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Save our Villages Group notes for the consultation feedback

Item Page No

Health 2

Schools 3 – 5

Housing 5

Greenbelt 6

Air pollution and flood risk 9 – 10

Transportation 10 - 12

Industry 12 - 13

Green Infrastructure 13 – 15

Newhey Quarry specific 15 – 16

Summary – GMCA Vision our view 17 – 18

FOI – Kingsway South Julian (Shaw Group) 19 - 20

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GM Allocation 3: Kingsway South GM Allocation 27: Newhey Quarry

Milnrow and Newhey Milnrow and Newhey are two villages lying on the edge of the Pennine hills, falling within the Rochdale Metropolitan Borough. At the last Census (2011) Milnrow and Newhey had 10,219 residents

Health

According to the Office for National Statistics (ONS) 2015 Mid-Year stats, the population of the outlying districts and the Borough as a whole is aging and more residents will need access to a GP and other health care services as the population of those aged 85 years and over is expected to increase by 28% with 1 in 5 being over 65 years by 2025.

Health care provision within the area is provided by 2 GP surgeries; Stonefield Street and Milnrow Village Practice.

Coral Mill was a development of 69 properties on former mill site in Newhey completed in 2017. No Section 106 funds had been made available for infrastructure changes to enable the surgeries to cope with the additional residents following this development. This is already causing a strain on the existing GP resources, one of which has advised it is running at 95% capacity with limited scope to increase capability within their existing premises.

Existing planning applications for the village would add another 208 properties and on top of this, the Greater Manchester Spatial Framework proposal would add approximately 950 new homes over 3 sites in Newhey and the surrounding area.

With our GPs already struggling, to add so many new patients to the area would require building expansion, further changing the village landscape and yet Rochdale no longer has its own Accident and Emergency and Maternity facilities. The Rochdale Infirmary (3.4 miles) having been ‘down-graded’ to an Urgent Care centre. A&E and Maternity services are now provided at The Royal Oldham Hospital (6.8 miles) or Fairfield General Hospital (8.7 miles).

Under the Spatial Framework in the Rochdale, Heywood and Middleton Health Trust would surely struggle to cope with the additional thousands of new homes and residents without massive changes and investment to expand the existing facilities. An alternative would be to include town centre regeneration into GMSF planning to reduce the already increased demand on the GP surgeries in the outlying districts and fully utilise the large healthcare buildings in the town (Rochdale Infirmary, Croft Shifa Centre and Nye Bevan House).

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In addition to the issues our healthcare services would face with such a massive influx of new patients, but the building of hundreds of new homes on our green open spaces will increase pollution and carbon emissions and reduce the clean air spaces which are used by existing residents of both town and country for leisure and relaxation.

Schools

Funding cuts since 2010 have made education spending shrink by 14% in real terms and from 5.8% of GDP to only 4.4%. Obviously more educational facilities are needed; the amount of children in primary schools in Rochdale has been steadily growing over the last few years as you can see from the diagram below.

Schools within 2 miles of Newhey and Milnrow

Scho

ol

Rati

ng

Year

of

insp

ecti

on

Age

rang

e

No

of

pupi

ls

Capa

city

Ove

r/U

nder

Milnrow Parish Good201

84-11 207 210 -3

Crossgates Primary Good201

75-11 307 306 1

Hollingworth Academy

Outstanding

2008

11-16 1263

1200 63

Moorhouse Primary Good201

63-11 254 266 -12

Newhey Community Primary Good

2016

3-11 317 295 22

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19500

20000

20500

21000

21500

22000

22500

23000

23500

11200114001160011800120001220012400126001280013000

Schoolchildren in Rochdale

Primary Secondary

Axis TitleNum

ber o

f Chi

ldre

n in

Prim

ary

Scho

ols

Num

ber o

f Chi

ldre

n in

Sec

onda

ry S

choo

ls


St Thomas CofE Good201

85-11 151 147 4

2499242

4 75

Source: OFSTED website

As you can see from the table above the majority of schools in this area are either good or outstanding which is in contrast to the overall figure for Rochdale. In the past five years, Ofsted reports suggest that standards are slowly declining, with those schools categorized as ‘Outstanding’ falling by 7% over the past 5 years to significantly below the rising national average (currently at 21%). Neighbouring Oldham too has received poor Ofsted reports with 24% of students studying at an institution classified as ‘Requires Improvement’ or lower. Points 9.18 and 9.20 suggest that a key reason for an education “If, for example, there are constraints such as an area of outstanding natural beauty, green belt or whatever it might be, and people can justify a lower number, an inspector should accept that. “If, for example, there are constraints such as an area of outstanding natural beauty, green belt or whatever it might be, and people can justify a lower number, an inspector should accept that.l focus is so that residents of the GM area can benefit from varied high tech and skilled sectors- a basic education will not suffice in this respect given the high levels of competition from elsewhere. This is especially important for Rochdale given the region’s ‘deprivation index’- Ofsted statistics note that ≈40% of secondary students in Rochdale are eligible for free school meals in contrast to the national average of only 28%, given a comparatively lower income it is essential that students retain access to school tuition equal to that found elsewhere in the UK. Earlier in the document Andy Burnham stated an aim to extend the prosperity of the centre outwards and especially to the North- yet there is no mention of this here; or any indication as to how this would be achieved.

We will need to watch carefully what will happen to those schools such as Newhey Community Primary who are over their official numbers in terms of capacity.

On top of all this there is the issue with a chronic shortage of teachers. Report on Patterns and Trends in UK Higher Education 2018 from Universities UK found that the number studying Education has decreased over the past ten years by 25%. More schools would spread those qualified teachers available thinner on the ground even faster than demographic growth currently is and reduce the quality of education and prospects for many. Already it is the case that only 36% of students in Rochdale attained 9 A*-C’s at GCSE compared to national average of 43% and, even before the GCSE reforms, a discrepancy was consistent. Clearly the quality of teaching must improve- facilities alone will be insufficient as RAND (International Research Org regarding public policies) finds that quality of teaching impacts the outcome of education more

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than any other single factor- the dearth of qualified and experienced teachers (an issue which, if left alone, will surely only get worse) must be addressed before improving facilities becomes a priority, let alone significant expansion of facilities and infrastructure. Moreover- management is a difficulty, truancy has been increasing in schools for years now- a key feature behind this is suspected to be a lack of strong leadership and poor teaching quality. Thus a good education requires these qualities teachers not only to ensure that students take in information but that they are even in the right place to receive it.

Manchester is a great student city- the size of the community is enough proof of that, but equally, that Rochdale has a minimal university population is equally evident. Again, how would the expansion of this ‘student region’ benefit the outer regions of GM? So far, only central Manchester particularly reaps the benefits of being a student city. Majority of students live in either halls or in the suburban sprawl surrounding the centre. We need University courses to be delivered at our outstanding provision Rochdale College for those students who

UK has found that adult participation in undergraduate degrees has steadily declined from approx. 1/3 of students in 2007 to 1/5 in 2016. If expansion of Uni campuses and the student region is part of the programme to promote the dissemination of skills to everyone in GM, current trends would suggest that this will be increasingly less beneficial to current adult residents and especially those without the disposable income to afford tuition fees, a factor which comes into play especially for the Northern and less prosperous regions of GM.

Housing In 2018 the Ministry for Housing and Local Government laid out three aims in the Technical consultation on updates to national planning policy and guidance;

to provide stability and certainty for planning authorities, ensure planning responds to projected households but also price signals,

and deliver “a housing market that works for everyone”

The government had advised councils in this document to ignore the latest set of ONS figures, which downgraded population and housing estimates based on research from 2016, and return to “2014-based data which will provide the demographic baseline for assessment of local housing need”. “The historic under-delivery of housing means there is a case for public policy supporting delivery in excess of household projections”

However, on the 21st February 2019 Kit Malthouse (xxx) in Westminster stated “If, for example, there are constraints such as an area of outstanding natural beauty, green belt or whatever it might be, and people can justify a lower number, an inspector should accept that”.

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Our natural environment in the Pennine Villages is too precious for politicians to squabble over. These contradictory comments are most unhelpful and we strongly object to Greenbelt being re-designated and housing figures inflated in our area without proper clarity.

What needs thinking about is how we in our borough have “a housing market that works for everyone”

What works for the people of the Milnrow and Newhey are a mix of homes that will meet the needs of the aging population as well as for the young.

According to the Office for National Statistics (ONS) 2015 Mid-Year stats, the population of the outlying districts and the Borough as a whole is aging as the population of those aged 85 years and over is expected to increase by 28% with 1 in 5 being over 65 years by 2025.

We strongly urge the GMCA and the government to think about this figure. The needs for the area in terms of people downsizing homes at this age is different to that of the needs of families and young people

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Greenbelt

The GMCA Greenbelt Scoping paper references the National Planning Policy Framework 2.3 With respect to taking a decision to alter Green Belt boundaries already established, Paragraph 136 tells us that: Boundaries should only be altered where exceptional circumstances are fully evidenced and justified, with a view to their intended permanence in the long term and so they can endure beyond the plan period.

Exceptional circumstances exist to justify changes; other reasonable options for meeting identified needs should have been examined fully including making full use of suitable brownfield sites, optimising the density of development and having regard to discussions with neighbouring authorities about whether they accommodate some of the identified need (Paragraph 137). Other factors should be taken into account such as the need to promote sustainable patterns of development and the consequences for sustainable development of diverting development inside or outside of the Green Belt boundary (Paragraph 138).

2.4 Once concluded that it is necessary to release Green Belt, Paragraph 138 tells us plans should give first consideration to land which has been previously-developed and/or is well-served by public transport and should also set out ways in which release can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. 2.5 When defining Green Belt boundaries, Paragraph 139 gives us six measures to satisfy including the need to ensure land is not included for which it is unnecessary to keep permanently open and the requirement to use boundaries that use physical features that are readily recognisable and likely to be permanent.

In the 25 year Environmental Plan (https://www.gov.uk/government/publications/25-year-environment-plan#history) the Prime Minister Teresa May stated

"We hold our natural environment in trust for the next generation. By implementing the measures in this ambitious plan, ours can become the first generation to leave that environment in a better state than we found it and pass on to the next generation a natural environment protected and enhanced for the future".

Other politicians agree:

David Cameron in 2015 stated that protecting the green belt is paramount

Sajid Javid, the then Communities Secretary, described the Green Belt as ‘sacrosanct’

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https://www.gov.uk/government/publications/25-year-environment-plan#history

https://www.gov.uk/government/publications/25-year-environment-plan#history


In the 2015 Conservative Manifesto it stated clearly that Ministers attach great importance to the green belt and will maintain existing levels of protection

Andy Burnham the Mayor of Greater Manchester has discussed the need for “no net loss”

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Greenbelt and our heritage

We strongly object to the use of Greenbelt land as the local authority has not reasonably shown evidence that it should be used.

- How will the town centre be regenerated to allow for town centre living for the young or elderly close to public transport links and amenities? A considerable

- The brownfield register is not conclusive and does need to be updated as a community we will work with the CPRE to do the work the local authority should be doing

Kingsway South borders Oldham and the council have produced their Joint Core Strategy and Development Plan Document that states that the focus for new homes, shops, jobs education and leisure will be within sustainable and accessible locations towards the existing built up areas of the borough and that the current boundaries of the Green Belt are to be maintained. The main purpose of the Green Belt is to keep land permanently open.

Once a green belt has been established and approved it requires more than general planning concepts to justify an alteration. (Gallager Homes Ltd V Solihull Metropolitan Borough Council 2014) The mere process of preparing a new local plan is not in itself to be regarded as exceptional circumstance justifying an alternative to a green belt boundary.

Alterations to Green Belt boundaries require exceptional changes in circumstances which necessitate revision. The very special circumstances threshold is a very high one, an example being Manchester Airport. Economic growth is not an exceptional case.The latest GMSF proposes to retain a strategic area of Greenbelt in the eastern half of the site to maintain separation between urban areas. This is just a token effort to try and appease residents to show that they are stopping the Urban Sprawl. This is not good enough; we should not be losing any of our Green Belt on this site.

Building on this site will affect Air Quality, Loss of precious wildlife, it will cause Flooding, Traffic Congestion and Light Pollution. The site is also home to a Meadow of Biological Importance. This should not and cannot be destroyed.

Green Belt was established to stop urban sprawl and to promote well-being and be the lungs of Greater Manchester. This has not changed in recent years, Air Quality in Newhey is affected negatively due to the proximity of the motorway and the horrendous increase in traffic, especially on the NOW REGULAR times that the M62 is gridlocked by accidents and all the traffic uses Newhey as a motorway by-pass. Nitrogen Oxide, a chemical produced by cars, is responsible for more than 1,200 deaths a year in Greater Manchester and the proximity of the M62 Motorway to our houses and schools is a great worry. The existing Green Belt at least gives a fighting chance of helping rectify the poor Air Quality in our area.

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The latest GMSF proposal is STILL based on out of date population figures and should be revised to take into account the reduced population and also take note of the effect of Brexit on the figures. We do not require the amount of housing that the GMSF is proposing.

Greater Manchester Mayor, Andy Burnham admits he has failed in his requirements of “No net loss of Green Belt” with the latest GMSF. In addition No net loss does not mean finding an already protected piece of land and calling that Green Belt.

- Queens Park, Heywood (http://www.visitrochdale.com/…/queens-park-green-flag-award…) An award winning green flag park.

- Firgrove Playing Fields (http://www.fieldsintrust.org/FieldSite/Firgrove) According to their website “One of the parks and green spaces protected by Fields in Trust in perpetuity. Because once they are gone, they are gone forever”... These fields have been protected since January 1929.

- Plus other small areas of Protected Open Land, Recreational Open SpaceWhy would you need to change the designation of an award winning park and playing fields held in trust!Who is gaming the system here? Is this really the no net loss Andy Burnham wanted councils to looks into?They may think this is a reduction in the loss of greenbelt because they have changed the status of these green spaces. However, this IS just game playing and that is just plain wrong.

In 2018 Environment Secretary Michael Gove announced there would be a review into the country's natural landscapes.

The plans for the South Pennines are currently being submitted and this will include our area. Surely, this is a good enough reason to keep this area green with rural countryside. With the proximity of Ellenroad Mill to the existing Green Belt surely it is more favourable to enhance the tourist attraction by keeping the Green Belt with its green fields, countryside and rural walks. Should we be an area for tourism? Wouldn’t this be more appropriate to move our villages on economically rather than killing them off by changing their character by removing the greenbelt?

The National Planning Policy Framework states that ‘to preserve the setting and special character of historic towns'. Newhey, Milnrow and the Pennine Villages must be included in this with this

Our area is historic and with a heritage sites such as Ellenroad Mill and Ogden/Piethorne Valley we already have areas we can tap into.

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https://l.facebook.com/l.php?u=http%3A%2F%2Fwww.fieldsintrust.org%2FFieldSite%2FFirgrove%3Ffbclid%3DIwAR0OM5P9p_KxuofuNuXHaTRGOgOs-Z7jxPIIM4yrnsgfaM25KDlf2c2Aq4E&h=AT1ng3-I6cGEytkAl71K6gtul201YG2CzNuXA3RPY_gOZfhBYaUM6gxFgezI5GXwwLtMZpHz5hzFEtzr9txn08LvE5j9GVccDjfHL4qXRrRTYXvZ2xkXVO7GMJo1kMeiNiBF7VRxR0gBmuDa5sLeKjC3heZPpdOWIC3eUsA

http://www.visitrochdale.com/rochdale-all/where-to-go/queens-park-green-flag-award-p12761?fbclid=IwAR1P_hak4OMOSKqmYxm9b-s8k2Yfj78BdrfN7jaXyFb35baUkaOb4GHepBI

http://www.visitrochdale.com/rochdale-all/where-to-go/queens-park-green-flag-award-p12761?fbclid=IwAR1P_hak4OMOSKqmYxm9b-s8k2Yfj78BdrfN7jaXyFb35baUkaOb4GHepBI


Air PollutionPolluted air is now the biggest environmental risk to public health in the UK. GMCA by their own admission state that by next year 152 roads across the region will have breached or will be close to breaching the legal limit for nitrogen dioxide If they don’t tackle air pollution. Their data shows that one of these highly polluted roads is Elizabethan Way, Milnrow. The large volumes of slow moving and stationary traffic at peak times are the cause of these seriously high levels. GMSF proposed developments for Kingsway, Newhey Quarry along with those at Smithy Bridge and Littleborough will only add to the congestion and increase nitrogen dioxide to alarming high levels which will seriously impact on the health of Milnrow and Newhey residents. Nitrogen dioxide is a major cause of asthma, bronchitis, heart problems and cancer. An increase in pollution related health conditions will put further pressure on our already oversubscribed NHS services. In an attempt to tackle the high emissions GMCA plan to create clean air zones; this means highly polluting vehicles will be charged to enter these zones. The proposal does not address the increased traffic or show plans to alleviate the congestion. Worryingly DEFRA state in their recent communications that air pollutants may not only be a problem in the immediate vicinity of the source but can travel long distances. GMCA have noted as part of their investigation that other contributing factors are tall buildings that lock in the poisonous gases and the wind direction which blows pollution to the north and east of the region. Flood riskSeveral areas surrounding the Kingsway South proposed GMSF development are categorised as having a high level flooding risk. The contributing factors are the land topography and the close proximity of the river Beal. In recent years there have been numerous instances after days of prolonged rainfall when the banks of the river Beal have been breached resulting in localised flooding in several locations throughout Milnrow and Newhey. Destroying our greenbelt and replacing it with houses and warehousing increases the vulnerability of our existing houses in the high risk areas as the natural resilience of the ecosystem is compromised if water is not allowed to permeate back into the soil. It is inevitable that if these plans are passed more areas of our precious villages will be upgraded to high risk.

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The impact of rainwater removed from the natural soakway areas by the development GMA15 and GMA14 will overwhelm the tributaries Sholver, Hodge Brook and Besom Hill Brook that feed into the River Beal. Likewise, the Duchess Street development of GMA3 will add to the Pencil Brook tributary which travels through the High to Medium flood risks area of Smallbrook and Wood End.There has always been high potential of flooding in all areas of the Beal Valley - where the River Beal emerges from its source at Stoneleigh Park, Derker and travelling through Shaw, Newhey, Milnrow and Belfield, where it joins the River Roch.

Areas currently identified as at high risk of flooding from both the river Beal and from surface water are:

- Properties at the junction of Two Bridges Road and Shaw Road, Newhey- Milnrow Precinct- Stonefield Street Health Centre, Milnrow- Land to the rear of Ellenroad Engine House- Ellenroad Farm- Beal Bank, Newhey- Whitebeam Close, Newhey

Due to the topography of the GMA3 site, a vast natural soakway area, rainwater removal will drain down to Newhey where the area is presently classed as a High risk flood area hence the need for the Monitoring Station at Beal Bridge (Junction of Shaw Road and Two Bridges Road, Newhey). Likewise Charles Lane, Milnrow is a Medium risk flood area with a Monitoring Station at the River Beal at Station Road.

The River Beal will be overwhelmed by the Rainwater run-off from the GMA3, GMA14 and GMA15 proposals and this will have an accumulative damaging effect downstream on the River Roch and subsequently Rochdale Town Centre.

We also have to worry about water usage (an average house uses 450 litres/day) and wastewater usage are not even broached in the consultation - have we the reservoir capacity? Have we the sewage treatment capacity? For such large scale developments throughout Rochdale?.

Transportation

We have serious concerns that section 106 monies from the 1,500 homes planned under GMSF for our villages will not be spent on infrastructure and the aim of (objective 2) GMSF to create neighbourhoods of choice will not make our Pennine Villages desirable places to live.

We disagree that the plan for any of the sites we are objecting to will allow Rochdale Borough Council and the GMCA to:

Prioritise the use of brownfield land; Focus new homes in the Core Growth Area and the town centres;

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Focus new homes within 800m of public transport hubs; Ensure that there is no increase in the number of homes and premises at

a high risk of flooding; Prioritise sustainable modes of transport to reduce the impact of vehicles

on communities.

Precedent has been set by a recent development at Coral Mill in Newhey. 75 new homes placed without a thought for the infrastructure needed. Why didn’t plans include parking for the

Has the aim to focus new homes within 800m of public transport hubs been properly thought through? The villages cannot cope with the number of vehicles as it is. It would be impossible to travel anywhere during peak times. What investigation has been done in terms of the peak travel in the Pennine Villages? People travelling to Shaw/Littleborough/Smithy Bridge/Upper Mill come off at Junction 21 and either go through Elizabethan Road.

There is a vision to prioritise sustainable modes of transport to reduce the impact of vehicles on communities. Without joined up thinking in terms of transportation in general our villages will be gridlocked.

- Bus services are poor and there is no direct bus link from Milnrow to Littleborough

- Tram services are regular but we need more carriages on this line

- The proposed Park and Ride at Newhey Quarry would not solve traffic issues in Newhey. People will park there and not contribute to the local economy

- Lines are currently too slow going to Manchester. It is sometimes quicker to drive there! a faster line to Manchester. Rochdale – Milnrow – Newhey – Shaw – Manchester

- Cost of travel by bus and tram is expensive and prices out lots of people

- Any proposed parking in the villages need to allow for limited loss of the character of the area ‘greener spaces in character with the surrounding countryside'.

We do strongly object to the volume of traffic that would be on an already busy Huddersfield Road increasing air pollution and congestion.

Have extensive studies taken place to provide evidence that there would be a requirement for 'enhanced bus corridors to the west of Rochdale Road'? What evidence is available to prove

The 2016 National Travel Survey in England states that 89% of passenger miles are by road. 77% of households have access to a car with 34% having two cars. How are you going to change people's mind about their form of transport and encourage them to use an inferior bus service and a tram service where

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you either have a 30 min plus walk or have to wait for a shuttle bus to get yo your destination? Current routes are miles from the Kingsway South site but what evidence is available to confirm that bus corridors would be available for employees on the site? There is nothing in the Transport for Greater Manchester Strategic Plan to confirm this.

Early morning and peak times on the tram does show that a large amount of people alight the tram at Kingsway business park but then get off in Oldham, Failsworth, Newton Heath and Manchester. This is not bringing economic growth to Rochdale as they live and spend their money in other parts of Greater Manchester. Currently the tram carriages are too few at peak times and it's 'standing room only'! This encourages more and more people to go back to their car. Guarantees have to be made to increase the number of carriages.

The new Kingsway South site is further from the Metrolink and bus transport. To walk form 1the Kingsway Metrolink station to J D SPORTS Warehouse it takes 10 mins to Asda CDC Warehouse it is a 27 min walk. Both journeys along an isolated piece of land that's not advisable for females to take. On the new Kingsway South site it would be longer from these tram stops and would be a 30 min walk from Milnrow tram station and a 40 min walk from Newhey tram station. Perhaps shuttle buses are the answer but that will pollute our air even more! Shuttle buses from the Kingsway tram stop are probably the answer, however, as the Rochdale Leader of the Council pointed out when asked about increased air pollution "buses and taxis are the biggest culprits". So you would just be increasing air pollution instead of making a cleaner and greener environment.

GMSF are promoting more 'green' modes of transport with enhanced cycle and walking routes. Walking routes are probably not advisable on this site due to the isolation and distance to tram stops. Apparently, each tram only allows two cycles on at any one time, so how can you guarantee you could cycle from home to tram, take your tram journey and then cycle to work?

The plan on the Kingsway South site is for executive homes to be built for the executives who will be working in the higher end industrial units on the site. Is this then realistic to envisage that these executives will walk or cycle to work when they are given, as part of their contract, a company car? Even more traffic on the already congested roads of Milnrow & Newhey.

Although, we applaud the enthusiasm to get more people active and to create cycling routes linking the Metrolink stops, one vital flaw is that most cycles cannot actually be taken onto the tram, only foldable bikes which are expensive and in most cases impractical. In addition to the increased traffic (cars & heavy goods vehicles) from the proposed new housing development & employment spaces this could have the reverse impact and actually deter more people from cycling.

The existing cycle lanes are not fit for purpose with many far too short and pointless whilst others are used for parking on or are not looked after/cleaned and are full of debris. Creating new cycle lanes within the current road

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infrastructure will be difficult as most of our highways are not large enough today with no option to widen.

Creating walkways between proposed warehousing sites cannot and should not try to replicate walking through the open spaces, greenbelt and in amongst this natural habitat. Many people use the open countryside to balance and enhance their mental well-being. we must also question the safety aspect of single people walking through dimly lit passage ways with many blind spots as we have now on Kingsway business park.

Industry

Why is there a need for deliver a further industrial development totalling 310,000 sqm? Currently the Kingsway business park only equates to 59% of the land used. There are 2 unoccupied sites already built with over 300,000 sq ft and 12 sites not even built on.

With the Mayors vision of Brownfield sites first why is Rochdale not proposing the potential 2438 housing plots as part of the GMSF proposal, with a further 800+ homes unoccupied within Rochdale? These numbers have been obtained from the Rochdale Borough’s own website.

When asked during a meeting with the council leader he was asked how they can propose sites without any forethought to infrastructure and he advised this plan was unlikely to go ahead and if it did the planning would come later.

This should not be allowed to happen; both elements are integrally linked and require careful consideration to ensure the plan can be delivered to include the local infrastructure.

Green infrastructure

Landscaping a site, post – development, is not countryside, it is at best, horticulture. Kingsway South will be a footprint on a tract of countryside which encompasses a diverse range of habitats, including meadow, woodland, rush pasture, wetland and fluvial environments. The biodiversity associated with these habitats is significant. No amount of mitigation (because too many of the aforementioned habitats will be compromised) can prevent the eradication of national and globally threatened species. On the site breed several ‘Red and Amber Listed Birds of Conservation concern’ (see below in the biodiversity response). Criteria for Red Listed are:

Globally threatened Historical Population decline during 1800 to 1995 Severe (at least 50%) decline in UK breeding over the last 25 years Severe (at least 50%) contraction of UK breeding range

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Under the current proposals these species will be consigned to history.

Perhaps the most recent and relevant local example where we can see a recent attempt at creating a ‘multi-functional green infrastructure & a high level of landscaping within the site & around the main development areas’ took place at the existing Kingsway Site across the M62 and we remember similar hifalutin language used at the consultation stage of that too. Unfortunately, the subsequent result was poor and there hasn’t been any effective land management since. Looking at the landscapes and habitats created there, attempts at woodland saw saplings planted too close together, with no subsequent thinning taking place. Water bodies were ill-thought out, with little thought for relevant aquatic plant species, with many introduced species having a southern geographical bias, which wouldn’t naturally be found in our local countryside. Currently the ponds are silting up at an alarming rate and aggressive species are taking over. It is no good just doffing your cap to a bit of artificial greenery and then just leaving it. If you are going to do it needs proper management if it is to fulfil its brief. we fear that the same would happen should Kingsway South go ahead.

To contextualise, Kingsway South falls within National Character Area (NCA) 54. ‘Manchester Pennine Fringe’. Note New Hey Quarry looks to just fall within NCA 36, ‘South Pennines’. So, Milnrow and New Hey straddle both. With regards to where Kingsway South would sit within NCA 54 and how compatible it would be within that framework, the statements of environmental opportunities amply show how incompatible Kingsway South would be. The statements make reference to:

Managing and enhancing the green infrastructure of habitats and ecosystems, like rivers and woodlands (these would be put at risk by Kingsway South).

Increasing biodiversity, strengthening access and recreational use (access would be more restricted with the loss of public rights of way, including three recreational footpaths that cross the area – the Oldham and Rochdale Ways and Crompton Circuit).

Increasing understanding of the natural heritage (the natural heritage would be hugely compromised under the current proposals).

Sustainably managing and enhancing distinctive features of the Pennine fringe landscape, including habitats, pastoral land use, dry stone walls and gritstone building (all of which are key components of the site currently).

Strengthening landscape character, improving habitat condition and connectivity (landscape character would be diluted by such development and habitats would be fragmented and thus would ultimately degrade).

To provide access to nature (nature would be depleted on a massive scale in the first place and access to countryside would be restricted).

NCA 54 also points to there being a high demand for recreational opportunities,

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especially walking, horse riding and cycling. Increasing housing and industry on an important green space not only intensifies that demand but limits the opportunities for countryside access. The importance of countryside and wildlife for good mental health and well-being is well documented. Increasingly, activities such as walking and bird-watching are being prescribed by doctors for anxiety and depression as a sustainable alternative to drugs.

Another factor which features in the document is the importance of ‘sense of place/inspiration’ and talks at length about how this is constrained by urban and industrial development. Replacing this area of countryside with housing and industry can only homogenise and take away our area’s special character and qualities. The following lifted from the document illustrates the point beautifully and can never be underestimated:

‘Similarly, communities value their local green spaces as places of local distinctiveness that provide opportunities to engage with nature close to where they live and work, and that helps to encourage a sense of community.’

Retain & enhance areas of biodiversity within the site, notably the existing Meadow North of Moss Gate SB1 with existing brooks & water features falling within the site, to deliver a clear & measurable net gain in biodiversity

In short, under the current proposals it will nigh on impossible to retain overall biodiversity. The mosaic of habitats outlined previously will be lost on a sufficient scale to ensure this to be so. Add on the fact we are talking about the impact on a range of particularly sensitive and sometimes rare and declining species. Enhancement is possible, though in all likelihood can only achieved by introducing species atypical to this area of the South Pennines, which is exactly what happened with the ‘landscaping’ of the current, patchy, Kingsway site across the M62 and/or encouraging a greater mass of species that are widespread, common and not under threat. The site in its current form supports breeding red and amber listed bird species (see above for the definition of Red Listed), species like lapwing, skylark and linnet, to name a few. Birds are just one element, taking it further one has to consider the flora of the site too. On the site is ‘the meadow north of Moss Gate’, a Site of Biological Importance. Here we have an area of neutral grassland (not common in this area of predominantly acidic geology), which again holds several rare and declining species, notably adder’s tongue, pignut, devils bit scabious, knapweed and betony. Not only are all these species declining and scarce (primarily through loss of habitat!), but they are also important plants for invertebrates and key pollinating insects such as bees, butterflies, hoverflies, moths, etc. Even if this SBI was retained, development of the surrounding pasture would result in habitat fragmentation and isolation, cutting it off from green corridors and severely limiting the movement of species.

GMSF GMA27

History

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Newhey Quarry has been dormant since the 1970’s and a proposed reactivation was challenged and stopped in 1996 and a housing development proposal by the owners was stopped in the mid 2000’s.

The GMA27 proposal has the same challenges today and the impact on the local residents, community and wildlife are unchanged.

The quarry is recognised as a geological site by the ‘UK Fossils Network’ and is quoted to be full of Calamities, bivalves and brachiopods, ripple marks, worm burrows and fish marks. The Milnrow Sandstone for which it was originally quarried for is estimated to be 306-316million years old.

Wildlife

The quarry also has a family of Peregrine Falcons (per C. Jepsom Brown) which are afforded the highest degree of legal protection (as quoted by RMBC) Interestingly RMBC have a live webcam set up on their own Town Hall clock tower to share the progress of a family of similar Peregrines which have called it home since 2008.

Environmental impactsReducing the Biodiversity balance can have negative environmental impacts when decimating grasslands and moss which can be a contributing factor to flooding due to the rain water causing erosion to the soil states and causing flooding beyond the site at the lower levels. A section of moorland near Oldham is to be planted with ‘Spagnum Moss’ (AKA Super Sponge) which will store water and hopefully reduce flooding in the Shaw and Crompton areas. (enviromentaljournal.online)

Inadequate Infrastructure

Newhey Quarry is accessed by 18th century roads via Huddersfield Road, Jubilee bends and the recently upgraded Smart motorway M62/M60. The motorways recent alterations haven’t noticeably eased any traffic problems and daily, the 18th century roads are used as a default alternative route and are already overflowing with traffic queues which can contribute to:

Pollution, poor air quality, (proven to cause health problems including Asthma)

Reduction in wildlife habitation Negative community spirit Mental health and Wellbeing issues Negative mindfulness and physiological state Poor emotional health Accidents Increased danger to pedestrians and cyclists

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The proposed plans to build 250 homes on the quarry site could add 2 cars per household and 1 child per household which would increase the traffic movements on Huddersfield road alone to approximately 1500 more vehicle movements per day.

Policing and schools

With the potential increase in residents in Newhey via the quarry, more Policing, school places and health centres would need to be included to support the homes.Developers rarely contribute to any infrastructure improvements when building homes as they are only concerned about making a profit and once the development is complete they move onto their next project without any concern for the local communities long term sustainability.we feel the planners are not listening to or protecting the community in this case and the proposed homes are not going to be affordable to most of the local residents which confirms that the planners want buyers to move from elsewhere into Newhey which will have not have a positive impact on the next generation of young homebuyers in Newhey and they will be forced out of their village leaving an ageing community in Newhey which is not sustainable.

Alternative uses for the quarry

Children in RMBCs catchment area have generally poor diverse recreational free spaces to enjoy. The quarry site could become a Scout, Cubs, Guides site for use by all similar groups in the NW and West Yorkshire. (currently most local groups generally travel to Yorkshire and beyond to enjoy quality facilities) This could include an adventure climbing site including rock climbing, abseiling, high ropes etc. including safer cycle tracks and endless possibilities for the outdoor adventure theme.

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Chapter 3 – GMCA Vision

We do not agree that the plan in its current form has allowed for this vision in Rochdale and particularly in the following areas – Here are some things you can include in your response…

GMCA Vision My ViewA place where all children are given the best start in life and young people grow up inspired to exceed expectations.

The pride people felt in living here in the Pennine Villages has diminished.

- Work that our young people can do locally is limited- We have an outstanding college in Rochdale but not schools

– investment in primary schools is paramount to ensure our young have the best start. Where schools have gone above their roll this will have a detrimental on our young people

A place where people are proud to live, with a decent home, a fulfilling job, and stress-free journeys the norm. But if you need a helping hand you’ll get it.

I am proud to live in the Pennine Villages but the fabric of our life will be decimated when we have more than 1500 homes built in the area as part of the spatial framework. This does not include any homes that will be built outside of the framework.

Journeys to work are incredibly stressful. During peal hours of 6.30 am – 9 am and the evenings 3.30 – 6 pm the villages are gridlocked

The ward of Milnrow, Newhey and Ogden are the forgotten villages of the Pennines. We have higher employment than other areas of Rochdale and limited access to

A place of ideas and invention, with a modern and productive economy that draws in investment, visitors and talent.

The plans for the areas I am commenting on do not have any vision for the world of work in 20 years’ time. Our investment should be tourism. This would be in keeping with the character of our villages. Understanding of the heritage of the area. We already have custodians of our heritage in Ellenroad Mill and the Facebook page Milnrow Now and Then. Walking tours of the area would if marketed properly bring in visitors using the tram network.

A place where people live healthy lives and older people are valued.

As we have an increasingly older population in the Pennine Villages where are the homes they need in this ‘mix of homes’. Homes that cater for the increase in care for the elderly to live independent but safe lives in their twilight years.

Should we be thinking of how we can make our villages dementia friendly?

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GMCA Vision My ViewA place at the forefront of action on climate change with clean air and a flourishing natural environment.

A number of our primary schools are on main roads. How can this be safe for our young?

Why should we lose our greenbelt the lungs of our areas for more housing, industrial units which has a knock on effect of more traffic? What about our health? We urgently need the plan to be re-evaluated and the 2016 figures to be used. Once our greenbelt is declassified we cannot return from this. Once it is gone, it has gone.

A place where all voices are heard and where, working together, we can shape our future

I do not agree that the consultation in 2016 or now has been well publicised by Rochdale Borough Council. They had only 6 consultation events over 9 working days and none at weekends. Events have only been advertised through social media. People have only known about the Spatial Framework through the actions of local campaign groups

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FOI – Kingsway South – Julian (Shaw Group)

MSF - GMA3 South Kingsway - Please provide details of how this site is to be potentially utilised. This information could be in the form of concept plans or a general overview of how the site is to be utilised for housing and/or industrial use, showing any potentially access routes and how heritage sites will be protected. Could you also provide an explanation of why some of the land within Rochdale's boundary, may be being utilised by Oldham Please find attached an indicative concept plan that has been prepared for the proposed strategic allocation at Kingsway South. This a high-level plan that has been prepared for illustrative purposes only and to help us understand how they site may be developed. The proposed strategic allocation at Kingsway South is a cross-boundary allocation between Oldham and Rochdale. GMSF Brownfield Sites - Suitable, Achievable & Available - Please provide details of all sites which have been identified whether suitable, achievable or available. Following this, the viability assessments on each of those sites to ascertain whether they are a) suitable, b)achievable, c)available. Then finally how the council have concluded that each site is to be utilised or not utilised for potential development. This information can be found in Oldham’s Strategic Housing Land Availability Assessment (SHLAA) as at 1 April 2018 which is available on the council’s website athttps://www.oldham.gov.uk/info/200709/documents_in_the_local_plan/2134/strategic_housing_land_availability_assessment. GMSF - It has been widely reported within the press that Local Authorities within GMCA have utilised Government housing projection figures for the region which were produced in 2014 showing 201,000 homes for the region. GMCA could potentially have utilised revised Government Housing figures which were revised in 2016 with a revised housing need of 140,000. Please could you explain Oldham Councils stance regarding this matter and provide any dialogue/correspondence regarding the matter and also specifically if this matter was challenged by Oldham Council The Greater Manchester Combined Authority (GMCA) challenged central government on the local housing need methodology on behalf of the ten districts across Greater Manchester. Details regarding correspondence between GMCA and the Ministry for Housing, Communities and Local Government is contained within the response to your Freedom of Information request received on the 25th February 2019. GMSF - It has been reported that Oldham Council may be including other boroughs housing targets within their own housing targets, as other GMCA Local Authorities have not achieved their own required housing targets. It has been reported that Oldham may have increased their figures to ensure housing targets across the GMCA region are achieved - please could you comment regarding this matter. Oldham Council is committed to meeting our own local housing need. Applying the standard MHCLG methodology this would give Oldham a local housing need of 716 a year or 13,604 over the GMSF plan period of 19 years. As stated in the Housing Topic Paper higher levels of housing growth have been focused in the central and northern districts of Greater Manchester. It is considered that supporting higher levels of new housing in the

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https://www.oldham.gov.uk/info/200709/documents_in_the_local_plan/2134/strategic_housing_land_availability_assessment

https://www.oldham.gov.uk/info/200709/documents_in_the_local_plan/2134/strategic_housing_land_availability_assessment


northern districts will assist in achieving a more balanced pattern of growth across Greater Manchester and a better distribution of skilled workers to support local economies, helping to reduce disparities. The proposed distribution of housing development also reflects the availability of suitable sites in each of the districts. Furthermore, Oldham consider it sensible to plan for a small buffer (5% in Oldham’s case or 686 dwellings), should sites not come forward as expected. Local Plan inquiry’s across the country indicate that this is an approach welcomed by Planning Inspectors. As a result, Oldham’s local housing need in the GMSF is 752 a year or 14,290 over the GMSF plan period. This equates to 105% of Oldham’s local housing need. The Housing Topic Paper can be found on the GMCA website

https://www.greatermanchester-ca.gov.uk/what-we-do/housing/greater-manchester-spatial-framework/gmsf-documents/.

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https://www.greatermanchester-ca.gov.uk/what-we-do/housing/greater-manchester-spatial-framework/gmsf-documents/

https://www.greatermanchester-ca.gov.uk/what-we-do/housing/greater-manchester-spatial-framework/gmsf-documents/

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