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WAG Objection to Alton Towers application for 150 lodges

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 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:-

 

  1. The permission for the Chalet Village – (ref SM373-86)
  2. An established use certificate for the Old Mill dated 31 January 1984
  3. 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.

 

Conclusions

 

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.

Yours sincerely,

Harry Blood

Chairman

 

Quiet Lanes in the Churnet Valley – interest from Karen Bradley MP

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.

Quiet Lanes in the Churnet Valley

QUIET LANES

  •  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

https://assets.dft.gov.uk/publications/traffic-advisory-leaflets/quietlanes.pdf.

East Cheshire Council’s Quiet Lanes Scheme

https://www.cheshireeast.gov.uk/transport_and_travel/highways_and_roads/streets_and_traffic/quiet_lanes.aspx.

Natural England

https://www.naturalengland.org.uk/ourwork/enjoying/places/greenways/quiet_lanes/default.aspx .

Alton Towers

Alton Towers Excessive Traffic

Traffic is the main issue.  Inadequate planning control has allowed Alton Towers to expand exponentially over decades with no control on the traffic problems it generates.  A proposal to build a relief road from Denstone has been shelved for no apparent reason.  The suggestion that opening the railway line to Alton Towers will solve the traffic problem is not credible.

Injury collision “hot routes”  are prominant on the approach roads.

High risk factors

  • Narrow country lanes.
  • High vehicle flow rates.
  • Drivers unfamiliar with the area.
  • High proportion of young inexperienced drivers travelling at inappropriate speed.
  • Multiple vehicle occupancy.
  • Passengers often young, excited and eager to arrive, increasing driver distraction risk.

Analysis of data obtained from Staffordshire County Council shows that in the rural areas of the Churnet Valley there is a greater density of injury collisions in the south than in the north with injury collision “hot routes” identified on the approach routes to Alton Towers as follows:-

  1. Between The Star Crossroads at Cotton and Alton Towers main entrance.
  2. On the Cheadle to Alton road.
  3. On the road from Cheadle through Oakamoor to Star Crossroads at Cotton.
  4. Between Alton Village and Alton Towers main entrance.
  5. Over High Shutt on the Cheadle to Oakamoor road.

Road Safety Concerns

Staffordshire County Council, with co-operation from the proprietors of Alton Towers and the local community, has a responsibility to improve the safety situation and reduce the number of injury collisions on the approach routes to Alton Towers.   If such a large scale attraction were to be built today, planning controls would probably locate the venture close to a major motorway intersection providing easy access for vehicular traffic, where high volumes of traffic could be accommodated at low risk.  However, the reality is that Alton Towers is located many miles from motorways and relies upon inadequate narrow country lanes to cope with abnormal volumes of traffic.   The venue attracts people from all across the country.  Many drivers have travelled considerable distances at high speed on motorways to then find themselves channelled onto unfamiliar congested narrow country lanes.  The passengers are often young, excited and eager to arrive at their destination, generating situations where drivers are vulnerable to distractions.

The dynamics of the nature of the journey; multiple vehicle occupancy; narrow country lanes; unfamiliarity of drivers with the area and high traffic flow rates, develop a potentially dangerous cocktail of circumstances resulting in a higher than normal risk of injury collisions.   Taking into account these facts, it is not surprising that the approach routes to Alton Towers show up as injury collision “hot routes”.

It is recommended that the identified risk factors warrant particular consideration by SCC,  in conjunction with appropriate stakeholders,  with the aim of developing early casualty reduction initiatives under the headings of engineering, education and enforcement.  Any proposals to attract more tourists to the venue are cautioned against, unless major infrastructure improvements are introduced to accommodate increased vehicle numbers. Otherwise there is an obvious risk of further increasing the collision and more importantly the casualty rate.

Traffic congestion

Traffic is the main issue for the public.  Inadequate planning control has allowed Alton Towers to expand exponentially over decades with no control on the traffic problems it generates.  A proposal to build a relief road from Denstone has been shelved for no apparent reason.  The suggestion that opening the railway line to Alton Towers will solve the traffic problem is not credible.

Vehicle Flow

Vehicle flow on the approach routes to Alton Towers shows:-

  1. A marked seasonal increase during the summer period (April to October) that coincides with a summer increase in injury collisions.
  2. The summer hourly peak traffic flow was 50 times greater than the peak on the quietest winter day.
  3. On the busiest summer day on the Cotton side of the main entrance, in the half of the carriageway flowing towards the main entrance, during the busiest hour, a vehicle would have passed you once every 3.5 seconds compared with a vehicle every 3.2 minutes during the busiest hour on the quietest winter day.

An efficient car parking system?

The high flow rates on busy days near the entrance in the summer are indicative of an efficient vehicle car parking management system within Alton Towers that has developed over many years, admitting the maximum number of vehicles in the shortest possible time.  However, anecdotal evidence from local residents suggests that despite its efficiency, the parking system within Alton Towers is often overwhelmed, resulting in traffic backing up from the car parks, out through the main entrance and onto the public road in both directions. Some residents say that the queue can extend all the way through the village of Alton and out on the Denstone road, and in the other direction out to The Star crossroads at Cotton.  The residents suggest that queuing traffic causes serious inconvenience to through traffic, impeding not only local residents, but also emergency service vehicles responding to incidents.  Residents also differentiate between thrill seeking visitors attracted to Alton Towers and the more conventional tourists attracted to the Churnet Valley for its natural beauty and industrial heritage. They assert that traffic volumes generated by the two visitor groups are not complimentary and that conventional tourists, like residents, are inconvenienced by traffic delays emanating from the Alton Towers tail backs.  Some argue that conventional tourists are deterred from coming to the Churnet Valley because of the stories they have heard of Alton Towers traffic problems, and that the problem is inhibiting the growth of conventional tourism in the wider valley.

Interviews with some local residents suggested that at times Alton Towers staff are deployed directing traffic in Alton village, a mile or more away from the main entrance, on the public highway.  If such deployments do take place it is difficult to see where the lawful authority comes from for such private interventions on a public highway.

From an objective analysis viewpoint, other than photographs of queuing traffic, no direct evidence of times and dates when such traffic hold ups have been experienced was available at the time of conducting the analysis, and so it is difficult to comment on allegations of highway obstruction at present.  However, in the future, if SCC were to gather speed data at busy times it would be possible to identify any periods of exceptionally slow moving traffic, thereby establishing facts to either support or refute the allegations on the highway obstruction queuing issue.

Consequently, it is suggested that SCC may wish to consider gathering speed data in the peak summer periods not only at the current monitoring points but also at more widespread locations on the approach routes.  Such data would provide facts to prove or disprove the view of residents that queuing traffic into Alton Towers obstructs the public highway.  Should SCC not have the resources to gather speed data, an option open to residents would be to carry out field observations to time the progression of the tail end of any queue as it extends along the highway, by simply walking with the tail end and noting the time at regular measured reference points. Either evidence gathering procedure would help inform the debate about the impact of Alton Towers on the free flow of traffic.

Alternative Access Route

It is understood that in the past proposals have been considered for a new access road into Alton Towers from the Denstone direction, and, whilst satisfactory options have been developed, little progress has been made owing to funding issues. Such an infrastructure improvement clearly has the potential to alleviate pressure on the existing main access.  In the absence of such a relief road it is difficult to see how further increases in visitor numbers can be safely justified as the vehicle flow rates at peak times into the existing entrance appear to be approaching saturation point.  Indeed, if the numerous allegations by local residents of tailbacks are substantiated, then saturation point has already been reached.

In the absence of an alternative access route being constructed it is difficult to see how further increases in visitor numbers can be accommodated at Alton Towers as the vehicle flow rates at peak times into the existing entrance appear to be reaching if not at saturation point.

 RECOMMENDATIONS

  • In response to assertions by local residents of  obstruction of the public highway it is suggested that SCC may wish to consider gathering speed data in the peak summer periods at the current monitoring points and at more widespread locations on the approach routes to shed evidential light on the traffic congestion issue.
  • Plans for a Denstone to Alton relief road should be re-visited in the interests of public safety.
  • Casualty reduction initiatives need to be developed and implemented promptly to combat the current high risk situation on the approach routes to Alton Towers.
  • In the interests of public safety no attempts should be made to attract more visitors to the venue until such time as the high risk situation has been resolved.

 

Transport

Transport & Road Infrastructure Inadequacies in the Churnet Valley

• There is a current reliance on an inadequate network of roads and lanes.
• Concerns are already recognised by the Highway Authority, Staffordshire County Council.
• Despite this the District Council is promoting tourism expansion.
• WAG is in discussions with the Highway Authority on proposals to introduce a network of “Quiet Lanes” in the Churnet Valley under government legislation.
  • WAG is currently planning a public survey to measure support for “Quiet Lanes” to inform more detailed proposals.