last quarter of 2011 was shown to be 0.6% and predictions indicate the economy is unlikely to recover before the next Parliament due in 2015 or indeed beyond that date.
  • Government policy states ‘It is imperative that we protect our communities from being blighted by inappropriate or ugly developments and to preserve important and nationally significant historic buildings and landscapes’. [DCMS March 2011 Government Tourism Policy page 38]
  • It further states ‘Any development must satisfy the criteria of being genuinely sustainable development’. [DCMS March 2011 Government Tourism Policy page 39]

NB. National Government failed to define exactly what is meant by the concept of ‘sustainability’ in the Localism Act and has been heavily and extensively criticised for that failure by MPs and national bodies and organisations possessing the expertise to know just what potential legal chaos that failure will cause.  SMDC has adopted its own definition of ‘sustainability’ but so far as the record shows there has been no public consultation with residents upon that self adopted definition.  In the light of the above it is surprising but nonetheless instructive to note that they say of the proposed development by LL{O}Ltd at Moneystone Quarry that ‘it will need to largely create its own market…[and] it is unlikely to survive from existing markets to the Staffordshire Moorlands’[Staffordshire Moorlands Tourism Study 2011 TEAM, page 38].

It is therefore been assessed in accordance with SMDCs own definition as being unlikely to meet the criteria of ‘sustainability’ however it is defined.



Transport issues and related effects


Whiston Eaves Lane - narrow country lane with many bends not suitable for increased traffic

Road links to Moneystone Quarry are very constrained. They are little more than narrow winding country lanes.  A previous survey conducted on behalf of WAG by a Highway Engineer showed that the roads between the A52 and Oakamoor [Whiston Eaves Lane] and between the A52 and Moneystone and Whiston Eaves [Blakeley Lane] have no substrate. The road is made up of an accretion of thin layers of tarmac and pebble washes that have been applied over the years. Inspection of the substantially degraded edges of the roads demonstrate vividly the accuracy of this diagnosis.

Now extraction at Moneystone Quarry has ceased the road between Whiston and Oakamoor and Blakeley Lane has returned to its almost forgotten traditional usage, namely as a lane used by residents to meet their domestic needs.  The ‘baseline’ count of vehicle movements along Whiston Eaves Lane now averages 50 movements per day. These movements comprise private car movements by residents.

  • Peak traffic flows occur between 7am-9.30am and 4.30pm-6pm.
  • One school bus collects and delivers local pupils at a pickup point adjacent to the public telephone box close to the junction with the A52.  The school bus uses the 150 metre section of road between the junction with the A52 and Brookfield Close to turn around, always entering Whiston Eaves Lane and leaving it from the A52.
  • Between 10 and 20 of the daily vehicle movements are accounted for by parents dropping off and collecting school children.

It follows that the accurate baseline usage of the road is very low and the configuration of the road, its surfacing, drainage etc., is not designed to take substantially increased traffic flows.

Whiston Eaves Lane - proposed access road, a narrow winding lane.

Whiston Eaves Lane has very limited street lighting and only has a short run of pavement running for approximately 35 metres between the Old Post Office and Brookfield Close. A previous Section 106 agreement to extend the footpath to the Oakamoor edge of the village was never honoured.  In winter months and at night pedestrians are at risk from vehicle movements along Whiston Eaves Lane. At night pedestrians are wise to carry a torch for their own safety.

At the public display staged at Whiston Village Hall in February 2011 LL{O}Ltd. indicated that they expected their proposed development at Moneystone Quarry to operate throughout the year and to attract 100,000 visitors.

Such a level of usage would:-

  • Fail to meet the obligation placed upon SMDC planning authority ‘to ensure that the quality and character of the wider countryside was protected’[Office of Deputy Prime Minister2004 sustainable Planning Statement- sustainable development in rural areas]
  • Fail to give ‘greater priority to restraining potentially damaging developments [ibid]
  • Fail to ‘give greater weight to the conservation of the natural beauty of the landscape and countryside’[ibid paragraph 21]
  • Fail to reduce the need for travel especially by car’ [ibid Policy Guidance Note 13 paragraph 2] but would seriously increase the need for travel by car because of the sites inaccessibility by Coach or PSV.
  • Fail the IMPERATIVE ‘to protect our communities from being blighted by inappropriate or ugly developments’.
  • Fail to ‘leave the natural environment of [Whiston/Moneystone and] England in a better state than was inherited’ [Natural Environmental White Paper {2011} para2].
  • Fail to ‘enable people to protect green areas that are important to them’  [ibid]
  • Fail to enhance green corridors [ibid].
  • Fail to meet the fundamental aim of Green Belt policy to prevent urban sprawl, keep land permanently open and [maintain] the most important attribute of Green Belt [namely] their openness, [Office of Deputy Prime Minister {1995 amended 2001} Planning Guidance 2 Green Belts paragraph 1.4]
  • Fail the test of sustainable rural  development [Staffordshire Moorlands Tourism Study 2011 TEAM page 38]
  • Fail to ensure that the countryside is protected for the sake of its intrinsic character and beauty, the diversity of the landscape, heritage and wildlife, the wealth of its natural resources…’[DCLG {2009} Planning  policy Statement 4 Policy E6.1]
  • Fail to acknowledge that ‘the topography of the area is challenging for development’.[CV Accessibility and Connectivity Study 2011 page 28.]
  • Fail to acknowledge that the Moneystone Quarry proposals contain provision for caravans, yerts and lodges in visible locations and as such should be discouraged’ [CV Landscape Character Assessment [2011] and paragraph 10.4.9 CVMP baseline Report]
  • substantially increase the impact of vehicle movements associated with the proposed development and [create] pressure to carry out visually intrusive road improvements.’[CV Landscape Character Assessment 2011]


How did Moneystone Quarry come to acquire the nomenclature of  ‘Key Opportunity Site’?

It has proved a very difficult, complex and an almost impossible task to discover how and why Moneystone Quarry came by the above designation.  Had SMDC dealt properly with various FOIA requests much time, effort and expenditure by residents would have been saved.  The seeds of the concept can now be shown to arise out of express representations made on behalf of LL{O}Ltd  feeding the concept to SMDC planners as part of a determination to exploit Moneystone Quarry in pursuit of its own financial interests.[The detail is shown below]

The first time Whiston and Moneystone knew of this nomenclature came about almost accidentally.  Less than 24 hours before a ‘visioning event’ was due to take place at Consall Hall Gardens a Kingsley Parish Councillor was telephoned and asked to attend the function on behalf of Kingsley Parish Council.  The Councillor present characterised the event as more of ‘an exercise’ not unlike a multi-choice examination. He and a few other attendees tried to ask questions but where told the event was inappropriate for questions and answers.

Those attending the event at Consall Hall Gardens on 4/3/2011 where almost exclusively characterised by the Councillor as representing private commercial enterprises and were described as ‘Key Stakeholders’. Representative on behalf of LL{O}Ltd were present.  In the course of the meeting of 4/3/2011 a pamphlet entitled ‘Churnet Valley Masterplan’ was displayed. Unfortunately it does not disclose its date of printing so how proximate to the staging of the event it was produced is not known.  The leaflet clearly shows in plan form and in narrative that Moneystone Quarry had already been designated as a ‘Key Opportunity Site’.  Within that version of the pamphlet was set out a heading which reads ‘How will it [the CVMP] be prepared?’ Below that script are a series of boxes describing four stages of preparation. The visioning exercise/event taking place at Consall Hall Gardens appeared in the stage 2 box.

The stage 1 box contained the legend ‘collecting baseline data’. From that information it is clear that the CV Baseline Report had been prepared prior to 4/3/2011.  It must logically follow from the above that SMDC planners, before consulting with district or parish councillors or residents of the Churnet Valley but AFTER consulting with some ‘Key stakeholders’ had already determined, inter alia, to designate Moneystone Quarry as a ‘Key Opportunity site’.

At paragraph 1.6.1 of the CVMP Baseline Report of 2012 it  states..’[Moneystone Quarry] has been identified for further consideration as part of the Masterplan process BECAUSE THERE ARE KNOWN PRESSURES FOR CHANGE IN [this] AREA’[our emphasis].

No evidence is produced to support that assertion or demonstrate any ‘pressure for change’. At that time [and up to the present date]FOIA applications to uncover any evidence remain unanswered.  It can be said with the utmost certainty that no pressure for change at Moneystone Quarry was coming from residents of Whiston or Moneystone who had not been consulted AT ALL by SMDC, though of course they had had the opportunity to see LL{O}Ltd’s displays at Whiston Village Hall in February 2011.

This line of reasoning leads to TWO possibilities about how Moneystone Quarry came to be designated a ‘Key Opportunity Site’ in official planning policy that was showing ‘pressure for change’. These are;

  1. The SMDC planners have themselves devised the concept without any consultation with residents.


  1. The concept comes from LL{O}Ltd or agents acting on their behalf and theirs is the [commercial profit driven ] pressure for change.

Had SMDC dealt openly and fully with the FOIA applications there would have been no need for the above speculation or indeed the atmosphere of doubt and suspicion it has generated.  In the last few days before this document was prepared for printing WAG has uncovered a letter dated 22/1/2010[1] from HOW Planning LLP addressed to  ‘The Head of Regeneration Services’ at SMDC stating that they are acting on behalf Laver Leisure [Oakamoor} Ltd.

The letter states, inter alia,

  • a number of meetings with the Local Planning Authority at varying levels have already taken place and these representations follow those discussions
  • Supports the ‘development of the Churnet Valley Tourism Corridor together with comprehensive proposals for key sites such as Moneystone Quarry…’
  • therefore requests that the Core Strategy vision and objectives reflect the important[2] contribution to the wider area that can be gained from redeveloping the Moneystone Quarry. Furthermore, the emerging policies should incorporate sufficient flexibility to allow the site to come forward for redevelopment…
  • The letter states that ‘we are very keen for the Core Strategy to provide sufficient flexibility to enable the Moneystone Quarry to come forward for future redevelopment WITHOUT HAVING TO OVERCOME SIGNIFICANT POLICY BOUNDARIES WHICH MAY BE SET’ [our emphasis]

[1] Presumably the letter writer means that it is important to his client rather than to the Residents of Whiston, Moneystone and the wider Churnet Valley.

[2] It should be noted that these representations and those made in the preceding meetings ‘at varying levels’ of the Local Planning Authority predate  by more than a year the display mounted by LL{O}Ltd at Whiston Village Hall in February 2011.


Moneystone Quarry and the Churnet Valley as a whole have the ability to support important populations of a number of protected and notable flora and fauna species and important habitat types, both at a local and also potentially at a county level of importance.

 A data search from Staffordshire Biological Record Centre has highlighted a range of protected species and habitats from within the quarry itself and its immediate surrounds, although it is considered that these records may be patchy as survey effort is generally only on an ‘as required’ basis and access to land for surveys is sometimes not possible, leading to the surmise that while a number of protected species are listed, a large number of rare species that may be present in the habitats found in the area (particularly invertebrates)  are likely to be under-recorded, and it is probable that data for a number of species that are in the list may be out of date or indeed non-existent if the need to survey for such species has not arisen.  Invertebrates in particular tend to be low on records in general, and it is entirely possible that the Churnet Valley could support populations of such speciesThe Churnet Valley has been proposed as an Area of Outstanding Natural Beauty (AONB), a status that would be richly deserved as it is one of the few remaining areas able to retain its natural attraction to ecologically friendly tourists due to the general lack of development in the area and the small unspoilt, and often historically interesting villages that can be found there.Habitats and Protected/Notable Species HabitatsMoneystone Quarry is surrounded by sites of interest for conservation, either for the habitats contained within them or individual/groups of flora and fauna species present.These include Sites of Special Scientific Interest1)      Whiston Eaves SSSI notified for its meadow habitats and the presence of the bullhead (Cottus gobio).2)      Churnet Valley SSSI notified for its mosaic of habitats and assemblages of rare bird and flora species3)      Froghall Meadows and Pastures SSSI notified for its unimproved grassland characteristics and flushes.In addition to this are a range of National Nature Reserves, Sites of Biological Importance, Staffordshire Wildlife Trust Nature Reserves, Biodiversity Alert Sites and areas of Ancient Woodland.While it is understood that these areas would be protected by the development proposals, it is considered that these habitats are important enough to the area to be increased and as Moneystone Quarry is,  by and large, at the centre of all these areas it is possible that with careful management of the emerging habitats following the cessation of quarrying, the quarry can become a biologically important area in its own right and aid in the connectivity of these areas, allowing numerous species to expand into it.Protected and Notable Flora and Fauna SpeciesA number of protected and notable species were given in the records from Staffordshire Biological Record Centre (SBRC), a number of which occur in Moneystone Quarry itself.Species found there include the European Protected Species great crested newt (Triturus cristatus), and also a number of species with protection under the Wildlife and Countryside Act 1981 (as amended) including common toad (Bufo bufo); slow worm (Anguis fragilis); grass snake (Natrix natrix); smooth newt (Lissotriton vulgaris); common lizard (Zootoca vivipara), and birds on the RSPB Birds of Conservation Concern list including jack snipe (Lymnocryptes minimus) and little grebe (Tachybaptus ruficollis), both of which are amber listed species.In the wider area, a number of protected and notable species have been recorded in the vicinity of Moneystone Quarry including otter (Lutra lutra) and freshwater white-clawed crayfish (Austropotamobius pallipes) among others.A number of bat species and badger are also recorded in the local area and it is entirely possible that they are using the quarry, although no bat records from the quarry itself were given by  SBRC, and the badger data is confidential so cannot be pinned down to an exact grid reference.Potential Ecological IssuesThe plans to develop Moneystone Quarry would, at the very least, cause disturbance to populations of any protected species present within it through increased human traffic, lighting and noise, and combined with the planned re-opening of the railway line between Moneystone and Alton Towers has the potential to cause disturbance and habitat fragmentation far beyond the boundaries of the quarry itself, most notably to the Daubenton’s bat (Myotis daubentonii) and pipistrelle bat (Pipistrellus sp.) populations that are known to use the disused railway tunnel in Oakamoor both as a winter hibernacular (SBRC record) and as a summer roost (personal observation).Add to this the possible impact of additional pollution to the local watercourses from increased vehicle traffic and diesel trains, and there is potential for the current proposals to have a large negative effect on flora and fauna populations not only within Moneystone Quarry, but also with further reaching implications throughout the Churnet Valley. The claim that the increased tourism would be of benefit to the economy of the Churnet Valley appears to be limited to the potential for a few jobs to be created in the Moneystone Quarry development, but any further benefits are likely to only be gained by the owners of Moneystone Quarry and Alton Towers at the expense of a delightful part of the British countryside and its wildlife.The original proposal to restore Moneystone Quarry and potentially declare it and its surrounds as an Area of Outstanding Natural Beauty would also increase tourism to the area, but in a more environmentally friendly way through sensitive use of the area by outdoor enthusiasts and wildlife watchers rather than simply shuttling people between the Moneystone Quarry development and Alton Towers and would result in a more ecologically sustainable use of the Churnet Valley area.Sensitive management of the quarry would enable habitats to be created that could provide highly positive connectivity between the existing areas of conservation importance surrounding the quarry and allow movement of species into other areas that would be unlikely to occur if the current proposals are allowed to go ahead.The restoration of the quarry (as originally agreed) would provide an ideal opportunity to improve the local area, both in terms of its wildlife and residents and for people from the wider area as well as providing scope to generate income for the local area as visitors would be more likely to use local shops, bed and breakfasts, public houses etc. and also valuable education for children and adults alike.Restored quarries are known to be havens for large numbers of species including flora species, invertebrates, herpetofauna, mammals, and not least bird species, particularly wildfowl as the lakes left behind following cessation of work often provide valuable breeding habitats for large numbers of wildfowl species.Employment could be generated in the area by paid workers (and also volunteers) taking part in the active restoration, giving local people a chance to get involved in their area and to gain skills that may otherwise be beyond their reach, potentially leading to worthwhile careers in their field of choice.The opportunities for the local community to benefit from the restoration are not limited to the immediate habitat work and continued management of the site. The area could also, once established, have the potential for the creation of an environmentally designed residential centre for the running of field courses for companies like the Institute of Ecology and Environmental Management, Joint Nature Conservancy Council and Field Studies Council as well as providing an educational facility for local schools, youth and adult groups alike.Creation of a mosaic of habitats within the site would also mean that it would appeal to specialist groups such as birdwatchers, bat groups and also potentially low-impact sports such as fishing, cycling and kayaking.Potential inclusion of a shop and information centre would mean that day visitors would be more likely to spend additional time in the area, and could be introduced to other local environmental attractions and informed of a range of activities that could be arranged including guided bat walks, badger watching or one day taster courses in field identification for a range of flora and fauna species.The restoration of the quarry and use of it in a way similar to that above would ensure that all residents of the Churnet Valley could make use of the site for leisure activities and that the site would continue to provide a haven for the species that currently inhabit it, and also species that would move in following the restoration.Overall, the restoration would be expected to raise the amenity profile of the area and also increase the biodiversity of the area as a whole, particularly if the restoration could extend to the disused section of railway, linking it to the current restored footpath to the east of Oakamoor.

Toad Crossing at Moneystone Quarry

Toad Crossing at Moneystone Quarry

A mass migration of mating toads has prompted local wildlife supporters to launch a rescue bid.  Members of Whiston Action Group have identified an important toad population in the disused Moneystone Quarry between Whiston and Oakamoor , where large scale development is proposed.   During the quarries operative years, as new parts of the quarry were opened up, the older parts were left to regenerate naturally.  Those older parts of the site have become a haven for wildlife and now attract a wide range of birds, animals and plants.   Of particular importance is a large naturalised pond that’s the main attraction for the toads at this time of year.  Amorous toads from a wide area travel there to breed, as it is a safe undisturbed place where they can mate and lay their eggs.   But the toads are under threat as Nick Cresswell, WAG’s communications officer, explained:-

“The toad main migratory route crosses the access road into the quarry.  What concerns us is that last year, in one day alone, 24 toads were squashed by quarry vehicles.  It’s probable that the accumulation of deaths over the whole migration period, which can last several weeks, amounts to hundreds and affects the breeding success and long term viability of the population.  A phased restoration programme to benefit wildlife, was put in place years ago when planning permission to extract sand was granted and still is a conditional requirement.  Unfortunately, the future of the toads is under threat from the new owners of the site, Laver Leisure, who have extensive tourism development plans for the site.  The high levels of traffic generated by such development would increase the mortality rate considerably and be devastating for the toad population.   Whiston Action Group wants Laver Leisure to complete the restoration plan, so that the toads and all wildlife may continue to enjoy valuable wildlife habitat.”

Members of WAG are exploring issues with the mineral planning officers of Staffordshire County Council, who have the responsibility for enforcing the restoration by Laver Leisure to ensure that they comply with their responsibilities. In addition WAG is liaising with Froglife, a national ecological organisation that co-ordinates recommendations for the registration of toad crossings with the Department for Transport, so that the highway authority can take appropriate measures to warn drivers of high volume toad migration crossing points around the quarry.

Tricia Williamson, a Whiston Wildlife enthusiast, is pictured highlighting the plight of the toads in the main problem area on the access road into Moneystone Quarry.





W.A.G. Concerns

  • Current tourist numbers are already degrading tourist ‘hot spots’.
  • Geography, topography and infrastructure of the Churnet Valley do not allow for the type and proposed levels of increased tourism.


Churnet Valley Master Plan – Lack of Public Consultation

  • Staffordshire Moorlands District Council failed to consult adequately with the public from the outset.
  • The proposals more reflect the demands of commercial enterprise than the aspirations of the public.
  • WAG wants Better tourism not More tourism. WAG supports a tourism industry based on small local businesses, where the profits stay within the community, rather than exploitation of the valley by major outside developers.



  • The district council proposals take no account of the inadequate road infrastructure in the Churnet Valley.  Alton Towers traffic is already a concern and further development can only make a bad situation worse.



  • The district council proposals will provide only a small number of jobs, most being part-time, low paid and likely to attract outside labour.  WAG would like to see more permanent skilled and professional jobs created through local tourism businesses and small scale industrial units on appropriate brownfield sites.

Area of Outstanding Natural Beauty. (A.O.N.B)

Area of Outstanding Natural Beauty

  • WAG supports the significant public interest in declaring the Churnet Valley an Area of Outstanding Natural Beauty.
  • At present the District Council fails to recognise the public’s obvious enthusiasm.
  • WAG supports Councillor Linda Malyon of Ipstones bidding for AONB status.

There is substantial pressure in the Staffordshire Moorlands for it to be declared an area of outstanding natural beauty.  That pressure is often manifest in news stories and letters in the press and wider media.  It has also been raised by residents at public and other meetings [e.g. meeting of SMDC Cabinet 15/11/2011] and is also to be found in written representations to SMDC  e.g. submissions by Churnet Valley Conservation Society regarding the Core Strategy and Masterplan documentation and those of various residents including those of Mr Paul Denning with his comments on the Core Strategy Revision ref CSR/23 of 30 Jan 12 and CSR/62 of 2 Feb 12 who gives a lucid and well argued submission in support of the adoption of AONB status, which WAG endorses.

A careful analysis of the documentation in the public domain and the structure and language of that documentation, linked to personal testimony, gives a clear impression that SMDC planners have set their face against supporting a proposal that AONB status should be sought.

The language and reasoning arguing against seeking such a status is both illuminating and at the same time ‘unreasonable’ in the sense of the legal test of ‘reasonableness’.  At a workshop meeting at the Nicholson Institute on 15th March 2011, following on from a ‘formatted school-like exercise’, a brief question and answer session was permitted.  Mr John Higgins, a resident of Old Furnace/Oakamoor and a longstanding and ardent supporter of the desire to protect the special qualities of the Churnet Valley asked the panel of officers from SMDC why the Authority was not in support of an application for ANOB status.  Two of those Officers where Mr Perry Wardle and Mr Gavin Clarke.  Mr Clarke chose to answer Mr Higgins question.  He is reliably reported as saying that ‘such a designation would be inappropriate because it would not be in the interest of the commercial enterprises that SMDC had been in discussion with and might restrict the plans SMDC had for the Churnet Valley’.  Witnesses were startled at Mr Clarkes’ response and more so by the sharp kick delivered by Mr Wardle to the legs of Mr Clarke as he displayed such candour.  So strong was the impression caused by this happening that at least one Councillor made a contemporaneous note of the happening. Other persons present testified to the facts of the incident shortly afterwards.

It should be noted that there are outstanding FOIA applications seeking to uncover the dates, times, details and written records of meetings between SMDC and representatives and commercial ‘Key Stakeholders’ spoken to or consulted with during the preparation of the Core Strategy Document or the CV Masterplan.  It is noted in passing that the typed notes of the meeting of the 15/3/11 at the Nicholson Institute do not record the details or content of the question and answer session about AONB status.  Before analysing further the commitment or otherwise of SMDC planners to supporting an application for AONB status it would be instructive to review the history of the documentation on this topic to avoid coming to a premature or erroneous conclusion.


  • Para 6.12.6 of the report of the L.D.F. Working Party  dated 9/2/2009 states ‘There is a suggestion that the Churnet Valley be designated as an AONB however this would clearly have significant implications for its future management and development.  It is considered that it would be inappropriate at this stage for Council to give any commitment to such a move.[ our emphasis]


  • In a report to the Service Delivery Overview and Scrutiny Panel dated 9th.November 2011, SMDC Regeneration Services under the Regeneration Manager Mr Perry Wardle commenting upon the option to seek AONB status for the Churnet Valley opined, inter alia, that,
  1. The methodology used for assessing areas being considered for designation is complex.
  2. There are lengthy procedural requirements necessary to achieve AONB status.
  3. Resources are needed to manage AONB status and could be significant.
  4. Designation as an AONB would place an additional duty on the Local Authority to have regard to the purpose of conserving and enhancing the natural beauty of the AONB when exercising or performing any function.
  5. AONB designation does not prevent development but gives the local authority greater scope to resist inappropriate development.
  6. Other options are available.
  • If the above are considered together with the remarks made by Mr Gavin Clarke at the Nicholson Institute on 15th March 2011 and the evidence revealed by the letter of 22/1/2010 sent by HOW Planning LLP to the Head of Regeneration Services on behalf of Laver Leisure [Oakamoor] Ltd, evidence begins to emerge that the opposition demonstrated by the above documents may be motivated more by a level of commitment to those agencies and ‘Key Stakeholders’ whom, through their agents, began shaping the Core Strategy and the Churnet Valley Masterplan Options Report long before there was any public knowledge that the process was already underway.

If such is a reasonable interpretation of events, it sets in context the requests made by HOW Planning on behalf of its clients Laver Leisure [Oakamoor] Ltd. as long ago as 22/1/2010.  It may be helpful in this factual analysis to remind ourselves of some of the salient points made in it, namely,

  • We are very keen for the Core Strategy to provide sufficient flexibility to enable the Moneystone Quarry site to come forward for future development without having to overcome significant policy boundaries which may be set in the Core Strategy [our additional emphasis].
  • By 22/1/2010 there had taken place ‘A number of meetings with the Local Planning Authority at varying levels’.
  • It is therefore requested that the Core Strategy vision and objectives reflect the important* contribution to the wider area that can be gained from developing the Moneystone Quarry. Furthermore the emerging policies should incorporate sufficient flexibility to allow the site to come forward for development.[our additional emphasis]

*Note ‘important’ to their client but not residents of Whiston or Moneystone who did not and could not have known about it.

A serious question is raised by the above factual recital.


It would be a perfectly legitimate conclusion to reach on the basis of the above that SMDC planners…

  • Have indeed shaped the Core Strategy document and the CV Masterplan Options Report to give effect to the request made by HOW Planning LLP on behalf of their clients Laver Leisure [Oakamoor] Ltd., to provide sufficient flexibility to enable Moneystone Quarry site to come forward for future development without having to overcome significant policy boundaries’ [ e.g.  AONB status ]
  • It would set in context and give added emphasis to the remarks made by Mr Clarke at the Nicholson Institute on 15/3/2011.
  • It would explain to some extent why commercial ‘Key Stakeholders’ were identified early and given preferential treatment over the residents of the Churnet valley in the process of consultation.
  • It may explain why SMDC did not, at an early stage consult with WAG as a residents group.
  • It may explain the apparent opposition to AONB status displayed in the documents referred to above



NB – If any of the above conclusions are incorrect it is always open to the SMDC to comply with the FOIA applications that have been made in requests to disclose the notes and details of those ‘numbers of meetings with the Local Planning Authority at varying levels that [by 22/1/2010] had already taken place’.

Antecedent Factual Issues.


1.  The Churnet Valley Masterplan Options Report was put before the SMDC Cabinet by Councillor Hart.

2  Upon specific invitation by the Chair Councillor Ralphs, residents in the public gallery, who otherwise had no right to contribute to the debate, were invited to comment. They did so. They pointed out, inter alia, that there was a direct contradiction between the contents of the Options Report and remarks made by Councillor Hart as to the purpose and usage of ‘Village Conversations’ to inform the shaping of the Options in the Report and the statements of Mr Gavin Clarke of the SMDC Planning Department at Village Conversations that they ‘had nothing to do with the Core Strategy or the Churnet Valley Masterplan’.

3  Cabinet also acknowledged that the SMDC had received a request under the Freedom of Information Act in relation to the ‘evidence’ base that purportedly supported the findings of the Options Report that remain [then and now] unanswered.

4  Despite the concerns expressed by Residents at the meeting of Cabinet on 15th November 2011 about the process, contents, ‘evidence’ and conclusions of the Masterplan, Cabinet determined to approve the document for public consultation. It is submitted that the decision was defective and unreasonable.

5  Cabinet gave assurances that the outstanding requests for disclosure would be met. At the time of the preparation of this document those assurances have not been met.

6   The Churnet Valley Masterplan Options Report was released to the public on 16th January 2012. On the same date some 800 pages of what is purported to be ‘evidence’ was posted on the SMDC website. The first public consultation was at Ipstones the next day, 17th January 2012, and other consultations are ongoing. Residents without access to a computer are disadvantaged by such a process.

7   The Options Report puts five options to the public for consideration. It does not justify why only five are chosen, although it concedes that a further option could be a combination of the five selected.

Quiet Lanes in the Churnet Valley


  •  The Churnet Valley has an inadequate road infrastructure caused partly by challenging topography but also by lack of investment over many years.
  • Narrow country lanes in the Churnet Valley struggle to cope with recent increases in traffic volumes, particularly the traffic attracted to Alton Towers.
  • The introduction of Sat-nav has already exacerbated the tendency for Alton Towers visitors to use some lanes as short cuts, increasing the risk of accidents.
  • Plans to develop Moneystone Quarry as a tourist site can only make the situation worse.

WAG’s Quiet Lanes Initiative

  • Staffordshire County Council, the Highways Authority, can designate certain narrow country lanes as “Quiet Lanes”, a policy that has already been adopted in neighbouring Cheshire and Derbyshire.
  • “Quiet Lanes” are intended to encourage low numbers of vehicles travelling at slow speeds to better mix with walkers, cyclists and horse riders so that all road users are safe.
  • The Churnet Valley is considered to be an ideal area in which to designate a network of quiet lanes.
  • An approach has already been made to Staffordshire County Council, the Highway Authority, with a request that the possibilities be explored.
  • WAG is also conducting a survey of road users to measure the level of public support .

More Information?

For more information on quiet lanes please follow the following links:

Department for Transport

East Cheshire Council’s Quiet Lanes Scheme

Natural England .


Councillor Lobbying

Harry Blood, WAG Chaiman, delivering the WAG Alternative Masterplan to the District Council.
  • A printed copy of the WAG Alternative Masterplan document was delivered to all 56 Staffordshire Moorlands district councillors to assist in their understanding of the issues relating to the development proposals.
  • Copies of the document were circulated by e-mail to parish council clerks in the Staffordshire Moorlands for the information of all parish councillors.
  • Support is ongoing to District Councillor Linda Malyon in her bid for Area of Outstanding National Beauty (AONB) status for the Churnet Valley.
  • Support has also been sought from Staffordshire County Councillors Atkins and Worthington in connection with a “Quiet Lanes” initiative put forward by WAG with the aim of preventing an increase in traffic problems on the valley’s narrow lanes.  More detail on the initiative is provided on the Quiet Lanes page.
  • WAG intends to further reach out to councillors through either a road show or centralised meeting to deliver a presentation and provide an opportunity for discussion on issues raised by the WAG Alternative Masterplan.