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.