A large number of residents turned out last Saturday, and braved the treacherous roads to make a strong statement to the decision makers of the Staffordshire Moorlands.
It is clear from the structure of the application and from earlier evidence provided by Officers of the Applicants that it is intended that this application is not a free- standing application but a part of a future wider scheme that the Applicants intend to make to develop Moneystone Quarry as a tourist leisure park. The representations made below and any decisions or recommendations reached by Planning Officers and/or the Planning Committee of Staffordshire Moorlands District Council should be viewed against that wider context.
In so far as the extant application does not set out the detail of that larger application it is submitted that it will be impossible for application SMD/2014/0682 to demonstrate compliance with the detailed provisions of the Authorities Core Strategy Policies and the contents and principles embodied in the Churnet Valley Master Plan [CVMP]. Neither does it demonstrate compliance with the principles of The Aarhus Convention Treaty so far as it relates to the Environment and/or Health, nor to the NPPF and the principles of the Localism Act 2011.
In the representations made below it should be noted that where appropriate they quote the CVMP and as applicable identify the relevant paragraphing. Emphasis has been added as appropriate.
1. The failures referred to below affects the human rights of those entitled to make representations and protect their rights under the Human Rights Act to a family life. The actions of the SMDC planning officers in entering into a prolonged and secret series of meetings with the applicants from approximately 2009 up to the present day and a refusal to disclose the details of those meetings amount to a denial of essential information that undermines the human rights of residents who would wish to make informed decisions about the present application and the linked application SMD/2014/0432.
It is noted that [quote] ‘A number of meetings with the Local Planning Authority [LPA] at varying levels have already taken place and these representations follow these discussions.’ [ HOW letter 22/01/2010 to Head of Regeneration Services SMDC]. The same letter states ‘We are aware that the Core Strategy for the Staffordshire Moorlands is now in an advanced stage and that a consultation exercise was undertaken on the Submission Version of the Core Strategy in May/June 2009. Whilst the Core Strategy is at an advanced stage, we are very keen for the Core Strategy to provide sufficient flexibility to enable the Moneystone Quarry site to come forward for future redevelopment without having to overcome significant policy boundaries which may be set by the Core Strategy.’ At page 2 of the letter it says ‘ The overall intention of the representations is…to promote Moneystone Quarry as a potential tourism and recreational hub…..‘ It is plain that Planning Officers ‘at varying levels’ have written the SMDC Core Strategy [and it is submitted the subsequent CVMP] in a manner that is both secret and intended to advocate the application[s] now made. As such these actions fall outside of the principle role of planning officers, acting as public servants [see SMDC Constitution] to act in the best interests of the public they serve and not to advocate for the private commercial interests of an applicant in ways that the evidence demonstrates. It is submitted that such actions demonstrate a clear intention to harm the human rights of residents.
2. The application is in breach of the provisions of the SMDC Core Strategy and the Churnet Valley Master Plan as set out more particularly herein.
3. The Application is governed, inter alia, by the provisions of the Aarhus Convention Treaty and its direct applicability in English Law under European Law, specifically in relation to any issues of the environment and/or health and is not so compliant.
4. The development site is part of the ‘rich and varied cultural heritage, the development of which has been greatly influenced by the diverse landscape and geology of the area’ and is part of ‘this unique rural historic character that has been mapped as part of the Staffordshire Historic Landscape Characterisation project 2006’ [see para 2.0.7 CVMP 2014]. As such it should be protected by the principles enshrined in the Core Strategy and the CVMP and not developed in the way proposed by this application. The site is also a ‘Special Landscape Area’ and when restored in accordance with the extant restoration plan will be a green field site. In 1996 the then quarry owners working with SCC Mineral Authority on a restoration scheme in a document entitled ‘The restoration vision’ promised residents that ‘ Our aim was to come up with an exciting plan which allowed progressive restoration of older working areas to blend them with the surrounding landscape and to create a variety of new habitats for plants and wildlife‘. We are looking at the possibility of a bat cave once the tunnel on site has become redundant’. The vision continued to stress that the site should not be ‘left with an alien landscape which would not be in keeping with the surrounding Staffordshire countryside.’ It is submitted that the current proposed development plans would produce just such an alien landscape. Residents are entitled to expect that they will get what they have been promised for very many years.
5. To grant the present application would be, or would inevitably result in, a breach of the Development and Management Principles set out in the provisions of paragraphs 8.1, 8.2, 8.3 and 8.4 of the CVMP more specifically set out herein.
Under a heading of ‘A Vision for the Churnet Valley’ at paragraph 4.1, SMDC acknowledges the Churnet Valley [of which Moneystone is an integral part] [is] ‘high quality landscape which is treasured by both the communities who live and work in the area and visitors to it. It will sustain its unique qualities of a diverse and varied environment which is rich in wildlife, heritage, landscape and tourist attractions’ and ‘will be [and already is] widely recognised, locally, regionally and nationally for its high quality landscape and its heritage and wildlife interest’. On the basis that what is not broken should not be fixed it is submitted that to grant the current application would be in breach of the Authorities own policies and it’s commitment to protect the Churnet Valley.
8.Para.2.1.1 CVMP [The] Weakness of promoting this development;
- ‘lack of physical linkages’
- ‘reliance on the private motor car due to the rural nature of the area, limited capacity of the highway network which is of poor standard ………. congestion at peak times [especially at nearby Alton Towers] due to visitor traffic.’
- ‘The rural nature of the area limits the opportunities for physical transport improvements and reduces the viability of new services.’
- ‘Limited access by public transport’
- ‘Topography and physical barriers can be [and are] restrictive to movement.’
- Lack of maintenance of heritage assets.’
- ‘Narrowness of [the] lanes.’
- The application site is ‘not an existing coherent visitor destination.’
- ‘Future development at Moneystone Quarry would cause loss of small scale landscape features further affecting the character of the local landscape.‘
- There are ‘biodiversity sites in close proximity which could potentially be vulnerable to future change.’ This is particularly the case as evidence shows that the Applicants have proved poor ‘stewards’ of the site allowing the deterioration of the Whiston Eaves SSSI, neglected the hydrology of the site, failed to provide bat, bird and badger surveys, failed to meet the criteria required by Natural England with regard to the Great Crested Newts and the European sand lizards present on the site.
- Planned and already extant expansion at Alton Towers Resort ‘may have an adverse impact’ on the road net work to and from the site and it is the stated ambition of the Applicants to link in to the Alton Towers Resort market.
- ‘Environmental sensitivity such as the Whiston Eaves SSSI.’ It is noted here that the requirement to maintain the ground water levels at the SSSI [which is a condition attaching to the land restoration applicable to extant planning permissions] is not currently being honoured. [For fuller details see letter dated 3/10/14 from Matthew Griffin SCC Planning, Policy and Enforcement of the many failings and non-compliance.]
- ‘Potential increased pressure on natural resources from [the] development.’
- ‘Sensitivity of [the] heritage asset of the Proposed development.’
Identified Challenges Paragraph 5.1.6 CVMP
- The CVMP notes in the evidence base to its CS and the CVMP that ‘there is little evidence of sustainable tourism being adopted [by the tourism industry].’ That being so the current application is unlikely to be ‘sustainable’ and as that is a requirement of the Localism Act 2011 and the N.P.P.F. there is no proper evidential basis upon which to grant this particular application. It should also be noted that the quoted comments are formally part and parcel of the SMDC’ CS and CVMP and must therefore be complied with.
- The same documentation notes that ‘Selling sustainability to business [such as the Applicant] and consumers purely on environmental grounds has not worked.’
- N.B. It should also be noted that the Aarhus Convention Treaty is binding in English Law on environmental and health issues and that the current application is non-compliant with its provisions.
- ‘An alternative to car based tourism is a challenge.’ It should be noted that the Chief Executive of SMDC signed off on an official report that stated the Staffordshire Moorlands exceeded the national average of CO2 emissions. The current application is bound to add to an increase of such emissions being dependent as it is [and shown on the face of the application and further acknowledged by the Applicants limiting the current outline application to issues of access] on an increased use of the private motor car.
Paragraph 5.1.14 ETC. CVMP
- The CVMP is committed to the ‘Overarching principle of sustaining and enhancing the natural, built and historic environmental quality of the area, its settlements and hinterland.’ If that is truly the case it will reject this application as being non-compliant with that ‘overarching principle’.
- How does the application demonstrate that it ‘ensures that [the] communities of [Moneystone, Whiston and Oakamoor] are at the heart of the future of the CV,’ when those communities have expressed in the clearest possible terms that they reject the applicant’s proposals. It demonstrates that the applicants have no intention of putting the views of those communities before their own narrow, selfish commercial interests.
- How would granting the application demonstrate ‘respect, enhance and protect [this] positive aspect of the CV?’ It does not do so.
- The Special Landscape Area that is the application site once restored in accordance with the statutory restoration scheme is a ‘sustaining and enhancing existing assets of the CV and its ‘qualities help make the area unique.’ On the other hand the application seeks to destroy those assets and is therefore contrary to the policies of the CVMP and the CS.
- The application does not ‘ensure the nature and scale of development it proposes is appropriate to its locality.’ It is not and the policy goes on to state that ‘this means limited OR NO development is appropriate for this part of the CV.’
- Granting this application would destroy and not ‘support existing local enterprises’. On the other hand, if granted this application would ‘cause harm to the essential qualities of landscape, ecology [and] heritage.’
- The CVMP contains the provision that its policy will ‘only permit ‘minimal change……..to protect sensitive areas.’ This application amounts to the planned destruction of a Special Landscape Area and its established sensitive areas. To grant the application would amount to a breach of ‘the KEY REQUIREMENT OF THE [CVMP] POLICY’ and as such it should be rejected.
- The application does not demonstrate ‘a strong emphasis on supporting [the existing] heritage.’ It should be rejected.
- The application shows that it has a ‘significant shortfall in terms of the environmental impact and in particular the impact on the need to travel and [the] potential to increase the use of the private car.’ As a result it does not meet the test of ‘sustainable appraisal of options’ that are part of the underpinning evidential base of the CS and the CVMP.
- To grant this application would not demonstrate that SMDC was acting in accordance with its own expressed policy ‘to resist development which would be [and will be demonstrated to be] harm[ful] to the character of the local landscape.’ Residents are entitled to expect that SMDC will uphold this policy.
Paragraph 6.8.4 TRANSPORT
- ‘There is to be identification of key transport nodes from which to travel by more sustainable modes, with improvements where necessary to car parking.’ [N.B. This is a future requirement and it is noted that the area of Moneystone, Oakamoor, Whiston Frogall and Kingsley is to be the subject of a detailed and separate traffic survey that yet to be commenced but has already been agreed. Until it has been done and the findings are applied to the Transport Policy it would amount to a breach of residents human rights. They have been given an express commitment in the CVMP that this process will be undertaken.
- The CVMP provides that ‘it aims to conserve, enhance and celebrate the heritage of an area of high landscape value’. To grant the current application would be a breach of that policy.
- ‘The sensitivity of the landscape, biodiversity, heritage and access issues are major factors and the key focus should be on conserving and enhancing the landscape and biodiversity of the area’. The current application does not meet the provisions of this policy and should be rejected.
Paragraph 6.5. CONSTRAINTS
- The CVMP policy is to ‘ensure development does not generate unacceptable volumes of traffic on the existing road net work and that major highway works are avoided.’ This application would breach that policy.
- The development ‘is unacceptable to the vast majority of locals.’ [It is noted that over a period substantially in excess of one year the applicants have failed to engage with Staffordshire County Council Highways Department about concerns that the Highway Department have expressed about the applicants plans for the site so far as it relates to traffic congestion issues. This unwillingness has contributed to the view of locals that the application is ‘unacceptable’]
- The application does not ‘Promote the use of sustainable modes of transport to reach the site’.
- The development is not ‘in-keeping with the scale and nature of the [existing] landscape character.’ Nor does it ‘ensure that any future development is located in a way that does not impinge on the small scale landscape or the open visible landscape.’
- The application is not as required by the CVMP ‘low key’ and ‘of a nature, character and style that is intrinsic to the character of the area.’ The area is of open farm and meadow land and it is noted that extant planning conditions attaching to adjacent land owned by the applicants require it to be restored to meadow land. The applicants are already substantially in breach of that requirement.
- The application does not contain ‘active conservation of the site to protect the SSSI’ and the applicants duty to meet the water table at the SSSI is not being met.
- The application fails to meet the requirement that ‘the protection and enhancement of the natural beauty of the CV IS THE OVER RIDING REQUIREMENT OF ANY DEVELOPMENT’
- Further the application proposal and associated infrastructure measures are/will be ‘detrimental to the sensitive ecology and geology of the area.’ [ SCC Environmental Officer has already raised concerns about adjacent sensitive areas]
- Cotton College is a ‘designated heritage asset’ and in accordance with SMDC policy it ‘shall be protected and maintained in a good state of repair.’ The current application is very likely to cause harm to parts of this heritage asset. It should be rejected.
- The application fails to meet [any] ‘appropriate degree of evaluation and/or mitigation commensurate to the level of impact and significance of the heritage asset.’ The above referred to letter from SCC date 3/10/14 lists some but not all of the ways in which this application will damage the Special Landscape Area which is a heritage asset.
- The application is antipathetic to the CVMP aim to ‘develop healthy sustainable communities.’
- As the applicants have failed over a prolonged period to engage with SCC Highways officials over their plans the application does not meet the policy requirements that ‘aim to support and increase sustainable travel means.’ Instead the application seeks to exacerbate already difficult traffic conditions. If granted the application would give rise to ‘excessive traffic that will harm the valued characteristics of [this part of] the CV.’ Neither does the application ‘seek to minimise the impact of traffic [in this] environmentally sensitive location.’
- The application fails to fit within the aims and aspirations of the Staffordshire Tourism Study  [STS 2011] that ‘seeks to take a co-ordinated planning and sustainable development approach.’ The STS 2011 is an evidential base for the SMDC Core Strategy and the CVMP and as such forms an integral part of those policy documents. The application has to be viewed in the context of SMDC’ binding obligation given to an Independent Inspector to revisit the CS again by 2016. and against its already adopted policy of seeking AONB status, a process in which it is already actively engaged. The STS 2011 recognises that ‘AONB status would be an ideal way to view matters.’ To ignore that approach and to grant this application in contravention of the principle STS 2011 sets out would, it is submitted, be a breach of human rights and ultra vires of SMDC’ powers.
- At a recent exhibition at Whiston Village Hall related to what was then the forthcoming application now SMD/2014/0682 to build a leisure complex at Moneystone Quarry, Mr. Peter Swallow, Director of the Applicant company, revealed that it is the intention of the Applicants to sell off a significant percentage [40% was mentioned] of the ‘lodges’ to private buyers. This amounts to the development of private dwellings in the Special Landscape Area and is contrary to the SMDC Core Strategy, the Churnet Valley Master Plan and the Strategic Housing Land Allocation [SHLAA] process.
A request for support from members of the public concerned about tourism related traffic congestion in the Staffordshire Moorlands.
Some of our councillors don’t appear to accept that existing levels of tourism generate considerable traffic issues at busy times in the Churnet Valley across a variety of routes and hot spot locations, including, Tittersworth, Rudyard, The Roches, Oakamoor and Alton. For some time now Whiston Action Group has been gathering video and photographic evidence of existing traffic congestion throughout the Churnet Valley, showing that encouragement of further traffic pressure on our fragile road infrastructure is inappropriate.
WAG intends to expand and develop the evidence base of what increased tourism is already doing to our roads in the Moorlands, and seeks the support of members of the public. In this day and age of mobile camera technology it is easy to take a photo of any clogged roads you see whilst you are out and about.
WAG asks that you miss no opportunity to take those photos AND IF YOU HAVE THE TECHNOLOGY TO DO SO SEND THE PICTURES DIRECTLY TO COUNCILLOR SYBIL RALPHS AND ANY OTHER COUNCILLORS YOU WANT.
Please keep a note of the date, time and venue of the photos and let WAG know so that the data can be collated. There will be no need to forward the pictures to WAG as long as you preserve your own copy in case it is needed later.
This is an ongoing project and applies throughout the Churnet Valley for the next twelve months. Your contribution can help WAG fight inappropriate council proposals that are likely to exacerbate an already unacceptable situation.
The commissioning of a transport company to write an independent report for SMDC has provoked reaction from Whiston Action Group because of the company’s close association with a major developer in the area.
Earlier in the year the Council presented a range of development options for the Valley. The public expressed an overwhelming preference for minimal development, a view at odds with the aspirations of developers.
Before writing the Churnet Valley Masterplan, the Council needed an independent report on the difficult topography and inadequate road infrastructure in the Churnet Valley, issues that are an obstacle to development. The Council selected the “Atkins” company, who wrote a Transport Study that now supports the Council’s plans.
As the Transport Study was such a key document, and needed to be truly independently written, it is very surprising to find out that SMDC chose the “Atkins” company, as Atkins have had a long association with the main developer in the Churnet Valley, namely Alton Towers. Alton Towers have contracted Atkins for many years to do traffic reports in support of their planning applications for new rides and accommodation extensions, a relationship well known to the Council Planning Department.
The general public may justifiably have concerns that a company so closely associated with a main developer has been selected by the Council to do a supposedly independent study.
Nick Cresswell, WAG’s Communications Officer, said:-
“WAG has examined the completed Atkins Transport Study and is concerned at the considerable bias shown in favour of the developers. The study content fails to adequately address key issues relating to Alton Towers that one would expect to be at the forefront of a truly independent study i.e. traffic issues, particularly injury collisions, on the approach routes to Alton Towers. Instead the study focusses on a catalogue of relatively obscure and inconsequential issues, such as suggested traffic delays at Bottom House crossroads of all places, that are not recognised by the public as genuine problems at all. The report has little credibility as an independent study and I would like to know who on earth selected a company so closely tied to Alton Towers. The only way forward is for the report to be re-commissioned, through a truly independent company.”
A planning application by Alton Towers Resort for 150 lodges to further expand the site has met with a comprehensive objection from Whiston Action Group. The following letter challenging the need for such additional expansion has been fowarded to Mr Mike Green, Planning Applications Manager, at Staffordshire Moorlands District Council.
Dear Mr Green,
Alton Towers Resort
Application for planning permission for the phased development of 150 lodges together with associated reception/restaurant and servicing buildings – ref 12/00998/FUL_MJ
This letter explains the strong objection of the Whiston Action Group to the above proposal.
The concept by Alton Towers for phased development of some 150 lodges and associated facilities has been prepared without any community consultation. Regrettably as a result it is lacking information that we believe is very relevant.
The application includes a letter dated 12 October 2012 from the applicant’s planning advisers Nathaniel Lichfield and Partners together with a Design and Access Statement of architects, Allison Pike Partnership Ltd of October 2012. There is reference to demand for additional accommodation and that the site has proximity to the JCB testing ground.
We note with concern pre-application discussions with Mr M Green and others in April 2012, i.e some six months before the application was submitted. There has been ample opportunity for community consultation especially at a time when the Core Strategy options for the Moorlands have been debated, together with consultation on a supplementary Churnet Valley Masterplan.
It is surprising that the information provided by the applicant’s experts is short of facts to guide an impartial appraisal of the proposal and yet must have been approved by the applicant.
The concern of the applicant about shortage of accommodation is surely answered by approval that the Council gave to an extension of the Splash Landings Hotel on 7 December 2006 ref 06/01004/FUL_MJ to provide 36 suites to sleep 6-8 people for a variety of user groups including family holidays. The applicant has received agreement to an extension of the time limit for implementation of the planning permission because development cannot be justified at this time of national recession. (ref 11/00402/REM1MJ)
Despite the best endeavours of local and central government to achieve a high level of community participation in the future planning of our cherished environment in the Staffordshire Moorlands we are surprised and disappointed that Alton Towers continues to show no interest in consulting with the community prior to submitting a planning application.
Planning consent to similar chalet development and this proposal
The applicant makes no reference at all to approval in 1988 of a very similar chalet development to that proposed but not implemented. This consent followed a Special Meeting of the Planning Committee on 27 November 1986 when the matter progressed to a Public Inquiry in March 1988 with approval on 10 April 1988 by the Secretary of State following the Inspector’s recommendation for approval. The planning reference was SM373-86.
Full details of this application, representations made and the decision process with key factors are within the District Council’s records. The whole of this record is extremely relevant to this planning application and justifies detailed analysis to inform all who are considering this application. It includes debate on the alternative Eastern access (See 1981 S52 Agreement) and an irrevocable letter of commitment by Alton Towers to implement this.
In the absence of any recent approved planning guidance the best available is the 1988 Supplementary Planning Guidance. A helpful reminder of why this was produced can be found on page 85 of the 1998 Local Plan. I quote as follows:-
“Para 8.39. The need for Planning Guidance was summed up in a report to the Planning Committee decided on 2 October 1986.
There is a need for a cohesive strategy, expressed in a statement or plan, against which the Local Planning Authority may judge and be seen to judge future applications submitted by the Company. Clearly the nature of a leisure park is such that it must be allowed to evolve and any strategy must make reasonable provision for allowing the management to respond to changing trends and fashions in entertainment. Likewise the public are entitled to know how the Local Planning Authority perceive future developments being controlled, and how the advantages to the economy of the area and the wellbeing of the customers, able to relax in a well run leisure environment providing value for money, are to be weighed against the position of the complex in an environmentally sensitive rural conservation area.
Para 8.40 In March 1988 the District Planning Authority adopted for Development Control Supplementary Planning Guidance against which planning proposals could be judged.”
We consider the application to be contrary to the 1988 Supplementary Guidance as referred to in the 1998 Local Plan and in particular Policy R22 (D) that Development Proposals at Alton Towers should protect the historic landscapes of the Estate and its trees and woodlands.
We also find it an interesting coincidence that the timing of the earlier chalet application in 1986 coincides with concerns of the Planning Committee for an overall strategy and that the Public Inquiry in March 1998 was the same month that the SPG was adopted where para 6.6 notes that the Eastern part of the Estate is as yet relatively undisturbed and adjoins the JCB experimental area.
The subsequent Supplementary Planning Guidance of 1988 remains valid to this day. Since then the Planning Applications Committee has needed to arrive at its decisions for Alton Towers based on Planning Guidance that is now some 24 years old.
Alton Towers has had every opportunity to revise the 1988 SPG for formal adoption as District Council policy after community consultation. Any further development at Alton Towers should only proceed if within the context of a long term plan (to replace the 1988 SPG) within the umbrella of a Churnet Valley Masterplan (with Alton Towers SPD) and that this can only follow Government approval of a Core Strategy next year that will replace the 1998 Local Plan.
We are now at the stage where the Planning Applications Committee is entitled to refuse any further applications for significant development at Alton Towers until the process of producing new policy documents is complete. A refusal decision on these grounds would surely be supported by a Planning Inspector should Alton Towers decide to take the District Council’s decision to Appeal.
Despite receipt of planning consent from the Secretary of State in 1988 the Chalet Development was not implemented by Alton Towers – a decision that may have been connected to a change of ownership and business strategy.
There was some concern that the siting at the extreme East of the park (and South of the chalet site as now proposed) would conflict with the entry point of the proposed eastern access but in addition the preference by Alton Towers was for accommodation to be provided by a hotel and not a chalet development.
Approval to the first hotel was given to the Tussauds Group on 16 November 1993 under reference SM93–0844. It was coupled with a S102 Agreement dated 25 January 1994 that in summary confirmed that Alton Towers would not implement:-
- The permission for the Chalet Village – (ref SM373-86)
- An established use certificate for the Old Mill dated 31 January 1984
- Any existing planning consents for static or touring caravans.
And not claim any compensation for withdrawal of the above.
There has been subsequent permission for a separate hotel known as Splash Landings (ref 01/00999/FUL) for which consent was not linked to cancellation of the consent for the chalet development as this had been satisfied by SM93-0844.
We find that approval to Splash Landings was subject to a Section 106 Agreement relating to improvements to the existing road network that we have yet to examine. There were then additions to the hotel ref 02/00588/FUL and a two storey extension ref 02/01001/FUL . Planning permission for an extension to this hotel 06/01004/FUL_MJ has not been implemented.
We therefore conclude that the demands for accommodation at Alton Towers have been well satisfied by approvals granted by the District Council which we feel have given more than acceptable preference to the business needs of Alton Towers. These decisions have not preserved and enhanced the protected landscape for the entire Alton Towers Estate within the 1971 Alton and Farley Conservation Area as designated some eight years before the Theme Park was established.
JCB Vehicle Testing Ground
We have serious concern that the proposed site is immediately to the west of the long established JCB vehicle testing ground. Proximity of the earlier chalet development, as approved, was also a factor considered in 1986 when concern was that vehicle types being tested could be seen.
The situation today is that the use of the JCB testing ground is constant and reflects the growing success of the business as a major UK manufacturer with a highly skilled workforce that has worldwide recognition. The planning consent from 1987 is CU 02718/03.
We consider that a chalet development so near to the testing ground will bring noise complaints from Alton Towers customers staying at the chalets from 24hr vehicle testing. The District Council is well aware of noise complaints from neighbours concerning activities at Alton Towers.
For the first time recent Planning Consents for new rides include noise limits at specific locations outside the curtilage of Alton Towers and may apply to other residential locations where intrusive noise is reported. These apply to daytime hours 07.00 to 23.00 with a higher level of sensitive measurement for night time hours 23.00 to 07.00 to ensure “that the reasonable amenities of neighbouring properties are adequately protected from noise pollution” .
(Please see Applications Ref 11/01203/FUL – Cond 8 and 08/02030/FUL – Cond 10)
If noise restrictions and specific operating hours to safeguard the amenity of chalet users were applied to the operation of the JCB testing ground we consider that it would impose an unacceptable business restriction on the JCB testing ground. No doubt the District Council will ensure consultation with JCB and with the controlling planning authority for this area – East Staffs Borough Council.
WAG considers there should be no approval for any development to the east of the Hotels that might pose any threat whatsoever to the ongoing use by JCB of its long established testing facility. This means that the proposed site and a similar sized area to the South that was designated in the previous chalet consent should be designated as a buffer zone in the Alton Towers SPD to ensure protection of the JCB business activity. Continuation of this area as undeveloped open space would also be consistent with protection of the historic landscape under Policy R22(D) within the Conservation Area and preserve options for the Eastern Access as supported by Policy R24.
Draft Core Strategy and Churnet Valley Masterplan
The report to the Planning Applications Committee for the replacement ride currently under construction ( Ref 11/01203/FUL_MJ ) notes in para 19 the Alton Towers Long Term Plan and of the expectation that this will feed into a Supplementary Planning Document as part of the Local Development Framework.
It seems that no progress with the CVMP and Alton Towers SPD will be possible until the Core Strategy has been approved by the Secretary of State – possibly later next year. Until the Alton Towers SPD has been approved the 1988 Supplementary Planning Guidance will continue to apply.
Whiston Action Group has significant interest in this application for chalet development having submitted detailed comments at the consultation stage of the draft Core Strategy that we understand will be considered at a Public Inquiry scheduled to start on Tuesday 5 February 2013.
It is only when decisions are known for the Core Strategy that progress can be made towards finalising the Churnet Valley Masterplan (CVMP)and for this the Whiston Action Group has made detailed representations to your authority. Comments on Alton Towers are included.
We understand that decisions on the Core Strategy are unlikely until later next year and so clearly some positive progress on the CVMP and Alton Towers SPD, with full public consultation, has to wait until we know the Inspector’s decision on the overall planning strategy for adoption by Staffordshire Moorlands District Council.
It is already clear from decisions of the District Council and Government Guidance that public participation in planning for the future of Staffordshire Moorlands is vital. At this stage in the review of planning strategy we note that the overall public response to the Core Strategy and CVMP is for no – or minimal – change.
No draft Alton Towers Long Term plan or draft SPD have been issued for community consultation. We understand that the District Council is relying upon Alton Towers and their advisers to produce these drafts. There has already been significant delay.
Considerations given to the previous chalet application in 1986 are equally valid today and need no repetition save that the transport and highway considerations are far worse than reported then. The affect of light pollution for the first time at this Eastern End of the parkland is not considered.
You will appreciate the strength of feeling by action group members against this proposed development. We hope that on consideration of our reasons for objection the management of Alton Towers Resort will be persuaded to withdraw the application (for which there are precedents in the face of opposition to other proposals by Alton Towers).
The immediate need is for a planning strategy for Alton Towers to replace the 1988 SPD that has been fully considered and approved by the community and , as applied in 1986, “the Local Planning Authority may judge and be seen to judge future applications submitted by the Company”.
In terms of planning records administration we wish to draw the District Council’s attention to the need for a comprehensive record of planning decisions and obligations associated with Alton Towers and ability for anyone to view and analyse the information with ease. The absence of this facility may well explain the inadequacy of the applicant’s submission.
The obvious conflict of the proposed chalet development with the need to preserve and enhance the 1971 Alton and Farley Conservation Area is very apparent. It is also at odds with the 1988 SPG and other policies and poses a threat to operational flexibility of the JCB test facility.
The ideal solution is for the applicant to withdraw this application but if not then we consider that the District Council has many reasons to refuse consent and will do so. If the applicant decides to Appeal the Council’s decision to refuse then the timing of an Appeal would coincide very well with the Government Inspector’s review of the Core Strategy during next year.
Would you please acknowledge receipt of this objection and keep me informed on progress. We understand that the deadline for any further comments is Monday 3 December 2012.
WAG’s open public meeting at Whiston Village Hall on Friday evening (02 Nov 2012) attracted over forty members of the public, not only local residents but people from villages throughout the Churnet Valley and other parts of the Staffordshire Moorlands, demonstrating wide ranging interest in concerns raised by WAG. An opening statement emphasised that WAG’s rigorous evidence based approach is intent on passing on conclusions based on facts – not opinions or gossip. Presentations were given by several speakers on a variety of issues, the most contentious being the Core Strategy Submission; Village House Building Proposals; Laver’s failure to restore Moneystone Quarry in accordance with the legally binding restoration plan, and public health concerns regarding the contaminated site at the Old Bolton Copperworks.
The District Council’s Core Strategy document, consider by many to be neither legally compliant nor sound, is currently being considered by the independent Planning Inspectorate. The inspector, Mr Patrick Whitehead, is to hold a Pre-Hearing Meeting at 10am Tuesday 11 Dec 2012 at the Bethel Suite, Tape Street, Cheadle, where he will set out the procedure and arrangements for his formal examination to be held in February of next year at Leek Council Offices. Anyone who made representations about the Core Strategy is encouraged to attend.
The Strategic Housing Land Availability Assessment (SHLAA), submitted as a last minute addition to the Core Strategy, raised many eyebrows. The document, compiled by SMDC officers in liaison with only landowners and developers, identifies and prioritises specific plots of land with housing potential in and around many villages in the Staffordshire Moorlands. Both during and after the meeting numerous attendees expressed their dissatisfaction with the complete absence of consultation by the District Council on this important issue. The document has been submitted with the Core Strategy without public input.
On 11 Sep 2012 Laver Leisure circulated a letter to households in Whiston, Oakamoor and surrounding villages stating their intention of submitting within two weeks proposals to Staffordshire County Council to change the longstanding and legally binding requirement to restore Moneystone Quarry to farmland. No such application has been submitted and consequently, in the absence of any further communication from Laver to residents, a state of uncertainty exists within the community as to Laver’s future intentions.
The audience was surprised to learn that the Old Bolton’s Copper Works site is not recorded on the District Council’s contaminated land register, despite the council’s own specially commissioned Taylor Young Report identifying high levels of contaminants and a serious public health risk. In addition, a portfolio of evidence gathered from ex-employees pointing out precisely where contaminants are buried has been submitted to the council, who can have no excuse for failing to act. However, it is perhaps re-assuring that following representations from the Foxt Action Group the concerns have now been registered with the Environment Agency, with an investigation pending.
On a more positive note, there was considerable support for WAG’s Quiet Lane initiative, aimed at overcoming some of the tourist related traffic problems of increasing numbers of vehicles inappropriately using the Churnet Valley’s narrow country lanes. WAG has already received supportive comments from Karen Bradley MP, and now County Councillor Mike Worthington has been nominated by the Highway Authority to deal with the matter. WAG’s public survey of 100 road users demonstrated unanimous support from both residents and visitors. WAG’s proposal for a pilot scheme along The Red Road between Oakamoor and Alton, with suggested funding from Alton Towers monies committed as a condition under their last planning consent, is currently under consideration by Councillor Worthington. The pilot scheme would be a first step in achieving a network of Quiet Lanes in the core of the Churnet Valley, so that cyclists, horse riders and walkers could safely share our narrow lanes with slow moving vehicles driven with care and consideration.
Overall, a high level of enthusiastic support was received from attendees and after the meeting, Harry Blood, Chairman of Whiston Action Group, commented:-
“I was very pleased with the turnout, particularly the interest and support shown by newcomers, as we continue to challenge inappropriate decisions that will affect our communities in the Churnet Valley for years to come. The importance of keeping locals in the picture on future plans for the Churnet Valley is exactly what the Government is expecting local councils to do. Sadly that message is largely ignored by SMDC. WAG is clearly filling a local need which is why the meeting went so well.”
The WAG initiative encouraging Staffordshire County Council to give Quiet Lane designation to narrow lanes in the Churnet Valley has received welcome encouragement from Karen Bradley MP. The initiative is aimed at encouraging drivers of vehicles to give greater consideration to walkers, cyclists and horse riders, thereby reducing road safety concerns emanating from sat-nav users and Alton Towers traffic taking short cuts on inappropriate roads.
Earlier in the year WAG conducted a survey of road users in the Churnet Valley the results of which demonstate wide support amongst both residents and visitors, across a wide spectrum of road users.
Extracts from Karen Bradley’s letter include:-
“You and the rest of the residents who have been involved in this project should be highly commended for the work that has gone into producing this piece of work. The issue of “quiet lanes” in the Moorlands is something that I have raised previously in the House of Commons so it is pleasing to see you and other residents taking the initiative in this way.
I would be most interested to hear any further news about this project and will bear your comments in mind when I am talking to the relevant ministers.”
WAG is now progressing the initiative with County Councillor Mike Worthington, who has been nominated by Councillor Atkins, Leader of Staffordshire County Council.
In 2012, during public consideration of the Churnet Valley Master Plan proposals, Whiston Action Group (WAG) received anecdotal verbal evidence from residents in the lower half of the Churnet Valley expressing concerns regarding tourist visitor related traffic on the area’s narrow country lanes. The comments included concerns relating to inappropriate speed; inconsiderate driving, and traffic volumes that were considered in conflict with walkers, cyclists and horse riders.
The neighbouring counties of Cheshire and Derbyshire have already helped resolve similar problems in tourist areas by implementation of a “Quiet Lanes” national policy that is available for adoption by all county highway authorities. The provision aims to encourage vehicle drivers to harmonise more effectively with other road users. There is the potential for Staffordshire County Council to implement similar schemes on the lanes in the Churnet Valley aimed at encouraging low volumes of vehicles travelling at slow speeds, thereby benefitting walkers, cyclists and horse riders.
The concerns expressed by the public were only anecdotal. Consequently, in the spring/summer of 2012 WAG set out to gather more reliable evidence by conducting a public road user survey in the southern part of the Churnet Valley.
The survey report has now been completed and forwarded to Councillor Atkins, Leader of Staffordshire County Council, and County Councillor Mike Worthington, who represents the Churnet Valley, to inform their considerations. The survey coincides with a July 2012 announcement by Mike Penning the Government Road Safety Minister encouraging local highway authorities to cut speed limits on many rural roads. He was quoted as saying, “It is vital that speed limits are suitable for local conditions and councils are best placed to determine what these limits are, based on local knowledge and the views of the community”.
WAG’s survey results contribute towards establishing the local knowledge base and express the views of local road users.
Staffordshire Moorlands District Council’s planning proposals for increased tourism in the Churnet Valley will exacerbate the existing traffic pressures on an area of outstanding natural beauty. WAG’s hope is that Staffordshire County Council will recognise public concern regarding existing traffic problems in the Churnet Valley and follow the lead of neighbouring counties by introducing simple Quiet Lane cost effective measures as one step in protecting the peace and tranquillity of the Churnet Valley.
A copy of the road user survey report can be viewed via the following link.
- 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 .
For more information on quiet lanes please follow the following links:
Department for Transport
East Cheshire Council’s Quiet Lanes Scheme