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					Draft Preferred Options Core Strategy Consultation Responses Report   February 2009




    DRAFT PREFERRED OPTIONS
        CORE STRATEGY




     CONSULTATION RESPONSES
            REPORT




February 2009
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Draft Preferred Options Core Strategy Consultation Responses Report          February 2009




This Report details the responses received to consultation on the draft
Preferred Options Core Strategy. It also includes comments from the
various consultation and stakeholder events where applicable and any
further evidence which may be relevant. It then sets out the Officer
response to those comments and details the suggested changes to the
Core Strategy where appropriate.



CONTENTS

                                                                                  Page

The Vision                                                                           3

Aims and Objectives                                                                  6

Development Approach and Spatial Strategy                                            8

Spatial Strategy Policies

SS1                                   Development Principles                        12
SS2                                   Future Provision of Development               14
SS3, SS5 & SS6                        Distribution of Development                   19
SS4                                   Managing the Release of Housing Land          25
SS5a                                  Leek Area Strategy                            29
SS5b                                  Biddulph Area Strategy                        47
SS5c                                  Cheadle Area Strategy                         65
SS6a, SS6b & SS6c                     Rural Area Strategies                         79
                                      Churnet Valley Tourism Corridor               96
SS7                                   Blythe Bridge RIS                            102

Development Control Policies

SD1                                   Sustainable Development                      104
E1, E2 & E3                           Economy and Employment                       112
H1, H2 & H3                           Housing                                      118
TCR1 & TCR2                           Town Centres & Retailing                     126
DC1, DC2 & DC3                        Design & Conservation                        132
C1 & C2                               Sustainable Communities                      139
R1 & R2                               Rural                                        145
NE1                                   Natural Environment                          150
T1 & T2                               Transport                                    156

Miscellaneous Comments                                                             161




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The Vision
Introduction
The vision describes what the are should be like in 2026 and, following consultation at the
Issues and Options stage, was considerably amended to make it more place-specific, better
reflect local aspirations and also better accord with the Council‟s priorities and the latest
Sustainable Community Strategy. Consultation on the Preferred Option Vision specifically
asked for comments on the amended vision (Q1a) and whether it required any further
amendments/additions (Q1b).


Summary of Comments

Comments from Questionnaires and Correspondence
There were 191 responses made relating to the vision. From those who responded there was
a significant level of support for the vision, which was seen as being well balanced,
appropriate to the District and imaginative. There was particular support for the emphasis on
tourism and local distinctiveness and it was also accepted as an improvement on the previous
Issues and Options draft.

The main criticisms made were –
    Too vague and idealistic - question whether it is achievable
    Too much emphasis on housing development, strain on resources
    Not enough emphasis on employment and jobs, on transport problems and on
     protection of green spaces and green belt (green infrastructure)
    No reference to existing facilities which need updating and improving
    Lack of coherence and contradictions between certain elements of the vision e.g.
     protecting heritage and housing development
    Need for more on how vision will be achieved and requirements identified
    Need for flexibility to accommodate changing circumstances over plan period

There was general support from Statutory Consultees who responded. Staffordshire
County Council requested further information regarding how the authority will proactively set
about identifying with other stakeholders the overall infrastructure requirements to help
implement development that will come forward. English Heritage suggest 2 minor additions
to the vision adding a reference to the District‟s natural and historic assets in relation to
tourism and to the District‟s landscape, heritage and its biodiversity in relation to the rural
areas. English Welsh & Scottish Railways comment that as the largest rail freight operator
it supports the Core Strategy. The Environment Agency consider that the vision is
acceptable provided that all proposed development is advised by the SFRA and guided to the
lowest flood risk areas.

There were 109 responses made suggesting amendments/additions to the vision. Many of
these related to specific areas and are therefore addressed in other policy responses. Of
those relevant to the general vision the following were highlighted as needing more emphasis
or attention in the vision:
      Better public transport provision
      Accommodation for tourism for local attractions
      Preserving the unique historical character of the area and to promote awareness of it.
      Role of retailing in regeneration and in achieving the specific vision identified for the
       market towns.
      Brownfield sites, the redevelopment of derelict and town centre sites and the reuse of
       empty, derelict and abandoned property
      Employment provision - encouraging more local manufacturing and smaller businesses
       and live/work spaces



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      How the provision of employment and retail space will impact on maintaining the
       distinctiveness and heritage assets of the area.
      Preservation of existing countryside, especially that inside or on the edge of built up
       areas.
      Recognising that the A50 is an important road on the edge of the Moorlands for
       industry
      Use of the word "resilient" rather than just "sustainable" when referring to the future
       community.
      Less emphasis on houses, more on better infrastructure and amenities
      Greater focus on tourism - exploit the regions assets more - i.e. selling of local produce,
       more places for people to stay and preservation of old buildings.
      Planning of the District to attract new investment/business providing higher quality
       employment which in turn will attract further investment
      Older community
      Improved public services - schools, police stations, cottage hospitals etc
      The Arts, public art for example, or performing arts space.
      No encroachment into green belt areas.
      Necessity of keeping the balance between development and retaining the unique
       charm and character of the area.
      Recreational and community facilities - should not encroach on these to meet housing
       demands.
      Enhance the collective countryside facilities and physical links between them, least for
       the benefit of the local population and tourism.
      Making full use of existing Council stock
      Reducing car travel.
      Specific reference to localisation and locally grown food and protection of food
       producing areas which includes the green belt.

The following comments were also made which are relevant to the Vision for local areas:
     Leek – vision should seek to provide an environment that encourages the growth of all
      existing companies.
     Biddulph – more emphasis on improvements of parts of Biddulph and better facilities
      for the town
     Cheadle - more emphasis on employment development, better retail provision for
      Cheadle and a better road system for Cheadle
     Rural Areas – more emphaisis on provision of amenities and better public transport
      provision for rural communities, AONB status for Churnet Valley

One respondent specifically recommended that the vision (as identified on page 30) be
amended at paragraph 4, sentence 3 to state: "The diversity and quality of the District's
natural assets will have improved and greater use will be made of the opportunities they
provide for recreation, tourism and for providing associated facilities and accommodation,
particularly in and around the Churnet Valley which together with Alton Towers will be a
significant tourist attraction".

United Utilities comment that "physical infrastructure" presumably includes utility
infrastructure – question whether this need stating. Rushton Parish Council comment that
would like the Council to make full use of their existing Council stock and also to improve
public transport links. Cotton Parish Council comment that very concerned that Cauldon
Lowe, a substantial area of the Moorlands and home to many people is not mentioned in the
villages list. This is also a large industrial area. Query the omission.

Comments from Consultation and Stakeholder Events
The stakeholder workshops and meetings did not specifically address the vision and there
were no comments made regarding the vision from members of the public who attended the
consultation days.




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Further Evidence and Other Issues Identified
No further evidence or other issues have been identified relating to the vision.



Officer Response
The level of support for the vision is encouraging. It is acknowledged that some respondents
feel that it is very idealistic, but this is a broad expression of long term aspirations and as such
needs to be challenging and ambitious as well as being realistic and deliverable. It is
considered that the vision is well balanced with particular attention to improving the local
economy and maintaining distinctive local areas and does not place unnecessary emphasis
on housing. The vision also needs to be considered alongside the Spatial Strategy which
sets out how it will achieved and implemented and how inherent conflicts will be addressed
whilst the need for flexibility to adapt to changing circumstances is acknowledge and
addressed throughout the Core Strategy.

Most of the suggestions for changes relate to matters which are best addressed through the
detailed Spatial Strategy and specific Area Strategies and these have been considered within
those sections. It is acknowledged however that some further improvements to the vision in
respect of green infrastructure and heritage protection should be made and these are
suggested below.



Suggested Changes
                                   th
1. Amend 2nd sentence of 6 Paragraph of Vision (p30) to read: “Settlements will develop in
   a way that acknowledges their historic and natural heritage, and their unique setting and
   their green infrastructure.”
               rd                 th
2. Amend 3 sentence of 4 paragraph of Vision (p30) to read “The diversity and quality of
   the District‟s natural and historic assets will have improved and greater use will be made
   of the opportunities they provide for recreation and tourism, particularly around the
   Churnet Valley which together with Alton Towers will be a significant tourist attraction.”
                st                      nd
3. Amend 1 sentence of 2 paragraph of Rural Areas vision (p31) to read “In the
   countryside, the richness of the District‟s landscape, heritage and its biodiversity will
   continue to be valued, maintained and protected in a way which sensitively
   accommodates the needs of farmers, rural businesses, visitors and residents.”

4. Add definition of „physical infrastructure‟ in Glossary




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The Aims and Objectives
Introduction
The aims and objectives indicate how the vision can be achieved, setting the scene for the
detailed policies which follow and providing the basis for subsequent targets and performance
indicators. The Preferred Options contains 4 cross-cutting aims and a set of 11 more specific
objectives based on the priorities in the Council‟s Sustainable Communities Plan and it‟s
Corporate Strategy. Consultation on these aims and objectives specifically asked whether
any amendments or additions were required (Q2).



Summary of Comments

Comments from Questionnaires and Correspondence
There were 143 general responses made relating to the aims and objectives and 48
responses made in relation to specific objectives. Many considered that they were
appropriate and comprehensive and did not require further change. Other comments made
were the need for positive support from key agencies ands partners to achieve the aims and
objectives; potential contradictions and conflict between objectives and with the proposals put
forward; the need to prioritise the objectives to reflect community needs and priorities; the
aims being too idealistic and generalised; and the need to build in more flexibility for changing
circumstances.

There were a number of issues where it was considered more emphasis was needed in the
aims or objectives:
     Wealth creation and diversity in employment provision from new industries and tourism
     Prioritising brownfield sites over greenfield
     Protection of the countryside and green belt
     Ensuring long term viability of villages and tackling rural regeneration

                                          2
      Tackling climate change and CO reduction
     Transport links and road improvements
     Affordable housing
     Services and facilities
     Needs of older people

A number of comments were also made which were specific to Biddulph, Cheadle and Leek.

In terms of the statutory consultees there was support for the aims and objectives from
WMRA, English Heritage, Highways Agency, Sustrans and Staffordshire Police. British
Waterways suggested the need to promote appropriate development in rural areas to bring
about rural regeneration. Sport England support objective 7 in principle but suggested that
some clarity was needed here and throughout document re-terminology to make it clear
where formal sport is being referred to. Staffordshire County Council suggest that
objective 9 would be benefit by addition of reference to geological/earth heritage.

Comments from Consultation and Stakeholder Events
The stakeholder workshops and meetings did not specifically address the aims and objectives
and there were no comments made regarding these from members of the public who
attended the consultation days.



Further Evidence and Other Issues
No further evidence or other issues have been identified relating to the aims and objectives.


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Officer Response
As with the vision, the level of support for the aims and objectives is encouraging and it is not
considered that significant changes are needed. The means by which the aims and
objectives will be achieved and delivered, how potential conflicts and how they relate to other
community priorities is considered to be clearly set out throughout the document for each
topic and in the appendices. Nonetheless it is accepted that the Core Strategy should clarify
in the Spatial Strategy that delivering them does require the support of other partners and
organisations. In terms of any inherent conflicts and contradictions, the accompanying
Sustainability Appraisal, which has informed the Core Strategy, does evaluate the
compatibility all of the policies with each other – it reveals on the whole that policies do
complement each other.

In terms of their content and coverage, the aims and objectives are necessarily general and
broad as they are related to the vision which itself is a general overview. As such it is
considered that they adequately cover, in broad terms, those issues which respondents have
raised and which reflect the priorities in the Council‟s Corporate Plan and its Sustainable
Community Strategy. Some of the suggestions made for change are also very specific and
localised and it would be inappropriate to include them in this section. The Spatial Strategy
and specific Area Strategies also address most of these issues in more detail and indicate
more clearly what the aims and objectives mean in practice. It is acknowledged however that
some further improvements to the aims and objectives could be made to better reflect the
vision in respect of employment diversity, rural needs, and countryside protection and these
are suggested below.



Suggested Changes
1. Amend aim SA3 (p32) to read "Encouraging a strong, prosperous and diverse economy"

2. Amend objective SO6 (p33) to read “To maintain and promote sustainable regenerated
   rural areas and communities with access to employment opportunities, housing and
   services for all. “

3. Amend objective SO9 to read “To protect and improve the character and distinctiveness
   of the countryside and the diversity of wildlife and habitats its landscape, biodiversity and
   geological resources.”




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Development Approach & Spatial Strategy
Introduction
The Development Approach and Spatial Strategy are key sections of the Core Strategy
document directing development to appropriate parts of the District and outlining the
measures and policies needed to deliver the aims and objectives. At issues and Options
stage 4 alternative options were presented for consultation - Town based development, Town
and larger village based development, Distributed development and Focused development.
Following consultation at the Issues and Options stage, the preferred development approach
was one which focused the bulk of development in the 3 towns and, to a lesser extent, the
larger villages in the rural areas but also allows for some development in other settlements to
meet local needs. Consultation on the Preferred Option specifically asked whether you
agreed with this approach (Q3).



Summary of Comments

Comments from Questionnaires and Correspondence
There were 184 responses made relating to the development approach. Of those who
responded the large majority supported the preferred development approach and only 32
(17%) specifically objected.

The main concerns and suggestions raised were:
Need to focus on brownfield sites rather than greenfield/green belt
Question the RSS assumption that 6,000 dwellings are needed
Should be more of a focus on employment development
Need for adequate provision in rural areas and smaller villages, particularly for affordable
      housing
Disagree with limiting growth in Biddulph to avoid undermining the regeneration of the
      conurbation
     Suggestion to insert paragraph which indicates that some already developed sites in
      the rural areas could, if redeveloped, contribute positively to the attainment of the
      Vision.
     Identifying the strategic importance of the Regional Investment Site in delivering the
      economic objectives at both a regional and local level.
     Stating a clearer objective for retail-led mixed-use regeneration, in recognition of the
      benefits such a use can deliver.
     Comment that paragraph 7.7 in respect of the Churnet Works and Cornhill should only
      indicate a mix of uses that could be acceptable, rather than indicate uses that will be
      included.

There was general support from the statutory consultees who responded. GOWM note the
development focus and comment that the Preferred Option includes a strong, clear Spatial
Strategy. The West Midlands Regional Assembly comment that notwithstanding a number
of issues relating largely to the level of detail appropriate within a Core Strategy and what
matters can be reasonably reserved for consideration in subsequent DPDs, the approach
being promoted within the Core Strategy is supportive of the broad objectives of the published
and emerging RSS.

Sport England comment on the need to take care not to put too much pressure on existing
green spaces/playing fields/sports facilities where development is proposed within existing
urban areas. Similarly the Parks and Countryside Manager suggests that rather than totally
develop and thereby cram the preferred locations in urban and town fringe sites as drafted,
additional, more expanded allocations are needed to allow appropriate interspersion of green
space amenities. The Environment Agency consider the preferred development approach
to be acceptable from a flood risk basis (but see comments on Churnet Works).


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Staffordshire County Council make a number of transport comments in relation to the
Spatial Strategy in respect of Cheadle (para. 7.11), to make reference to sustainable travel
measures alongside the need for related highway imrpovements, and Infrastructure Provision
(para. 7.31) to set out developers need to demonstrate principles of sustainable development
have been met. Also comment on the statement in para. 7.40 that the development of land
south of the town will require a new road link between the A53 and A520 that this may
sterilize the site and restrict development opportunities. In the absence of a supporting
evidence base suggest it would be better to say that the provision of a new A520-A53 road
link may be required.

English Heritage comment that the broad approach of the spatial strategy is explained well
and make a number of observations and suggestions in respect of the proposed master
planning for areas such as Leek and the major urban expansions of settlements which must
be informed by a robust consideration of the historic environment; Leek (paragraph 7.6) -
promoting and investing in the town‟s heritage should be encouraged; Churnet Valley
tourism corridor (paragraph 7.46) - refer also to heritage features.; Paragraph 7.50 – the
strategy should also aim to secure the sustainable management of other assets which
although not designated make an important contribution to the character, distinctiveness and
identity of the area.

Natural England suggest amending paragraph 7.31 to make reference to green
infrastructure also being necessary to support future development requirements. Comment
that developer contributions through section 106 agreement or the proposed Community
Infrastructure Levy (CIL) should be used to support the development and long-term
management of Green Infrastructure.

West Midlands RSL Planning Consortium support the Council's preferred development
approach, which seeks to focus growth at Leek, Biddulph, Cheadle and the larger villages of
the area. Comment that it is also important that new housing development is provided as far
as possible on brownfield and infill sites and that whilst concentrating development in the
larger settlements where economic growth can be expected to take place is considered to be
a sustainable approach, it is also important that sufficient housing is delivered in rural
locations where housing delivery is considerably lower and the problem of affordability is even
greater.

Comments from Consultation and Stakeholder Events
There were some concerns raised at the various Consultation and Stakeholder Events
regarding the need for additional housing and ensuring that the needs of the rural areas were
adequately addressed but generally the preferred development approach was supported.
Discussions with school pupils brought mixed views on the development approach with a
recognition of both the need to focus development in the towns but also a need to support the
villages.

North Staffordshire PCT consider that the approach of concentrating most future development
in towns was in principle aligned with PCTs future plans to deliver more services locally
focusing on the towns.



Further Evidence and Other Issues
In the light of the recent housing and economic downturn it is evident that there is a need to
build in some flexibility to recognise risks such as slump in housing market and increasing
unemployment.




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Officer Response
The high level of support for the preferred development approach is encouraging. In
response to those comments made, the Spatial Strategy does give clear preference for the
development of brownfield sites (para. 7.29) and has a strong focus on employment provision
(paras. 7.34 to 7.47). It also recognises the need to support the rural areas and smaller
villages as well as developed areas in the countryside (paras. 7.15 and 7.16). The housing
requirements in the Core Strategy reflect the RSS housing figures for the District which are
based on extensive evidence base which in any case will be subject to separate examination
at the RSS EIP – any changes as a result of this will need to be reflected in the Core
Strategy. Similarly the restraint on development in Biddulph is in accordance with the RSS
and also reflects the extensive green belt constraints around it. It is not considered
appropriate to state a clearer objective for retail-led mixed-use regeneration as this would
potentially undermine other planning objectives. However, it is acknowledged that there
should be reference made to the role of the Blythe Bridge RIS in supporting economic
objectives.

In response to the concern regarding para. 7.7 and its reference to including certain uses at
the Churnet Works and Cornhill, it is considered appropriate to suggest that these sites will
contain appropriate commercial elements including employment, retail, tourism and leisure as
these uses are considered essential to delivering the strategy for Leek.

With regard to the suggestions for changes made by English Heritage, these are in the main
considered acceptable as they are consistent with the aims and objectives of the Core
Strategy. It is also acknowledged, in response to the comments by Sport England, the Parks
and Countryside Manage and English Nature that further reference should be made to
protecting and enhancing the green infrastructure within existing urban areas as well as
creating new green spaces in new allocations. However, it is considered that the changes
suggested by Staffordshire County Council in respect of the A520-A53 link road would not be
appropriate as it would undermine the provision of this road which is a key strategic proposal
for the area, whilst the suggested reference to developers needing to demonstrate principles
of sustainable development have been met is considered more appropriate for the Transport
policy T1 which deals in more detail with this issue. The suggestion regarding an inclusion of
reference to sustainable travel for Cheadle is in accordance with the aims and objectives for
the Core Strategy and is therefore considered acceptable.



Suggested Changes
1. Add following new sentences to para. 7.1: “As well as providing certainty, it seeks to be
   flexible and resilient enough to enable the District to endure and respond to changes in
   the economy and housing markets during the lifespan of the Plan. Delivering the vision
   and the objectives will also require the support of other partners and organisations.”

2. Amend last sentence of para. 7.6 (Leek) to read: “Its role will therefore be reinforced by
   focusing development on expanding the range of housing and community facilities the
   town can offer; by creating further employment growth and increasing the diversity of
   employment opportunities to meet existing and future needs; by strengthening the role of
   Leek as a principal service and retailing centre for the District; and by promoting and
   investing in Leek‟s special character and heritage and strengthening its role as a visitor
   destination.”

3. Amend para. 7.11(Cheadle) to read: “The strategy is based on taking a comprehensive
   view of the expansion of the town and programming ahead for the phased release of land
   and related infrastructure improvements. This will take the form of a major urban
   expansion involving housing and employment development with related sustainable travel
   and highway improvements.”




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4. Amend first sentence of para. 7.31 (Infrastructure Provision) to read: ' A major factor in
   achieving the strategy is the delivery of the necessary social, physical and green
   infrastructure to support future development requirements, both within existing urban
   areas as well as in new areas of development”.

5. Add following additional sentence to para. 7.36: “The Strategy also recognises the
   strategic importance of the Blythe Bridge Regional Investment Site in delivering the
   economic objectives at both a regional and local level.”

6. Amend second sentence of para. 7.46 (Churnet Valley Tourism Corridor) to read: “This is
   an area with a number of well established tourist attractions and heritage and natural
   features where sensitive development can provide a strong focus for rural regeneration
   and a significant sub-regional asset.”

7. Add following new sentence to para. 7.50: “The strategy also aims to secure the
   sustainable management of other assets which although not designated make an
   important contribution to the character, distinctiveness and identity of the area.”




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SPATIAL STRATEGY POLICIES

SS1 - Development Principles
Introduction
Policy SS1 (Development Principles) underpins the whole Core Strategy setting out the
criteria that will be applied to all development proposals. Question 26 requested comments
on any of the policies in the Preferred Options Core Strategy.


Summary of Comments

Comments from Questionnaires and Correspondence
Only 5 responses were made relating to this policy, 3 of which were from statutory
consultees. 1 respondent considered the policy to be in line with the national and local
objectives. 1 respondent commented that Policy SS1 should also identify 'tourism' given its
current and future importance to the District over the plan period.

Sport England support the principles as long as it is clear that formal and informal facilities
are defined within 'leisure' and/or 'community facilities'. Staffordshire County Council
suggest that this policy should make specific reference to climate change mitigation and
adaptation and renewable energy in line with the key principles of PPS1. English Heritage
support the general thrust of this policy and the reference to the historic environment.

Comments from Consultation and Stakeholder Events

There were no comments made specifically in relation to this policy at the stakeholder
workshops and meetings and there were no comments made from members of the public
who attended the consultation days.


Further Evidence and Other Issues
No further evidence or other issues have been identified relating to this policy.


Officer Response
This is a key over-arching policy and it is therefore important that it reflects the vision, aims
and objectives of the Core Strategy and regional and national guidance and addresses all of
the principles of sustainable development. The suggestion for reference to tourism is in
keeping with the vision which sees tourism as a key element in the diversification of the
District‟s economy and its role within the sub-region and could usefully be extended to include
cultural facilities. It is also accepted that the policy should make clearer reference to climate
change mitigation and adaptation. The comment form Sport England regarding the definition
of terms is acknowledged and will be addressed within the Glossary.


Suggested Changes
1. Amend bullet point 2 of Policy SS1 (p53) to read: "quality local services, including
   provision for education, healthcare, leisure, and community, cultural and tourist facilities in
   response to anticipated population change and visitor numbers;"




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2. Amend bullet point 8 of Policy SS1 (p53) to read: “development which secures high
   quality, sustainable environments, and efficient and effective use of resources and
   contributes effectively to tackling climate change and reduced carbon emissions.”

3. Add to glossary following definition of „leisure‟ – comprises of formal and informal sport
   and recreational activities, both outdoor and indoor. It also includes passive as well as
   active pursuits including entertainment venues such as cinemas and town centre uses
   such as restaurants and nightclubs.

4. Add to glossary following definition of „community facilities‟ – facilities which are open to
   and provided for the health, welfare, social, educational, leisure and cultural needs of the
   community. Includes village/community halls, local convenience stores, post offices,
   schools, colleges, nurseries, places of worship, health services, libraries, public houses,
   theatres, arts centres.

5. Add to glossary following definition of „cultural facilities‟ - Any building or structure used
   for programs or activities involving the arts. Includes theatres, museums, art galleries as
   well as tourism related facilities such as heritage and interpretive centres.




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SS2 - Future Provision of Development
Introduction
Policy SS2 establishes the level of future provision of development for housing and
employment and the need for other services and facilities for the whole District. It reflects the
requirements of the emerging RSS Phase 2 Revision for the District as well as other evidence
of need by establishing targets of at least 6,000 dwellings by 2026 and 18 hectares of
employment land by 2021.



Summary of Comments

Comments from Questionnaires and Correspondence
There were 10 responses made relating to Policy SS2 of which 6 were made by statutory
consultees.

Comment was made from individuals that the Council is likely to have significant difficulties in
delivering the high proportion of affordable housing sites it aspires to unless there is
significant injection of financial support from the public sector. As such the setting of a
'minimum' affordable housing target is likely to present a difficult policy aim to achieve. It was
also commented that with the expected prolonged problems 6000 additional dwellings may
not be possible.

Government Office for the West Midlands note that in the event of the final revised RSS
requiring a higher housing figure for the District, then additional capacity could be delivered
without undermining the preferred development approach and the principles which underpin
the strategy. The West Midlands Regional Assembly (WMRA) considered however that
consideration should be given to a sequential approach to accommodate any additional
growth requirements above the levels currently identified as this may be more sustainable.

Concern was also expressed by the WMRA that the policy appears to identify the District
housing allocation as a minimum requirement. This is contrary to the approach currently
adopted in the RSS and should be amended by deleting reference to the phrase „at least‟.
The City of Stoke-on-Trent also object to the provision of at least 6,000 additional dwellings
to be completed within Staffordshire Moorlands and commented that the amount of housing
proposed within the Core Strategy should be a target and not a minimum requirement as this
gives rise to the potential for an infinite amount of dwellings over this figure to be developed
which will prejudice the strategy set out within the Newcastle-under-Lyme and Stoke-on-Trent
Joint Core Spatial Strategy and emerging Regional Spatial Strategy Phase II Revision.

The City of Stoke-on-Trent also consider that the phasing periods set out within policy SS2
be reconsidered to align more fully with the overall spatial strategy to support the regeneration
and urban renaissance of the North Staffordshire conurbation through controlled
development. Recommend further consideration of „backloading‟ more of the development
requirement to later plan periods to firstly reflect the current market conditions and secondly
better align the policy with the overall strategy to support regeneration within the conurbation.

Renew North Staffordshire comment that the amount of housing proposed should be a
target not a minimum requirement. A minimum figure allows the potential for an increase in
an unspecified amount which could undermine the Housing Market Renewal programme and
the regeneration of the MUA. Concerned also that the proposed phasing appears to spread
housing growth evenly over the lifetime of the plan. Feel the phasing should be revised to
focus more development on the latter stages of the plan period to better reflect the NSRPs
priority to support regeneration and urban renaissance within the conurbation.

Sport England support the final paragraph of policy SS2, but suggest that it refers to 'open
space, sport and recreation' as used in PPG17.

                                                      14
Draft Preferred Options Core Strategy Consultation Responses Report               February 2009




West Midlands RSL Planning Consortium comment that if housing numbers provided in
the RSS indicate that further land is required, greenfield land that is located adjacent to
existing sustainable settlements should be developed first. The approach to the use of
greenfield sites for affordable housing should be 'dispersed release' of sites according to
where the need is greatest. This should in the first instance be small extensions to the
existing settlements and taking into consideration the social dimensions of the area.

Comments from Consultation and Stakeholder Events

The stakeholder workshops and meetings did not specifically address the total provision for
the District and there were no comments made regarding policy SS2 from members of the
public who attended the consultation days.

At meeting with North Staffordshire Bodies concern was expressed regarding the over the
„minimum‟ of 6,000 dwellings (particularly by Stoke). Had accepted that 6,000 was now the
target figure for Staffordshire Moorlands, but would not want to see any further housing over
and above this because of impact on the N Staffs MUA. It was also considered that need to
look again at the phasing of development in light of recent housing market – unlikely to be
able to deliver more in early phases and could also undermine regeneration of MUA. overall
housing and employment land needs which have been reflected in the specific comments
made above.

Query raised at Werrington Neighbourhood Forum questioning why still have to meet RSS
targets given current housing recession and number of empty houses.



Further Evidence and Other Issues
Early in 2008 the Government Office for the West Midlands commissioned consultants to
develop options for the RSS for delivering higher housing numbers across the West Midlands.
The study was undertaken by Nathaniel Lichfield & Partners and published in October and
considered a range of options. The final report presents three potential growth scenarios
proposing between 417,100 and 445,600 housing units up to 2026. These represent housing
allocations which build on and are between 51,500 and 80,000 higher than the draft RSS
Phase 2 Revision. However, the Study does not recommend any increase in provision for
Staffordshire Moorlands.
                                                     th
Housing Land Supply calculations for 30 September 2008 indicate a significant fall in
development rates from 261 (for year 2007/8) to 73 (for a half year period during year
2008/9). This represents a 56% drop in the rate of development.

The Employment Land Study Update (September 2008) updates the previous Staffordshire
Moorlands Employment Land Study (ELS) which was undertaken in 2006. The ELS update
provides advice in respect of the demand and supply for employment land and floorspace for
the period 2008 to 2026. The 2026 end-date of the study is consistent with those of the
Regional Spatial Strategy for the West Midlands and the Council‟s emerging Core Strategy.
Key elements of the study have included updating of the economic forecasting work relating
to future employment demand in the District to include current market conditions and the
revised end-date of the study. The employment supply side of the study has also been
revised. This has included updating the baseline information relating to certain sites surveyed
in 2006 which have experienced significant change in the interim period, and the addition of
several new sites which were previously not surveyed. In total, there are a total of 44
employment sites in the District. Of the existing sites, vacancy level in the District remains
low at around 2.4%, although a lack of newer premises including those which could attract
higher value industries, is a common theme of the District. A shortage of suitable small scale
premises under 100 square metres is also identified. The ELS update concludes demand
exists for an additional 22.2 hectares of employment land in the District to meet demand until
2026. This represents additional need over and above the existing quantum of employment


                                                      15
Draft Preferred Options Core Strategy Consultation Responses Report                February 2009



land in the District. Based on analysis of the site supply findings, there is potential to
accommodate this need within existing parcels of vacant land at current employment sites, or
within redevelopment opportunity areas at existing sites. The findings suggest that additional
Greenfield sites are not required to meet future demand for B-class employment land.


Officer Response
Policy SS2 seeks to ensure that sufficient provision of housing is delivered to meet the
requirements of the RSS Phase 2 Review. This requirement is itself still to be subject to
examination and could be varied. However, it is acknowledged that in the light of the
Nathanial Lichfield & Partners Report on options for further housing growth which does not
recommend any further housing within the Staffordshire Moorlands area, the 6,000 dwelling
requirement is unlikely to increase and there is no evidence to suggest that an increase is
needed. The 6,000 dwellings should therefore be viewed as a target and the deletion of the
words „at least‟ is accepted as this does wrongly give the impression that more housing is
being sought. However, this should be counter-balanced by suitable wording in the Reasons
and Justification explaining that this target should not be seen as an absolute ceiling as there
needs to be flexibility to ensure there is a continuous 5 year supply of deliverable land in
accordance with PPS3, provided it does not undermine the regeneration of the MUAs.

It is also acknowledged that the recent downturn in the housing market and the need to
support the regeneration of the MUA would justify adjusting the phasing to lower development
rates up to 2016 and increased development rates post-2016. Indeed recent evidence
indicates that the development rates currently proposed in the RSS are unlikely to be
achieved in the short to medium term.

Also, in the light of the current uncertainty over the RSS housing requirements it is considered
that the Core Strategy still needs to indicate the extent and means by which any increase
could potentially be accommodated, but based more on a sequential approach favouring
areas which can absorb growth or where it can offer additional support to justify enhanced
infrastructure and service provision.

In terms of employment land, the latest findings of the Employment Land Study indicate that
around 24 hectares of employment land is required to meet demand by 2026. This is
equivalent pro-rata to the emerging RSS requirement of 18 hectares for the period 2006 –
2021. The RSS does recognise that this requirement is indicative only and should be subject
to review through the Core Strategy. It is therefore considered appropriate to incorporate the
latest Employment Land Study figure into Policy SS2. However, it should be made clear in
the supporting text that this forecast is aspirational and makes various assumptions not only
of the district‟s economic development but also continued national economic growth. If
growth is slower the forecasts may need to be further revised to reflect a more realistic
demand for employment land.

With regard to the affordable housing requirement, this would be met from all sources of
affordable housing provision including RSL developments and other public funded schemes
as well as affordable housing delivered through private sector developments. It is therefore
considered a realistic figure and one which should be regarded as a minimum rather than a
target in view of the high level of need in the District. The policy would however benefit from
a minor amendment to clarify that the affordable housing would be from all sources.




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Draft Preferred Options Core Strategy Consultation Responses Report                February 2009




Suggested Changes
                    st
    1. Amend 1 paragraph of Policy SS2 (p54) to read: “Provision will be made for at
       least 6,000 additional dwellings (net of demolitions) to be completed in
       Staffordshire Moorlands (excluding the Peak Park) during the period 2006 to
       2026.”

    2. Amend phasing of housing development in Policy SS2 (page 54) as follows:

             Period                        Annual          Development   Net Dwelling
                                           Rate                          Completions
             2006 – 2011                   292 260                       1460 1300
             2011 – 2016                   320 300                       1600 1500
             2016 – 2021                   300 320                       1500 1600
             2021 – 2026                   288 320                       1440 1600
                     nd
    3. Amend 2 paragraph of Policy SS2 (page 54) to read: “A minimum of 1700
       affordable housing units will be provided from all sources between 2006 and
       2026 as part of the overall housing provision for the District in order to meet the
       proven needs of those who are not able to obtain a home on the open market.”
                    rd
    4. Amend 3 paragraph of Policy SS2 (page 54) to read: “Provision will be made for
       at least 18 24 hectares of additional employment land in Staffordshire
       Moorlands (excluding the Peak Park) during the period 2006 – 2021 2026.
       Sufficient deliverable land will be identified to provide at least 6 hectares of
       employment land at all times.”

    5. Add following additional text to para. 8.1.12 of Policy SS2: “The requirement for 6,000
       dwellings is a target and should not be seen as an absolute ceiling as there needs to
       be flexibility to ensure there is a continuous 5 year supply of deliverable land at all
       times in accordance with PPS3. The Council will however monitor and manage the
       amount of development over the plan period to ensure that the 6,000 dwellings target
       is not excessively exceeded to prevent undermining the North Staffordshire MUA.”

    6. Amend para. 8.1.14 (p55) to read: “Policy CF4 of Preferred Option RSS Phase 2
       Revision requires an increasing rate of development to 2016 and a lower rate
       thereafter. However, in light of the recent downturn in the housing market and the
       need to support the regeneration of the MUA it is considered more realistic and
       appropriate to propose lower levels of development in the first half of the plan period
       to 2016 and higher levels post-2016. The above table reflects this with increasing
       levels of development to 2016. Post-2016 a decreasing rate of development is
       proposed to avoid over-provision. In order to manage the rate of development the
       requirement is divided over 4 phases of the plan period - phase 1 (2006-2011)
       includes actual completions for 2006/7 and 2007/8 of 260 and 261 dwellings
       respectively.

    7. Amend para. 8.1.15 (p55) to read: “The provision of employment land is similarly
       based on the emerging RSS requirement of 18 hectares for the District which is
       consistent with the findings of the Council‟s Employment Land Study (2006) based on
       the latest Employment Land Study Update which establishes demand for 24 hectares
       of employment land across the District to 2026.          The rate This amount of
       development is based on a requirement to maintain a 5 year supply of deliverable of
       employment land of 6 hectares in accordance with policy PA6A of the emerging RSS
       Revision. This will be achieved through the phased release of allocated sites and the
       granting of planning permissions on unidentified sites. However, this provision is for
       the period to 2021 only and it will therefore be necessary to assess future needs
       through a review of the Employment Land Study prior to 2021 to ascertain whether
       this rate should continue beyond 2021 or be varied. This forecast is aspirational and


                                                      17
Draft Preferred Options Core Strategy Consultation Responses Report               February 2009



         makes various assumptions not only of the district‟s economic development but also
         continued national economic growth. If growth is slower the forecasts may need to be
         further revised to reflect a more realistic demand for employment land.

    8. Amend para. 8.1.17 (p56) to read: “As the housing and employment land
       requirements are derived from the Phase 2 Revision to the RSS which is currently still
       to be subject to examination and further work to consider options for delivering more
       housing, it is possible that the final RSS requirements may change from that in the
       Preferred Option. In such circumstances the Core Strategy will need to reflect those
       changes. From the evidence available from the SHLAAs and Development Capacity
       Study it is considered that up to an additional 1,000 dwellings could be delivered over
       the plan period without undermining the preferred development approach and the
       principles which underpin the Spatial Strategy. By using proportional distributions for
       housing and employment to determine net housing requirements based on a robust
       spatial strategy it will be possible to accommodate such a scale of increase pro-rata
       across the District. This will be achieved through distribution based on a sequential
       approach favouring areas which can absorb growth or where it can offer additional
       support to justify enhanced infrastructure and service provision having regard also to
       policies SS3 and SS4. However, in the event of any significant changes to the overall
       housing or employment requirement for the District an early review of the Core
       Strategy may be necessary.”

    9. Amend housing trajectory in Appendix F to reflect changes in phasing.




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Draft Preferred Options Core Strategy Consultation Responses Report                  February 2009




SS3, SS5 & SS6 - Distribution of Development
Introduction
The distribution of development is set out in 3 related policies. Policy SS3 sets out the
distribution of housing and employment development between the 3 towns and rural areas in
order to guide future levels of provision in accordance with the spatial strategy. Policy SS5
goes on to set precise targets for housing (including affordable housing), employment land
and retail provision for each town, whilst policy SS6 sets similar targets for the rural areas.
Questions 5, 11, 16 and 20 all asked whether the proposed development levels where
appropriate for Leek, Biddulph, Cheadle and the Rural Areas respectively.



Summary of Comments

Comments from Questionnaires and Correspondence

Leek

There were 114 responses made relating to Q5 regarding the proposed development levels
for Leek. Of these, 54 (47%) were in general agreement that the levels were appropriate,
whilst 21 (18%) did not consider them appropriate, being too high or unjustified. The
remainder were either undecided or raised concerns regarding how it could be
accommodated. Other concerns expressed were the loss of green space and green belt, the
need to utilise brownfield sites or mill buildings, need to retain the character of Leek, need for
adequate support services and infrastructure. Only a few considered that Leek had the
potential for more growth then is proposed. Only 10 made comment on the retail
requirements, some in support and others considering the amount proposed to be too much.
1 respondent considered that there should be no more 'bulky goods retail provision' in Leek.

Staffordshire Police considered that support services infrastructure should be similarly
developed to support such expansions e.g. transport, social care etc. Sport England
welcomed the intention to improve community facilities, leisure, open space and recreational
facilities. The West Midlands Regional Assembly comment that further justification be
included within the Core Strategy to support the scale of additional comparison retail
floorspace for Leek - there is a potential conformity issue in terms of policy PA12B of the
RSS. The City of Stoke-on-Trent express concern that the amount of retail development
planned for Leek does not appear to be fully justified within the document. It seems out of
step with the rest of the strategy and has the potential to be contrary to Regional Spatial
Strategy revision, policy PA12B of which states that it is not expected that requirements for
additional comparison retail floorspace in non-strategic centres will exceed 10,000m2 gross.
Any proposals for an increase of 10,000m2 gross comparision retail floorspace or more in a
non-strategic centre should be accompanied by evidence to demonstrate there is a clear local
need and the proposal would not have an adverse impact upon or put at risk the delivery of
development within a strategic centre in accordance with policy PA12A. Also concerned that
bulky goods retailing is undefined within the document - PPS6 does not recognise this as
being separate to non-food retailing. All retailing development is subject to the tests set out in
PPS6 which is predicated on a town centres first approach and sequential assessment.
Consider further justification is required and consideration made to a phased approach over
the whole plan period to ensure it is in step with the rest of the strategy and the amount will
not impact upon existing nearby centres including those within Stoke-on-Trent.

Biddulph

There were 115 responses made relating to Q11 regarding the proposed development levels
for Biddulph. Of these, 48 (41%) were in general agreement that the levels were appropriate,
whilst 32 (28%) did not consider them appropriate, being too high or unjustified, mainly in
relation to housing. The remainder were either undecided or raised concerns regarding how it


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Draft Preferred Options Core Strategy Consultation Responses Report                 February 2009



could be accommodated and over-development of the town. Other comments made were
that there should be no development in green belt areas and on green spaces, there is a lack
of services and facilities (such as park) in Biddulph and a need to provide more green areas,
concern that development would be too large, need to encourage more visitors into the town.
Only a few considered that Biddulph had the potential for more growth then is proposed.

United Utilities commented that it would not be appropriate for them to influence any
development aspirations. However, they do have sewer capacity issues in several locations in
Biddulph and it is important that there is good liaison with them to ensure that clean surface
water is excluded from the public sewer where possible.

Cheadle

There were 69 responses made relating to Q16 regarding the proposed development levels
for Cheadle. Of these, 35 (51%) were in general agreement that the levels were appropriate,
whilst only 11 (16%) considered the amount of development proposed too high or
unnecessary. A further 4 considered that more development was needed and 7 considered
that there should be more provision made for employment development. The remainder were
either undecided or raised concerns regarding how it could be accommodated, detrimental
impact on the character of areas or neighbouring villages, the need for flexibility to respond to
changes in the housing market, and highway and accessibility constraints.

Dilhorne Parish Council commented that the proposed number of additional dwellings in
Cheadle will overburden the existing road system that is already problematic. Expressed
concern that the reference in the draft to "reducing levels of through traffic in the town centre
and along the A521 and A522" is vague - can see no alternative route unless a bypass is built
around Cheadle. The Environment Agency commented that there should be an adequate
sustainable drainage solution available and provided that development is undertaken in
accordance with PPS 25 and all flood plains are kept free from incompatible development
then they have no further comments to make.

Rural Areas

There were 130 responses made relating to Q22 regarding the proposed development levels
for the Rural Areas. Of these, 62 (48%) were in general agreement that the levels were
appropriate, whilst only 18 (14%) considered the amount of development proposed too high
on the grounds that it is unnecessary, would spoil rural areas or inadequate services and
infrastructure to support this much development. A further 7 however considered that more
development was needed in the rural areas, particularly to support smaller villages. The
remainder were either undecided or had some concerns regarding the scale and nature of the
development. The main concerns raised generally were the need for more affordable housing
and housing for younger people and local needs, ensuring that the character of villages is
maintained, taking too much development away from the towns and the need to support the
smaller villages.

The West Midlands Regional Assembly comment that additional justification in support of
the higher proportion of employment land allocations within the rural areas would be
welcomed, in particular which objectives are being supported by this approach. Kingsley
Parish Council does not agree that the proposed development levels are appropriate.
Cotton Parish Council and Caverswall Parish Council also do not agree that the proposed
development levels are appropriate. Rushton Parish Council comment that they support
small developments only. as there is little local employment in Rushton and no facilities.
Forsbrook Parish Council comment that development in the green belt should be avoided
other than in extreme circumstances. The consequences of over development in rural
villages should be scrutinised in detail as in many cases lack infrastructure. Stoke-on-Trent
NHS have considered proposals in respect of wards of Bagnall and Stanley, Brown Edge,
Endon and Caverswall and do not feel that they represent a significant impact on health
services. Staffordshire Police comment that the value of these areas and the role of
supporting communities and protecting green space is significant. United Utilities comment
in respect of the Biddulph area that it would not be appropriate for them to influence any


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Draft Preferred Options Core Strategy Consultation Responses Report                   February 2009



development aspirations. However, there are sewer capacity issues in several locations and it
is important that there is good liaison to ensure that clean surface water is excluded from the
public sewer where possible. The West Midlands RSL Planning Consortium comment that
it is important that sufficient housing is delivered in rural locations where housing delivery is
considerably lower and the problem of affordability is even greater. It should be explicitly
recognised that if there is a demonstrated need for affordable housing in a particular village
then affordable housing should be provided within that village to meet that need. If necessary,
the provision of affordable homes should be provided via rural exception sites.

Other Comments

Only 4 other comments were made specifically in respect of Policy SS3 of which 3 were
generally in support. 1 considered that the policy needed to be more flexible especially as it
seems likely that housing numbers will be increased in which case Leek appears most suited
to accommodating an increased level of development. There were also only 2 comments
made in respect of Policy SS5 and 1 in respect of Policy SS6 all of which were generally in
support.

Comments from Consultation and Stakeholder Events
At the Parish Council Workshops there were no strong opinions expressed that proposed
development in the rural areas is too much or too little. It was generally acknowledged that
800 dwellings across the rural area is not excessive but there was general concern over
where any of this could be accommodated. Some considered that 5.4 hectares of
employment land is not enough in the rural areas. There was also some concern over
existing infrastructure constraints and how the downturn in the economic climate may affect
building rates and whether the amount of development reflects demand for housing in the
rural area. There were also no strong concerns raised regarding the scale of provision at any
of the Town or Parish Council meetings attended although the need for a bypass for
Cheadle to facilitate further development was raised at the Cheadle Town Council meeting.

At meeting with North Staffordshire Bodies some concern was expressed regarding the
retail capacity figures for Leek as to whether this was justified – could potentially conflict with
emerging RSS Review policy re-retail development in non-strategic centres. Considered that
the policy needs strengthening in terms of consideration of impact and need to be more
explicit. Also that should not differentiate between bulky goods and comparison goods
retailing. It was also questioned where the evidence is regarding demand/need for different
employment types and how it relates to the strategy.



Further Evidence and Other Issues
                                                   th
Housing Land Supply calculations for 30 September 2008 show a marginal decrease in
                                          st
completions and commitments since 31 March resulting in an overall increase in the net
requirement for the District from 4074 to 4088 dwellings. At a local level the changes are
more variable with a slight fall in net housing requirement in the rural area from 802 to 799
dwellings and in Cheadle from 1335 to 1327 dwellings, a fall of only 1 dwelling in Biddulph
and an increase in net housing requirement in Leek (as a result of permissions expiring) from
1019 to 1045 dwellings.

The Employment Land Study Update (September 2008) shows that a total floorspace
requirement of the equivalent of approximately 23.8 ha of employment land could be needed
in Staffordshire Moorlands by 2026. In terms of meeting local demand, this would mean
approx. 6.5 hectares in Leek, 2.3 hectares in Cheadle and 1.7 hectares in Biddulph. This
would leave approximately 13.3 hectares in the rural areas. Leek is expected to have the
most requirements in terms of B1a & B1b employment land. These sub-divisional figures are
indicative only however and are much less accurate than the District-wide figure.




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Draft Preferred Options Core Strategy Consultation Responses Report               February 2009



A recent update to the 2006 Retail Study has also been undertaken to assess the potential
impact of new foodstore development in Leek and Cheadle on neighbouring centres and to
respond to and address each of the policy „tests‟ set out within emerging draft RSS retail
policy PA12B in respect of comparison goods retailing for Leek. The assessment concludes
                                                                 2
that the overall impact of a new foodstore development of 3,000m convenience for Leek and
         2
2,500m convenience for Cheadle on competing centres would be minor in quantitative terms.
However, the impacts of the proposed foodstore allocation within the towns will only be
acceptable in PPS6 terms where new development is allocated on a sequentially preferable
site in order to maximise the wider economic and regenerative benefits to both town centres.

In terms of the proposed comparison goods floorspace it concludes that the proposed
allocation of new comparison retail floorspace within Leek is compliant with emerging draft
RSS policy PA12B and will not materially impact on the delivery of the major redevelopment
scheme in Hanley (Stoke) City Centre or any other centre within the sub-regional retail
hierarchy. However, it advises a phased approach to future provision with a lower initial
                                2
requirement of around 12,000 m (gross) for all comparison goods retailing (including bulky
                              2
goods) rather than the 16,400m initially proposed.



Officer Response
The distribution of development reflects the preferred development approach which seeks to
focus development in the towns, particularly Leek and Cheadle, and, to a lesser extent, the
larger villages in the rural areas as well as allowing for some development in smaller villages
to help meet local needs. The actual apportionment of housing between areas is based not
just on the preferred development approach but also on the findings of the Development
Capacity Study which support higher levels of development in the towns and the RSS which
requires restraint in areas nearer to the conurbation such as Biddulph. The apportionment of
the employment requirement is based on achieving a balanced provision to support future
workforce needs.

Whilst it is acknowledged that there are some concerns regarding the required provision,
particularly with regard to the housing requirements for Biddulph, the responses in the main
support this distribution and there is no further evidence to suggest a different distribution,
particularly in respect of housing. Furthermore as the overall housing requirement for the
District is set by the emerging RSS target of 6,000 dwellings, the actual targets for each town
and the rural areas need to be consistent with this - any reduction or increase in the targets
for one area would require a comparative change elsewhere. Unusually the overall net
requirement to be found on new sites has increased marginally to 4088 dwellings – this is
indicative of the significant downturn in the housing market with fewer permissions being
granted and an increase in permissions not being implemented and expiring. At a local level
there have also been changes in the net requirements which will need to be reflected in the
Core Strategy. The most significant change is in the rural areas where the net requirement of
housing to be found on new sites is now only 785 dwellings. Given the large number of
villages in the rural areas and the fact that some of this requirement will need to be provided
in the smaller villages, it is clear that there is unlikely to be any significant level of new
development in any of the larger villages. With regard to the smaller villages, the strategy
does seek to provide support to them and clearly expects them to accommodate some
provision in order to meet local needs.

The need for flexibility in Policy SS3 to reflect any changes in RSS housing figures is
addressed within the Reasons and Justification to Policy SS2 (para. 8.1.17) which
acknowledges the need for flexibility and makes specific reference to an additional 1,000
dwellings which could be delivered over the plan period if required as a result of changes in
the RSS and that any significant changes in the RSS requirements may necessitate an early
review of the Core Strategy.

In terms of employment land distribution, the Core Strategy and Policies SS5 and SS6 will
need to be amended to reflect the latest Employment Land Supply requirements to 2026.
Currently the requirements for employment land in the Core Strategy relate to the period to

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Draft Preferred Options Core Strategy Consultation Responses Report                    February 2009



2021 only – this should be extended to 2026 to provide an additional 6 hectares which would
increase requirements proportionately for the towns and the rural areas. In terms of their
distribution, it is considered that this should remain as in Policy SS3 as it accurately reflects
workforce and unemployment distribution and therefore local needs. In response to the
concerns regarding the amount of provision, this is justified by the Employment Land Study
update both for the District and broadly for the sub-divisions and also accords with the
requirements in the emerging RSS.

With regard to the concerns regarding comparison goods retail provision in Leek, the latest
evidence undertaken by consultants for the Retail Study confirms that there is an overriding
quantitative and qualitative need for new comparison retail provision within Leek in order to
address the present deficiencies in the town‟s retail offer, including further provision for bulky
goods retailing. It does however recommend an initial lower comparison goods requirement
                                         2
(including bulky goods) of 12,000m which it clearly concludes would not impact on
neighbouring centres. It is suggested therefore that this lower figure be used. However, in
recognition of the fact that retail requirements need to be reviewed every 5 years it is also
suggested that these should be seen as amounts to be planned for and not maximum figures.
Whilst it is acknowledged that PPS6 does not separate bulky goods retailing from other
comparison goods retailing, it is nonetheless still considered appropriate to indicate how
much of this would be for bulky goods in accordance with the findings of the Retail Study. It is
also suggested that all figures should be rounded up as an approximation and that an
additional paragraph is inserted into the Reasons and Justification to clarify that these are
indicative figures only.


Suggested Changes
Policy SS3 - No Changes

Policy SS5 (Towns)

1. Amend employment land provision in table in Policy SS5 (p61) as follows:

Town            Housing (net         Affordable        Employment          Retail      (additional
                dwelling             housing           (additional         convenience         and
                completions          target            employment land     comparison       goods
                2006 -2026)                            2006 – 2021 2026)   floorspace). aximum
                                                                           provision up to 2016.
                                                                                  2        2
Leek            1800                 450               5.4 7.2 hectares    2,975m 3,000m
                                                                            convenience
                                                                                   2
                                                                           9,204 m comparison
                                                                                   2
                                                                           7,186 m bulky goods
                                                                                     2
                                                                           12,000 m comparison
                                                                           (of which 50% is for
                                                                           bulky goods retailing)
Biddulph        1200                 400               3.6 4.8 hectares    AAP Proposals

                                                                                  2        2
Cheadle         1500                 550               3.6 4.8 hectares    2,564m 2,500m
                                                                           convenience
                                                                                   2
                                                                           2,945 m comparison
                                                                                   2
                                                                           2,882 m bulky goods
                                                                                   2
                                                                           6,000 m comparison
                                                                           (of which 50% is for
                                                                           bulky goods retailing)



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Draft Preferred Options Core Strategy Consultation Responses Report                February 2009



2. Amend paragraph 8.1.37 of Reasons and Justification to Policy SS5 to read: “The
   housing and employment requirements are based on the distributions set out in policy
   SS3 which reflect the spatial strategy and local needs. The housing requirements will be
   met from completions since 2006, current commitments and new allocations. The
   employment requirements are capable of being met from existing commitments or
   extensions to existing employment areas. The retail requirements are based on the
   capacity figures identified in the Retail Study (2006 as updated in 2008) and are indicative
   only of the amount of floorspace currently required in order to address identified
   quantitative and qualitative deficiencies in retail floorspace in Leek and Cheadle. They will
   be met through new allocations informed by Masterplans. The Retail Study also
   concludes that the proposed allocation of new comparison retail floorspace within Leek is
   compliant with emerging draft RSS policy PA12B and will not materially impact on the
   delivery of the major redevelopment scheme in Hanley (Stoke) City Centre or any other
   centre within the sub-regional retail hierarchy. The figures for housing and employment
   and retail are targets for the appropriate whole plan period and will be monitored through
   the Annual Monitoring Report and monitoring schedules to assess performance and the
   need for management measures. It will be necessary to reassess the employment and
   retail requirements prior to the end of their respective plan period through a review of the
   Employment Land Study and the Retail Study to determine needs beyond their respective
   plan periods. The affordable housing targets are based on estimates of what could
   realistically be delivered on allocated sites and from other sources.

Policy SS6 (Rural Areas)
               nd
1. Amend 2 paragraph of Policy SS6 (page 74) to read: “In total these will provide for
   around 1500 new dwellings between 2006 and 2026 including 300 affordable
   dwellings and 5.4 7.2 hectares of employment land between 2006 and 2021 2026 in
   accordance with the Area Strategies set out in policies SS6a – SS6c below.”

2. Add following sentence to paragraph 8.1.69 of Reasons and Justification to Policy SS6:
   “The employment land is necessary to provide sufficient local employment opportunities
   in the villages and also to enhance and diversify employment provision at existing
   established employment sites in the rural areas in support of objective SO3.




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SS4 - Managing Release of Housing
Introduction
Policy SS4 sets out how the Council will manage the rate of housing development in order to
ensure there is a continuous supply of housing land over the plan period and to ensure that
wider strategic objectives are not undermined.



Summary of Comments

Comments from Questionnaires and Correspondence
There were 16 responses made relating to Policy SS4. The following issues were raised from
those who responded:
     An assumed contribution from windfall sites 25% is significant, this would need to be
      demonstrated as justified in any assessment of land supply.
     The preference for previously developed land over edge of urban area sites is
      understood, but this should not stand in the way of the release of suitable sites
      necessary to maintain the delivery of housing at appropriate rates.
     It is considered that windfalls should not be used as a basis to prevent allocated
      previously developed sites coming forward by, for example, re-phasing them if there
      are more windfalls than anticipated.
     In terms of restricting development in those parts of the District nearest to the Stoke
      conurbation up to 2016, it is important that the LDF does not undermine the needs of
      Biddulph in the course of trying to protect the regeneration of the major urban area.
     This policy is very unclear and offers no certainty to landowners or developers as to
      when their sites may be released and accordingly the policy is considered unsound as
      it fails to confirm delivery. It also leaves the delivery of housing within the District down
      to the uncertainties of the delivery of housing within the North Staffs conurbation.
     Case for greenfield sites within the development boundaries of towns and villages
      should be examined more closely as these can, on occasions, be more sustainable
      options than some brownfield land.
     Emphasis should be put on developing brownfield sites

The only response from statutory consultees was from West Midlands Regional Assembly
who comment that support for the renaissance of the Major Urban Areas is a fundamental
objective of the published and emerging RSS. It is therefore requested that additional detail
be provided on the operation of the delivery of development within those parts of the district
nearest to the North Staffordshire conurbation. Specifically it is suggested that the area over
which the policy of restraint will operate should be identified upon the key diagram, this could
potentially coincide with the extent of the Green Belt given the alignment of objectives in
supporting regeneration of the conurbation. Secondly an additional category could be
included within the settlement hierarchy which identifies those settlements which are within
the area of restraint and indicating the nature of the restraints which will operate within these
areas. Finally a clearer indication of the levels of development which would be considered
acceptable in meeting the objective of supporting rather than undermining the renaissance of
the MUA would be welcomed. They also comment that a clearer indication would be
welcome on the operation of the windfall policy and in particular how this will relate to the
management of future site releases to ensure that there is no risk of a significant levels of
over-provision of housing within the District. Related to the first point above it is suggested
that a more restrictive approach to the release of windfall site within the area of restraint
should be adopted.

Comments from Consultation and Stakeholder Events




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The stakeholder workshops and meetings did not specifically address this policy and there
were no comments made regarding this policy from members of the public who attended the
consultation days.



Further Evidence and Other Issues
                                                     th
Housing Land Supply calculations for 30 September 2008 indicate a significant fall in
development rates from 261 (for year 2007/8) to 73 (for a half year period during year
2008/9). This represents a 56% drop in the rate of development. The net requirement to be
identified on new sites has also increased from 4074 to 4088 dwellings as a result of existing
permissions expiring and less new permissions. This also reflects the recent significant
downturn in the housing market.



Officer Response
Managing the delivery of housing is perhaps one of the most challenging planning issues
facing the Council, particularly in the current period of housing and financial market
uncertainty. Policy SS4 seeks only to outline the mechanisms which will be used but it is not
intended to set out in detail out these will operate, nor is it considered appropriate to do so
given the current uncertainties with the emerging RSS and the housing market. How these
mechanisms will operate will be addressed through the Housing Delivery SPD which is being
prepared in tandem with the Core Strategy. This will be able to provide more detail in the
form of a Housing Implementation Strategy on how delivery will be ensured and on how the
windfall allowance will operate and will be capable of being reviewed more rapidly to
accommodate changes in guidance and the housing market. Reference to this is made in
para. 8.1.26 but this needs also to be further clarified within the policy itself.

The Housing Delivery SPD is also considered to be the appropriate document for setting out
how new housebuilding will be restricted near to the conurbation. It is, however, accepted
that the policy itself needs to be clearer in terms of identifying the extent of the area within
which the restriction would operate. Given that the Green Belt was established partly in order
to check the unrestricted sprawl of large built-up areas it would be logical and consistent to
apply the restriction to this part of the District including any settlements inset within it. A list of
the main settlements affected should be included within the Reasons and Justification to the
policy. It is also acknowledged that any such restraint should be balanced with the need to
improve prospects in other local regeneration areas identified in the RSS such as Biddulph.
Reference should also be made to this within the Policy and the Reasons and Justification.

The assumed contribution from windfall sites of up to 25% in urban areas and 30% in rural
areas is a maximum level of contribution and is justified by evidence from past levels of
contribution from windfall sites which have recently been much higher. This level of windfall
development is considered appropriate and necessary to ensure that a mix of housing
opportunities are provided and that required development rates are achieved. The means by
which this will be monitored and managed through the Housing Delivery SPD should also be
clarified.

In response to those comments regarding the issue of brownfield versus greenfield
development, it is pointed out that the policy does give clear preference to developing
previously developed (brownfield) sites before greenfield in accordance with PPS3, but it also
recognises within this policy and policy SD1 that not all brownfield sites are suitable and that
greenfield sites may come forward in certain circumstances. It is suggested that a cross-
reference to Policy SD1 would be helpful.

In respect of the comment regarding the need to give clarity to developers as to when sites
would come forward, it is considered more appropriate for this to be addressed in the Site
Allocations DPD which will identify specific sites for development and their phasing. The Core
Strategy does however identify the order of priority for the broad locations within the Area


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Strategies and assumptions regarding an anticipated contribution from future allocations have
been incorporated into the housing trajectory in Appendix F.

It is also considered that it would be more appropriate to move figure 7 (Net Housing
Requirements) from page 62 to page 58 in the Reasons and Justification to Policy SS4 and to
update it to reflect the latest housing land supply situation.



Suggested Changes
                st
1. Amend 1 paragraph of Policy SS4 (p57) to read: “The release of land for housing
   across the District will be managed in order to deliver the level and distribution of
   development set out in policies SS2 and SS3. The adequacy of supply will be
   assessed and monitored through the Housing Land Availability Assessment and
   the Annual Monitoring Report. A housing implementation strategy that details the
   approach to managing delivery of the housing will be set out in a Housing Delivery
   SPD. Where deemed appropriate, measures will be used to adjust the delivery of
   housing by bringing forward or holding back development in accordance with the
   Housing Delivery SPD.
                rd
2. Amend 3 paragraph of Policy SS4 (p57) to read: “There will be a preference for
   previously developed sites and sites within urban areas before greenfield and edge
   of urban areas other than where required to bring forward significant infrastructure
   needs or as set out in Policy SD1.”
               th
3. Amend 4 paragraph of Policy SS4 (p57) to read: “In those parts of the District nearest
   to the North Staffordshire conurbation the Green Belt and settlements inset within
   the Green Belt, levels of new housebuilding will be restricted in the period up to
   2016 through the phased release of housing allocations and the limited granting of
   permissions on unidentified (windfall) sites in order to avoid undermining the
   renaissance of the North Staffordshire conurbation. Any restraint should be
   balanced with the need to improve prospects in the Biddulph local regeneration
   area.”

4. Add following additional sentence to para. 8.1.25 of Reasons and Justification to Policy
   SS4: “The means by which the windfall allowance will be monitored will be set out in the
   Housing Delivery SPD.”

5. Amend para. 8.1.28 of Reasons and Justification to Pollicy SS4 to read: “The need to
   restrict development in those parts of the District nearest to the North Staffordshire
   conurbation is important in order to avoid excessive development undermining the
   renaissance of the conurbation by stimulating further in-migration. This will be apply to
   those areas around and including Biddulph, Endon, Werrington and Blythe Bridge and
   settlements washed over by the Green Belt and the following settlements which are inset
   in the Green Belt: Biddulph, Biddulph Moor, Brown Edge, Endon, Stanley, Bagnall,
   Cheddleton, Wetley Rocks, Werrington & Cellarhead, Kingsley, Caverswall & Cookshill,
   Blythe Bridge & Forsbrook. The Council will limit housing development in these areas
   primarily to that which is required to meet local needs by identifying an appropriate level
   of allocation and by resisting large scale housing development on unidentified sites. The
   „Housing Delivery‟ SPD will set out how housing development will be controlled in these
   areas. Biddulph is identified in Policy UR2 of the RSS as a local regeneration area where
   local authorities should work with other agencies and partners to develop regeneration
   strategies to promote urban renaissance. Restraint will therefore be balanced with need
   to improve prospects in Biddulph, provided this does not prejudice the need to focus
   resources within the MUAs. This restriction will be in place only until 2016 to allow
   progress on urban renaissance in the conurbation to become established and will be
   reviewed after that time.”




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6. Add following updated table of net housing requirements to Reasons and Justification to
   Policy SS4:

Net Housing Requirements
Area       Amount    Required             Annualised     Completions       Net
                                                                                        2
                     Provision            Development    and               Requirement
                                                                       1
                                          Rate           Commitments
Leek         30%          1800            90             781 755           1019 1045
Biddulph     20%          1200            60             282 283           918 917
Cheadle      25%          1500            75             165 173           1335 1327
Rural        25%          1500            75             698 701           802 799
Total                     6000            300            1926 1912         4074 4088
Note: 1: Comprises of completions since 1/4/06 and sites with planning permission or under
construction as at 31/03/08 30/09/08 net of any losses
2: Net requirement to be found from allocations and windfall development between 31/03/08
30/09/08 and 2026

7. Define in the Glossary what is meant by „urban area‟ – the continuously built up area




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SS5a - Leek Area Strategy

Introduction
The Leek area strategy sets out the future role for Leek as the principal service centre and
market town. It establishes the key proposals and requirements for Leek. It proposes 2
regeneration areas at Cornhill and the Churnet Works. In the consultation it was specifically
asked if respondents agree with the future role for Leek (Q4) and whether they agree with the
key proposals for Leek (Q6), and Q26 asked for views on the contents of the draft policies.
Additionally, question 9 asked for views on the proposed mixed use development of Churnet
Works and Cornhill and what uses are appropriate in these areas.

There were 8 broad locations for housing identified (including Area 1 Churnet Works - mixed
use area) and assessed for Leek. Area 2 White‟s Bridge was subsequently excluded due to
flood risk constraints. Four areas were then suggested as preferred locations and 3 were
other alternative locations. Two preferred broad location for employment land were identified,
EM1 Cornhill and EM2 Leekbrook. The consultation specifically asked whether respondents
agreed with the preferred broad areas for housing and employment development in Leek and
whether they considered that any of the other broad locations for housing should be included
instead or as additional areas (Q7 & Q8).

This section is divided into comments and responses relating to general policy and
relating to Churnet Works, Cornhill and the broad locations. Suggested changes are at
the end of this section.



Summary of Comments

Comments from Questionnaire and Correspondence

General Policy

There were 228 comments made relating to questions 4, and 6 regarding the role of Leek and
the key proposals. Support was expressed for strengthening Leek‟s role as a principal
service centre and retailing centre for the District. There was support for increasing and
improving the provision of open space and recreational facilities. Maintaining the existing
provision and extending sports facilities and access to community green spaces, gardens,
visual landscape areas etc. Protect open space and children‟s play areas. Some respondents
expressed support for increasing and improving provision of educational, health and
community facilities.

The following issues and concerns were raised from those commenting on the Area Strategy:
     Listed buildings and conservation areas should be preserved. The town‟s unique
      character and distinctiveness should be maintained/ preserved and enhanced. It should
      be possible for future development to be more sensitive than in the past. Make Leek a
      strong sustainable town where people want to live work and contribute to the
      community.
     Need for town centre environmental improvements.
     Needs to be recognition of the role of tourism in the town‟s future.
     Providing large scale employment sites in Leek would only serve to undermine its
      distinctive character as a rural historic market town.
     The town‟s future lies in encouraging antiques and retail outlets.
     Need to promote leisure facilities including a marina, development of the canal and
      Churnet Valley Railway in Leek.
     The disused mills and other derelict buildings which have a negative impact on the
      townscape should be developed. Some respondents felt that these should be
      demolished and redeveloped, and that this would make the town more attractive.


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      A very significant level of support was expressed for using urban area brownfield sites
       for housing first before greenfield sites and that the emphasis should be given to
       regeneration of brownfield sites rather than development outside the town development
       boundary.
      Open countryside in Leek and surrounding it should be preserved and the green belt on
       the western side of Leek should be protected.
      Protection of habitats/ wildlife and the need to have consideration for the environment
       were raised as issues that need to be addressed (see broad areas section for further
       detail). Protection of farming land was raised as an issue.
      Improving public transport is seen as an issue for Leek including improving the links
       between Leek and the rural hinterland and between Leek and Biddulph.
      The road structure around Leek must be improved. Traffic through Leek is a problem at
       times. It was suggested that a bypass is needed and it was also stated that the road
       links to and in the town are inadequate and need improvement. Concern was
       expressed that if there is too much development the infrastructure will not be able to
       cope.
      It was questioned whether cycle paths and walkways have been considered for
       improvement.
      It was suggested that affordable/ social housing is needed and more affordable housing
       should be provided. Queried whether the affordable houses will be occupied by locals.
       The need to meet the requirements of an ageing population was raised as an issue. It
       has been suggested that there are too many flats in Leek and that no more are
       required.
      Concerns were raised relating to the proposed retail development. Suggested that
       small town centre business selling local produce should be encouraged, which could
       utilise empty units and further develop the town centre. Concern was expressed that
       new retail development may be located some distance from the town/ out of the town
       and that this could have a potentially negative impact on the town centre/ detract from
       it. Question how providing a supermarket fits with creating a sustainable local economy
       especially when there is evidence that bringing supermarkets into areas reduces
       employment and profits generated leave the area. Some questioned why there is a
       need for more retail development when there are difficulties in filling the existing units
       (also see comments regarding Churnet Works).
      Support was expressed for the proposed Town Centre Masterplan. There was an
       objection to the proposed multi-storey car park. It was commented that no mention is
       made of strategy for car parking.
      It was questioned what entertainment proposals are in the planning stage. Theatre/
       community arts facility/cinema should be located in the town. Question when such a
       community facility will be delivered. No mention of a theatre especially when there is a
       ready made site, with car parking in the High Street. It was stated that leisure needs to
       be centrally located and work in conjunction with other facilities. These facilities help
       attract new employment, housing investment etc.
      More disabled facilities are needed.
      It was suggested that the policy text should read, „increasing and improving the
       provision of, and communications with, educational, health and community facilities,
       and visitor attractions within the town and across the District‟.
      Comments were received in relation to green issues with this needing to be considered
       in new building projects.
       It was questioned what employment opportunities there will be for the additional
       houses. Questioned what kind of industry Leek is planning to prompt. More
       employment is/ would be needed to warrant so many houses. The town should be able
       to grow in efficiency, expertise and diversity. Leek‟s location is not suitable for heavy
       industry, road connections to the motorway are narrow and congested. Providing large
       scale employment sites in Leek would only serve to undermine its distinctive character
       as a rural, historic market town.
      Leek has benefited from its position as administrative centre through investment in
       industry at the expense of other areas. It already has a wide range of services and
       facilities and a high proportion of jobs. It seems excessive and unfair to apportion more



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       to Leek than the other two main towns. It was commented that Leek does tend to get
       community resources and look after itself first with the giant share.

General comments received included that the precise locations of all sites should be outlined
before it is possible to comment. The proposals require expression in greater detail. Do not
see how the Council plan to achieve them. There are no practical objectives in the plan. The
key proposals for Leek seem vague. The success of Leek as a viable centre for the future
requires more thought, dynamism and vision.

The statutory consultees were generally supportive of the Leek Area Strategy although there
were some suggestions and concerns identified. The West Midlands Regional Assembly
state that the additional broad housing location(s) should be identified within the Core
Strategy to meet the shortfall in Leek. They suggest further justification be included within the
Core Strategy to support the scale of additional comparison retail floorspace for Leek.
Staffordshire County Council states that to comply with PPS 1 the Area Strategy policies
SS5-7 need to ensure that they are adequately supported by an appropriate evidence base
for issues such as broad locations. PPS 1 states that, “In deciding on areas and sites to
identify for development, priority should be given to those that will perform well against the
criteria set out in Paragraph 24.” The planning authority needs to reassure itself that these
policies meet these criteria. The Government Office for the West Midlands has questioned
when the identified shortfall of around 230 dwellings for Leek will be resolved. There could be
a potential conformity issue with the emerging RSS with regard to proposed comparison retail
floorspace. City of Stoke-on-Trent has expressed concern regarding the amount of retail
development planned for Leek (further details of these comments can be found in the
Distribution of Development Section). All retailing development is subject to the tests set out
in PPS6 which is predicated on a town centres first approach and sequential assessment.
Consider further justification is required and consideration made to a phased approach over
the whole plan period to ensure it is in step with the rest of the strategy and the amount will
not impact upon existing nearby centres including those within Stoke-on-Trent. Recommend
therefore that the employment policies are brought in line with general town centre policies in
terms of office development.

English Heritage supports the encouragement in the policy to reuse the town‟s mill buildings
which are a key element of the town‟s character and an asset for sustainable use. We also
welcome the recognition in the policy of the conserving and enhancing its historic character
and assets.

Staffordshire Police raised the issue that retail and business accommodation within an
expansion plan needs to be considered carefully against the impact of such development.
This was explained by stating that whilst economic development could be supported for
instance by ten additional licensed premises, the impact on health and safety could be
prohibitive. Staffordshire Police have also commented that the development levels appear
significant and support services infrastructure is needs to be similarly developed to support
such expansion e.g. transport, social care etc. Agree with the broad proposals and would ask
that they remain responsive to changing conditions within the area. For example the credit
crunch could create issues of obtaining sustainable building developments for dwellings.

The Sport England agree with the future role of Leek and welcome the intention to improve
community facilities, leisure, open space and recreational facilities. The intention to provide
new community facilities and infrastructure with new development is strongly supported.
Proposals for growth at Britannia Building Society would be unacceptable if any new access
impacts on the playing fields. Although they support the principles, they have suggested that
     th
the 4 bullet point of section 1 should also refer to protecting existing community facilities and
improving access to them and also refer to „open space, sport and recreation.‟

Advantage West Midlands are pleased to see that the significance of the town centre has
been recognised by proposed masterplanning exercise.

Children and Lifelong Learning Directorate, Staffordshire County Council comment that
it is not possible to provide detailed information due to the inclusion of „broad locations‟.


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Details regarding site boundaries, phasing and housing types would be required before an
exact educational requirement could be determined. The possible range of educational
requirements could involve „the necessary reorganisation of nursery, primary, secondary and
sixth form education. Section 106 contributions will be necessary from all sites to ensure the
sufficient supply of school places, and could require:
      expansion and changes to the infrastructure of existing schools;
      additional land to expand an existing school beyond its current boundary;
      relocation and expansion of current schools onto new sites; or
      additional land and building for new schools.‟
The current policy could require the building of a new primary school for developments in an
area totalling around 1,000 houses.

The Parish Councils who responded were generally supportive of the Leek strategy. Rushton
Parish Council expressed the view that more employment is needed to warrant so many
houses, Hambleton similarly raised this point. Oakamoor Parish Council and Cotton
Parish Council agree with the future role for Leek and the proposed development levels for
Leek. British Waterways agree with the future role for Leek and the proposed development
levels.

Cornhill

A number of respondents expressed their support for the proposed link road and that this
should proceed as soon as possible. A new link road is a good idea to take through traffic
away from the built up area but needs careful consideration/handling. A comment was
received that the connection between A520/A53 is far too timid. Much stronger intentions and
timescales need to be developed. A design brief should be commissioned to achieve a link to
the A53 using the existing A520 roundabout to minimise encroaching on Birchall and
progressing through Barnfields with the opportunity taken to enhance this area. This road
would present a chance to access the cattle market and provide off road parking for Junction
Road residents. Opportunity to access the cattle market, improve Barnfields, provide parking
for junction road residents and develop combined marina. Support for tourism uses in this
area - the Churnet Valley Railway and Canal Basin proposals would further enhance the town
as a tourist destination. Support for a hotel.

Concerns and oppositions have also been expressed – some do not agree with the building of
the link road, examples of reasons given are that it would simply become another congested
road, incompatible with a need to reduce car transport, is unnecessary. Concern was also
expressed over implications on traffic congestion at peak times. It will result in the creation of
sprawl of office/ factory which will ruin the approach to Leek. Congestion and parking will
have adverse impacts on the town and residents living in south Leek.

Comments were received regarding the sites being very visible and particularly Cornhill.
Great care needs to be taken over design. Need to ensure quality development. Development
needs to blend in with the rural setting of the area. Comments were received regarding the
need to ensure the uses are appropriate.

Residential use has been suggested in addition to the ones already stated in the strategy or
instead of the employment use.

The Environment Agency has stated that this area is acceptable provided that Flood Zone 3
is preserved. Staffordshire County Council has stated that the requirement for a link road
may not be justified, an access road to the A53 or A520 could be sufficient to enable
development of the site. The site could be sterilized due to limited land availability and
ownership constraints. On bullet point 1 (SS5a part 5) it is suggested that the following is
added, “Preparing a developer contribution methodology to fund associated development
infrastructure.” Sport England has expressed concern about potential impact on Birchall
Playing Fields which should be protected. British Waterways say of the Cornhill proposal
that it could enhance the area if done sensitively and linking area on foot to town centre.
Leisure and tourism uses associated with the canal should be actively encouraged.



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Cornhill Residents Association say residents do not want an industrial development, as
already have Barnfields Industrial Estate and the Cattle Market that are visible to a lot of the
properties within the area and the noise from some of the industries that operate 24hrs.
Residents appreciate that the area needs cleaning up but feel it would be best served as
being top priority in promoting tourism with an emphasis on the canal basin and railway
extension. This could lead to a lot of opportunities for the future, canal side café‟s, restaurants
etc and provide a gateway for an increase of tourists coming into Leek and spending money
in the town. Some residents said they would not like to see a Travelodge type of hotel due to
the design of the hotels and noise associated with people leaving and arriving at all hours.
They would like more information on the link road and if it will ever be viable having a full
scale industrial development at the bottom of their gardens. Residents are concerned about
the value of their properties and wish to be involved in the process all the way.

Churnet Works

In relation to Churnet Works, concern/ objections were received in relation to residential
element with some qualifying this with reasons including it is an existing employment site and
so should remain as such, flooding problems, too far out of town, residential and industry
should be separate and therefore it should remain as an industrial area. Comments in support
of residential use in the area were received and that it provides the opportunity for developing
housing with a riverside setting. Housing which is screened by extensive planting from the
existing industrial area. Should be possible to widen the river to achieve a wide shallow
waterway to enhance the setting of housing being built here making a development to be
proud of.

Comments were received relating to its existing employment use on the Churnet Works and
questioning why mixed use is proposed rather than pure employment use. Comments
included that it is broadly recognised that there is an under supply of suitable industrial land in
Leek, so much so that greenfield sites have been seriously reviewed for inclusion. Workshop
units of varying sizes are essential to allow proper development and this site is eminently
suitable.

There was a mixed response to retail use. Some comments were received expressing
concern/ objection due to potential negative impact on the town centre and would conflict with
section 3 of policy SS5a. Any proposal that causes empty shops in the centre should be
avoided. Should not include too much retail, retail should be aimed at the town centre which
needs regenerating. It is too far out of town for a supermarket/ retail development. Accept that
there may be a need for further retail capacity in Leek but believe that the Churnet Works site
is too distant from the centre to help the regeneration of Leek and might have an adverse
effect.

Others have expressed support for retail development on the site as it will keep people doing
their shopping needs in town instead of going elsewhere. Churnet Works site should be
devoted to food and non food retail with ample parking. It is an ideal site for factory outlet for
the town. With regard to retail proposed at the site, it has been stated, that whilst no details
are provided at this stage on the scale of such a facilities, these should be considered in more
detail in drafting the Site Allocations DPD and therefore subject to public consultation.

Macclesfield Road Developments has stated they have an interest in the development of
the Churnet Works site and have made comments in this context. They support the strategic
allocation of the site as a Major Regeneration Opportunity. The site offers the potential to
meet the very significant retailing needs of residents in Leek, helping to improve customer
choice and retain more of the available expenditure within the District. The provision of
substantial additional retail on the site in Leek is therefore paramount in delivering the
significant regeneration sought in this location. Macclesfield Developments agrees that the
detailed uses for the site should be developed through Site Allocations DPD but that the retail
uses listed in SS5a should be sub-divided in recognition of the very different attributes of each
use. It is established planning practice to differentiate convenience retail from comparison
retail and indeed bulky goods for the purposes of assessing needs and planning for
development. The Core Strategy Appendix E makes such a differentiation identifying a


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substantial need for convenience, comparison and bulky goods retailing in Leek over the LDF
period, drawing on the Retail Study. We therefore consider it appropriate for the Core
Strategy (at Policy SS5a) to specifically state convenience retail and bulky goods retail in the
list of suitable uses for the Churnet Works site.

The Environment Agency has major concerns about flooding and safe access and would
wish to comment further when a site specific FRA is undertaken. They state Churnet Works
site has major flooding problems and is unlikely to be suitable for residential development.
This site will require a detailed site specific FRA to be undertaken in order for the Agency to
make more detailed comments especially in terms of safe access.

Staffordshire Police made comments relating to the strategic sites stating that it would
appear that out of town but accessible retail development may be an appropriate use of the
land in order to draw attention to the rural leisure activities available within Moorlands.

Broad Locations

There were 104 general responses relating to the preferred broad areas. There was a
significant level of support for the broad areas for housing and employment development in
Leek with the exception of Area 4 where there was overwhelming objection to its inclusion
(see the comments under Area 4). Some respondents agreed in part or disagreed with certain
elements of the proposals. Others considered that housing development should be provided
as far as possible on brownfield and infill sites, avoiding urban sprawl and preserving the
countryside and green belt. Some respondents offered support as long as certain areas were
not included such as areas 5, 6 and 7, the Highfield area, Mount Road area and Abbey Green
area. Concern was expressed regarding the suggestions that major greenfield sites should
only come forward in the longer term due to the significant issues associated with brownfield
sites and the most important consideration in managing the supply should be ensuring there
is a continuous level of provision.

As detailed in the Area Strategy section, the West Midlands Regional Assembly has stated
that additional broad housing location(s) should be identified within the Core Strategy to meet
the shortfall in Leek. GOWM has questioned when the identified shortfall in Leek will be
resolved. Staffordshire County Council state that to comply with PPS1 the Area Strategy
policies SS5-7 need to ensure that they are adequately supported by an appropriate evidence
base for issues such as broad locations.

The Environment Agency says the preferred areas for development are acceptable in
principle except for Churnet Works. EM1 Cornhill is acceptable provided that Flood Zone 3 is
preserved. Staffordshire Police agreed with the preferred broad areas and would ask that
they remain responsive to changing conditions within the area. Sport England agree with
the broad locations as long as there is no impact on open space, sport and recreation land/
buildings. The National Trust welcome the focus of development on previously developed
land and in the existing built up area. The Highway Agency favour sites for housing and
employment uses in sustainable locations, which promote travel by methods other than the
private car and have the least impact upon the SRN. British Waterways agreed with the
proposals. Cotton Parish Council state that they agree with the proposals. West Midlands
RSL Planning Consortium state that if housing numbers provided in the RSS indicate that
further land is required, greenfield land that is located adjacent to existing sustainable
settlements should be developed first.

Preferred Broad Locations

Area 8 (the urban area) - attracted 14 comments, the majority of which related to
redevelopment of brownfield sites/ derelict land sites in the town and wanting this to be the
priority. Areas such as Mill Street, the Ashbourne Road were identified and more generally
the mills in Leek suggestions included that the former mills should be redeveloped for housing
and some suggested the urban area as an alternative to area 4 (see comments listed under
Area 4). Additionally, comments were made regarding the urban area within the Leek Area
Strategy (see Area Strategy). The Environment Agency state that the development


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proposed in the urban areas is acceptable in principle. Parks and Countryside highlight that
no detailed Phase 1 information is available and further surveys are required. Removal of
accessible green areas could reduce the public's access to nature. New areas of infill within
Leek should be designed to maximise the amount of green infrastructure.

Area 1 (Churnet Works) – this site is addressed in the Leek Area Strategy section.

Area 4 (East of Leek) – this area attracted large numbers of objections. 118 individual
responses were received regarding the area and a further 611 on standard response cards.
Of these only 3 were in support, all others being objections. The main reasons for the
objections were the loss of Pickwood Recreation Ground, the SBI status of the area, visual
impact of development, concern that it would cause overdevelopment in the area, traffic
concerns, the loss of a green corridor, flooding issues and that derelict, underused and vacant
brownfield land in the town should be used instead or before greenfield land is considered.
Parks and Countryside comment that this option site is located on Ladydale SBI and will
have an adverse impact on the integrity of the SBI and its intrinsic value. Large areas of the
preferred option site are sited on the SBI. Development here would harm the intrinsic interest
of the SBI. The grassland areas that comprise the majority of the SBI form a series of
interconnected fields with a diverse range of species. The marshy grassland areas, including
areas within the preferred housing allocation site, include rare species such as creeping
cinquefoil, common spotted orchids, yellow pimpernel, black sedge and square stalked Saint
John's wort. Development on option 4 will remove a green corridor extending into the existing
residential core of Leek. Leek and District Civic Society express concern about proposals
relating to area 4. Whilst not against legitimate development, feel that 130 houses on or very
near to Pickwood Recreation Ground would have detrimental consequences. The loss of this
amenity area and consequent impact on biodiversity would be extremely regrettable. The
Environment Agency states the area is acceptable in principle. Leek Town Council
expressed concern over development of area 4 due to wildlife and SBI designation. They also
hope greenfield sites would not be built upon and that the town boundary would remain the
same. The Local Strategic Partnership raised specific issue regarding the development of
greenfield sites where areas of nature conservation value.

Area 3 (North of Leek) – this area attracted only 5 comments specifically relating to this
area, 2 of these comments were in support. One of these was an owner of land in the north of
Leek expressing their support for the area and there lands inclusion in Area 3 or Area 8.
Other comments related to this being a long term allocation and stating more land in the
urban area would need to be identified which is deliverable in line with paragraph 54 of PPS
3. An objection to the broad area was received which stated that there are splendid green
areas in the north of Leek on the fringe of the present housing that should remain protected.
Parks and Countryside state that the site is located adjacent to Brough Park Fields SBI and
local nature reserve. It is unlikely that an adjacent housing development will adversely affect
the woodland and grassland habitats present at the SBI. Any development on adjacent land
would require a full protected and priority species scoping and site survey of the adjacent
Brough Park Fields SBI as part of the development brief. Development may impact on
protected species that use the SBI plus the adjacent preferred housing allocation site as part
of their habitat range. Though not currently designated SBI this recent former tip site has
been expertly planted and restored to establish a valuable natural environment of trees and
open wild vegetation. Development here has the potential to cause greater loss of wildlife
value than some areas of agricultural land where the predominant vegetation may be
ecologically poor grassland and limited hedges.

EM1 (Cornhill) – this site is addressed in the Leek Area Strategy section.

EM2 (Leekbrook Industrial Estate) - attracted only 5 comments, most expressing support
for the area. However a comment was received that Leekbrook is an area where the industrial
development of small units is incompatible with its surroundings. It was suggested that limited
housing development on the perimeter of the undeveloped land would provide protection
against potentially unauthorised occupation. The Environment Agency states it is
acceptable in principle. Parks and Countryside has stated the boundary of EM2 needs to be



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drawn to take account of the landscape value of the protected woodland that would form an
important screen to any development and or has intrinsic wildlife value.

Other Broad Locations

There were 80 comments received in relation to whether people considered any of the other
broad locations (5, 6 and 7) for housing should be included instead or as additional areas.
16% offered clear support for the inclusion of these areas instead or as additional and 40%
were against their inclusion. Additionally, some respondents offered support for the inclusion
of particular broad areas etc but not all and some of these comments in support only related
to sites in the existing urban area therefore have not been included in the % of yes responses
or some responses said no to a single are so these have not been included in the % of no
responses. A significant number of respondents said there should not be any development in
the Highfields, Mount Road and Abbey Green area of Leek and if other areas were to be
identified these should not include Green Belt land.

Other areas that were suggested included the area around the A520 (to Leekbrook).One
respondent stated that rather than broad locations which will dramatically affect the rural
character more numerous smaller developments should be considered attached to existing
settlements such as Wallbridge adjoining the golf course, selective infilling Higher Woodcroft
to Beggars Lane area, Kiln Lane to Oakwood Road, Fairview Road extended to the
Ashbourne Road. Poor quality land off the Buxton Road.

The Environment Agency state that the other broad locations should be included in order to
reduce pressure caused by a possible shortfall resulting from possible inadequacy of the
Churnet Works location. The National Trust say if there is a need to identify greenfield sites
then scoping work should give careful consideration to the probable adverse impacts of
development on the eastern side of Leek upon the setting of the National Park. Staffordshire
Police did not think other areas should be included. The Highways Authority favours sites
for housing and employment uses in sustainable locations, which promote travel by methods
other than the private car and have the least impact upon the SRN.

Area 5 (Eastern Fringe) - attracted 8 responses, predominantly objections to it being
considered as a broad area for housing. Although, one respondent suggested that the area
below Mount Road is suitable for housing as it has no special biodiversity or landscape value
and is well served by infrastructure. The ridge line of the Mount would still be kept. Parks and
Countryside state a very small segment of option area is situated on Ladydale SBI. Further
survey work is required to be sure that there are no adverse impacts. There is no other data
available and further surveys are necessary to determine impacts. The National Trust
welcome the rejection of greenfield housing sites on the eastern side of Leek (areas 5 and 6)
which would have the potential to impact on the setting of the Peak District National Park.

Area 6 (North East of Leek) - attracted 7 responses relating to this broad area. The majority
were from people who do not want the area to be considered (one comment received in
support) with the following concerns were raised, which in the main were very similar to those
raised regarding area 5. Parks and Countryside state Phase 1 information is not available to
identify the habitats covered by site 7 and further surveys are required to determine if priority
habitats are present. See map 7 showing the adjacent Phase 1 habitat data. Areas of semi-
improved grassland and woodland form part of the Biodiversity Alert Site (a site not quite
reaching SBI grade criteria) to the north of the proposed allocation area. A survey and
assessment is required for the proposed allocation area. The National Trust welcome the
rejection of greenfield housing sites on the eastern side of Leek (areas 5 and 6) which would
have the potential to impact on the setting of the Peak District National Park. Leek Town
Council questioned the possibility of development on area 6.

Area 7 (North West of Leek) - attracted 11 comments. There were no specific comments in
support of its inclusion. The concerns and objections raised included that it would encroach
on the green belt, it would ruin agricultural land, impact on rural character of Leek and visual
impact. Parks and Countryside commented that Phase 1 information is not available to
identify the habitats covered by site 7 and further surveys are required to determine if priority


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habitats are present. See map 7 showing the adjacent Phase 1 habitat data. Areas of semi-
improved grassland and woodland form part of the Biodiversity Alert Site (a site not quite
reaching SBI grade criteria) to the north of the proposed allocation area. A survey and
assessment is required for the proposed allocation area.

Comments from Consultation and Stakeholder Events
Leek Town Council hope that greenfield sites would not be built upon and that the town
boundary would remain the same. They expressed concern over development of area 4 due
to wildlife and SBI designations and questioned the possibility of development on area 6.
Also, it was stated that affordable housing targets need to be reconsidered.

The Local Strategic Partnership raised specific issue regarding the development of
greenfield sites where there were areas of nature conservation value was raised. The North
Staffordshire PCT has stated that in Leek there is pressure on GP Surgeries at the present
in terms of the number of patients they deal with and is likely that new premises will be
required in Leek over the lifetime of the plan, particularly with new development proposed in
the town. This will be lead by the GP practices. Recent investment has taken place in Leek
hospital including extending the car park.

The young people events highlighted a number of specific issues that young people have or
feel need addressing. It was considered that an improved larger skate park is required and
ideally a bowling alley and a cinema. A comment was made that facilities could be adapted to
cater more for young people e.g. a roller park disco at Brough Park Leisure Centre. It was
considered that young people need more to do to help prevent what is perceived to be anti-
social behaviour. When asked if there are any parts of Leek which they consider are untidy
and would benefit from redevelopment the bus station and Smithfield Centre were mentioned
as needing environmental improvements and improved occupiers of the shops as there is not
considered to be enough to attract young people here in terms of the retail offer. It was
generally agreed that the vacant pubs in Leek are unsightly. A view was expressed that
terraced housing in Leek should be improved. Another view was expressed that these are
part of Leek‟s heritage. It was also suggested that communal car parks be created for
residents of terraced streets to alleviate parking problems. There are areas of Leek where
lighting is poor e.g. Brough Park, pathway around Kiln Lane When asked if improvements to
the town centre are required most felt they were required. Examples that were stated were
that more clothes shops are needed, less antique shops and charity shops. It was stated that
the town centre needs to be made more attractive to visitors and residents. It was considered
that a more centrally located car park (than California - underused) to serve Leek Town
Centre would be useful. In response to a question about whether there are any parts of the
countryside they would particularly like to see protected the Green Belt was stated. Transport
both into and out of the town was raised as a key issue with buses considered to be too
expensive in some cases and some of the timetabling does not help the students to travel
easily e.g. between Leek and Hanley. It was considered that it would be desirable to re-open
the railway line between Leek and Stoke as access to the national rail network can be gained
from Stoke.

A meeting was held to discuss the needs of older people in the District. The issue of traffic
congestion in Leek was raised and it was considered that Leek would benefit from a bypass.
It was also considered that spreading development around was appropriate. It was stated
that employment is also an important element of future plans. The number of houses
proposed was questioned and it was queried as to whether conversions of larger houses to
flats could take place to help meet the need. The issue of availability of open space was
raised in terms of Leek having a lot of terraced housing so access to open space for
recreational use is important and new housing development should not restrict this e.g. the
open areas forming part of Haregate.

A meeting was held between Staffordshire Moorlands and other North Staffordshire Bodies
(Renew, City of Stoke-on-Trent and Newcastle-under-Lyme Borough Council) were some
concern expressed regarding the retail capacity figures for Leek as to whether this was
justified, as it could potentially conflict with emerging RSS Review policy re-retail development


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in non-strategic centres. Some concern was expressed over out-of-centre office development
and it was suggested that it is made clear that this relates to Cornhill only (see PPS6).

The Disability Action Group raised concern that if housing numbers were increased in Leek
then would leisure facilities also be increased e.g. sport and entertainment (particularly a
theatre).

Leek Neighbourhood Forum asked for clarification on the 1800 additional dwellings figure
and questioned how the housing has been split between the towns and villages. It was
commented that infrastructure is needed to support housing i.e. jobs.



Further Evidence and Other Issues
                                                     th
Housing Land Supply calculations for 30 September 2008 indicate that the net housing
requirement for Leek has increased from 1019 to 1045 as a result of unimplemented
permissions expiring and fewer new permissions. An update of the Strategic Housing Land
Availability Assessment (SHLAA) has been produced which has identified a potential capacity
of approximately 700 dwellings in the urban area. This includes an allowance for
development on smaller windfall sites.

The update to the Strategic Housing Land Availability Assessment has identified
significant additional capacity in the urban area through increasing the density ranges that
could be accommodated on sites to reflect the ranges proposed in Policy H1, the identification
of new sites and the addition of sites that have been involved in preliminary discussions with
the local planning authority in recent months. The SHLAA indicates that there is potential to
accommodate 700 dwellings in the urban area. This figure includes both greenfield and
brownfield sites on sites of 10 and more and also includes an allowance for unidentified sites
which PPS3 and RSS recognise can make a contribution.

Landscape and Character Settlement Assessment identifies the distinctive qualities of
individual settlements including Leek. The peripheral areas of Leek have been assessed with
regards to their ability to accommodate development without compromising landscape
character. Leek lies within four character areas, the main areas being Dissected Sandstone
Cloughs and Valleys to the south and Gristone Highland Fringe to the north. The landscape
setting is important to the town, where more open landscapes north and west of the town
contrast with strong vegetation along field boundaries and streamlines to the south and east
of Leek. Area 3 is identified as an open area which forms important landscape setting to the
settlement. Outside of this broad area, to the north of it is remnants of parkland landscape
which is based around the Abbey remains at Abbey Green. Area 4 is also identified as
important landscape setting to the settlement. There are remnants of small scale well
structured parkland landscape to the south west of this broad area. To the east of area 5 is a
ridgeline. The north of this broad area is identified as important landscape setting to the
settlement. The western part of area 6 is identified as being important landscape setting to the
settlement. A ridgeline ends in the southern end of the broad area. There is strong vegetation
along the streamlines. Area 7 is identified as an open area with little vegetation. The area
around EM1 is identified as important space/ tree cover.EM2 is identified as important
landscape setting to settlement. To the north of Churnet Works is identified as open area.

The Development Capacity Study produced for the Council assessed each settlement
against social infrastructure (education, healthcare, community/social activities, leisure
facilities and emergency services) physical infrastructure (electricity supply, gas supply water
supply and sewerage) and accessibility (public transport and highway network). It concludes
that Leek is one of only 4 settlements which are rated green for all three elements so they
have the greatest capacity for development without significant investment in infrastructure.
Notably the only area which did not score green is „healthcare‟. The GP surgery, dentists,
opticians and University Hospital of North Staffordshire are operating at capacity and are
therefore rated red.




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The Community Infrastructure Levy forms Part 8 of the 2008 Planning Bill. This will allow
LPAs to apply the levy to fund sub-regional infrastructure (over and above planning fees).
The nature of these schemes will be identified in the RSS or from local research, so that LDFs
can identify them at the local level. A wide definition of „community infrastructure‟ is suggested
ie transport, schools, health centres, flood defences, play areas etc, such that “development
can be…made sustainable”. Clearly this has implications for this policy in as much as
developers may be required to contribute to establishing or improving facilities, public
transport etc, such that less accessible areas become more accessible/sustainable.



Officer Response

General Strategy

The level of support for the Leek Area Strategy is encouraging. However, a number of
concerns have been expressed and these need to be addressed in order to ensure that the
most appropriate strategy for Leek is in place.

In response to the Staffordshire County Council, WMRA and GOWM comments regarding
the identified shortfall. It is recognised that there is a need to ensure that the net requirement
for Leek is fully allocated. The Broad Areas Section addresses this issue.

The strategy also recognises the need to increase the range of available house types and to
meet the needs of specific groups such as older people. The view that there are too many
flats in Leek and that there is not a need for further flats is something which will be monitored
through the monitoring of commitments and completions and will inform site specific work.

Affordable housing provision is addressed in policy SS5 and H2.Core Strategy Policy H2 acts
upon the HMA recommendations. The affordable housing targets set out in Policy SS5 are
based on estimates of what could realistically be delivered on sites to be allocated.

During production of the Core Strategy consultation has taken place with service providers
including the PCT, education authority, police and utility companies etc in order to ensure that
there is full awareness of their requirements so that this can be incorporated effectively in to
the LDF process. In addition a Development Capacity Study has been produced in order to
ensure that the need for service and infrastructure provision is appropriately dealt with
through the LDF process. A baseline assessment of the availability and appropriateness of
key social, physical and accessibility infrastructure elements was carried out. In terms of
education, community, leisure, emergency, electricity, gas, fresh water, sewerage and overall,
Leek scores a green rating which means that supply currently exceeds demand and is
expected to do so for the foreseeable future, however, healthcare received an amber rating
which means that supply is currently adequate but is expected to be outstripped by future
demand. This reflects the comment made by the North Staffordshire PCT that new GP
practice accommodation will need to be developed over the lifetime of the plan. The Leek
Area Strategy offers support for such development.

In terms of the ability of the road network to cope with development proposals this would be
further investigated at Site Allocations stage and if necessary developer contributions may be
required to fund infrastructure improvements. Further consultation with the local highway
authority will be undertaken at Site Allocations stage. Further issues relating to transport are
covered in Policy T1 and T2 of the Core Strategy. The Leek Town Centre Masterplan will also
address issues of accessibility, traffic flow, car parking, pedestrian and cycle route provision.
Part 3 of the Leek Area Strategy recognises improving accessibility to the town‟s major retail,
service and employment areas, particularly by public transport, from the rest of the District
and the managing of car parking in strengthening the role of Leek as a principal service and
retailing centre for the District.

With regard to the view expressed by Rushton and Hambleton Parish Council and others
that more employment is needed to warrant so many houses, the employment and housing
requirement is set at the regional level through the RSS with the distribution of the District

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requirement reflecting the preferred development approach with 30% of the housing and
employment requirements being apportioned to Leek. The apportionment of the employment
is based on achieving a balanced provision to support future workforce needs (see
Distribution of Development section for further details). The proposed employment sites are in
existing employment areas to the south of the town and have good access to the road
network. They are considered to be the most sustainable locations for employment
development and will minimise the impact of development on the countryside and residential
areas. With regard to the concern expressed over out of centre office development by North
Staffordshire Bodies this is addressed in policy E1.

The Retail Study (2006) suggests Leek is losing a significant amount of trade to other stores
outside the District for both food and non-food retail and has highlighted the importance of
enhancing the retail offer in Leek in order to encourage more sustainable travel patterns. The
location of retail development, impact on the town centre, existing empty/ underutilised
premises will be addressed through the Leek Town Centre Masterplan and Site Allocations
DPD. The masterplan will also address issues such as the appearance of the town,
movement patterns of people and vehicles using the town and will seek to address any
particular issues/ problems/ opportunities. The Retail Study (2006) policy recommendations
include that Leek should be promoted as the main focus for retail and leisure within the
District.

The comments raised by Staffordshire Police regarding retail and business development
needing to be considered carefully against the impact of such development in terms of health
and safety is a more site specific issue and it is therefore more closely linked to the policies in
the Core Strategy. The Core Strategy sets out policies which will assist in addressing such
issues including Policy C1 on Creating Sustainable Communities and the Council‟s proposed
Design SPD. Such issues will also need to be considered in the Leek Town Centre
Masterplan.

With regard to the comments on town centre car parking provision, this is an issue which will
be addressed through the Town Centre Masterplanning exercise. In light of comments made
it is suggested that the strategy reflects the fact that a multi-storey will be supported where
there is considered to be a need. With regards to the comments on the need for a theatre it
is intention that this is addressed through section 3, bullet point 4 which refers to the
provision of a „new community arts facility and cultural facility‟.

The need to consider sustainable construction technologies and carbon neutral design is
addressed in Policy SD1 which contains the requirements the Council proposes to set for new
development. The Site Specific Policies and Proposals DPD may set additional requirements
for certain site allocations where the requirement is justified.

Issues raised relating to protection/ enhancement of listed buildings, conservation areas and
the towns distinctiveness are already identified in section 4, point 1 of the strategy on page
64. The addition of a reference to new buildings needing to be sensitively designed would
address the concerns expressed over the need for future development to be of a style
appropriate to Leek and sensitive to the town‟s unique character and distinctiveness. In order
that the town‟s identity is not lost.

Regarding the comments related to the proposed link road between the A520 and A53 and
the development of the Churnet Railway and the Caldon Canal this will further be developed
through the masterplanning exercise for the area. Further details regarding theses areas are
included under the broad areas section.

Cornhill

In response to concerns raised by respondents over the impact of employment development
in this area on the road infrastructure it is noted that Staffordshire County Council do not
raise any issues in this respect and indeed they state that an access road could be sufficient
to enable development of the site. This suggestion is not considered acceptable, as it would
not have the wider strategic benefits of linking the A520 Cheddleton Road and the Barnfield


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Industrial Estate, to allow easier access across the southern side of the town, and relieve
pressure on Junction Road. The suggestion made regarding the need to make reference to
preparing a developer contribution methodology to fund associated development is
considered more appropriate for inclusion in the Site Allocations DPD.

The Environment Agency comment on preserving Flood Zone 3 has been noted and will be
acted upon at the Site Allocations stage when site boundaries will be drawn. In response to
the Sport England comments it is felt that other policies in the Core Strategy already offer
protection to playing fields and the recommended wording change to the strategy to add
protection of community facilities to the policy text are sufficient.

The specific uses of the site will need to be carefully considered through the masterplanning
exercise and Site Allocations DPD as will the need to pay careful consideration to design,
siting and landscaping. Existing and proposed uses in the vicinity of the area will need to be
carefully considered. Although a greenfield site, the site scores particularly well in the
Sustainability Appraisal in part due to the regeneration benefits associated with development
of the area and its relationship with the town being located within the existing town
development boundary and although in close proximity to Flood Zone 3 the site itself is not
affected by Flood Zone 3. Careful consideration will also need to be paid to the uses which
are proposed for this site in order to ensure that they do not have a negative impact on the
town centre and to ensure accessibility to leisure facilities. The masterplan for the area will
address such issues.

Churnet Works

In the light of the strong concerns from the Environment Agency regarding residential
development on this site it is considered that it would be inappropriate to maintain the Churnet
Works area in the calculations of housing potential and therefore an additional 170 dwellings
will need to be found in Leek to compensate for this loss. However, residential should remain
in the list of possible uses for the area as the FRA may find that with appropriate mitigation
measures the site is suitable for residential development. It is recommended that the element
of the site which would have been used for residential should be used for employment uses.
This additional employment land would then have the potential to enable former employment
sites within the urban area to be used for residential schemes subject to assessments of
individual sites being made through the Site Allocations process. This would increase the
urban capacity in Leek and go someway to addressing the identified residential shortfall and
has been considered within the HLAA update. However in order to ensure that regeneration
of the site is viable the other uses listed in the strategy need to be considered including
residential. There have been concerns raised over the location of this site for retail
development and the potential negative impact this could have on the town centre. The
masterplanning will need to address such issues and any proposal that includes a retail
element will need to satisfy the requirements of PPS 6 and Core Strategy Policy TCR1. In
light of the comments received related to retail use it is suggested that the supporting text is
amended to explain that the potential uses for the area will be addressed through the
masterplanning and that any retail proposal will need to meet the requirements of PPS 6 and
Core Strategy Policy TCR1.

Broad Locations

Preferred Broad locations

In response to the comments made regarding the preferred broad locations it is encouraging
that in general terms most respondents either fully or partially supported development in the
preferred broad locations, the main exception to this being Area 4 (East of Leek) which
generated the most objections.

In terms of the wide variety of concerns raised these are largely addressed below in response
to individual areas. Many of the concerns related to the need to bring forward urban and
brownfield sites before considering greenfield sites. As detailed below, under the „Urban
Area‟ heading, there is not enough capacity on urban or brownfield sites alone to meet Leek‟s


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housing requirements to 2026. Whilst it is acknowledged that the priority should be to
develop on urban and brownfield sites before greenfield sites, it will also be necessary to
develop on greenfield sites both within the urban areas and also on the edge of Leek. It is
acknowledged however that the preference for previously developed (brownfield) sites should
be expressed within the policy.

Area 8 (Urban Area)

The Sustainability Appraisal identified the urban area as the most sustainable area for
development and it is the Council‟s priority to re-use brownfield land in the urban area. Indeed
Policy SS5a identifies this broad area as the priority for development in Leek. The comments
received offer a significant level of support to this approach although there were concerns
expressed over the use of greenfield land. Policy SS4 does however establish the Council‟s
preference for previously developed sites within the urban area whilst policy SD1 identifies
that the Council seeks to achieve 65% of development on previously developed land in the
period 2006-2016.

Many of the sites highlighted by respondents already have planning permission and therefore
are included within the commitments or have been considered within the SHLAA as potential
housing areas. The latest results from the SHLAA show that around 600 dwellings could be
accommodated on sites (brownfield and greenfield) within the urban area. Out of this 440
would be on brownfield sites and 160 on greenfield sites. Precise land allocations will be
made in the Site Allocations Development Plan Document. Additionally, it is estimated that a
further 100 dwellings could come forward on smaller windfall sites i.e. sites which become
available unexpectedly (which are often brownfield and could include any net gains in
dwellings through clearance and rebuilding of areas or flats above shops, for example).
PPS3 and the RSS recognise that such windfall sites can make a contribution where there is
evidence and therefore it would be appropriate to assume that some of the requirement would
be met from these sites during the plan period. However, whilst this is a significant increase
in provision, there still remains insufficient capacity in the urban areas to meet the proposed
requirement for Leek therefore other areas outside the urban area will also need to be
considered.

The comments of the Parks and Countryside section on maximising green infrastructure
should be acted upon in the Site Specific Policies and Allocations where requirements for
specific sites can be set. It is also acknowledged that further habitat survey work will need to
be carried out as part of the production of the Site Allocations DPD.

Area 1 (Churnet Works) - This area is addressed above.

Area 4 (East of Leek)

This area was identified as a preferred broad location for housing as it scored particularly well
in the Sustainability Appraisal (SA) due to its good relationship to the urban area, proximity to
the town centre, and access to local facilities and public transport and it not being in a flood
risk area. The SA also identified that whilst a large portion of the site is located within the
Ladydale SBI, some development could be accommodated on the area lying outside the SBI
which lies within the current development boundary and forms part of the existing urban area.

There has however been misunderstanding during the consultation period over the extent of
this broad area with the majority of respondents believing the Pickwood Recreation Ground is
included or under threat of being part of the proposal which was never the case. This
misunderstanding may in part be the reason for such strong objection to the area although,
many of the respondents objected to the whole broad area with other reasons also being
given.

Since the draft preferred options was produced an important study has been produced, which
highlights particular landscape considerations for this part of the town. The Landscape and
Settlement Character Assessment identifies land to the south west of the broad area as
having remnants of small scale well structured parkland landscape – Pickwood Hall. The


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greenfield land to the south and west of the Recreation Ground is identified as being
important landscape setting to settlement. The recreation ground has also been assessed as
meeting the criteria for being designated as Visual Open Space. Concern was also raised
regarding flooding however the Environment Agency has said that development of the area is
acceptable in principle. The area is not in a Flood Zone.

Those parts of the broad area that are on the fringes of the existing urban area and are not
designated as SBI or used for recreational purposes remain appropriate to be considered for
inclusion in the Urban Area capacity (amounting to around 50 dwellings), although further
survey work would be needed before any such areas could be considered as allocations in
the Site Allocations DPD to ensure that development would not impact adversely on the
neighbouring SBI. However, in the light of further evidence and comments regarding the
impact of development on the integrity of the SBI and the findings of the Landscape and
Settlement Character Assessment, it is felt that these factors outweigh the identified
sustainability benefits identified in the Sustainability Appraisal process and as such it is
recommended that area 4 should not go forward as a broad area for development.

Area 3 (North of Leek)

This broad area lies within the current development boundary and comprises in the main of
filled land which has been restored but is yet to reach the end of its settlement period. The
use of the filled land for housing is therefore a long term one although there are other parcels
of land which potentially could be developed sooner.

Since consultation on the draft preferred options document, the Landscape and Settlement
Character Assessment has been published for the District. This identifies that there is
remnant parkland to the north of this area based around the Abbey remains at Abbey Green
which combines with the landscape that abuts the northern edge of the town to form the
landscape setting.

The impact on the environment however is one of a number of considerations that should
inform the selection of broad areas and whilst it is acknowledged that planting on the site has
been undertaken, the area itself has no wildlife designation. This area scored particularly well
in sustainability terms in the SA on the grounds that part of the area is arguably still a
previously developed land site as it is still in the early years of its afterlife, it relates relatively
well to the town, has access to the town centre and local facilities and would have a
community benefit as it would provide the opportunity to address contamination issues
associated with its previous use.

It is considered that this area remains suitable as a potential broad area for development
although the specific details of development including design and layout will be vital to
ensuring development is not detrimental to the setting of the settlement. These issues will
need to be addressed through the Site Allocations DPD. Consideration also needs to be had
for Brough Park Fields SBI and the survey work described by Parks and Countryside in their
response will need to be carried out during the preparation of the Site Allocations DPD in
order to ensuring appropriate mitigation.

The original broad area was calculated on the basis of a low density scheme due to the
constraints of the site. The low dph calculated will enable avoidance of areas where there is
the most potential for having an adverse impact on biodiversity and for mitigation measures to
be put in place. There may also be issues associated with access which will need to be
addressed through the Site Allocations DPD.

EM1 (Cornhill) - This area is addressed above.

EM2 (Leekbrook Industrial Estate)

This broad area already has planning permission and therefore the principle of employment
use has already been established. The boundary of the site would be identified in the Site



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Allocations DPD and would reflect that of the extant planning permission. The protected
woodland would not be included.

Other Broad Locations

Area 5 (Eastern Fringe)

Whilst this area scored worse in the Sustainability Appraisal then areas 3 and 4 due to its
poorer accessibility and the greater loss of greenfield land, it has fewer landscape and wildlife
constraints. The Landscape and Settlement Character Assessment identifies only the
northern portion of this area as providing an important landscape setting to the settlement. To
the eastern boundary of the area lies a ridgeline, providing a natural break in the settlement
below which the landscape could take development without impact on the setting of Leek.
The land to the west of Mount Road is also considered to relate well to the urban area in this
part of Leek and could provide an opportunity to incorporate further open space to serve the
wider area. Whilst development would represent a loss of greenfield open countryside, it is
considered that provided development were limited to Mount Road, parts of this area could
still be considered as a potential broad area for future development if needed.

Area 6 (North East of Leek)

This area also scored worse in the Sustainability Appraisal then areas 3 and 4 due to its
poorer accessibility and the greater loss of greenfield land. Whilst the Landscape and
Settlement Character Assessment does not identify this area as being important to the setting
of Leek, it does identify strong vegetation along the streamline to the eastern edge which
could help to screen development, whilst land just outside the western edge of this area is
described as providing an important landscape setting to the settlement. The potential impact
on the setting of the Peak Park is also a significant consideration with this area. As with area
3, it does not have significant wildlife constraints but it is not considered to relate as well to
the urban area as most of the other broad areas, being relatively isolated from the town. As
with area 3, whilst development would represent a loss of greenfield open countryside, it is
considered that this area could still be considered as a potential area for future development if
needed although careful deign and landscaping would be required to assimilate development
into the area.

Area 7 (North West of Leek)

This area was overall the lowest scoring area in Leek in the Sustainability Appraisal. It scored
particularly poorly due to its Green Belt and greenfield status, location outside of the
settlement boundary and distance from the town centre. There was also significant objection
to development in the Green Belt. Accordingly it is considered that it would be inappropriate to
pursue this area further for development when there are other non-green belt areas which
perform better in terms of their sustainability.

Conclusion

It is considered that area 8 (urban area) should be the priority for housing development and
that area 3 (North of Leek) should be identified as a broad location for subsequent
development. Area 4 (East of Leek) should not go forward as a broad location for
development due to the identified landscape and wildlife constraints. However, although the
additional capacity which has been identified in the urban area (area 8) has helped to
alleviate the shortfall that already existed in Leek, the additional requirements that would be
created through the removal of area 4 and the concerns regarding residential development on
the Churnet Works Area mean that there would still remain a possible shortfall of at least
around 100 dwellings. It is not considered appropriate to reduce the housing requirement for
Leek as this could undermine the overall development approach which seeks to strengthen
Leek‟s role as the principal town in the District. More significantly it would not provide
sufficient flexibility in terms of the range of housing sites to ensure the housing requirements
can be delivered over the plan period (particular given the difficulties in developing on the
filled land in area 3 and inevitable uncertainties over capacity in the urban areas). It is


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therefore suggested that an additional broad area for housing with a capacity of 250 dwellings
should be identified. This would only come forward towards the end of the plan period if it
were needed to overcome any shortfalls.

It is suggested that this additional broad area should be either area 5 (eastern fringe) or area
6 (north east of Leek). From the evidence currently available the most appropriate area is
considered to be area 5 as this relates better to the urban area and has a well defined
boundary along Mount Road and it also has potential to incorporate additional open space
provision to serve the area.



Suggested Changes
               nd
1. Amend 2 bullet point in item no. 1 of Policy SS5a (page 63) to read:
   „allocating a range of deliverable housing sites both within the urban area and, on
   land adjacent to the urban area. Sites within the urban area shall be in locations
   across the town which have good accessibility to services and facilities with
   priority being given to previously developed (brownfield) sites. Sites on land
   adjacent to the urban area shall in locations which relate well to the urban area, can
   be assimilated into the landscape, and would help secure infrastructure
   improvements for the benefit of that part of the town. Locations for new housing
   development will be identified and phased through the Site Allocations DPD in the
   following priority order depending on the need for sites to be brought forward:
      o Within the Urban Area
      o Extension to the Urban Area to the north of Leek
      o Extension to the Urban Area to the north east of Leek or on the eastern
         fringes of Leek
                rd
2. Amend 3 bullet point in item no. 1 of Policy SS5a (page 63) to read: „protecting,
   increasing and improving the provision and accessibility of open space, sport and
   recreational facilities, including the provision of a Sports Village. Specific areas will
   be identified through the PPG17 Audit and the Sports and Physical Activity
   Strategy.‟
                st
3. Amend 1 bullet point in item no. 3 of Policy SS5a (page 64) to read: „the sensitive
   redevelopment and expansion of the town centre to increase the quantity and
   quality of the retail offer, improve linkages between areas and establish new
   development opportunities in accordance with policy TCR1‟.
               th
4. Amend 6 bullet point in item no. 3 of Policy SS5a to read: “managing car parking to
   support the role of Leek as a destination for shopping, employment, entertainment
   and tourism without leading to congestion of the town centre, including the
   provision of consideration of the need to provide a new multi-storey car park.”
               st
5. Amend 1 bullet point in item no. 4 of Policy SS5a to read: “conserving and enhancing
   buildings, sites areas of heritage and cultural importance, complemented by new
   distinctive, sensitively designed, high quality, sustainable buildings.‟
               th
6. Amend 4 bullet point in item no. 4 of Policy SS5a to read: “improving and creating
   pedestrian and cycle links in the town and in particular between the town centre
   and Brough Park.”
               rd
7. Amend 3 bullet point in item no. 5 of Policy SS5a (page 65) to read: „Masterplans will
   also be produced to guide the detailed planning of these areas. High quality
   design will be expected for these visually sensitive sites in line with the
   requirements set out in Policy DC1 and the Council‟s Design SPD.‟

8. Amend the first sentence in paragraph 8.1.42 of the Reasons and Justification to Policy
   SS5a to read: „The Site Allocations DPD will review and define the precise extent of the
   town development boundary of the urban area which will be shown on the proposals map

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    to accommodate, where appropriate, peripheral expansion and also to protect the
    surrounding countryside and green belt from further encroachment.‟
                    st
9. Amend the 1 sentence in paragraph 8.1.43 of the Reasons and Justification to Policy
   SS5a to read: „In order to deliver the housing requirements for Leek set out in Policy SS5
   it is estimated that there will need to be a minimum of 1019 1045 additional dwellings
   provided on new allocated sites‟.

10. Add the following to paragraph 8.1.45 of Reasons and Justification to Policy SS5a: „The
    bulk of development will take place in the urban area on a mixture of brownfield and
    greenfield sites distributed around the town including infill development, redevelopment
    and conversions. In identifying sites preference will be given to brownfield sites
    particularly sites within or near to the town centre or redevelopment sites. The total
    estimated capacity on sites which could accommodate 10 or more dwellings within the
    urban area is 600 dwellings but this may vary as a result of more detailed assessment of
    sites as part of the Site Allocations DPD. Additionally, evidence from the SHLAA
    suggests that a further 100 dwellings could come forward on smaller windfall sites which
    can accommodate less than 10 dwellings. The need to release land adjacent to the
    urban area will be assessed against the release and likely release of land within the urban
    area. The proposed broad locations for land outside the urban area are to the north of
    Leek and either to the north east or on the eastern fringes of Leek. These should be in
    the form of new community neighbourhoods of up to 250 dwellings. With past
    completions and current commitments these allocations would provide in total 1955
    dwellings for Leek which exceeds the town‟s requirements (see table of provision) but will
    provide flexibility for slippage on constrained sites.‟

11. Amend paragraph 8.1.49 of Reasons and Justification to Policy SS5a to read: „„The
    Churnet Works area is an existing industrial site on the Macclesfield Road which is largely
    underused and presents a poor approach into the town. Its redevelopment presents a
    significant opportunity to regenerate an area of poor environmental quality and achieve a
    mix of uses and infrastructure improvements which will benefit this part of the town. The
    uses listed that may be suitable for this area will be further explored through the
    masterplanning. This will need to address issues associated with potential retail use in
    this area including the impact on the town centre. Any proposal that includes a retail
    element will need to satisfy the requirements of PPS6 and Core Strategy Policy TCR2. It
    is at this stage that the specific nature of the retail element will be explored. In the light of
    concern over flood risk and safe access in this area, a site specific Flood Risk
    Assessment will need to be undertaken in order for the Environment Agency to be able to
    make more detailed comments. Due to the major flooding problems the Environment
    Agency have stated that it is unlikely to be suitable for residential use. In response to
    these comments this area has been removed from the housing allocations requirement
    however residential remains in the list of potential uses until the outcome of a FRA is
    known.‟

12. Include following table of provision within Reasons and Justification to Policy SS5a:

          TOTAL REQUIREMENT                                            1800
          Completions since 2006                                       214
          Current Commitments                                          541
          New allocations – Within the urban area (area 8)             600
          New allocations – North of Leek (area 3)                     250
          New allocations – North East of Leek (area 6) or             250
          Eastern Fringe of Leek (area 5)
          Windfall allowance                                           100
          TOTAL POTENTIAL PROVISION                                    1955




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SS5b - Biddulph Area Strategy
Introduction
The Biddulph Area Strategy describes the role of Biddulph to 2026. Consultation on the
Preferred Option Biddulph Area Strategy specifically asked for comments on the Strategy in
terms of whether respondents agreed with the future role for the town, the key proposals and
the wording of the policy (Q10, Q12 & Q26).

There were 10 broad locations for housing identified and assessed for Biddulph of which 5
were subsequently suggested as preferred locations and 5 were other alternative locations.
There was one preferred broad location identified for employment land. The consultation
specifically asked whether respondents agreed with the preferred broad locations for housing
and employment development in Biddulph and whether they considered that any of the other
broad locations for housing should be included instead or as additional areas (Q13 & Q14).

This section is divided into comments and responses relating to general policy and
relating to the broad locations. Suggested changes are at the end of this section.



Summary of Comments

Comments from Questionnaires and Correspondence

General Policy

There were a total of 246 comments made relating to the Biddulph Area Strategy (responses
to questions 10, 12 and the relevant part of 26).

From those who responded there was a significant level of support for the Biddulph Area
Strategy in whole or partially. In particular, support was given to regeneration of the town
centre including gateways and Biddulph East including the Schlinder properties, restraint on
development particularly in the Green Belt, further employment development, Biddulph having
its own identity and being part of the Moorlands, enhancing the role of Biddulph as a
significant service centre and market town, locating development within the development
boundary, provision of additional housing (all types including residential care for older people
and affordable housing), improved infrastructure/community facilities including primary care
centre, recreational and educational facilities, promotion of the town and links with the
countryside.

There was general support from the Statutory Consultees who responded, though there are
some issues to address. At a special meeting, Biddulph Town Council stated that they do
not want to see development on greenfield sites in green belt areas. They consider that there
is scope for housing in urban areas – flats above shops and conversion of mills (think that
some are an eyesore and are not currently economically feasible to develop as live/work
units). They would like to see the use of CPO powers on derelict buildings. They see
gateways to the town as a priority and are opposed to any development on Church Road
Playing Fields, having the view that the former Meadows School site is more suitable for a
Primary Care Centre. In their written response to the consultation, they consider that part of
the strategy is contradictory in terms of how the proposal to build housing on Church Road
Playing Fields equates with Policy SS5b which includes retention of open space / recreational
facilities. They also point out a minor amendment to be made to the wording of the policy
regarding Schlinder properties. United Utilities serves Biddulph with wastewater services
and points out that there are sewer capacity issues in several locations and stresses the
importance of good liaison between the company and the Council to ensure that relatively
clean surface water is excluded from the public sewer where possible. Staffordshire County
Council refer to guidance in PPS1 Climate Change and state that the District Council need to
ensure that the area strategy policy for Biddulph meets the criteria set out in paragraph 24 of
this Government Guidance. Sport England expresses support for the principles of the

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strategy and suggests a minor amendment to the wording of the policy. The West Midlands
RSL Planning Consortium prioritises new housing development on brownfield and infill sites
and considers that the approach to the use of greenfield sites for affordable housing should
be 'dispersed release' of sites according to where the need is greatest.

The main concerns made and issues raised were –

        Should retain the town‟s individuality, countryside setting and avoid building on green
         spaces.
        Maintenance of the existing green belt boundary is necessary.
        Concern about levels of housing development proposed and queries about the need
         for this development.
        Regeneration is needed in the urban area i.e. the reuse of existing sites like disused
         mills. The Council needs to be more proactive to achieve this.
        Detailed issues relating to the regeneration of the town centre e.g. unsatisfactory
         highway arrangements, commenting on poor range of shops, querying need for
         additional shops, untidy appearance of some shops and the likelihood of a market
         being reinstated.
        Core Strategy fails to respond to Biddulph‟s issues – declining employment,
         commuter town for wealthier with pockets of severe deprivation where people are less
         able and mobile.
        Further development would put a strain on infrastructure which is lacking including
         roads, schools, medical services (no local hospital), police, fire, ambulance services,
         recreational facilities, sewage, drainage (flooding occurs) other utilities.
        Negative impact of development on the environment – pollution, wildlife, carbon
         footprint.
        Disagreement with particular areas put forward for development.
        Concern that employment development is not given enough attention in terms of
         available jobs in the town, including higher level jobs.
        Query the need for additional employment development, recreational facilities.
        A cleaner and safer environment should be a priority.
        Include a social vision for the town.

Broad Locations

There were a total of 344 comments made relating to the Biddulph Preferred Broad Locations
and Other Broad Locations (responses to questions 13 &14).

Preferred Broad Locations

Most of the responses to the preferred broad locations were made in general terms (100
comments) though some made specific reference to one or more of the broad locations. Of
those responses made in general terms, most (65 respondents) were in full or partial
agreement with the preferred broad locations. Examples of comments made in support of the
preferred broad locations are that they are supported because they do not encroach onto
green belt land, agree with the use of existing brownfield sites for new development within the
urban area, agree in relation to employment development, areas are accessible to local
facilities and there are plenty of windfall sites available.

The main criticisms made were that developing on greenfield sites could lead to a loss of the
town‟s character, in the current economic situation it may not be viable for new development
to take place, more precise details of building locations are required, open spaces need to be
retained, housing should be accommodated on existing brownfield sites in the town, there is
no plan to replace the large amount of old dwellings in the town, query why that amount of
new development is required, road network is poor, should be plans for transport, there are
already houses on the market in the town, not enough employment land included to create
jobs, the infrastructure is not in place to support new development and a concern that if
significant new development takes place the town could merge with Stoke on Trent.



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In terms of Area 8 (the urban area), there was a very significant level of support from the 17
responses made for building houses within the urban area, though most specifically referred
to brownfield sites. A variety of suggestions of suitable sites / areas for redevelopment were
made including disused mills at Walley Street / Stringer Street / Station Road, derelict areas
e.g. part of Congleton Road in the town centre (including the Roebuck), disused shops in
town centre, flats above shops, selective demolition of existing housing areas in need of
improvement, bringing empty properties back into use and Wharf Road car park. There was
an opinion expressed by several respondents that there are plenty of brownfield sites suitable
for housing development, particularly in the town centre. There were no objections made to
building in the urban area (in general).

Area 2 (Uplands Mill) attracted support from most of those who commented on it (6
respondents) as it was considered to be previously developed and within an existing
residential area. It was also considered that the capacity of the site could potentially be
increased, visual impact would be limited and that other supporting uses like public open
space could be accommodated. There was some concern about the loss of the land for
employment use given the lack of job opportunities in the town and that this employment use
could make delivery of housing on the site problematic.

Area 5 (Newpool Meadows) attracted objections from the vast majority of those who
commented (25 responses). Reasons given were that the land is too boggy and flooding /
drainage problems occur in the area, it is the site of previous mine workings, loss of the green
space for use by the local community, loss of unspoilt wildlife habitat, there is a lack of green
space in the area, would not like to see play area on the site as it would attract crime, site
would be difficult to develop due to the presence of peat subsoil and pumping foul water and
possibly surface water up to Tunstall Road. It was queried as to why this land has been
included when the village green application has not been concluded yet.

Area 7 (Biddulph East) attracted support from most of those who commented on the area (6
responses). Examples of views were that the area would be suitable for high density housing,
a mix of housing types and redevelopment of existing housing to improve it. In commenting,
most respondents were referring to the Biddulph East area in general rather than the Church
Road Playing Fields. In objection to this area, a respondent argued that development here
would destroy the local community.

Area 4 (West of Biddulph) attracted objections from most of those who commented on the
area (9 responses). Examples of views were that this represents the beginning of green belt
encroachment, would lose an attractive open area and views of Mow Cop and Congleton
Edge, would have a huge impact on the landscape, would make this gateway unattractive if
developed to a high density, would destroy the local community and should be improving the
urban area instead. In support of development in this area a respondent states that part of
the land was used for open cast mining so has little or no value as agricultural land.

Area EM1 (Victoria Business Park) attracted support for further employment use from most
of the 9 responses received. Comments stated that this is a high quality employment site,
already an established business park, well located on the edge of the town and with
infrastructure already in place. There were some criticisms made e.g. querying how
employment would be attracted to this site, why there are no sites set aside in the town
centre, the quantity of employment land set aside for Biddulph being significantly less than
Leek and Cheadle and the presentation of the existing business park being untidy in terms of
landscaping and poor quality advertising.

Other Broad Locations

Most of the responses to the other broad locations were made in general terms (74
comments) though some made specific reference to one or more of the broad locations. Of
those responses made in general terms, the vast majority objected to the development of the
other broad locations for housing. The most common criticism was that development in the
green belt is not appropriate. Other criticisms made were that empty properties in the urban
area should be occupied to reduce the number of new homes required, brownfield sites


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should be used first, existing stock should be improved, new community facilities are needed
instead, development on these sites would be expensive as new infrastructure would be
required, more consultation is required with those who would be directly affected by
development, development would spoil the character and landscape of the area, would have
a negative impact on the environment including wildlife, impact on farmers livelihood,
disagreement about whether further housing is needed, development which spreads the town
along the A527 should be resisted, more local jobs are needed first, and that there are other
sites available – namely the preferred broad areas identified.

Of the small number of general responses which were not objections those who qualified their
response identified specific broad areas which they considered were suitable for
development. A small number of other comments were made raising the issues of the
possibility of restricting the size of houses so they are more affordable, querying what
sustainability reasons were for discounting sites and sewer capacity issues in Biddulph.

Area 1 (North East Biddulph) attracted objections from the vast majority of those who
commented on it (31 comments were received). Criticisms by objectors include concerns
about resulting traffic congestion, particularly along Pennine Way and Woodhouse Lane,
landscape / visual impact, negative impact upon the character of the area, would narrow the
gap between Biddulph and Biddulph Moor, impact on the environment including noise,
pollution and wildlife, flooding / drainage concerns, location of access, how infrastructure e.g.
schools, roads and utilities will cope, consider brownfield sites instead, green belt should be
protected, loss of land for recreational purposes, loss of agricultural land, negative impact on
property values and Biddulph Grange. There was very little support expressed for
development in this area though a point was made about local infrastructure already being in
place.

Area 3 (North Biddulph) attracted a mixed view from the 16 comments received, with half
being in agreement and half disagreeing. Criticisms made were the need to take into account
the proximity of Baileys Mill, narrow access roads not suitable for additional traffic, land in the
Green Belt should be protected, land provides a valuable haven for wildlife, right of way runs
across the land, land is boggy, land is a valuable local amenity for the community, negative
amenity as a result of smells from the sewage works and questioning the viability of house
building in the current financial climate. Issues raised by those in agreement were that the
proximity of the sewage works is not a bar to development due to modern regulations, the
area is surrounded on three sides by existing housing development, there are several access
points to the site, flooding only affects the lower part of the site and the land doesn‟t perform
the functions of the Green Belt.

Area 6 (Newpool Area) attracted objections from the majority of people who commented on it
(13 comments received). Criticisms by objectors raised the issues of the presence of
mineshafts in the area, playing fields should not be built on, lack of infrastructure like roads,
sewers, schools, lack of access, brownfield sites should take priority over greenfield sites,
green belt should be protected, areas selected as preferred broad locations would meet
housing requirements, would destroy the environment including wildlife and the character of
the area and land speculation where land is purchased for hope value is unethical and should
be disregarded. Points raised by those in support of development in this area were that
development here would hardly be noticed, national coal board work on the land has made
agricultural use unviable and the land would need major drainage work to improve it.

Area 9 (Knypersley) attracted objections from the vast majority of those who commented on
it (12 comments were received). Criticisms by objectors include concern about loss of sports
pitches, area has potential for other leisure facilities and the land is green belt. Of those who
expressed support for development in this area it was considered that visual impact would be
minimal and that the Knypersley Hall area has the potential to accommodate some housing.

Area 10 (Forge Colour Works) attracted support from the vast majority of those who
commented on it (17 comments were received). Reasons for the support were that the area
is currently unsightly and would benefit from redevelopment, has been derelict for a long time,
would be an opportunity to decontaminate the site, the site is brownfield and could result in


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road improvements to the A527. Criticisms made were that the site is green belt and could be
vulnerable to flooding.

There were a variety of additional areas (not included as preferred broad locations or other
broad locations) suggested by nine respondents as being suitable for housing development
with most being smaller sites within the existing settlement boundary, though some
suggestions were made for areas in the green belt.

There was general support for the preferred broad locations from the Statutory Consultees
who responded, though there were some specific issues raised. Biddulph Town Council
considers that development within the urban area, particularly the town centre should be a
priority including dwellings above shops and bringing empty properties back into use. They
also support development at the former Forge Colour Works site on Congleton Road. They
are concerned about loss of Church Road Playing Fields as open space is at a premium in
Biddulph East and question whether it would be possible to use surplus land at Victoria
Business Park for housing. The Sports Council stated that they would not agree with
development which would lead to the loss of open space, sport and recreation land and
facilities. The National Trust and West Midlands RSL Planning Consortium wish to see
growth directed towards the built up area rather than the green belt. The Highways Agency
prefers new development to be located in sustainable locations so travel by methods other
than the private car is possible. United Utilities serves Biddulph with wastewater services
and points out that there are sewer capacity issues in several locations and stresses the
importance of good liaison between the company and the Council to ensure that relatively
clean surface water is excluded from the public sewer where possible.

Comments from Consultation and Stakeholder Events

No different issues were raised at the Biddulph Neighbourhood Forum from those set out
above. At the Biddulph Primary Care Centre Stakeholder Event it was said that there is a
high need for a new health facility in the town and that Biddulph has the highest priority in the
County for extra care housing. Four potential sites are being considered although Newpool
Meadows and Uplands Mill are not preferred sites due to their locations and other constraints.
Church Road Playing Fields and the site of the former Meadows Special School are
considered to be more appropriate particularly Church Road Playing Fields which is
considered to be well located close to areas where there is the greatest need for healthcare,
well related to other facilities and accessible. The North Staffordshire PCT currently favour
the Church Road Playing Fields site for a Primary Care Centre.

Children and Lifelong Learning Directorate, Staffordshire County Council – it is not
possible to provide detailed information due to the inclusion of „broad locations‟. Details
regarding site boundaries, phasing and housing types would be required before an exact
educational requirement could be determined.           The possible range of educational
requirements could involve „the necessary reorganisation of nursery, primary, secondary and
sixth form education. Section 106 contributions will be necessary from all sites to ensure the
sufficient supply of school places, and could require:
      expansion and changes to the infrastructure of existing schools;
      additional land to expand an existing school beyond its current boundary;
      relocation and expansion of current schools onto new sites; or
      additional land and building for new schools.‟
The current policy could require the building of a new primary school for developments in an
area totalling around 1,000 houses.

Young people attending the YOMAC meeting objected to housing on greenfield sites in
Biddulph. The North Staffordshire Bodies questioned whether it was necessary to identify
broad locations in the green belt in Biddulph (areas 1 and 9) and expressed concern over the
infrastructure implications of proposed housing and employment development for the town.

Comments made at the consultation events were very similar to those made by respondents
above.



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Further Evidence and Other Issues
The Strategic Housing Land Availability Assessment (SHLAA) is constantly being
updated as new areas for development come to light and a recent review of the figures has
taken place for Biddulph. This indicates that the capacity of sites which could accommodate
10 or more dwellings within the development boundary is around 930 dwellings.          This
includes land at Uplands Mill (280 dwellings) and an allowance for development on smaller
windfall sites.

The Landscape Character & Settlement Setting Assessment identifies the distinctive
qualities of individual settlements including Biddulph. The peripheral areas of the town have
been assessed with regards to their ability to accommodate development without
compromising landscape character. Area 4 (West Biddulph) is considered to be an important
landscape setting to Biddulph with the bypass being identified as a strong edge to the
settlement. In terms of Area 7 (Biddulph East), the Church Road Playing Fields are
considered to be suitable for a Visual Open Space designation due to the land‟s value as an
informal recreation space and as a break between development in a dense residential area.
No other landscape constraints have been raised by the study relating to the other broad
areas.

The Development Capacity Study produced for the Council assessed each settlement
against social infrastructure (education, healthcare, community/social activities, leisure
facilities and emergency services) physical infrastructure (electricity supply, gas supply, water
supply and sewerage) and accessibility (public transport and highway network). It concludes
that Biddulph is rated green for emergency services, leisure, community / social infrastructure
and accessibility. Education and health are rated as amber i.e. just meeting existing capacity,
though it should be noted that the North Staffordshire Primary Care Trust are actively seeking
a suitable site for a primary care centre in Biddulph. The study reveals that Biddulph High
School is operating over capacity along with GPs surgeries, dentists and opticians and there
is a demand for further accident and emergency services.

The Community Infrastructure Levy forms Part 8 of the 2008 Planning Bill. This will allow
LPAs to apply the levy to fund sub-regional infrastructure (over and above planning fees).
The nature of these schemes will be identified in the RSS or from local research, so that LDFs
can identify them at the local level. A wide definition of „community infrastructure‟ is suggested
ie transport, schools, health centres, flood defences, play areas etc, such that “development
can be…made sustainable”. Clearly this has implications for this policy in as much as
developers may be required to contribute to establishing or improving facilities, public
transport etc, such that less accessible areas become more accessible/sustainable.


Officer Response

General Policy

The level of support for the Biddulph Area Strategy is encouraging.

In response to Biddulph Town Council‟s comments about not wanting to see development on
greenfield sites in the green belt and the scope for housing in the urban area including mills,
this is addressed in the „Biddulph – Broad Locations‟ section of this report. In terms of the
Council using its CPO powers on derelict buildings this is an option but would only be used as
a last resort when all other options have been exhausted. It is agreed that gateways to the
town are important and this is reflected in the Biddulph Town Centre Area Action Plan (AAP)
Policy PR3. The Town Council‟s opposition to any development on Church Road Playing
Fields is noted - the full officer response regarding this area can be found in the „Biddulph –
Broad Locations‟ section of this report. At present, it is not known where the proposed
primary care centre will be located, though there have been a number of sites discussed. It is
considered that a location which is accessible to the town‟s population would be most
appropriate. The minor wording change suggested is agreed and is listed in the „suggested
changes‟ section below.

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United Utilities comments are covered in the „Biddulph – Broad Locations‟ section of this
report. In response to Staffordshire County Council‟s comments that the area strategy policy
should meet criteria set out in paragraph 24 of PPS1 (Climate Change supplement) it is
considered that the areas chosen for development perform well against these criteria as new
housing development is only being proposed in the existing urban area (unless Newpool
Meadows is designated as a village green) which is highly sustainable.

The minor change to the wording of the policy suggested by Sport England is agreed and
listed in the „suggested changes‟ section below. In terms of the West Midlands RSL Planning
Consortium‟s comments, these are covered in the „Biddulph – Broad Areas‟ section of the
report where, in line with the organisation‟s comments, it is suggested that brownfield sites
are prioritised for new development. In terms of their comments about the release of
affordable housing sites, this is covered elsewhere in the report in the Housing Policies
section, in particular Policy H2.

In response to the issues which emerged from the Biddulph Primary Care Centre Stakeholder
Event, the need for the health facility and the extra care housing in Biddulph is acknowledged.
The Biddulph Area Strategy policy specifically refers to the provision of a primary care centre
and also to increasing the range of available and affordable house types including those for
older people. However, it is considered appropriate that this specifically refers to extra care
housing to reflect this need as housing for older people is not necessarily the same thing. A
suggested change to the policy is detailed below to reflect this. In terms of where in the town
the new health facility will go, this will be decided by the service provider, the North
Staffordshire Primary Care Trust, though their approach to site selection in terms of
considering where there is the greatest need for healthcare, relationship with other facilities
and accessibility is supported.

Many of the criticisms of the area strategy raised by the public regarding development on
green belt land, levels of housing development, broad locations, reuse of disused mills,
infrastructure provision and need for additional employment provision are addressed
elsewhere in this report. In response to the concern that employment development is not
being given enough attention in terms of available jobs in the town and providing higher level
jobs, the District Council‟s updated Employment Land Study shows only limited need for
additional employment land in Biddulph and also very limited demand for the provision of
office development (which would accommodate higher level jobs) in the period to 2026.

In response to the view that the Council needs to be more proactive in terms of reusing
existing sites, as mentioned above, compulsory purchase powers are available to the Council
but these would only be used as a last resort. Most brownfield sites which become available
in the urban area are redeveloped without the need for the District Council to acquire land if
the site is suitable and market conditions are favourable. In terms of the concerns expressed
about retaining the town‟s individuality, countryside setting and avoiding building on green
spaces, it is considered that these issues are adequately covered in part 4 of the area
strategy policy. The policy states an intention to improve the image and identity of the town
and strengthen its role as a visitor destination through a number of measures including
upgrading the general environment, creating green spaces and protecting and enhancing the
setting of the town. Part 1 of this policy also states an intention to increase and improve the
provision of open space and recreational facilities.

The detailed issues raised relating to the regeneration and shopping provision of the town
centre are noted. However, these are matters which are being addressed through the
Biddulph Town Centre AAP and it is not considered appropriate nor necessary for the Core
Strategy to propose any revision to the adopted AAP. The District Council is actively seeking
to improve the town centre both through a shop front grant scheme which has been operating
in the town and policies in the AAP which identify particular properties in need of improvement
and undertake to work with property owners to improve their appearance. In terms of the
possibility of a market being reinstated in the town, this has been actively pursued and a
competitive process to appoint a private-sector operator to run the market was put in place.
This did not result in a successful appointment. A second opportunity is provided by a further



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tender exercise which includes a wider range of market-related activity, with tenders due back
in late January 2009.

It is not agreed that the Core Strategy fails to respond to Biddulph‟s issues. The pockets of
severe deprivation in Biddulph East where people are less able and mobile are acknowledged
in the reasons and justification accompanying the area strategy policy. Specific policy
measures are included to address this deprivation, in particular, measures to improve the
local housing market and range of community facilities, improvement of housing stock in
Biddulph East, the provision of a primary care centre in the town, creation of employment
growth, regeneration of the town centre including provision of additional retail floorspace and
improvement of public transport connections to the town centre.

The potential negative impacts of development on the environment raised by respondents,
namely pollution, impact on wildlife and carbon footprint, were also raised in relation to some
of the broad areas for development put forward. It is considered that other policies in the
Draft Core Strategy adequately cover these issues.

In response to the query about the need for additional recreational facilities in the town, the
District Council‟s PPG17 audit details which facilities exist and whether there are shortfalls in
facilities. Shortfalls are calculated using national guidelines. The importance of good quality
open space and facilities is recognised by the Government in tackling obesity and improving
the quality of life and health of communities. In terms of the view that a cleaner and safer
environment should be a priority, it is considered that this is adequately reflected in the Draft
Core Strategy Vision which states that „…town centres will be welcoming, safe and
appealing…..‟ Draft Policy DC1 – Design Considerations also includes safety as a
consideration in the context of the design of new developments.

In response to the view that a social vision for the town should be included, this is the function
of the Sustainable Community Strategy, a key document detailing the priorities of the local
community. The Staffordshire Moorlands Sustainable Community Strategy highlights local
priorities such as raising educational attainment and skill levels, improving health and
reducing health inequalities and understanding the impact of our aging population. A key
function of the Local Development Framework (of which the Core Strategy is a part) is to
implement elements of the Sustainable Community Strategy which relate to the development
and use of land. Therefore a social vision is not within the scope of the Core Strategy but it is
closely aligned with the Sustainable Community Strategy which does include a social vision.

Broad Locations

Preferred Broad Locations

In response to the comments made regarding the preferred broad locations it is encouraging
that in general terms most respondents either fully or partially supported development in the
preferred broad locations.

In terms of the wide variety of concerns raised, it is acknowledged that development will
change the character of the town. However, careful design and site layout on greenfield land
will ensure that the impact is not necessarily negative. In response to the concern about the
building locations not being precise enough, the Core Strategy is a strategic document and it
is only intended to show broadly where development will go. The Site Allocations
Development Plan Document will show detailed site boundaries and will be undergoing
consultation in mid 2009. It is agreed that the retention of open spaces is important, however
there may be exceptional circumstances where remodelling or reproviding open space to
accommodate development could be justifiable. As detailed below, under the „Urban Area‟
heading, there is not enough capacity on brownfield sites alone to meet Biddulph‟s housing
requirements to 2026. In terms of there being no plan to replace old dwellings in the town,
replacement dwellings cannot be counted towards the number of new houses needed in
Biddulph as they are already in existence. Where replacement dwellings are required, the
District Council acts as an enabler as it does not have sufficient resources to fund such



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schemes itself. The Biddulph Area Strategy policy allows for improving housing stock in the
town through selective redevelopment.

In response to disagreements about levels of housing and employment development in
Biddulph, this is addressed elsewhere in the report in the response to Policy SS2 (which
covers the future provision of employment and housing development) and Policy SS3 (which
covers the distribution of housing and employment development).

In response to the concerns that the road network is poor, it is considered that accessibility of
new development to local facilities, public transport and the highway network is important.
The preferred development sites are all within the urban area where they are most
accessible. If improvements to the road network in a particular area are required to
accommodate new development, this can be achieved through developer contributions. In
terms of transport, the District Council acts as an enabler rather than a service provider.
However, there has been provision made in the „Biddulph Area Strategy‟ policy to improve
public transport connections to the town centre.

It is acknowledged that in the current financial climate, some house building schemes have
become unviable and that there are unsold houses on the market. However, the Core
Strategy looks forward to 2026 and it is not anticipated that there will be difficulties in the
market for the entire plan period. In any case, Government guidance intends that Core
Strategies are flexible enough to deal with changing circumstances if they arise.

In terms of infrastructure capacity issues, the Council‟s Development Capacity Study shows
that there is capacity in Biddulph in most local schools, community facilities, leisure facilities
and emergency services. The capacity problems in Biddulph are with health facilities and the
North Staffordshire Primary Care Trust is currently actively seeking a site for a primary care
centre in the town which would go a long way towards resolving this. In terms of individual
sites, developers will be required to mitigate the impact of their development through making
financial contributions towards relevant community facilities which could include education,
public open space and also improvements to the road network. The District Council regularly
consults with utility companies when producing planning documents and will continue to work
with them to ensure the viability of development sites.

In response to the concern expressed about Biddulph merging with Stoke on Trent, if
significant new development takes place one of the purposes of the green belt is to ensure
that settlements do not merge. The area of green belt between the southern tip of the town
and Stoke on Trent is particularly narrow which is why no development is proposed south of
Victoria Business Park to maintain this separation.

Area 8 (Urban Area)

Clearly, focusing as much development as possible within the urban area, particularly on
brownfield sites is, in line with national planning guidance, a priority as this would result in
less need to develop greenfield and / or green belt sites. The views stated above that more
development should be on brownfield sites and that the green belt should be protected from
development support this stance.

The suggestions made by respondents for suitable sites / areas of redevelopment within the
urban areas have been considered as part of the District Council‟s Strategic Housing Land
Availability Assessment (SHLAA), a key piece of evidence informing the Core Strategy which
looks at the potential capacity for new housing development throughout the District both
within and outside of the urban area. It should be noted that in calculating the number of
dwellings which could be accommodated within the urban area, only sites which could
realistically be developed have been included. For instance, regarding the suggestions made
about selective demolition and rebuilding of existing dwellings or demolition of shops in the
town centre or areas in existing employment use (with no indication from the land owner that
this is likely to change), no allowance has been made for this in the figures as it is uncertain
as to whether these would actually be developed. In terms of the suggestion that mills are not
economically feasible as live/work units, it is agreed that changing circumstances need to be


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taken into account. The mills in the town centre are zoned in the Biddulph Town Centre Area
Action Plan as being within a mixed employment / residential area where the proportion of
such uses should remain the same. However, it is accepted that in the context of delivering
housing within the urban area, this needs to be carefully considered.

The latest results from the SHLAA show that around 830 dwellings could be accommodated
on sites within the development boundary. Out of this around a third would be on brownfield
sites and around two thirds on greenfield sites. This includes 280 dwellings at Uplands Mill
(Area 2) which lies within the urban area. Precise land allocations will be made in the Site
Allocations Development Plan Document. Additionally, the SHLAA suggests that around 100
dwellings could come forward on windfall sites i.e. sites which become available unexpectedly
(which are often brownfield and could include any net gains in dwellings through clearance
and rebuilding of areas or flats above shops, for example). Evidence from recent past trends
regarding windfall development shows that such development has played a significant part in
Biddulph‟s housing supply. PPS3 and the RSS recognise that such windfall sites can make a
contribution where there is evidence and therefore it would be appropriate to assume that
some of the requirement would be met from these sites during the plan period.

Regular monitoring of housing figures is carried out to ensure that targets are being met and
the phasing of sites over the whole plan period to 2026 is an important part of managing
housing supply. Priority would be given to brownfield sites with greenfield sites being phased
for later in the plan period. If enough brownfield sites come forward for development as a
result of windfall developments, this may result in some greenfield land identified for
development becoming surplus to requirements in the plan period. However, the evidence
from the SHLAA indicates that there is not enough capacity on brownfield sites alone to
accommodate all of Biddulph‟s development requirements to 2026 and the Core Strategy
must demonstrate where the bulk of development will take place which is why other possible
areas for development are being considered.

Area 2 (Uplands Mill)

The support expressed for development in this area is noted. It is agreed that part of the site
is previously developed and that it is within an existing residential area. However it is not
considered appropriate to increase the capacity of the site to accommodate more dwellings.
This has been reviewed as part of the SHLAA and it has been concluded that in view of the
site itself and the area‟s suburban location, 40 dwellings per hectare is the maximum density
which could be applied and would yield 280 dwellings. This is also in line with draft Core
Strategy policy H1 which states that an appropriate density range in urban areas outside of
the town centre is 30 – 40 dwellings per hectare. The reason for applying the higher end of
the density range is to enable as much of Biddulph‟s housing requirements to be met on
brownfield sites within the urban area as possible to avoid incursions into the green belt.

It is also agreed that visual impact would be limited, though good design will be important to
achieve this. The Landscape Character and Settlement Setting Study does not identify this
area as being important to the setting of the Biddulph. In terms of accommodating public
open space it is agreed that this would be required on site and this can be achieved by
developer contributions in line with the District Council‟s requirements which will be set out in
the Public Open Space Supplementary Planning Document. In response to criticisms made
about the loss of the employment use, it is not considered that an employment use in this
area is viable due to the close proximity of residential property surrounding the site and the
access arrangements which are all via unclassified residential roads. The District Council‟s
Employment Land Study has assessed existing employment sites and this site is not
identified as having a high suitability for employment use. The study considers that further
investigation would be required to determine its suitability for retention for employment use.
The Core Strategy proposes to focus new employment development to meet the town‟s
needs at Victoria Business Park. In response to the comment that delivery of the site could
be problematic due to the employment use being of higher value than housing, it is not
agreed that this is the case as housing development generates a higher value than
employment development.



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It is suggested that rather than identifying Uplands Mill as a broad area in the Core Strategy,
that it becomes part of the urban area housing capacity figure for Biddulph, in line with the
strategic function of the Core Strategy. A detailed site boundary can then be determined in
the Site Allocations Development Plan Document.

Area 5 (Newpool Meadows)

The objections raised by those who commented on this area are noted. This area is different
from the other broad areas in that it already has outline planning permission for housing
development so consequently is included as a commitment in the District Council‟s housing
supply figures. However, no progress has been made on developing the site as an
application to designate the land as a village green was made some time ago. The
application was heard before an inspector in late November 2008 and the results of this are
awaited. If the land is designated as a village green no development can take place on it so
consequently the 117 houses expected to be developed on that site will need to be
reallocated elsewhere in the town. The results of the SHLAA suggest that there is not enough
capacity within the existing settlement boundary to replace these dwellings. Consequently, if
Newpool Meadows is designated as a village green, land in the green belt will need to be
used to replace these dwellings. It is considered that under these circumstances the most
appropriate option would be land in the Newpool area (Area 6), as out of the other broad
areas considered, this is the most appropriate as it has the available capacity and constraints
which can be overcome.

If the village green application is unsuccessful, then Newpool Meadows will remain as a
commitment in the District Council‟s housing supply figures and there will be no need to
identify the Newpool area for development.

Area 7 (Biddulph East)

The support expressed for development in this area is noted. This area was included as a
broad area as interest has been shown in a development scheme on the Church Road
Playing Fields which would provide new market housing in the area whilst also cross
subsidising the improvement of some of the unimproved Schlinder properties. However,
there is a degree of uncertainty as to what could happen. The area is also one of a number of
sites being considered for a new Primary Care Centre by the North Staffordshire Primary
Care Trust. If development does take place in this area it is not intended that the local
community be disadvantaged by loss of facilities, as it would be required that qualitative
improvements should be undertaken to compensate for any quantitative loss. It is also
acknowledged that the Landscape and Settlement Setting Study considers that the Church
Road Playing Fields is suitable for a Visual Open Space designation as it forms a break
between development in a heavily developed area.

In view of the uncertainty regarding the deliverability of housing on this site it is considered
that the Church Road Playing Fields should not be included as a potential housing area for
the purposes of calculating housing capacity within the urban area. However, should any
housing development take place then it would be included as windfall development and count
towards the provision for Biddulph to 2026.

Area 4 (West of Biddulph)

The objections made to development in this area are acknowledged. In response to the
criticism about green belt encroachment, none of the land forming area 4 is designated as
green belt, though it is greenfield. In response to the concern about the loss of an attractive
open area, views and landscape impact, it is acknowledged that development in this location
could potentially have a harmful impact upon the landscape. The Landscape Character and
Settlement Setting Study identifies this area as being important to the setting of the town and
it is allocated as Visual Open Space in the Staffordshire Moorlands Local Plan (though this
designation was lifted by the Council in the Revised Policies & Proposals Local Plan Review
document). However this landscape impact could be mitigated to an extent by careful design



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and site layout e.g. leaving more elevated parts of the site undeveloped. It is not agreed that
development here would destroy the local community.

Regarding the criticism about improving the urban area instead, as mentioned above, the
evidence from the SHLAA indicates that there is not enough capacity on brownfield sites
alone to accommodate all of Biddulph‟s development requirements to 2026, though there is
the capacity within the urban area (i.e. settlement boundary) to accommodate the
development if this area and other greenfield land were to be included. Clearly, in order to
accommodate future development in the town choices need to be made between areas within
the settlement boundary and those in the green belt. The Sustainability Appraisal recognises
that this area is well located in terms of accessibility to the town centre and local facilities but
this is balanced against possible landscape impact.

It is suggested that the area to the west of Biddulph continues to be identified as a broad area
in the Core Strategy. Although it is within the settlement boundary, it is on the edge of the
built up area. A detailed site boundary can then be determined in the Site Allocations
Development Plan Document.

Area EM1 (Victoria Business Park)

The support for use of this area for employment is noted. It is agreed that this is a high
quality employment site already in an established area and well located. In terms of the
criticisms made about how employment uses will be attracted to the site, it is considered that
if employers are looking to locate to Biddulph, this area is advantageous due to its road links,
established infrastructure and prestige. In response to the concern about no sites being set
aside in the town centre, the Biddulph Town Centre Area Action Plan has allocated land on
the west side of the bypass for employment and retail use.

In response to disagreements about levels of employment development in Biddulph, this is
addressed elsewhere in the report in the response to Policy SS2 (which covers the future
provision of employment development) and Policy SS3 (which covers the distribution of
employment development).

Regarding the view that the presentation of the existing business park is untidy, part 4 of
Policy SS5b seeks to improve the image and identity of the town through a number of
measures including improvement of the main approaches to the town from the south.

Other Broad Locations

The general concerns raised by respondents regarding empty properties, infrastructure,
facilities and levels of development are largely addressed elsewhere in this report. In
response to the comments made regarding the other broad locations the concerns expressed
about development in the green belt, spreading the town along the A527, spoiling the town‟s
character, landscape and wildlife in the area are noted. All of these areas were subject to a
Sustainability Appraisal which ranked them below the preferred areas for development
because of green belt, locational or environmental constraints.

As discussed above it is considered that there is enough capacity in more sustainable areas
within the settlement boundary to accommodate Biddulph‟s development needs without
incursions into the green belt under normal circumstances. However, as discussed in the
Newpool Meadows section above, if the pending village green application is successful, the
site cannot be developed and the 117 houses will need to be replaced elsewhere in the town.
Evidence shows that they could not be accommodated in the urban area so green belt land
on one or more of the other broad locations would be required. The suitability of each of
these broad areas for accommodating development is therefore discussed below.

Area 1 (North East Biddulph)

The lack of support for development in this area is acknowledged.        The Sustainability
Appraisal of the broad locations shows that the North East Biddulph area scored the lowest


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out of all the broad locations for a variety of reasons, namely its greenfield status, its location
in the green belt, distance from the nearest primary school and doctors, potential difficulty
with road access, potential impact of development on Biddulph Grange Gardens and
landscape impact. In response to the issue raised about traffic congestion it is acknowledged
that highway improvements, particularly to any access points would be required to ensure that
development in this location does not raise highway safety or capacity issues.

Although evidence from the Landscape Character and Settlement Setting Assessment does
not identify this area as being important to the setting of the settlement, it is acknowledged
that development in this location would have a visual impact, particularly from Biddulph Moor,
which is located in an elevated position. In terms of the character of that particular area, large
scale development is likely to change it but careful design can minimise negative impact of
development. It is agreed that significant development in this area would narrow the gap
between Biddulph and Biddulph Moor and that maintaining the separation of settlements is
one of the key functions of the green belt. In terms of impact on the environment, it is
possible to mitigate wildlife impacts, for instance, by maintaining habitats within large sites.
Most wildlife species are protected by law in any case and the protection of their habitats is
covered in Core Strategy Policy NE1 – Biodiversity and Geological Resources.            The issue
of pollution is covered by part 8 of Policy SD1, though it is acknowledged that building work
could in the short term have a negative impact on adjacent areas in terms of noise. In
response to the issue raised about flooding and drainage, no part of this area is defined as a
flood zone by the Environment Agency. It is accepted that new development can cause
drainage problems particularly in terms of surface water run off but there are solutions to this
through careful design and landscaping (e.g. use of permeable materials).

In terms of infrastructure capacity issues, the Council‟s Development Capacity Study shows
that in Biddulph there is capacity in most local schools, community facilities, leisure facilities
and emergency services. In terms of loss of the land for recreational purposes, the Council
has standards for the provision of public open space in place which large developments must
comply with. In response to the issue raised about loss of agricultural land, there is no high
grade agricultural land in this area (i.e. Grades 1 & 2). This particular area is only classified
as Grade 4. Regarding the issue about possible negative impact on property values in the
area, this cannot be considered as a planning issue.

As discussed above it is considered that there is enough capacity in more sustainable areas
within the settlement boundary to accommodate Biddulph‟s development needs without
incursions into the green belt. If in exceptional circumstances green belt land is required
for development, this area is not considered to be appropriate.

Area 3 (North Biddulph)

The mixed views regarding development in this area are noted. The Sustainability Appraisal
acknowledges that this area is located outside of the settlement boundary and is greenfield
and green belt.

In response to the criticisms made, any development in this area would take into account the
proximity of Baileys Mill. Regarding highways issues, any development would need to meet
the requirements of the highway authority. The number of dwellings which could be
accommodated in the area may be constrained by the road network. There may be highway
improvements in the immediate area which could be made through financial contributions
from the developer in order to accommodate additional development. Further investigation as
to how the highway network could affect capacity in the area would be required if this site is
identified as a broad location for development.

In terms of impact on wildlife, it is possible to mitigate this, for instance, by maintaining
habitats within sites. Most wildlife species are protected by law in any case and the protection
of their habitats is covered in Core Strategy Policy NE1 – Biodiversity and Geological
Resources. Rights of way would also be taken into account if this area is developed. It is
possible to relocate them to make way for new development, though each case would be
carefully considered on its own merits.


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In terms of flood risk, according to Environment Agency data, there is a flood zone running
through the centre of the area. Though this does not prevent development of adjacent areas
falling outside the flood zone, it is a constraint which could limit the number of dwellings which
can be accommodated in the area. In terms of the amenity value of the land for the local
community, although the land is not designated as public open space it is acknowledged that
if the area were to be developed much of the open space would be lost.

As discussed above it is considered that there is enough capacity in more sustainable areas
within the settlement boundary to accommodate Biddulph‟s development needs without
incursions into the green belt. If, in exceptional circumstances, green belt land is
required for development, this area is not considered to be appropriate.

Area 6 (Newpool Area)

The lack of support for development in this area is acknowledged. The area scored poorly in
the Sustainability Appraisal of the broad locations, particularly with regard to its greenfield
status and green belt location, road access, the fact that the majority of the land is Grade 3
classified agricultural land and that the area is open countryside.

In response to the issue regarding the presence of mineshafts in the area, it is acknowledged
that this is a constraint on the area and would have to be thoroughly investigated if this
location became a preferred broad area. In terms of the comment about playing fields not
being built on, it is not anticipated that there would be a net loss of playing fields in this area
as evidence shows that there is a shortage of these facilities in Biddulph.

In terms of infrastructure capacity issues, the Council‟s Development Capacity Study shows
that in Biddulph there is capacity in most local schools, community facilities, leisure facilities
and emergency services.

Vehicular access and utility provision to this area, would have to be carefully considered by
the District Council in consultation with Staffordshire County Council Highways Section and
the utility companies. In terms of the character of that particular area, large scale
development is likely to change it but careful design can minimise negative impact of
development. It is also possible to mitigate the impact on wildlife by maintaining habitats
within large sites. Most wildlife species are protected by law in any case and the protection of
their habitats is covered in Core Strategy Policy NE1 – Biodiversity and Geological
Resources.

It is acknowledged that the Council‟s Landscape Character & Settlement Setting Assessment
does not identify this area as being important to the setting of the settlement and that there
are other areas where development would be more visually intrusive.

As discussed above it is considered that there is enough capacity in more sustainable areas
within the settlement boundary to accommodate Biddulph‟s development needs without
incursions into the green belt under normal circumstances. However, as discussed in the
Newpool Meadows section above, if the pending village green application is successful, the
site cannot be developed and the 117 houses will need to be replaced elsewhere in the town.
Evidence shows that they could not be accommodated in the urban area so green belt land
would be required. It is considered that under these circumstances the most appropriate
option would be land in the Newpool area, as the area has the available capacity and
constraints which could be overcome.

Area 9 (Knypersley)

The lack of support for development in this area is acknowledged. The Sustainability
Appraisal of the broad locations shows that the Knypersley area scored significantly lower
than all of the preferred broad locations for a variety of reasons namely, its greenfield status,
its location in the green belt, distance from the town centre, potential difficulty with road
access and potential impact on Knypersley Hall (a listed building). The area is also
constrained by existing development. In relation to the issue raised by an objector about the


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potential loss of sports pitches, there are several such facilities in this area including football
pitches, a cricket pitch and a playing field. Such facilities are at a premium in the town and it
would not be desirable to lose them in this area. Similarly the point about the area having
potential for other leisure facilities is valid and it is acknowledged that large scale
development in this location could constrain further leisure development.

The issue raised about visual impact of development in this area being minimal would clearly
depend on the extent and precise location of development. Regarding the point that the
Knypersley Hall area has the potential to accommodate further housing development, there
may be some potential for small scale development in this location provided that there would
be no adverse impact on the setting of this listed building. However, the determination of
specific sites for development will take place at a later stage in the Site Allocations
Development Plan Document. The Core Strategy is just intended to show broadly where
development will be accommodated.

As discussed above it is considered that there is enough capacity in more sustainable areas
within the settlement boundary to accommodate Biddulph‟s development needs without
incursions into the green belt. If in exceptional circumstances green belt land is required
for development, this area is not considered to be appropriate.

Area 10 (Forge Colour Works)

Although there was some support for inclusion of the Forge Colour Works site as a potential
broad location for development, it is not considered appropriate to include the site for several
reasons. Although the site previously housed a dye works, the buildings were removed some
time ago and there is little visual evidence of this previous use remaining on the site apart
from the concrete bases from the former built development. The site is overgrown in places
and well screened from the highway so there is minimal visual impact. In terms of the issue
raised about possible contamination on the site, developing the site is not the only option for
addressing this. The possibility of sourcing funding to restore the land back to agricultural use
could be explored. The view that the site is brownfield needs to be carefully balanced against
the fact that it is part of the green belt and not located adjacent to the settlement boundary for
Biddulph. Development here would mean an incursion into the green belt and result in
development spreading along the A527 in a linear way. This could also open up the land
located between the settlement boundary and the Forge Colour Works site to development as
green belt boundary changes would be required in that area.

The site is located along an attractive approach road to Biddulph which is rural in character
and consideration should be given as to how a potentially large scale development would
impact upon this area. The issue of flooding in this area has been raised and according to the
latest available Environment Agency data, there is a Flood Zone 3 area immediately adjacent
to the site covering part of the site boundary and part of the A527 itself. This could have
implications for the amount of development which could be accommodated on the site though
it is unlikely to preclude development completely as most of the site is not within a flood zone.
In terms of the issue raised about development on the site helping to bring forward road
improvements to the A527, if road improvements are required new development is not the
only way to achieve them. In terms of the Sustainability Appraisal of the broad areas, a key
part of the evidence base, the former Forge Colour Works scored lower than all of the
preferred broad areas, mainly due to its green belt location and distance from the town centre
and local facilities (i.e. the nearest primary school and doctors).

As discussed above it is considered that there is enough capacity in more sustainable areas
within the settlement boundary to accommodate Biddulph‟s development needs without
incursions into the green belt. If in exceptional circumstances green belt land is required
for development, this area is not considered to be appropriate.

Other Areas

The other potential development areas suggested have been considered. Some suggested
sites in the urban area and are too small to be allocated but could come forward as windfalls.


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These would then be counted towards Biddulph‟s housing supply figures to 2026. The larger
sites within the urban area can be considered for allocation as part of the Site Allocations
Development Plan Document at the appropriate time. Those in the green belt are not
considered suitable for inclusion as broad areas because there is enough capacity within the
urban area to satisfy Biddulph‟s housing requirements and if green belt land is required there
are more appropriately located areas.

In terms of responses to the comments made by the Statutory Consultees, Biddulph Town
Council‟s comments about development within the urban area being a priority, including
dwellings above shops and bringing empty properties back into use are covered in the „Urban
Area‟ section above where it is agreed that accommodating development in the urban area is
a priority. The Town Council‟s identification of the Forge Colour Works as a suitable
development site is not agreed for the reasons stated in the Forge Colour Works section
above. In terms of their concern about development of the Church Road Playing Fields, as
covered in the Biddulph East section above, it is uncertain as to whether development will
take place and is suggested that this area is not identified as a broad area for this reason.
However, this would not preclude some development taking place in the area which would be
counted as windfall and included within Biddulph‟s housing requirement figures to 2026. It is
not considered appropriate to use surplus land at Victoria Business Park for housing as a
large proportion of this is needed to meet Biddulph‟s employment land requirements to 2021
and the remainder would be suitable for employment use beyond this date. It is considered
that there are other sites within the urban area which are closer to the town centre and
community facilities which would be more suited to housing development. In terms of the
Sports Council not wishing to see the loss of open space, as stated above, it is uncertain as
to whether development will go ahead in Biddulph East and for this reason it is suggested that
this is not included as a broad area.

The concentration of development within the urban area is in line with the comments made by
the National Trust, West Midlands RSL Planning Consortium and the Highways Agency.
In terms of the comments made by United Utilities, it is agreed that good liaison between the
company and the District Council is required to exclude relatively clean surface water from the
public sewer. It is considered that localised sewer capacity issues can be addressed as part
of the Site Allocations Development Plan Document.

In response to the North Staffordshire Bodies concerns about identification of broad
locations in the green belt, particularly areas 1 and 9, these were not identified as preferred
broad locations and as stated above, it is anticipated that Biddulph‟s housing requirements
can be met without the need to identify either of these areas for development.

Conclusion

There is sufficient capacity for Biddulph‟s development needs to be accommodated within the
development boundary on land within the urban area (including Uplands Mill and the
committed site at Newpool Meadows) and land on the edge of the urban area to the west of
the bypass. However, if the village green application currently pending on Newpool Meadows
is successful, green belt land in the Newpool area will be required for housing as there is
insufficient capacity within the urban area to accommodate the 117 dwellings committed on
this site. It is proposed to include the Uplands Mill and Newpool Meadows broad locations
within the urban area and not to identify them separately. It is proposed that the land to the
west of the bypass continues to be separately identified as a broad location owing to its
position on the edge of the urban area.


Suggested Changes
               st
1. Amend 1 bullet point in item no. 1 of Policy SS5b (page 67) to read: „increasing the
   range of available and affordable housing types, especially for first time buyers,
   families and older people, including extra care housing;‟
               nd
2. Amend 2 bullet point in item no. 1 of Policy SS5b to read:

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    „allocating a range of deliverable housing sites both within the urban area and, on
    land adjacent to the urban area. Sites within the urban area shall be in locations
    across the town which have good accessibility to services and facilities with
    priority being given to previously developed (brownfield) sites. Sites on land
    adjacent to the urban area shall in locations which relate well to the urban area, can
    be assimilated into the landscape, and would help secure infrastructure
    improvements for the benefit of that part of the town. Locations for new housing
    development will be identified and phased through the Site Allocations DPD in the
    following priority order depending on the need for sites to be brought forward:
        o Within the Urban Area (including land at Uplands Mill and the current
           commitment at Newpool Meadows)
        o Extension to the urban area to the west of the Bypass
        o In the event of Newpool Meadows being designated as a Village Green, land
           in the green belt at Newpool”
                rd
3. Amend 3 bullet point in item no. 1 of Policy SS5b to read: „improving the housing
   stock in Biddulph East through selective redevelopment and broader regeneration
   measures including the need to improve all unimproved Schlinder properties‟
               th
4. Amend 4 bullet point in item no. 1 of Policy SS5b to read: „protecting, increasing and
   improving the provision and accessibility of open space, sport and recreational
   facilities, including the provision of a Sports Village. Specific areas will be
   identified through the PPG17 Audit and the Sports and Physical Activity Strategy.‟

5. Amend the first sentence in paragraph 8.1.52 of the Reasons and Justification to Policy
   SS5b to read: „The Site Allocations DPD will review and define the precise extent of the
   town development boundary of the urban area which will be shown on the proposals
   map.‟

6. Amend paragraph 8.1.53 of the Reasons and Justification to Policy SS5b to read: „The
   Spatial Strategy seeks to restrict levels of new housing development in order to prevent
   the regeneration of the North Staffordshire conurbation being undermined, and to improve
   the housing market within the town. In order to deliver the housing requirements for
   Biddulph set out in Policy SS5 it is estimated that there will need to be a minimum of 918
   917 additional dwellings provided on new allocated sites. The focus for Evidence from
   the District Council‟s Strategic Housing Land Availability Assessment (SHLAA) shows that
   all new housing development will could be accommodated within the existing
   development boundary in areas of housing need and where there are opportunities for
   redevelopment.       However, accommodating development within the development
   boundary will also necessitate utilizing greenfield sites . The preferred broad locations
   for such development have been identified through the Sustainability Appraisal report as
   being the most sustainable location or which will help facilitate the provision of key
   infrastructure projects and it is in these locations that allocations could be considered. A
   summary of the broad locations is set out in Appendix G and their locations are shown on
   the Inset Map. The estimated capacity of all of the preferred broad locations totals 970
   dwellings. The bulk of development will take place in the urban area including the
   redevelopment of Uplands Mill (around 280 houses on brownfield and greenfield land).
   Other development in the urban area will take place on smaller sites distributed around
   the town including infill development, redevelopment and conversions. The total capacity
   on sites which could accommodate 10 or more dwellings within the urban area is
   estimated at around 500 dwellings but this may vary as a result of more detailed
   assessment of sites as part of the Site Allocations DPD. Additionally, evidence from the
   SHLAA suggests that around a further 100 dwellings on smaller windfall sites could come
   forward during the plan period. In order to meet the requirements for Biddulph, land is
   also proposed for a new community development on the edge of the urban area to the
   west of the bypass (around 330 houses on greenfield land – excluding the existing
   playing fields). With past completions and current commitments this would provide in
   total 1213 dwellings for Biddulph, which is sufficient to meet the town‟s requirements (see
   table of provision). The need to release land adjacent to the urban area will be assessed
   against the release and likely release of land within the urban area. The urban area also


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    includes a major committed site of 117 dwellings at Newpool Meadows which is currently
    the subject of a village green application. If a village green is designated here, green belt
    land in the Newpool area will additionally be required for housing as there is insufficient
    capacity within the urban area or on land west of the bypass to accommodate the 117
    dwellings committed on this site‟.

7. In the reasons and justification paragraph 8.1.55 amend the first sentence to read: „The
   allocations of sites within and on the edge of the urban area will take place in the Site
   Allocations DPD.‟

8. In the reasons and justification paragraph 8.1.57amend the final sentence to read: „A
   number of alternative broad locations for housing development located in the green belt
   were considered and assessed but were discounted for sustainability reasons and as a
   result of public consultation on Draft Preferred Options.‟

9. Include following table of provision within Reasons and Justification to Policy SS5b:

      TOTAL REQUIREMENT                                                    1200
      Completions since 2006                                               83
      Current Commitments (incl. Newpool Meadows)                          200
      New allocations – Within the urban area (incl. Uplands Milll)        500
      New allocations – West of Bypass                                     330
      Windfall allowance                                                   100
      TOTAL POTENTIAL PROVISION                                            1213




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SS5c - Cheadle Area Strategy
Introduction
The Cheadle Area Strategy describes the role of Cheadle to 2026. Consultation on the
Preferred Option Cheadle Area Strategy specifically asked for comments on the Strategy in
terms of whether respondents agreed with the future role for the town, the key proposals and
the wording of the policy (Q15, Q17 & Q26).

There were 8 broad locations for housing identified and assessed for Cheadle of which 5
were subsequently suggested as preferred locations and 3 were other alternative locations.
There were 2 preferred broad locations identified for employment land. The consultation
specifically asked whether respondents agreed with the preferred broad areas for housing
and employment development in Cheadle and whether they considered that any of the other
broad locations for housing should be included instead or as additional areas (Q18 & Q19).

This section is divided into comments and responses relating to general policy and
relating to the broad locations. Suggested changes are at the end of this section.



Summary of Comments

Comments from Questionnaires and Correspondence

General Policy

There were a total of 171 comments made relating to the Cheadle Area Strategy comprising
of 85 in response to question 15 regarding the role of the town, 77 in response to question 17
regarding the key proposals and 9 specifically in response to policy SS6c.

Amongst those commenting on the role of the town, there was a significant level of support
with 59 (70%) generally agreeing with the Area Strategy, many recognising the need for
further investment in the town provided the infrastructure was provided to support this. Some
considered that there should be more employment provision. Only 8 did not agree, mainly on
the grounds that too much housing is proposed. The remaining 18 were undecided or raised
specific issues.

The majority of respondents also agreed with the key proposals for Cheadle, particularly the
provision of a bypass. There were 48 responses agreeing and only 8 disagreeing with a
further 21 undecided or raising specific issues.

The following issues were raised from those commenting on the Area Strategy:

      Transport was one of the key issues raised by respondents. The majority agreed with
       the provision of a bypass and only a small number questioned how successful the
       southern link road would be on reducing traffic congestion in the town centre and
       whether it was in the most appropriate location. Other issues raised were:
            o Bypass should be an urgent priority
            o 1 suggestion that should go to the east of the town.
            o 1 suggestion that a direct link to the A50 is necessary. With much of the traffic
                running north - south through the town the proposed link road would do little to
                reduce traffic levels. Views that an eastern or western bypass is necessary.
            o At this stage there is insufficient understanding of future traffic flows to indicate
                any bypass to the west of the town centre. The major urban extension to the
                south of Cheadle seems to be proposed solely to provide for the prospect of a
                southern link road from private finance rather than being rooted in sound land-
                use planning principles.



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              o Concerns over impact that development of employment areas and housing in
                SW when linked with southern link road will have on the traffic in Tean.
              o Close consideration of the nature of traffic using the local road network now
                and in the future must be understood before public or private funds are
                committed to a bypass. The more self-sustaining that Cheadle becomes the
                lower will be traffic volumes.
              o Concern that relief road will increase traffic and is unecessary. Need to review
                its rail connections - railway is not only more environmentally friendly but way
                cheaper too. Reopening the rail line would mean that jobs could be made
                available at already established companies.
              o Question whether the southern link road will connect with the existing
                Industrial areas (of New Haden and Brookhouses) and form the basis of a
                bypass. Pollution must be carefully controlled as it is a valley location. Roads
                must be improved with good traffic control measures.
              o Better transport links with surrounding villages
              o Reducing levels of through traffic in the town centre is really important.

      There were very few comments received regarding part 2 of the Cheadle Area Strategy
       regarding employment growth and opportunities. Other issues raised were:
            o Need for more emphasis on employment
            o Should be more effort to bring a broader base to the industry.
            o Concern over design of industrial buildings in Cheadle.
            o Industrial developments must be preceded by road improvements not the
                 other way round.

      Although the majority of respondents supported the Area Strategy, some respondents
       did not agree with the Strategy, mainly on the grounds that too much housing is
       proposed. Other issues raised were:
             o Affordable housing for local people needs to be addressed.
             o Serious doubt over the ability of the market to provide 550 affordable houses
                unless public funding is confirmed.
             o Should avoid areas in green belt if possible.
             o Consider that growth can be accommodated on a variety of brownfield and
                smaller greenfield sites within or on the edge of the town without altering the
                inherent character and nature of Cheadle or its form.
             o New sites for housing development are close together possibly creating a
                large urban sprawl - recent developments have not provided enough green
                space and areas for children.
             o Clear and unambiguous policy support for broad housing allocations that are
                closest to the town centre ought to be given.

      There was support for new retail provision in the town centre and recognition that it was
       an important feature of the town‟s growth. Other issues raised were:
            o Cheadle needs a dedicated T.I.C. and museum and community arts centre.
            o Not enough emphasis on developing the high street in Cheadle or making
                greater use of the market. Not physically space for Cheadle town centre to
                expand. Need for more individual shops.
            o Interest in facilitating the provision of religious premises in Cheadle (Jehova's
                Witnesses) – question whether reference to 'community facilities' would
                include religious facilities.
            o Recognise that strengthening the role of Cheadle is an important step forward
                - the key requirements are significant and will help meet needs of the
                community in 2026 as well as open up other opportunities for improving
                leisure and community facilities. Further foodstore provision in the centre is
                recognised as an important feature of the town's expansion and reflects the
                findings of the Retail Study.
            o Any supermarket operator aim to maximise choice of goods at keen prices
                and discourage car-borne food shopping trips outside of town.
            o New primary school in the north east of the town is badly needed.



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      Suggestion for creation of a Tean Valley Way between Kingsley and Checkley
      Must not lose sight of the fact that Cheadle is a small market town and if we
       overdevelop this will be lost.

Danebank Developments Ltd., confirm that it has a strong developer interest in the land to
the south and south west of Cheadle and that its continuing strategy is to make complete
provision for the development of areas 4 and 5 including the provision of the southern link
road.

Forsbrook Parish Council comment that as their Parish borders Cheadle, any development
in that area will have an impact on traffic through our village. Would like more details
regarding planned bypass.

Dilhorne Parish Council comment that the Cheadle proposals will detrimentally affect all
surrounding villages. Additional dwellings will overburden the existing road system. All
existing main roads into/out of Cheadle are already over-used and congested with cars and
heavy vehicles, and also Alton Towers traffic. Improving the road network in and around
Cheadle should be a priority before housing can be allowed. Concerned that the reference in
the draft "reducing levels of through traffic in the town centre and along the A521 and A522" is
vague - can see no alternative route unless a bypass is built around Cheadle. Pol SS5c states
that "sensitive redevelopment and expansion to accommodate new retail development
including provision of a major new supermarket" this would have detrimental effect on local
small businesses, which are already suffering in the present economic climate. No thought
has been made about the volume of all traffic and subsequent parking that a major
supermarket would bring to Cheadle. There are already 3 supermarkets and one large cut-
price store in the town with a major supermarket within a 5 mile radius.

Environment Agency comment that there should be an adequate sustainable drainage
solution available at these locations and provided that development is undertaken in
accordance with PPS25 and all flood plains are kept free from incompatible development then
we have no further comments to make.

Staffordshire Police comment that the broad proposals are agreed and the use of situational
crime prevention together with appropriate traffic design should be prioritised in order to
deliver a more pedestrianised market approach to the core elements of Cheadle Town.

Sport England support the principles but consider that 4th bullet point of section 1 should
also refer to protecting existing community facilities and improving access to them and also
refer to 'open space, sport and recreation'. Question whether part 3 includes sports provision.

Advantage West Midlands pleased to see significance of the town centre has been
recognised by proposed masterplanning exercise.

Staffordshire County Council comment that the promotion/implementation of a southern
link road would be wholly dependent on developer funding. Also comment that to comply with
PPS1 (Climate Change) the Area Strategy policies SS5-7 need to ensure that they are
adequately supported by an appropriate evidence base for issues such as broad locations.

English Heritage comment that growth within and on the edges of the town will need to give
particular consideration to potential impacts on views to St Giles Church and be informed by
an appropriate assessment of the town‟s historic character and resource.

Children and Lifelong Learning Directorate, Staffordshire County Council – it is not
possible to provide detailed information due to the inclusion of „broad locations‟. Details
regarding site boundaries, phasing and housing types would be required before an exact
educational requirement could be determined.           The possible range of educational
requirements could involve „the necessary reorganisation of nursery, primary, secondary and
sixth form education. Section 106 contributions will be necessary from all sites to ensure the
sufficient supply of school places, and could require:
      expansion and changes to the infrastructure of existing schools;


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     additional land to expand an existing school beyond its current boundary;
     relocation and expansion of current schools onto new sites; or
     additional land and building for new schools.‟
The current policy could require the building of a new primary school for developments in an
area totalling around 1,000 houses.

Highways, Staffordshire County Council (SCC) – A report prepared by Staffordshire
County Council details a Project Estimate for the Cheadle Southern Link Road. It concludes
that the cost of constructing approximately 1500m of 7.3 wide single carriageway, with a 3m
wide footway/cycleway along one side, 2 internal roundabouts and 2 “T” junctions plus the
improvement of existing junctions at Brookhouse Way and Tean Road by conversion into new
roundabouts will cost £10.3 million. This is based on a construction date of 2016.
Construction in 2014 is estimated at £9.3 million and construction in 2018 is estimated at
£11.3 million. SCC are also concerned that it may not be possible to privately fund the whole
of the link road by means of the urban extension. In addition the benefits of the road are not
considered to be of strategic importance and therefore public funding would not be available.

Broad Locations

There were a total of 176 comments made relating to the Cheadle Preferred Broad Locations
and Other Broad Locations (responses to questions 18 &19).

Preferred Broad Locations

In terms of the Preferred Broad Locations, most of the responses made were general
comments (68 responses).        Of those responses made in general terms, most (51
respondents) were generally in agreement with the preferred broad locations, although a few
expressed concern regarding the loss of greenbelt land and some suggested that more
growth, particularly for employment, was needed.

Of the remainder making general comments, 10 objected and 7 expressed no preference.
The main concerns were that there are too many sites which are close together, they would
not all help provide a bypass, other sites could make a contribution, there is no need for more
houses, and that more consideration should be given to sites closest to the town centre or
which could deliver the most planning gains.

In terms of specific comments on the preferred broad locations, most comments (15
responses) were in respect of Areas 4 (south-west Cheadle) and 5 (south of Cheadle)
which are both related to the provision of the southern link road between the A522 and A521
via Brookhouses Road. Comment was made that the previous proposals for housing on this
site were rejected by the Inspectorate due to lack of infrastructure. It was also suggested that
at this stage there is insufficient understanding of future traffic flows to indicate any bypass to
the west of the town centre. The major urban extension to the south of Cheadle seems to be
proposed solely to provide for the prospect of a southern link road from private finance rather
than being rooted in sound land-use planning principles. A clearer and stronger case for this
major urban extension needs to be made and at the least it must be made clear that land in
this area will not be released until land within urban area and closer to the town centre has
been released for development where it is available. It was also questioned whether the
southern link road is sufficient for Areas 4 and 5 for the proposed number of dwellings and
that it should be extended to the A521 to relieve the town centre traffic. One person
expressed concern that the building of 470 & 200 homes in areas 4 & 5 will ruin the current
green spaces and views for residents. The development may also affect the water table and
the wildlife. The old railway line runs through this area and should be preserved as an
important part of Cheadle's industrial heritage. The building of an estate would put this in
jeopardy and be a blot on the landscape and the relief road may also cause noise and
pollution. Concern was also expressed that building housing on Green Belt area 5 will not
increase the provision of open space in Cheadle but destroy it. One person suggested that if
housing development must be created in area 5, the building of bungalows for the increasing
elderly population would be more acceptable.



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Area 8 (the urban area) - 4 responses. Comments made were that it would cause extra
congestion in the town centre, it is not clear how far it extends, locations in close proximity to
the town centre should be included even where this may necessitate small changes to the
current Green Belt. One respondent included a map of land in their ownership at Bank Street
that could be offered for housing development.

Area 1 (North Cheadle) - 4 responses including the Environment Agency (see below for
comments) and Parks and Countryside who comment in respect of areas 1 and 2 that Cecily
Brook is a key breeding site for water vole in Staffordshire which is a UK and Staffordshire
priority Biodiversity Action Plan species with high ranking protection and that further detailed
survey will be required to obtain up-to-date survey data to inform any development brief for
these areas. Consider that area 1 has the potential to form a planned expansion of Cecilly
Brook Local Nature Reserve therefore increasing public access to nature and green space.
Other 2 respondents supported this broad area, 1 requesting consideration of land in their
ownership.

Area 2 (North East Cheadle) - 2 responses comprising of Parks and Countryside (see
comment above in respect of area 1) and 1 individual who supported this broad area.

Area EM1 (New Haden/Brookhouses Industrial Estate) – 1 response only suggesting that
this industrial site be reconsidered as the greenbelt area to the west of the town is a buffer
between the town and Stoke on Trent. There is danger this will be lost. Suggests considering
the north of the town around the JCB factories as this is an industrial area and is on a main
route.

Area EM2 (Draycott Cross Road) - 2 responses suggesting that this site is unsuitable as it is
in green belt outside the town and is important.

In terms of general comments from statutory consultees and local organisations on the
preferred broad locations Cotton Parish Council do not agree with the preferred broad areas
for housing and employment in Cheadle. Parks and Countryside comment there is a lack of
data regarding phase 1 habitats for any of the proposed sites. Survey information is required
to assess biodiversity impacts on all proposed allocation sites in Cheadle. Sport England
comment that they have no objection as long as proposed sites do not lead to loss of open
space, sport and recreation land/facilties. Staffordshire Police comment that these areas
appear appropriate and suitable to the current infrastructure of Cheadle. Environment
Agency comment that from a drainage aspect we do not disagree with the preferred broad
areas for housing and employment.

Other Broad Locations

There were 79 responses made in respect of other broad locations, most of which were
general comments. Of those responses made in general terms, 34 did not consider that any
of the other broad locations for housing should be included instead. A further 5 were
undecided. The remaining 18 who made general comments were supportive of further
development in the other broad locations or suggested other potential locations.

Comments on other specific broad locations:

Area 6 (East of Cheadle) – 5 responses of which 4 supported development in this area
including the Environment Agency on the grounds that it broadens out development, is
preferable to area 3 and there are no reasons not to include it. Only 1 opposed development
on the grounds that there is no justification for it.

Area 7 (South East of Cheadle) – 6 responses of which 3 supported development in this
area including the Environment Agency on the grounds that it is not in the green belt, is
preferable to area 3 and there are no reasons not to include it. 3 opposed development on
the grounds that it is beautiful countryside and there is no justification for it.




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Area 3 (North West of Cheadle) - 9 responses of which 4 supported development in this
area including the Environment Agency on the grounds that it is logical infill between JCB and
Cheadle north, there are no reasons not to include it, and it may be suitable for limited
housing. 4 oppose development on the grounds that it is green belt and there is no
justification for it. 1 suggests the broad location of Cheadle Northwest (around Park Lane) is
a better location than the areas to the southern and northern edge of the town.

Suggestions for other broad locations were for infilling of spaces particularly brownfield prior
to expansions into the Green Belt. Future expansions on the fringes of the town should be
selective and small so as to limit the impact on the town map. 1 respondent attached a plan
showing area on Park Lane as site for housing preferable to 3/6/7 broad areas and is likely to
be preferable in sound planning terms than broad areas 4/5/2. It was questioned why the
north of the town around the JCB factories was not being considered for future employment
allocations as it is preferable to both EM1 and EM2 because they would result in loss of
western greenbelt buffer inbetween Stoke on Trent. 1 respondent suggested the area south
of Eaves Lane/East of A522 as housing instead of Area 5 as it would not have the same
detrimental impact on residents.        Another respondent suggested Huntley Quarry for
development.

Comments from Consultation and Stakeholder Events

Concern was expressed at the Cheadle Neighbourhood Forum that the infrastructure
(particularly the bypass) of the town should be sorted out before allowing any further
development.

Meeting with Cheadle Town Council – support the need for a bypass and consider that it
should be implemented before development commences.

At the consultation events, the comments made were very similar to those listed above.


Further Evidence and Other Issues
Since production of the Draft Preferred Options Core Strategy the net housing requirement
for Cheadle has decreased very slightly from 1335 to 1327 as a result of permissions being
implemented and new permissions granted.

The Strategic Housing Land Availability Assessment (SHLAA) is constantly being
updated as new areas for development come to light. The update has also identified
additional capacity in the urban area through increasing the density ranges that could be
accommodated on sites to reflect the ranges proposed in Policy H1, the identification of new
sites and the addition of sites that have been involved in preliminary discussions with the local
planning authority in recent months. The SHLAA indicates that there is potential to
accommodate up to 480 dwellings in the urban area. This figure includes both greenfield and
brownfield sites on sites of 10 and more. Small site allowance?

The Landscape Character & Settlement Setting Assessment identifies the distinctive
qualities of individual settlements including Cheadle. The peripheral areas of the town have
been assessed with regards to their ability to accommodate development without
compromising landscape character however no landscape constraints have been raised by
the study relating to the broad areas identified.

Previous Appeal Decision, Area 4 – South-west Cheadle
A previous application for housing and industrial development was refused and dismissed at
appeal by the Planning Inspectorate. It concluded that:
     the proposed link road, which was an integral part of the development, could not be
        constructed within the site area included in the application;
     refusal of permission could not be justified on visual grounds;
     wildlife concerns need not in principle prevent the development of the land;


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         part of the site proposed for industrial development was in green belt and special
          circumstances had not been justified; and
         although housing development was in accordance with the development plan, it
          should not be developed until there had been a comprehensive appraisal of
          brownfield opportunities and that there was not a pressing need for this greenfield
          site to be brought forward immediately.

The Development Capacity Study produced for the Council assessed each settlement
against social infrastructure (education, healthcare, community/social activities, leisure
facilities and emergency services) physical infrastructure (electricity supply, gas supply water
supply and sewerage) and accessibility (public transport and highway network). It concludes
that Cheadle is only one of two settlements which are rated green for all three elements so
they have the greatest capacity for development without significant investment in
infrastructure. Notably the only areas which do not score green are „healthcare‟ and
„community‟ infrastructure. The GP surgery, opticians and University Hospital of North
Staffordshire are operating over capacity and are rated red. The village hall and Post Offices
are just meeting existing capacity and are rated amber. However, it is noted that primary
education is rated green and notes the allocation of land to the east of Churchill Road for
future educational provision.

The Community Infrastructure Levy forms Part 8 of the 2008 Planning Bill. This will allow
LPAs to apply the levy to fund sub-regional infrastructure (over and above planning fees).
The nature of these schemes will be identified in the RSS or from local research, so that LDFs
can identify them at the local level. A wide definition of „community infrastructure‟ is suggested
ie transport, schools, health centres, flood defences, play areas etc, such that “development
can be…made sustainable”. Clearly this has implications for this policy in as much as
developers may be required to contribute to establishing or improving facilities, public
transport etc, such that less accessible areas become more accessible/sustainable.


Officer Response

General Policy

Overall the response to the Cheadle Area Strategy and the Key Proposals is very positive
recognising that Cheadle has suffered from under-investment in terms of its infrastructure and
town centre and has had a lack of housing opportunities in the past. The proposed strategy
seeks to strengthen its role as a service centre and market town by providing additional
housing and infrastructure improvements. The comment is accepted that the Council should
not lose sight of the fact that Cheadle is a small market town and if it is overdeveloped it will
be lost.

One of the most significant challenges of the Cheadle Area Strategy is to address traffic
congestion in the town centre and this was supported by the responses received. However, it
needs to be recognised that its provision is totally dependent on developer contributions and
this should not undermine the deliverability of the housing itself and the achievement of other
key objectives, such as affordable housing and other infrastructure. Therefore whilst the
provision of this road and the benefits that it would bring to Cheadle should still be supported
and remain a key aim of the Cheadle Area Strategy, it is considered that a policy statement
should be incorporated which lends support to a bypass and the first phase comprising the
southern link road, but recognises that the need for and viability of providing the road should
be assessed through a Transportation Study. Other minor changes to the policy suggested
include giving stronger reference to protecting and improving open space, sport and
recreational facilities.

In response to comments about the location of the link road on the westerly edge of Cheadle,
it is considered that this is the most suitable location because it takes advantage of the
existing road network and can be linked to the future development thus making it a more
viable and realistic option.


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With regard to suggestions that the southern link road should be implemented before any
further development is allowed, the reasoned justification for Policy SS5c does recognise that
„it is impractical to deliver the scale and phasing of development proposed for Cheadle by a
strict adherence to a sequential approach to the release of land‟ because it would not allow
the infrastructure to be delivered at the right time to allow for the growth to be sustainable.

In response to the potential of reopening the railway line in Cheadle, the Council will
safeguard all existing disused railway lines within the District and support the reuse of these
for public or commercial/tourism use (Policy T2) however it is not within the Council‟s remit to
reopen the line.

The proportion of housing allocated to Cheadle was based on the outcome of previous
consultations including Issues and Options consultation stage where there was considerable
support for improving the towns infrastructure and providing additional housing opportunities.

There was clear support in part 1 of Policy SS5c for locating new housing in locations close to
the town centre and avoiding green belt if possible. However, it is not agreed that all the
growth can be accommodated on a variety of brownfield and smaller greenfield sites within
and on the edge of Cheadle alone. The amount of housing proposed will include brownfield
sites as a priority but will also require larger areas of greenfield land, although these will be in
the most sustainable locations.

In response to concern raised about the impact that the proposed number of dwellings would
have on the character and form of Cheadle and on views to St Giles Church, the Landscape
and Settlement Character Assessment identifies sites and areas in and around Cheadle that
are important to the setting and the character of the town. This document will be particularly
valuable at the Site Allocations DPD stage to inform site selection. English Heritage will also
be consulted on this document.

With regard to the level of affordable housing in Cheadle, the Housing Market Assessment
demonstrates a significant need for affordable housing and it therefore remains a high priority
for this Council. The majority of any affordable housing that is likely to be provided will be on
allocated sites where developers will be expected to provide a percentage of the total amount
of dwellings on the site to meet the affordable housing requirements. In response to the
concern expressed that in the past large areas of housing have not provided enough green
space and areas for children, developers will be required to provide various types of open
space as an integral part of any proposed scheme and also make contributions to other types
of open space where relevant (see Policy C2).

Concern was raised in particular by Forsbrook and Dilhorne Parish Council regarding the
impact of new development (housing and employment) on the surrounding road network. To
date the Highways Authority (Staffordshire County Council) have not raised any concerns
about the potential impact of development on surrounding areas. Advice will be sought from
the Highways Authority at the Site Allocations DPD stage as to what local highway
improvements would be required as a result of developing individual sites and any wider
improvements that would be needed.

The Environment Agency‟s comments regarding sustainable drainage solutions and
conformity with PPG25 is covered by Policy SD1 and will be incorporated into the Site
Allocations DPD.

Concern was raised that there is not enough emphasis on employment in Cheadle and that
there should be more effort to bring a broader base to the industry. The Employment Land
Study and its subsequent update highlighted the need for the local economy to rely less on
the manufacturing industry and stimulate the private sector by making more sites available.
The study particularly identified the need for additional employment allocations to provide
small to medium sized premises in Cheadle where demand exists at popular locations but
where no available vacant land or premises exist. Part 2 of Policy SS5c identifies 7 hectares
of employment land which exceeds the requirement in Policy SS5. This will provide additional
capacity for growth and is considered to adequately address the future needs of Cheadle.


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In response to concerns over the design of industrial buildings in Cheadle, Policy DC1 will
promote a high standard of design which is locally distinctive and reinforces the unique
character of the town. In response to the comment that industrial developments must be
preceded by road improvements not the other way round, the Site Allocations DPD will look
at employment allocations and identify what improvements would need to be made before
work on site commenced.

In terms of part 3 of the Cheadle Area Strategy comments relating to developing the high
street, making greater use of the market and encouraging individual shops are noted. It is
agreed that strengthening the role of the town centre is an important step in meeting the
needs of the community, discouraging car-borne trips outside of the town as well as opening
up other leisure and community facilities.

In response to concerns from Dilhorne Parish Council about the impact of a major new
supermarket, the retail study concluded that a significant amount of Cheadle residents and
people living within the Cheadle catchment area are not using the town for their main
shopping and instead are choosing to shop outside the District. Data collected from town
centre user surveys indicate that the town needs to improve its retail offer in both quantitative
and qualitative terms to attract local shoppers. Details regarding traffic and parking would be
explored as part of the Cheadle Town Centre Masterplan as will measures to deliver a more
pedestrianised market approach.

With regard to the need for a dedicated Tourist Information Centre, Museum and Community
Arts Centre, the last bullet of part 1 of the Cheadle Area Strategy supports the provision of
additional community facilities however it is not role of this document to allocate such
facilities. For clarification „community facilities‟ would include places of worship.

In response to the need for a new Primary School in the north-east of the town, Staffordshire
County Council cannot give detailed requirements for education provision until details
regarding site boundaries, phasing and housing types are provided. It will not be possible to
provide this level of detail until the Site Allocations DPD document, however, the County
Council states that a new primary school will be required for development in an area totalling
1,000 dwellings. The first bullet of Policy SS5c does allow for the provision of educational
facilities and therefore it is not considered appropriate to make any further reference in the
policy.

The minor changes to the wording of the policy suggested by Sport England is agreed and
listed in the „suggested changes‟ section below.

In response to the creation of a Tean Valley Way between Kingsley and Checkley, Policy T2
supports and promotes the development of a network of safe walking routes linking
communities and recreational/tourist routes however it is not the role of the Core Strategy to
designate a route.

Broad Locations

It is encouraging that in general terms most respondents either fully or partially supported
development in the preferred broad locations. Specific comments on areas are considered
below.

In response to Cotton Parish Council‟s opposition to the preferred broad locations for housing
and employment in Cheadle, all locations were subject to a sustainability appraisal to assess
the social, environmental and economic impact of development. Those locations that were
considered to be most sustainable we selected for inclusion within the Draft Preferred Options
document.

With regard to Parks and Countryside comments regarding the impact of development on
biodiversity, there are no known local nature sites that would be affected by the development



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of this area, however the lack of data regarding phase 1 habitats is accepted. These surveys
will form an important element of the evidence base for the Site Allocations DPD.

Preferred Broad Locations

Areas 4 (south-west Cheadle) and 5 (south of Cheadle)

This area is allocated in the adopted Staffordshire Moorlands Local Plan for residential
development but a subsequent application on the site was dismissed at appeal (see further
evidence above).

In response to concerns over insufficient understanding of future traffic flows, a
Transportation Study will fully investigate this issue which will inform the allocation of sites,
their phasing and related highway requirements. The Development Capacity Study considers
Cheadle to have good accessibility with capacity for further development. A road would have
to be provided to gain access to new development but the advantage of a new road in this
location would also benefit the town centre by providing an alternative route for traffic on the
A521/A522. It is agreed that one of the benefits of a major urban extension (Areas 4 and 5)
is a link road, however these broad locations along with all the others were subject to a
sustainability appraisal and performed very well compared to other areas in terms of location
and type of land, accessibility, environmental impact, flood risk and community benefit. A
Masterplan will be produced to ensure that any adverse impacts from a new road can be
minimised.

In response to one comment raised, the southern link road defined on the Cheadle Inset Map
by a dotted line would continue south from the existing Brookhouse Way where the road
currently ceases, creating a full link from the A521 to the A522.

With regard to suggestions that land within the urban area and closer to the town centre
should be released first, Policy SD1 gives preference to allocating development on previously
developed land in the most sustainable locations and bullet 1 of Policy SS5c states that sites
within the urban area (area 8) is the first priority. However, the reasoned justification for
Policy SS5c does recognise that „it is impractical to deliver the scale and phasing of
development proposed for Cheadle by a strict adherence to a sequential approach to the
release of land‟ because it would not allow the infrastructure to be delivered at the right time
to allow for the growth to be sustainable.

In response to concerns regarding the impact of development on green spaces and residents
views, it is inevitable that some views would change and nearby residents would lose their
outlook over open fields. Landscaping and open space would be an important element of the
overall development of this broad location and will be considered in more detail at the Site
Allocations DPD stage and by a Masterplan. Developers will be required to provide various
types of open space as an integral part of any proposed scheme and also make contributions
to other types of open space where relevant (see Policy C2).

With regard to development in this area affecting wildlife, there are no known local nature
sites that would be affected. The next stage, the Site Allocations DPD will include a detailed
biodiversity site survey and assessment and identify any mitigation measures that would have
to be carried out as part of the development. The Environment Agency will be consulted
regarding drainage and flooding issues.

In response to the preservation of the railway line in Cheadle, the Council will safeguard all
existing disused railway lines within the District and support the reuse of these for public or
commercial/tourism use (Policy T2).

In response to the comments regarding the need for bungalows for the increasing older
population, Policy H1 states that new housing development should provide for a mix of
housing sizes, types and tenures and where appropriate housing for special groups. The
types of housing appropriate on particular sites will be explored as part of the Site Allocations
DPD and the Masterplan.


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Area 8 (Urban Area)

Area 8 (urban area) includes sites within the built up area that could accommodate 10 or
more dwellings and are a combination of brownfield and greenfield sites. In response to
comments that Area 8 would cause extra congestion in the town centre the Highways
Authority have not raised any concerns about the potential impact of development. The
Transportation Study will investigate this issue which will inform the allocation of sites, their
phasing and related highway requirements. The Site Allocations DPD would identify any local
highway improvements that would be required as a result of developing individual sites.

The site put forward for consideration at Bank Street has already been included within the
SHLAA as a potential development site. Precise land allocations will be made in the Site
Allocation DPD.

Area 1 (North Cheadle)

It is worth noting that no respondents opposed the principle of development in this location.
In response to the comments from Parks and Countryside that the nearby Cecilly Brook Local
Nature Reserve is a key breeding site for the protected water vole, a detailed biodiversity site
survey and assessment will be undertaken as part of the Site Allocations DPD to identify any
mitigation measures that would need to be implemented and also to explore opportunities to
expand the nature reserve and increase public access to it.

The site put forward for consideration at Froghall Road has already been included within the
SHLAA as a potential development site. Precise land allocations will be made in the Site
Allocation DPD.

Area 2 (North East Cheadle)

Again it is noted that the principle of development in this area is not opposed. The response
to the comments from Parks and Countryside is the same as for Area 1 (North Cheadle)
above.

Area EM1 (New Haden/Brookhouses Industrial Estate)

This area is allocated in the Staffordshire Moorlands Local Plan for employment development
and has not been developed. In response to the only comment received in relation to this
location, it is excluded from the green belt and lies within the Cheadle development boundary.
Although it is a greenfield site it is considered to be well related to the existing employment
sites off Brookhouse Way and Draycott Cross Road.

Area EM2 (Draycott Cross Road)

In response to two comments of respondents, this is a previous area of opencast workings
situated within the town development boundary and therefore not within green belt. The area
is partly being used for temporary employment uses, however there still remains capacity
within the site for additional employment provision. There is currently an undetermined
application for a scrap metal site within the south western corner of the site.

Other Broad Locations

Areas 6 (East of Cheadle) and Areas 7(South East of Cheadle)

In response to the respondents that supported the development of these areas for housing,
they did not perform as well as the other areas in the sustainability appraisal in terms of
social, environmental and economic impacts. It is considered that development of these
areas would result in significant intrusions into the countryside with no scope for infrastructure
or regeneration benefits.




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Area 3 (North West of Cheadle)

A small number of respondents supported development in this location on the grounds that it
is a logical infill between JCB and the north of Cheadle, however, Area 3 scored the least in
the sustainability appraisal due to its location in the green belt, incursion into the countryside
and lack of scope for infrastructure or regeneration benefits.

Other Areas

The other broad locations suggested were to the north of Park Lane in Cheadle and south
east of Cheadle. The area lying north of Park Lane lies within green belt, is in an elevated
position and is considered by the Landscape and Settlement Character Assessment as an
area of important landscape setting. The area to the south east of Cheadle is also considered
as an area of important landscape setting and has flooding issues. It is not therefore
considered appropriate to include these areas as broad locations.

Conclusions

It is considered that all of the preferred broad locations remain appropriate for development.
The 440 dwellings that could be accommodated within the Urban Area (Area 8) comprise all
the sites within the built up area, including some sites that were formerly within Area 1 (North
Cheadle), but exclude a site at Brookhouse Way. This site at Brookhouse Way has been
included as part of the Urban Extension (Areas 4 and 5) and together could accommodate up
to 700 dwellings. In addition to this there is a large site within Area 1 that could accommodate
up to 240 dwellings. Together this brings the total to 1380 compared to the overall
requirement for 1327 dwellings.

According to the calculations Area 2 which was listed as a preferred broad location and could
accommodate up to 190 may not be required, although if some of the sites included within the
Urban Area do not come forward it still may be needed. It is therefore considered appropriate
to retain Area 2 within Policy SS5c but add a proviso that it may not be required if the
requirement is met by the development of the other preferred locations. The inclusion of this
broad area would bring the estimated capacity of all of the preferred broad locations to 1570.


Suggested Changes
                nd
1. Amend 2 bullet point in item no. 1 of Policy SS5c (page 70) to read: „allocating a
    range of deliverable housing sites both within the urban area and, on land adjacent
    to the urban area. Sites within the urban area shall be in locations across the town
    which have good accessibility to services and facilities with priority being given to
    previously developed (brownfield) sites. Sites on land adjacent to the urban area
    shall be in locations which relate well to the urban area, can be assimilated into the
    landscape, and would help secure infrastructure improvements for the benefit of
    that part of the town. Locations for new housing development will be identified and
    phased through the Site Allocations DPD in the following priority order depending
    on the need for sites to be brought forward:
   o Within the Urban Area (Area 8)
   o South West Cheadle Urban Extension (Areas 4 and 5)
   o Extension to the Urban Area at North Cheadle (Area 1)
   o Extension to the Urban Area at North East Cheadle (Area 2) - this location will not
      be required if capacity is met by the development of the broad locations listed
      above.
               rd
2. Amend 3 bullet point in item no. 1 of Policy SS5c to read: „protecting, increasing and
   improving the provision and accessibility of open space, sport and recreational
   facilities, including the provision of a Sports Village. Specific areas will be
   identified through the PPG17 Audit and the Sports and Physical Activity Strategy.‟




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               th
3. Amend 5 bullet point in item no. 3 of Policy SS5c to read: „expanding the range and
   diversity of educational, health, sport, cultural and community services and
   facilities in the town‟.

4. Amend item no. 5 of Policy SS5c to read „The development of sites within the urban
   extension must be planned and implemented in a comprehensive way that is linked
   towards the delivery of key infrastructure to include a southern link road,
   community, open space, sport and recreational facilities and enhanced services as
   appropriate and viable. A Masterplan will be produced to guide the detailed
   planning of these areas and means of funding the required infrastructure.‟

5. Add following additional item no. 6 to Policy SS5c: „The benefits and viability of the
   provision of a bypass and the first phase comprising a southern link road should
   be confirmed by means of a Transportation Study.‟

6. Amend paragraph 8.1.59 of the Reasons and Justification to Policy SS5c to read „In order
   to deliver the housing requirements for Cheadle set out in policy SS5 it is estimated that
   there will need to be a minimum of 1335 1327 additional dwellings provided on new
   allocated sites.
               rd        th
7. Amend 3 and 4 sentences of paragraph 8.1.60 of Reasons and Justification to Policy
   SS5c to read: „The feasibility and funding options for a western bypass is currently under
   investigation requires to be fully investigated and it is unlikely that this can be fully
   delivered within this plan period. However, a phased scheme providing which aims to
   provide a southern link road can could be funded through a major extension to the south
   of the town and will allow for the partial implementation of the bypass‟.

8. Amend the first sentence in paragraph 8.1.61 of the Reasons and Justification to Policy
   SS5c to read: „The urban extension to the south west and south of Cheadle (areas 4 and
   5) is a key proposal for the town and will accommodate up to 700 dwellings. As well as
   aiming to facilitate the delivery of a southern link road, it will also enable other major
   social and recreational facilities to be delivered to serve this part of the town. These will
   be identified through a Masterplan which will provide a planning framework for the area
   and set out detailed infrastructure requirements.‟

9. Amend paragraph 8.1.62 of the Reasons and Justification to Policy SS5c to read: „As well
   as the urban extension, further greenfield sites will be required to deliver the housing
   growth needed. The preferred broad locations for the urban extension and to
   accommodate other development have been identified through the Sustainability
   Appraisal report as being the most sustainable location or which will help facilitate the
   provision of key infrastructure projects and it is in these locations that allocations could be
   considered. Some of this development will take place in the urban area on a mixture of
   brownfield and greenfield sites distributed around the town including infill development,
   redevelopment and conversions. In identifying sites preference will be given to brownfield
   sites particularly sites within or near to the town centre or redevelopment sites. The total
   estimated capacity on sites which could accommodate 10 or more dwellings within the
   urban area is 440 dwellings but this may vary as a result of more detailed assessment of
   sites as part of the Site Allocations DPD. Additionally, evidence from the SHLAA
   suggests that a further 50 dwellings could come forward on smaller windfall sites which
   can accommodate less than 10 dwellings. In order to meet the requirements for Cheadle
   further land outside the urban area is identified, although the need to release this land will
   be assessed against the release and likely release of land within the urban area. It is
   anticipated that Area 1 North of Cheadle could accommodate up to 240 dwellings. Area 2
   North East of Cheadle has also been included as a broad location and could potentially
   accommodate an additional 190 dwellings, however it will not be required if the capacity is
   met by the other broad locations listed in Policy SS5c. A summary of the broad locations
   is set out in Appendix G and their locations are shown on the Inset Map. The estimated
   capacity of all of the preferred broad locations totals 1365 dwellings which is sufficient to
   meet the requirements for Cheadle. With past completions and current commitments
   these allocations would provide in total 1793 dwellings for Cheadle which exceeds the


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    town‟s requirements (see table of provision) but will provide flexibility for slippage on
    constrained sites.‟

10. Include following table of provision within Reasons and Justification to Policy SS5c:

       TOTAL REQUIREMENT                                              1500
       Completions since 2006                                         40
       Current Commitments                                            133
       New allocations – Within the urban area                        440
       New allocations – South of Cheadle Urban Extension             700
       New allocations – North Cheadle                                240
       New allocations – North East of Cheadle                        190
       Windfall allowance                                             80
       TOTAL POTENTIAL PROVISION                                      1823




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SS6a, SS6b and SS6c - Rural Area Strategies
Introduction
Policy SS6 of the Core Strategy establishes the hierarchy of „larger villages‟; „smaller villages‟;
and „other rural areas‟ and resultant Policies SS6a, SS6b and SS6c set out the proposed
Area Strategy for each category of rural area including policy measures and actions. Whilst
Q22 asked for views on the whole strategy as it relates to rural areas, the following analysis
divides responses into the three categories. Q21 asked for views on the categorisation of
villages/settlements subsequently identified.

Policy SS6c also identified the Bolton Copperworks at Froghall and the Anzio Camp at
Blackshaw Moor as major developed areas suitable for regeneration. Qs 23 and 24
specifically request views on future uses.

This section is divided into comments and responses relating to the rural hierarchy,
area strategies, Boltons Copperworks and Anzio Camp. Suggested changes are at the
end of this section.


Summary of Comments

Comments from Questionnaires and Correspondence

Rural Hierachy

122 responses were made relating to the categorisation of the villages as part of the rural
hierarchy of which about 80% gave support or qualified support to the hierarchy.

Comments in support included the importance of providing affordable and family „starter‟
homes in villages; that larger villages act as rural „service centres‟ – so should accommodate
further appropriate growth; support for prioritising brownfield/infill options first, then peripheral
greenfield village sites; and that the hierarchy should allow for „natural growth‟ of villages.

There were mixed comments from statutory consultees:- Staffordshire Police, the
Environment Agency, the West Midlands RSL Planning Consortium and Kingsley Parish
Council were generally in support; however a number of Parish Councils were critical with
respect to the categorisation of their own, or other, villages (Rushton, Dilhorne, Caverswall
and Cotton Parish Councils).

Comments relating to specific villages include:
    Stockton Brook and Wetley Rocks should not be small villages
    Cauldon Lowe has industrial areas already and needs more housing, therefore
     should be small village
    Cresswell (should be grouped with Draycott ) and accommodate further residential
     growth
    Froghall has the potential to become a “large village” or even bigger
    Dilhorne should not attract any future housing (not even social housing) owing to a
     lack of services/facilities/utilities
    Ipstones should not be a large village
    Caverswall and Cookshill should not be a larger village. Further, because of past
     growth, and inadequate infrastructure, it should not accommodate any more housing
    Additional housing should be allowed in the washed over Green Belt villages of
     Longsdon and Rudyard.

The main concerns were that villages within the same category may have very different
physical characteristics; perception that only settlement size or capacity, have been taken into
account in the categorisation; whereas other factors (eg remoteness, ability to serve rural


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hinterlands) are just as important; that certain „larger villages‟ have had enough development
already (eg Cheddleton and Endon) sometimes to the detriment of „smaller villages‟; there is
still a need to provide additional facilities/services in remoter villages, irrespective of their
categorisation; housing locations should be demand and capacity led, rather than through
trying to „guess supply‟; and that it is only a broad, generalised categorisation.

General Comments on Area Strategies

In total there were approximately 110 general comments which covered all three policies of
which about 72% gave support or qualified support.

Comments in support include that there should be more relaxation towards greenbelt
applications; that larger villages should not be allowed to become towns; greater links to
services/facilities for village residents (for example when located in nearby towns) is vital for
village vibrancy /sustainability. Also that it must be borne in mind the relationship of these
villages with the District‟s towns, and the regional context. Whilst most new retail should be in
the 3 towns, village shopping provision is also important; there is overlap between the 3
Policy areas but the approach that village growth be commensurate to size/capacity/facilities
is correct.

The main concerns and issues raised were that the greenbelt should be protected; that in the
countryside certain types of development are not appropriate; policies do not do enough to
provide younger persons housing or make local communities self-sustainable; policies should
provide for villages to have workspaces; the Spatial Strategy Policies should provide for an
equality of distribution of facilities/services between all villages; more remote villages require
additional facilities/services irrespective of their categorisation; policy action should be taken
to stop small villages dying with priority against the loss of rural facilities/employers. Other
concerns were that there is too much emphasis on larger villages and that environmentally
friendly infill housing in small villages is acceptable. There were concerns at current traffic
problems/road safety issues in certain villages (Wetley Rocks, Blythe Bridge, Werrington)
whlst some considered that communities should be more „self-sustaining‟ in future.

There was a mixture of support, criticisms, and neutral comments from statutory consultees.
The Environment Agency, Rushton Parish Council, and Staffordshire Police gave
support/qualified support for the rural strategy. However British Waterways felt that in rural
areas development – apart from that aimed at “promoting rural activities” – is inappropriate
so a policy rewording was suggested -. "Further development is appropriate to promote rural
activities". WMRA argue that Policies SS6a and SS6b do enough to ensure sufficient local
needs housing will be provided in the countryside, therefore Policies SS6c and R2 are
superfluous and may lead to isolated rural dwellings being built. Ipstones Parish Council
are concerned that the intention of the spatial strategy appears to be to expand Leek
significantly at the expense of the other towns and villages. They also interpret para 8.1.69,
page 74 to mean that taking into account 2006-2008 commitments will mean no new rural
housing. The Sports Council also suggest that any reference to community halls should
include them being “multi-functional”, to ensure rural communities have access to community
sports facilities.

Policy SS6a (Larger Villages Area Strategy)

There were 22 responses specific to „larger villages‟. Positive or general comments include
that an assessment into the capability of each settlement to accommodate additional housing
should be carried out; that with respect to Oakamoor there should be better public transport
between Leek, Oakamoor and Ashbourne and also better banking and post office facilities
there. Various responses were in support of not only Upper Tean‟s inclusion as a larger
village, and consequent SS6b Policy measures, but also the suggestion of certain sites/areas
there for housing/industrial growth. Further to this it was also argued that the development
capacity study‟s poor „social infrastructure‟ rating for the village was on the one hand
erroneous, or that additional housing would stimulate additional facilities anyway.




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The main concerns and issues raised were that the greenbelt around larger villages
(especially greenfield land) should not be developed so as to encourage brownfield
development in northern Stoke and that some larger villages (Brown Edge) have had their
fare share of brownfield development already. However there was a counter-view that
existing village development boundaries were too inflexible – that there should be an
allowance for, for example local needs affordable housing to ensure the delivery of the
strategy in terms of ensuring village viability (an example given being Alton). It was also
commented that the policies should allow residential expansion in greenbelt next to main
roads and that there should be more support for certain types of rural diversification around
the villages. There was also concern regarding traffic growth in certain larger villages (eg
Oakamoor and Biddulph Moor). It was also suggested that when approving housing within
settlements consideration should be given to the most appropriate type and location of new
housing across that area, and whether it would genuinely be „affordable‟.

Again there was a mixture of comments from statutory consultees. The West Midlands
Registered Social Landlord Planning Consortium supports the general spatial strategy
approach towards town & larger village growth; and preference to brownfield sites etc. With
regards to „rural exceptions‟ affordable housing, they suggest sites should be “disperse
released” according to geographic need. English Heritage support the emphasis on new
development respecting individual character of villages. Ipstones Parish Council argue that
the current [Local Plan] Ipstones village boundary needs adjustment (as it erroneously cuts
through buildings). Staffordshire County Council firstly request that additional text is added
to the Policy that commits the Council to implement “a local area developer contribution
strategy where applicable”; and secondly they re-iterate the importance of an evidence base
of justifying the SS6 Policies against para 24 of PPS1. Caverswall Parish Council were
critical as they felt the rural strategy was too. The Sports Council questions what role the
larger villages have with respect to sport/recreation provision – the community use of schools,
or multi-use community centres.

Policy SS6b (Smaller Villages Area Strategy)

There were 27 responses specific to „smaller villages‟. Positive or general comments include
that an assessment into the capability of each settlement to take additional housing should be
carried out; that it is right that smaller villages only accommodate „organic‟ growth and nothing
larger; that local materials should be used; support for providing for local needs housing only.
Also a request that future infill boundary of Foxt include certain, peripheral village facilities.

The main concerns and issues raised were that the policy is too inflexibly worded eg in
restricting development to housing only whereas other types of development (such as
agricultural or quarrying) may be appropriate; and that the policy does not do enough to
address either existing shops/facilities shortfall, or inevitable shops/facilities closures, in some
smaller villages – so the priority for growth should be on these smaller villages, not other
villages. Another view was that the Policies should provide for a 5% increase in affordable
housing in small villages (possibly via infill development) to provide for village children to
remain in their village. It was also suggested that more remote villages require additional
facilities/services irrespective of their categorisation, that smaller villages should also provide
local employment opportunities for young locals and that there should be better public
transport serving these villages, preferably subsidised.

Some considered that greenfield development should be avoided and (brownfield) infill
development should be strictly controlled, as adverse decisions can negatively affect village
character. A related but possibly contrary comment was that future development in smaller
villages should not detract from the „open space‟ element of their built character. It was also
suggested that every small village should have a sewerage system connected before 2026.

The following responses were from statutory consultees. Cotton Parish Council
considered that more affordable housing is needed in both Cotton and Cauldon Lowe than is
currently proposed. Similarly Endon with Stanley Parish Council felt the Core Strategy was
not place specific enough, in that locations in that Endon or Stanley were not pinpointed. They
also argue that the most important issue is that local occupancy needs are met. British


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Waterways query why infill development would not normally be permissible beyond smaller
villages, ie where a „frontage‟ does exist. Dilhorne Parish Council object strongly to future
housing development in their village on a number of grounds and that further housing would
exacerbate problems. Kingsley Parish Council argue that previous „rural development‟ has
not materialised, resulting in the loss of a number of shops/post offices/pubs [it is not stated to
which village(s) they refer]. Rushton Parish Council feel that the current development
boundary for Rushton Spencer is correct for the purposes of a future infill boundary.
Staffordshire County Council argue that reference to “local social or economic need” in
SS6b should also refer to “community need”. Further, and as per SS6a, they again suggest
that additional text is added to the Pol SS6b that commits the Council to implement “a local
area developer contribution strategy where applicable”.

Policy SS6c (Other Rural Areas Area Strategy)

There were 31 responses specific to the „other rural areas‟. Positive or general comments
were that the general strategy for rural areas, and in particular support for farm diversification,
was supported. One respondent suggested that part 3 of SS6c could be slightly more
positively phrased so as to permit “suitable development in the countryside” – a re-wording of
existing text was suggested.

The main concerns and issues raised were that more local needs housing is needed for
young locals, because local housing is currently unaffordable; many remote villages (eg
Threapwood) continue to lose facilities/services or do not have sufficient facilities/services
already; more provision should be made for rural facilities; there should be more local
employment opportunities for young locals. There was a view that policy SS6c should have
additional text allowing for the (residential) redevelopment of existing „smaller developed sites‟
in the countryside where this is consistent with the wider development strategy and it does not
                                                                                          st
support development to meet family needs. There was also a view that Part (3) 1 bullet
should be amended slightly, to be more positively worded to permitting “suitable
development” in the countryside.

With regard to the green belt, it was suggested that part 6 of the Policy contradicts itself ie by
stating it will maintain green belt with strict control, but then saying detailed boundaries will be
reviewed. It was also suggested that greenbelt coverage should be extended to include
Heaton and Meerbrook.

The following comments were made by statutory consultees. Whilst Odd Rode Parish
Council were supportive of the priority of brownfield over greenfield sites, Kingsley Parish
Council expressed disagreement with the „Other Rural Areas‟ Strategy. Cotton Parish
Council were adamant that more affordable housing is needed in both Cotton and Cauldon
Lowe than is currently proposed. English Heritage supported the policy emphasis on
respecting village character, however they also suggested additional text in Policy SS6c to
refer to the protection/enhancement of the District‟s heritage. The National Trust suggest
that the Policy wording be amended to better safeguard the landscape of the Peak District
National Park. Further, the Peak District National Park Authority make detailed comments
which explain how Regional Guidance iterates what LPAs duties are with respect to
conserving the environmental quality of national parks. For these reasons it considers that
the core strategy policies should make specific reference to the need for decisions to
conserve and enhance the valued characteristics of the National Park. Therefore the current
wording in Policy SS6c only refers to "enhancement" and to "recognising":- it should be
amended to "conserving and enhancing" as required by the EA 1995.

Bolton Copperworks

A total of 31 comments were made specifically in relation to the Bolton Copperworks site as
well as 72 comments on alternative uses for both Boltons and Anzios.

Continued industrial or employment use was supported by some whilst some felt that Bolton‟s
should stay industrial/commercial and not change to other uses either because of
pollution/amenity issues, or owing to contamination legacy. Separately, there was support for


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“commercial mixed use”. Separately it was argued that owing to existing infrastructure and
utilities connections, contamination issues, and because of its large size, Bolton‟s would be
best marketed for a large [industrial] employer. Some had traffic concerns, arguing that the
acceptability of employment is dependent on traffic flows.

Leisure and/or tourism as uses were also popular. One felt the site should become a holiday
resort. Another felt there was a „need‟ for “tourist retail provisions”. The “key location” of the
site in the Churnet Valley Tourist Corridor was identified by many, for example one argued
“we must not miss this opportunity to combine the current tourist sites of railway and canal
with a leisure/craft/museum and heritage centre type development to boost and enhance
tourism in this area”. Others argued that redevelopment would need to be sensitively done
because of the Churnet Valley Tourist corridor:- with one arguing that uses other than for
tourist accommodation and leisure (or “developments associated with the Churnet Valley
Railway or the canal”) should not be allowed at Bolton‟s for this reason. Related comments
about the canal were that a green corridor should be left along the route of the canal to allow
for a heritage trail and for its long term restoration.

Some respondents were not against mixing residential/commercial/tourist/retail/leisure uses,
subject to scale and sensitivity of development. One felt the site should be used to create a
large new village. Another comment that because the site would become in effect a „village‟
in its own right, development would need to be innovative and include certain community
facilities and that care should be taken not to overdevelop the site. As per Anzio Camp, wider
points were made that the site needs reinvestment, but that development levels in major
developed areas should only „subsidise‟ wider strategies.

A number were opposed to any housing on the site - housing should be focused in existing
settlements instead. Common reasons for this include the negative impact on residential
amenities at Bolton‟s (if industrial uses continue), concerns over traffic/highway capacity, the
large nature of the site [resulting in too many dwellings] and the current lack of local
shops/school etc. One respondent felt that just because the site is brownfield does not justify
redevelopment other than for a small retail craft centre – especially given the exceptional
quality of the rural area. There were also traffic concerns expressed.

In terms of alternative uses, specific suggestions included a local heritage centre, Oakamoor
Action Group and others suggested a marina and other improved facilities for boats that
would attract more to the Caldon Canal (and Churnet Valley Railway). One argued that
Bolton‟s as a brownfield site could be expanded and redeveloped.

Stirling Investments consider that the identified range of land uses is appropriate for a site
which offers significant potential for environmental enhancement; and as the masterplan for
the site is progressed the extent of each land use will be clarified taking into account physical
constraints and commercial viability.      The site is capable of accommodating a significant
mixed use development which as well as meeting local needs will provide facilities to serve
the wider area. Regeneration of the vacant land around the copperworks will provide a range
of benefits, include securing the future of Bolton Copper, providing economic benefits, as well
as enhancing the local environment through remediation of surplus brown field land and
removal of derelict and redundant buildings, creation of additional tourist facilities, creation of
a mixed use sustainable development, new residential development to meet local needs
whilst generating sufficient value to secure the package of regeneration benefits. Comment
also that potential leisure and tourism related uses could be a visitor centre / museum facility
for the Churnet Valley Railway, canal side restaurant, small scale retail uses and a hotel. As
part of a mixed use development it is considered that tourism development will result in
significant environmental and economic benefits consistent with the objectives of the Core
Strategy. The inclusion of an element of residential development will be essential to achieve
the regeneration of the site. In order to cover costs this could be around 4.3 hectares.
Residential development at Froghall would ensure that a significant amount of the rural
housing requirement would be developed on a brown field site. An appropriate mix and
tenure of housing could be provided. A masterplan is currently being prepared for the site
taking into account physical constraints including flood risk and ground conditions. The



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masterplan will identify parcels of land for various uses.            Detailed economic and market
analysis report included as part of representation.

In terms of statutory consultees, British Waterways were supportive of the Bolton‟s
proposals. Cotton Parish Council appear to support both proposals. English Heritage
point out that development of Bolton‟s would need to be informed by appropriate survey of
any remaining industrial heritage. The Environment Agency have no drainage related
concerns about development at Anzio Camp. However, significant parts of the Bolton‟s site
are affected by flooding along the main river corridor, two watercourses affect the site. So EA
would need a detailed site specific Flood Risk Assessment to be undertaken in order to
comment further on details such as flood flow routes, flood plain preservation, climate change
and safety.

Ipstones Parish Council disagree with any large scale residential development at the
Bolton‟s site, as there is not the infrastructure for it. The preferred option is for a mix of
industry, leisure and tourism to include a retail park, similar to the one at Trentham Gardens
and a heritage centre. This would enhance the existing attractions of the Canal Basin and
Steam Railway and create employment opportunities. It is also very important to protect the
existing employment and provide more opportunities for further employment.

Kingsley Parish Council does not agree with the classification of "other Rural Areas" in
respect of Bolton‟s which it considers should be placed in the "Small Villages" section as it is
situated in the village of Froghall. It objects to the inclusion of two sites (Anzio Camp/ Bolton
Copperworks) in one single question as this would appear to encourage comment by
individuals/ groups on whom any development would have little if any impact. Comment that
the views of the residents of Froghall and Ipstones should have a greater impact on any
developments at Bolton Copperworks than the views of individuals or groups outside these
parishes. Rushton Parish Council support both proposals.

Staffordshire Police were generally supportive of both sites. They did not suggest any
alternatives although argue “..the integration of key areas such as Alton Towers with Alton
Village should remain a core consideration”.

WMRA argue that further assessment and justification should be provided to support the
redevelopment of the two..sites at Blackshaw Moor (15.4 hectares) and Froghall (17
hectares). In particular the consequence for housing delivery and the preferred development
strategy of permitting significant amounts of residential development upon either or both of
these sites should be examined and demonstrated. It should be noted that the provision of
extra care housing as suggested at Blackshaw Moor would be seen as contributing to the
RSS housing requirement and not additional. Supporting evidence should be provided with
respect to the nature of the rural need to be satisfied by the redevelopment of these sites and
some indication on the scale of development which may be acceptable in such rural locations.
The core strategy is clear in other rural areas that only a limited amount of development
justified to meet local needs, will be considered acceptable outside of the main settlements
within the District.

Anzio Camp

A total of 23 comments were made specifically in relation to the proposals for Anzio Camp as
well as 72 comments on alternative uses for both Boltons and Anzios.

Positive or neutral comments were that Anzio Camp would be ideal for (light) employment use
or “commercial mixed use” or that it should only be used for industrial/commercial
development. Also that only tourism/leisure would be appropriate together eg, camping,
caravanning parks, outward bound camps. Another view was that employment be combined
with tourism/leisure, but that housing should only occur within settlements. Some views were
that it should become a retirement/extra-care village (with on-site health care facilities) as
suggested in the policy. However a major criticism to this was that Anzio Camp is too
remote/unsustainable for extra-care/retirement housing.



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General comments included that redevelopment needs to be sympathetic/unobtrusive, owing
to the beautiful location – redevelopment should not exceed existing built mass. Comment
that because both sites would become „villages‟ in their own right development would need to
be innovative and include certain community facilities. Wider points were that both sites need
reinvestment, but that development levels in major developed areas should only „subsidise‟
wider strategies.

In terms of alternative uses, housing [ie that not specified as “extra-care”] was supported by
some, both „upmarket‟ and „low cost‟. Other comments (common to Anzio Camp and Boltons)
include that retail would not be viable, that central government research labs could be
accommodated, that brownfield opportunities for housing and commercial development
should always be sought; it would be suitable for a gypsy site; and that the Council should
respond to requests for uses rather than „guessing‟ uses.

The owner of the Anzio Camp site (Smartwright Developments Limited) welcome the
suggested uses (employment; extra care housing; and tourist accommodation) as these are
consistent with those documented as accepted in principle by the District Council when
Defence Estates marketed the site in 2005. Comment that it is a matter of record that the
local community is content in principle with this extra care housing re-use as they participated
in the design process, and the Parish Council has responded constructively to the planning
application consultations. Comment also that tourist accommodation is an interesting
alternative use which would be compatible with some existing developments in Blackshaw
Moor such as the Caravan Club site and the Three Horse Shoes Hotel. Welcome this use in
principle, and can see possibilities as a component of a mixed use development or large
scale (but compatible with the setting) stand alone tourist accommodation and facilities.
Employment is a possibility we welcome, though the site location suggests that this is not a
premium site.

In terms of statutory consultees, Sport England support the Anzio Camp proposals as they
believe it includes sports provision; but this is subject to the facilities being appropriate to the
type/age of community proposed. Anzio Camp sports facilities should be encouraged for
retention and community use. Others made comments on both Anzios and Boltons (see
Boltons Copperworks responses for these).

Alternative Sites as Major Developed Areas

A number of respondents put forward alternative sites as major developed areas:
 Land at Cresswell as it has excellent road links to A50 Stoke-Derby and to sustainable
    town and village centres via local level bus routes [location not specified].
 Land at Leekbrook suggested for appropriate and sympathetic housing development.
 Cotton College request that a specific policy for the restoration of and enabling
    development at Cotton College be included in the Core Strategy in order to clarify its
    situation and aid future restoration.
 Area nearer to Tean – this reduce..traffic in Cheadle with a road link to A50. [location not
    specified]
 Existing developed sites adjoining, or close to existing settlements can contribute to
    sustainable housing development. For example, existing workshops and adjoining
    developed land at Winterfield Lane near Weston Coyney [near Hulme].”
 Allocating Moneystone Quarry as a strategic development site in the emerging Site
    Allocation DPD given its key location in the Churnet Valley Tourism Corridor and
    proximity to Oakamoor and Whiston. It is considered that development at Moneystone
    Quarry could deliver significant sustainable economic benefits and make a significant
    contribution towards rural diversity, tourism, recreation and leisure objectives”.
 Poor quality land off Buxton Road” [location not specified].
 For Cheadle [location not specified]




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Comments from Consultation and Stakeholder Events

In terms of the hierarchy of rural settlements, the following views emerged from the
consultation and stakeholder events:
     Upper Tean‟s position as a larger village was queried by some
     Caverswall‟s „larger village‟ status was criticised – owing to disagreement over
      facilities listed, infrastructure issues, and a desire to see it physically unchanged
     Concern that Werrington being a larger village may necessitate greenbelt loss owing
      to future allocations, or successful rural exceptions housing on its edge
     Cheddleton, was large enough already; and did not have the range of
      facilities/services of other „larger villages‟. Similar views were expressed about Endon.
      Both were perceived to have highway capacity problems.
     There was some agreement with Blythe Bridge‟s „larger‟ status – further a small
      medical facility is proposed there, and Moorlands Housing may also have identified
      potential housing sites there. However there were concerns at rush hour traffic in both
      Endon and Blythe Bridge and therefore additional housing would exacerbate this.
     Swinscoe should be a „smaller village‟ with an infill boundary – it is larger than some
      „smaller villages‟
     Some felt Ipstones did not need much more growth and did not want its village identity
      being lost; whereas others feel there is scope for local needs „infill‟ housing.
     Consall expressed a need affordable housing for local people
     One view that Froghall could accommodate further growth (eg local needs housing) -
      however some felt there were already highway/infrastructure problems there; and there
      is an apparent conflict if a „small village‟ is to be next to a „major regeneration
      opportunity‟
     Strong view that Oakamoor should not be a “larger village” (because of topography
      and lack of play facilities, and because SMD have not yet considered its road
      capacities). However, additional affordable housing was viewed more favourably. It
      was also commented that proposed Churnet Valley Corridor would make Oakamoor
      traffic worse.
     Comment that both Boundary and Dilhorne have legacy of mineworkings which might
      work against future development, and Dilhorne has only limited infill opportunities
      anyway.
     There was agreement for Rushton Spencer being a „smaller village‟; and Thorncliffe
      not having this status (whilst allowing for local needs housing).
     Some felt that a better categorisation approach would be to „couple‟ adjacent villages
     Common view that the estimated housing split between „larger‟ and „smaller‟ villages
      was weighted too heavily towards „larger villages‟:– some smaller villages eg
      Whiston/Foxt/Cauldon Lowe/Ipstones are desperate for housing whereas some larger
      villages eg Cheddleton/Endon are too developed already. A more individualised
      approach was thought needed.
     The schools meetings produced mixed views on this subject – some felt that smaller
      villages should get more growth because they are small (to support local facilities);
      whilst others felt this would be unviable; would generate unsustainable travel patterns;
      would endanger the countryside/greenbelt between villages; and would only result in
      unaffordable village housing anyway - therefore housing should be concentrated in the
      three towns.

In terms of the strategies for larger villages, smaller villages and other rural areas, the
following views emerged from the consultation and stakeholder events:
      Neighbourhood Forums - In Upper Tean concerns were expressed with respect to
       lack of retail facilities especially when compared against recent housing growth. For
       this reason some did not want further development. Also more play facilities provision
       was sought. In Blythe Bridge there were concerns as to how individual „community
       facilities‟ in villages would be protected in Core Strategy. The role of Village Action
       Plans in an evidence base, was questioned by some.
      Cotton Parish Council meeting - Because of affordable housing shortages in many
       small villages in the District, each „small‟ village (including „smaller‟ and certain sub-
       smaller villages) should receive a „one-off‟ allocation of about 6 dwellings (a mix of


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       open market/affordable/agricultural). Consequently „smaller villages‟ should attract a
       higher proportion of the overall rural housing requirement (and not restricted to local
       needs housing). Also felt that were Cauldon Lowe to be expanded in future, this would
       be preferable via „infilling‟ as opposed to peripheral expansion. View that certain
       „smaller‟ and sub-smaller villages eg Cauldon Lowe, should attract local occupancy
       housing which is village-specific in the first instance (ie open to village residents only).
       It was felt there would always be a demand for such units from qualifying residents. It
       was queried if the rural housing requirement reflected demand from the rural area.
       Concerns as to how individual „community facilities‟ in villages would be protected in
       Core Strategy.
      Kingsley Parish Council meeting - considered that Kingsley has specific shortage of
       detached housing.
      Leek Town Council meeting - had general concerns about greenfield development in
       urban areas.
      Rushton Spencer Parish Council meeting - considered that they had different
       physical characteristics from other „smaller villages‟, however did not object to their
       „smaller‟ classification in itself, nor Policy SS6b measures. They also questioned
       whether „backland‟ development could occur as infill development. The role of Village
       Action Plans in an evidence base, was questioned by some.
      Werrington Parish Council meeting - were generally in favour of local needs housing
       policy in general, although were concerned if this might result in loss of peripheral
       greenbelt (under the exceptions policy). Also the loss of public houses (community
       facilities) was an area of concern; and a desire was expressed for a new leisure centre.
       It was queried why housing would be allowed at Bolton‟s given that it is contaminated.
      Moorlands Housing are generally supportive of the spatial strategy however consider
       that affordable housing is a major problem in both „larger‟ and „smaller‟ villages –
       especially bungalows, and shared equity dwellings generally. They have identified
       potential affordable housing sites in Dilhorne, Caverswall, Draycott and Blythe Bridge.
      The Peak Park Planning Authority iterate that they are seeking to have no housing
       requirement in the RSS, and presently only have a notional „per annum‟ target. Like
       Moorlands Housing they propose to re-use empty properties for affordable housing
       (and need around 59 affordable dwellings a year). PPPA do not normally allow
       residential barn conversion on cost and remoteness grounds.
      North Staffordshire PCT meeting - made it clear that their practice is to concentrate
       facilities in the three towns, and to reduce the need to travel by for example remotely
       monitoring „rural‟ patients. Consequently there are no plans for further rural facilities,
       except at Blythe Bridge. Older People‟s housing, such as extra care housing, is
       similarly better located in non-remote locations where there is access to shops, bus
       routes, and community facilities (and where relatives may live already); and are better
       for care staff who of course must live nearby.
      Older Person‟s Forum - emphasised how local facilities and bus routes are important
       for older people, and how reducing the need to travel is desired – this has implications
       on the strategic provision of older people‟s services ie where older people should live -
       there should be either more sheltered housing, or tailored provision of other housing in
       different rural areas. In the Schools/Younger Persons Meetings it was questioned if,
       where new employment and new housing are located nearby, would this work be
       available/suitable to those residents.

At the Parish Council Workshops it was questioned how individual village boundaries will
be determined, and whether this would „encompass‟ all (possibly outlying) village facilities
identified. In general there was strong agreement with the concept of „smaller village‟ infill
boundaries; further there was a strong desire to see greenbelt remain undeveloped,
especially between and around towns/villages. In general there was strong support for
affordable and local needs housing for young people in all villages and support for the higher
50% requirement in larger villages (and lower size thresholds generally). There was also
discussion around rural „phasing‟ – ie there needs to be scrutiny to avoid some of the larger
villages using up all the rural requirement. It was considered that there should be better rural
public transport as a whole, especially integrated (meeting connections), and in the evening.
Criticisms that SS6 Policies as a whole [and other policies] may give preference to tourism


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over the (housing) „needs‟ of local villages in some situations eg barn conversions. Therefore
some felt that local needs housing should be the „first option‟ for a rural building conversion.

There was support at the Parish Council Workshops for the principle of employment
development in rural areas – allowing rural expansions etc. However there were concerns
that 5.4ha employment land is not enough outside the 3 towns (the exception to this being
around Blythe Bridge/Draycott/Cresswell, owing to proximity to the 50 ha Regional Investment
Site allocation). Start-up units were supported too, although it was argued that rental levels
should be affordable. „Live-work‟ developments were supported subject to being sensitively
located. In general it was hoped that rural industrial developments could provide employment
to locals first, before outsiders [even though the planning system could not require this]. One
common view was that existing industrial land should remain industrial (for reasons of
amenity, contamination issues etc).

A frequent comment at the Parish Council Workshops was that the current housing market
crisis would presumably affect building rates therefore housing figures should reduce (and
also that existing empty properties should be utilised first). In terms of infrastructure existing
highways capacity was considered crucial in deciding where to develop; also the related point
that consideration must be given to how development in one settlement affects the road
network in surrounding areas. It was questioned as to whether renewable energy
developments were included in the spatial strategy.

In terms of the Anzio and Boltons Copperworks sites the following views emerged from the
consultation and stakeholder events:
      At the Older Peoples‟ Needs Meeting reference was made to a [recently refused]
       application for a care retirement community development at the Anzio Camp site – this
       was supported in principle subject to issues such as scale. However in general it was
       noted that the approach of service providers is to focus extra-care facilities around
       towns, where facilities/services/bus services etc already exist, which are easier for staff
       to access (and where relatives may live already).
      At the Parish Council Workshops there was general support for housing in both
       locations subject to highways issues being addressed. Anzio Camp - Redevelopment
       was supported. There was general support for the recently refused application for a
       care retirement community development at Anzio Camp though issues were raised
       about transport owing to site‟s remoteness. On the other hand there was objection to
       the extra-care proposal due to lack of services/bus services, and again remoteness.
       Employment and possibly budget hotel suggested instead. Argued that the road is
       dangerous (speeding). May be no interaction between new and existing community.
       Boltons Copperworks - It was argued that you cannot redevelop Bolton‟s site without
       having first considered road infrastructure; and secondly that not only would traffic be
       increased around site, but also through Kingsley and Froghall. One suggested that
       industrial sites in general remain industrial; another that housing and employment
       cannot co-locate (on amenity grounds); in any case new dwellings should be of
       sympathetic design and reflect area. There was objection to housing due to lack of
       infrastructure. Employment (small business units) should accommodate most of the
       site; and possibly a hotel (as part of Churnet Valley Tourist Corridor) - however a
       counter-view was that the site needs a mix of uses. It was questioned whether any
       open market housing would „count‟ against the rural requirement.


Further Evidence and Other Issues
The Sustainable Communities Act 2007 came into force in October 2008. This has the
effect putting a duty on the Secretary of State to promote the sustainability of communities via
allowing residents (via Local Authorities) to suggest practical changes to [Planning] law or
policy to achieve this.

The Community Infrastructure Levy forms Part 8 of the 2008 Planning Bill. According to
DCLG the Bill will allow LPAs to apply the levy to fund sub-regional infrastructure (over and
above planning fees). The nature of these schemes will be identified in the RSS or from local

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research, so that LDFs can identify them at the local level. A wide definition of „community
infrastructure‟ is suggested ie transport, schools, health centres, flood defences, play areas
etc, such that “development can be…made sustainable”. Clearly this has implications for all
three Pols SS6a-c, in as much as developers may be required to contribute to establishing or
improving village facilities, public transport etc, such that less accessible areas become more
accessible/sustainable. See also Transport Policies and Sustainable Development Policy
Sections.

The Matthew Taylor Review identifies that rural communities face pressures affecting their
sustainability from restrictive planning practices, a low supply of housing (particularly
affordable housing) to meet local needs, and very high house prices which are unaffordable in
relation to local wages.

The Development Capacity Study produced for the Council assessed each large village
against social infrastructure (education, healthcare, community/social activities, leisure
facilities and emergency services) physical infrastructure (electricity supply, gas supply water
supply and sewerage) and accessibility (public transport and highway network). It concludes
that only Blythe Bridge and Ipstones are rated green for all three elements so they have the
greatest capacity for development without significant investment in infrastructure. Brown
Edge, Kinglsey and Werrington are rated amber meaning that supply is currently adequate
but may be outstripped by future demand, whilst Alton, Caverswall/Cookshill, Cheddleton,
Endon, Oakamoor, Upper Tean and Waterhouses are all rated red meaning that supply
currently falls shorts of demand and the situation may worsen in future without further
investment. Most of the shortfall is in the health services.



Officer Response

Rural Hierachy

The significant level of support is encouraging as is the recognition that village categorisation
is commensurate to village size and range of facilities, and the sequential approach of
identifying brownfield sites within villages first, before peripheral greenfield sites. In response
to comments that the categorisation approach excluded „remoteness‟ of certain villages; and
that smaller villages were more vulnerable to decline than larger villages, the Core Strategy
evidence base (Development Capacity Study) does refer to village „accessibility‟ as a criterion
in its assessment [which is comprised of public transport availability & travel times, and
access to „A‟ Roads]; and it is considered no parts of the District are so remote as to warrant
a different approach, as this would undermine sustainability principles. Further, policies in
other sections of the Core Strategy (and National Guidance) do address meeting limited „local
needs‟ economic/community development (and protection of existing facilities).                  The
fundamental principles behind the spatial strategy mean that local needs are met in a
sustainable manner, with necessary controls over development in unsustainable locations,
and to protect countryside/greenbelt. For clarification the District would not include any Peak
Park villages, however the wider geographical context of settlements (and hinterlands) in the
hierarchy was considered.

The request to see more open market housing in the smaller villages, and less in the larger
ones, must be viewed in the context of a District-wide approach at meeting local needs
sustainably, and avoiding unsustainable travel patterns. Further the wording of the SS6b and
SS6c Policies is clear in allowing for limited affordable/local needs/rural worker housing. Also
as to the concerns that certain „smaller‟ villages should not expand further; it must be borne in
mind the above policies are clear that this would result from tightly delineated infill in the first
instance and only for affordable/local needs housing. All settlements (even ones not
identified as „smaller‟) would benefit from affordable/local needs housing under this wording.
It is significant that the broad spatial strategy approach of directing most future growth to the
larger, or best served settlements is also the approach of medical and older persons service
providers.



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The categorisation of villages takes into account a number of criteria including population,
accessibility, and facilities/services. A number of strong objections to the classification of
certain villages has been noted – these mostly pertain to a desire to see certain larger villages
“downgraded” to smaller villages. It is considered that in most cases, the initial categorisation
of the 13 „larger‟ villages is broadly correct - they all have sizable populations already and
generally have the better access to facilities/services (either on-site or accessible in nearby
towns) and many benefit from the better „Stoke-centric‟ public transport patterns. Although the
development capacity study does point to over-capacity in terms of some services within
these villages, many services in these centres do have remaining capacity. Furthermore,
although issues of over-capacity were argued to be material such that certain villages be
“downgraded”, it must be borne in mind that the Spatial Strategy policies do not at this stage
consider how allocations be apportioned between the larger villages:– so just because a
village is „large‟ it does not follow there will automatically be allocations (of any kind) in the
near future. Further, issues of over-capacity in different areas (eg highways) can, to a lesser
extent be addressed through the existing planning contributions system.

However, in the light of concerns regarding the categorisation of certain villages, all of the
villages have been reviewed to determine which would be the most appropriate category and
a number of changes are suggested below.

Area Strategies

In terms of the broad approach to development in the rural areas and meeting RSS
requirements, it is encouraging that a majority of the overall comments (and especially the
comments relating to all three categories) were supportive.

In response to suggestions that there should be more employment provision in the rural
areas, it must be borne in mind that whilst the proportion of employment provision is less than
the proportion of population in the rural areas the distribution reflects the broad spatial
strategy towards employment development directing most growth in/around larger
settlements, around transport hubs, or employment areas and also recognising constraints on
development in countryside and green belt areas.

In response to concerns regarding the level of housing provision, the requirement for the rural
areas is based on local need and capacity in the settlements whilst the actual provision has to
take account of past completions and current commitments in order to avoid any over-
provision.

In terms of the relative amounts of development in each settlement, it is proposed to prioritise
sites between settlements in a way which not only reflects the hierarchy but is also informed
by capacity, accessibility, landscape character issues etc. It is considered that this would
more appropriately be done through the Site Allocations DPD when full consideration can be
given to individual sites

With regard to concerns that there was insufficient provision of housing (largely affordable or
local needs) in the smaller villages to meet local needs, the Area Strategy for smaller villages
does allow for appropriate levels of development to meet local and affordable housing needs,
whilst the Area Strategy for the other rural areas makes reference to provision meeting local
needs (which may include affordable housing). It is considered that this would be sufficient to
sustain these settlements but avoid over-development. It is acknowledged however that the
policy as currently worded does not make clear reference to the provision of affordable
housing in the smaller villages and other rural areas and this should be incorporated.

It is not agreed that outside larger villages, provision should be made for any open market
dwellings (other than in exceptional cases such as rural workers‟ dwellings) because these
are not the most sustainable areas and such provision should be directed towards the larger
villages and towns where the infrastructure exists to support such housing. Market housing
would also be unlikely to meet local needs and may only serve to preclude more essential
affordable and local needs housing from being provided.



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In terms of how local/affordable housing provision would be „tailored‟ to the needs of
individual settlements, it is acknowledged that requirements will vary from place to place
owing to average income differentials. The District Council consults closely with its Housing
Section with respect to the above issues. Policy H1 also makes it clear that larger
developments (10+ dwellings) must provide a range of dwelling types, and also provide 20%
lifetime homes (these are dwellings designed to be more suitable for older- and disabled-
users, which would therefore pre-empt the need for such users to “downsize” later in life).

In response to comments concerning environmental issues, for examples calls for housing to
be more eco-friendly, this is addressed in policy SD1 which sets out minimum requirements
for housing to incorporate sustainable construction techniques and on-site renewable energy
in line with the RSS.

With regard to concerns regarding the conversion of barn conversions to residential use being
restricted to „local need‟, this is addressed in relation to policy R2. In response to concerns
about conversions to tourism and commercial use taking precedence over local needs,
national planning guidance does require giving precedence to commercial uses before
residential. The onus would be on the owner or developer to demonstrate that such uses
were not viable. This is also considered further in the responses to Policy R2.

It is acknowledged that the issue of retail, employment and public transport provision in the
rural areas is also a significant concern and in this respect the Area Strategies for the Rural
Areas do give support for such provision to meet the needs of settlements and their
hinterland. Whilst the Council itself could not make such provision, it can support such
provision through the determination of planning applications and in its role as an enabler and
in conjunction with other service providers. It is also contended that, in „larger‟ villages which
are identified for future housing growth (especially those attracting allocations), increased
population would in part stimulate further demand for local retail provision etc from the private
sector. Policy SS6a allows for small-scale new employment development / expansion /
redevelopment in „larger villages‟ whilst policies SS6b & SS6c similarly allows for existing
rural firms (including live-work), and rural diversification in other settlements. The wording of
these policies would also not preclude „starter units‟ which was supported by some. Further,
in the case of larger villages, outside of employment allocations, employment development
might be permitted (subject to amenity issues etc) in/around the development boundary;
likewise within „infill‟ boundaries in smaller villages. It is however considered that there should
be a definition of live/work units in the Glossary.

In response to comments regarding encouraging the multi-use of facilities, including comment
from the Sports Council, whilst this is not specifically mentioned within the Rural Area
Strategies, the SS6 Pols do promote the expansion of village facilities/services in general and
policy C1 also lends support to the multi use and shared use of community facilities [which
would include schools]. The District-wide approach to sport/recreation facilities provision is
laid out under Pol C2.

With regard to the provision of rural bus services this is largely beyond the remit of the District
Council and the responsibility of the County Council through the Local transport Plan,
although there may be circumstances where planning contributions towards bus services from
developers are required). However because the spatial strategy is geared towards
sustainable District-wide growth, many of the „larger‟ and „smaller‟ villages are those located
along the best bus routes that presently operate throughout the District.

It is encouraging that there was general agreement as to the approach of identifying “infill
boundaries” in the smaller villages, so long as resultant development would be sensitively
achieved. In response to questions regarding specific circumstances, schemes would have to
be decided on a case by case basis, taking into account all material considerations. With
regard to issues regarding the density of rural residential development, these are set out in
Pol H1 (which is based on PPS3 requirements). The delineation of future infill boundaries,
will be undertaken as part of the Site Allocations DPD and will in part be informed by the
results of the District Council‟s recent Landscape Character Assessment. It is not however
considered appropriate to extend the use of „infill boundaries‟ to other settlements beyond the


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smaller villages as whilst there may be examples of other „ribbons‟ of built-up frontage in the
countryside, it does not automatically follow that these would be appropriate settlements for
continued growth with recourse to sustainability criteria other than built form. Having said this,
there may be cases where a „rural exceptions‟ scheme in such an area, may be otherwise
acceptable under Pol H2 (and if it is a brownfield site may be preferable to other alternatives
in that settlement).

In response to the comments of the WMRA that there was no need for provision of (local
needs) housing beyond SS6a/b areas, it is considered that policy SS6c makes it clear that
„rural exceptions‟ housing in other rural areas, whilst acceptable in principle (as a genuine
need may arise), must be shown to not first be locatable in „larger‟ or „smaller‟ villages. This is
considered sufficiently flexible without prejudicing the overall strategy at directing most
housing to „larger villages‟ ie because if a “need” could not be demonstrated, approval would
not normally be granted.

It is noted that there were many comments supporting the protection of greenbelt in general,
especially between villages/towns. The essential nature of greenbelt is its permanence –
where future greenbelt allocations are proposed around settlements in the Site Allocations
DPD, this will need to be fully justified and then be subject to consideration by the Inspector.
The Site Allocations DPD may also consider the need for minor modifications of the green
belt boundary to reflect local circumstances, but significant green belt boundary changes can
only be made where this is supported by the RSS.
                                                                                        th
It is agreed (as suggested by English Heritage), in the interests of clarity, that the 5 bullet of
Part (3) of policy SS6c should also refer to “heritage”, the Policy will be amended. National
                                                     th
Trust‟s suggestion for additional text under the 4 bullet relating to the Peak Park is also
agreed with – since policy SS6c makes most reference to protecting the quality of the
countryside. Further, the PDNPA‟s criticism that Part (3) makes no reference to “conserving”,
is justified. These changes to the Policy are therefore suggested.

It is not however agreed that the words “avoiding over-development” in para 8.1.71 (Reasons
and Justification) need further emphasis – the sentence refers to the need to balance a
number of factors equally. It is also not agreed that SS6c Part (3) should be amended to
imply that rural activities are “suitable” or should automatically be promoted since there may
be situations where „rural development‟ shouldn‟t be promoted; and secondly the
appropriateness of rural development is specified in more detail in other Policies (R1, also R2,
T1 etc).

Similarly it is not agreed that additional text is needed under Part (4) policy SS6c to authorise
additional „smaller developed sites‟ for housing redevelopment (subject to location and
characteristics). The 3rd bullet already addresses this; to make further concessions would
undermine the Rural Strategy. For the same reason, it is not considered that a separate
Policy for redevelopment of Cotton College is require - any proposal for such would need to
demonstrate the 3rd bullet requirements.

It is not agreed [with Staffordshire County Council] that polcies SS6a-b should refer to
implementing local area developer contribution strategies – the forthcoming Developer
Contributions SPD will consider the scope for these. However, reference to “community” need
under Part (2) policy SS6b is agreed with, and the text will be amended.

Bolton Copperworks and Anzio Camp

Overall there was a high degree of support for both proposals, in general and individually. It
should be noted that part (4) of policy SS6c uses the word “may”, as the range of potential
appropriate uses will be subject to further examination under the Site Allocations DPD. Also it
is not intended that the running order of uses at either site in the Policy text bears any relation
to preferentiality.

It is agreed however that development levels in major developed areas should only „subsidise‟
                                                    nd
wider strategies, as is made clear in the Part (4) 2 bullet. The two major developed areas


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proposed are suggested as rural sites requiring regeneration under the RSS Policy RR1
(Rural Renaissance): additional to the wider thrust of the Rural Area Strategy and wider
Spatial Strategy, geared at attracting most future growth to the most sustainable areas. It is
considered their redevelopment would not prejudice this because whilst both sites cover a
significant area, redevelopment would be constrained by not only environmental/highways
factors, but also viability factors; that is, in the case of open market housing [not extra-care],
this would be limited to that required to „enable‟ wider mixed use schemes, and in most cases
would be limited to meet the needs of the “local area” [possibly defined on a „ward‟ basis].
However it is conceded this could be made clearer in the Reasons and Justification.

Large-scale business uses (B1 and B2) would be limited to the provisions of policy E1 so only
small scale B1 [light industrial] employment uses could be condoned – and in reality its scale
would further be limited by market viability, as it is clear that neither site is in an optimum
location.

The range of uses deemed acceptable on both sites will be more closely examined during the
preparation of the Site Allocations DPD, including reference to scale, and site constraints.
The viability of various uses will be explored by the District Council with the sites‟ owners. The
DPD will also set out the requirement for applicants to submit a design brief or masterplan
(and what this would have to cover). In any case where an applicant proposes a major
scheme, in most cases they would be required to submit accompanying evidence detailing
contamination, environmental and traffic impacts. Also in the case of „enabling‟ housing this
would be required to be demonstrated the minimum needed to “enable” a larger mixed
scheme. The District Council is not proposing large-scale housing at either site, as this would
be considered contrary to the wider Spatial Strategy. Further it is likely the subsequent Site
Allocations DPD will iterate „maximum‟ housing levels at both locations – for clarification this it
is suggested that this be made clear in the Reasons and Justification.

In terms of the additional uses suggested by respondents, housing as a use in its own right at
Anzio Camp was not included in the Policy owing to sustainability (remoteness) and
environmental impact concerns. Tourist (or leisure) related development at Anzio Camp may
be appropriate subject to scale/ environmental impact. Any extra-care housing schemes
would have to be justified by evidence of need, with scale/environmental impact carefully
considered. With regard to retailing and hotel uses, this would only be acceptable were it is of
an appropriate scale and associated with the leisure and tourism offer. Individual suggestions
for museums/heritage centres, and canal related developments at Bolton‟s (or in the Froghall
area) would not appear inconsistent with the Policy as worded. In the case of both sites, the
desire for total or partial „reversion‟ of brownfield areas (for example landscaping as part of
larger mixed uses schemes) must be balanced against the desire to make the best use of
brownfield resources available.

A number of alternative „major developed‟ areas were suggested. None of these are
considered to be major regeneration opportunities, but this would not preclude them being
considered under Part (4) of the Policy. The Council would again invite suggestions for
specific sites during the site allocations DPD consultation stage. It is not considered that the
Policy as set out should be amended to refer to any of the examples individually, nor that an
                                                     rd
additional Policy is required for this purpose; the 3 bullet sets out the Council‟s position in
                                                  rd
this regard. However it is considered that the 3 bullet could more clearly explain that not all
areas will be appropriate to develop on environmental or highways grounds; and also to
distinguish a “major developed area” from that of a major developed site which is defined
separately.


Suggested Changes

Rural Hierachy

1. That further consideration be given to the classification of the following villages:-
   Oakamoor – to be reclassified as a „smaller village‟ under Pol SS6b, not SS6a.
   Kingsley Holt – to be reclassified as a „larger village‟ under Pol SS6a, not SS6b.

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   Swinscoe – to be reclassified as a „smaller village, under Pol SS6b, not SS6c.
   Wetley Rocks – to be reclassified as a „larger village‟ under Pol SS6a, not SS6b.
2. The following paragraph be added to the Reasons and Justification to Policy SS6: “When
   the Core Strategy is reviewed, the District Council will re-assess the categorisation of
   villages, based on their respective services, facilities, populations, and capacity to
   accommodate further growth ”.

Policy SS6a (Larger Villages Area Strategy)
               nd
1. Amend 2 bullet point of item no. 2 of Policy SS6a (page 75) to read “allocating a range
   of deliverable housing sites primarily within the urban area in locations across the
   town village with good accessibility to services and facilities. Where development
   is required to be met on land outside the urban area this will be only of a small
   scale and on sites outside the Green Belt which relate well to the urban area, can
   be assimilated into the landscape and have good access”.

Policy SS6b (Smaller Villages Area Strategy)

1. Amend first sentence of item no. 2 of Policy SS6b (page 77) to read: “„Meet local
   community, social or economic need by:”

2. Amend first bullet point of item no. 2 of Policy SS6b to read: “Enabling new housing
   development which is essential to local needs, including affordable housing (in
   accordance with Policy H2)”.
3. Insert following new sentence at end of paragraph 8.1.75 of Reasons and Justifications to
   Policy SS6b: “This also includes live-work units, since the occupant will be local.”

4. New entry in Appendix H Glossary (starting on page 160) to define “live-work” unit as
   follows: “Live-work units are units of living accommodation, which are specifically
   designed to accommodate work facilities for those residing therein. They may arise from
   conversion or from new-build, and can occur in both urban and rural areas. As residential
   use is justified by an element of employment use; planning conditions are normally
   attached that specify maximum/minimum percentages of residential/employment
   floorspace”.


Policy SS6c (Other Rural Areas Area Strategy)

1. Amend first bullet point of item no. 1 of Policy SS6c to read: “Restricting new housing
   development to that which is essential to local needs, including affordable housing
   (in accordance with Policy H2)”.

2. Amend first sentence of item no. 3 of Policy SS6c to read: “Enhance and conserve the
   quality of the countryside by:”
               th
3. Amend 4 bullet of item no. 3 of Policy SS6c to read: “Recognising and conserving the
   special quality of the landscape in the Peak District National Park, in accordance
   with Policy DC3"
               th
4. Amend 5 bullet of item no. 3 of Policy SS6c to read: “Encouraging measures which
   protect and enhance the biodiversity and geological resources, and heritage of the
   District”.
               rd
5. Amend 3 bullet point of item no. 4 of Policy SS6c to read: “Facilitating the appropriate
   redevelopment of other major developed sites areas where the proposed
   development brings positive benefits to the area and measures are implemented to
   mimimise environmental impacts including traffic generated any resultant
   environmental or highways concerns could be adequately addressed and
   minimised.”



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6. Amend item no. 5 to read: “Enhance tourist opportunities by:
   o Identifying the Churnet Valley between Leek and Alton as a major sustainable
     tourist corridor in accordance with Policy SS7. Within this corridor the
     following forms of development and measures will be supported:
          short stay and long stay visitor accommodation;
          tourist facilities and services;
          extension of the Churnet Valley Railway;
          links to strategic footpaths/cycle routes;
          improvements to the Caldon Canal;
          sensitive expansion of Alton Towers
   o Any development should demonstrate strong sustainable development
     principles and be sensitive to the landscape and biodiversity of the area. A
     Masterplan will be produced to guide the detailed planning of the corridor.
   o Supporting improvements to the Alton Towers and Denstone road link and other
     alternative means of access to Alton Towers;
   o Allowing for small-scale tourism developments in other areas;
   o Establishing strong linkages between recreational and tourist resources;
   o Recognising and developing the close linkages to the Peak District National
     Park.

7. Amend paragraph 8.1.82 of Reasons and Justification to Policy SS6c to read: “Historically
   development of a large scale has taken place in a number of areas in the countryside of
   Staffordshire Moorlands, often associated with past industrial activity or specific needs.
   These are brownfield sites and where these are no longer needed it is necessary to
   consider whether an alternative use would be appropriate. The complete or partial
   redevelopment of such major developed sites areas may offer the opportunity for
   environmental improvement without adding to their impact as well as helping to meet the
   needs of the rural areas and improve the rural economy. This is supported by RSS Rural
   Renaissance Policy R1 which promotes improvements in housing choice and the rural
   economy, and environmental quality in rural areas. Two such areas have been identified
   at:
         Bolton Copperworks, Froghall - The historic copper factory of Thomas Bolton
          and Sons most of which is now closed and derelict apart from a small section that
          services copper wires. It lies within an area of high landscape and tourism value
          adjoining the village of Froghall. The whole site occupies an area of approximately
          17 hectares comprising of a range of industrial buildings. Its strategic location at
          the centre of the Churnet Valley Tourist Corridor is considered crucial to the
          Corridor‟s success.
         Anzio Camp, Blackshaw Moor – Former army training base located 3 miles to the
          north of Leek on the southern edge of the Peak District National Park. Site extends
          to some 15.4 hectares and includes 17 existing buildings.

8. Amend paragraph 8.1.83 of Reasons and Justification to Policy SS6c to read: “The extent
   and nature of future development of both of these sites will be identified through the Site
   Allocations DPD. This will also specify maximum levels of dwellings permissible on both
   sites and will also determine type of housing (ie whether affordable, local needs, tenure
   etc). Significant amounts of housing will not be permitted on either site. At the Bolton
   Copperworks site any housing permitted shall be limited to that required to cross-
   subsidise other uses. At the Anzio Camp site any extra care housing shall be of a scale
   required only to meet local needs which cannot be otherwise met in a settlement. Any
   housing which falls within Use Class C3 (Dwellings) will count against RSS housing
   requirements.”




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Churnet Valley Tourism Corridor
Introduction
The Churnet Valley Tourism Corridor is a significant new initiative in the Preferred Options
Core Strategy which aims to manage and promote the Churnet Valley as a major tourism
area by facilitating opportunities for further appropriate visitor accommodation and tourist
facilities, improving and developing links between existing activities and facilities and
establishing new links with regional tourism facilities. It is identified and referred to in Policy
SS6c and also Policy E3. Consultation on the Preferred Option Vision specifically asked for
views on the proposed Churnet Valley Tourism Corridor (Q25).


Summary of Comments

Comments from Questionnaires and Correspondence

There were 140 responses made relating to the Churnet Valley Tourism Corridor. From those
who responded there was almost unanimous support for the initiative with only 2 objections.
Generally it was considered that it is an excellent idea which would be positive for the local
economy and reinforce the District‟s role as a tourist destination provided that it is properly
and sensitively implemented and does not undermine the natural beauty and heritage of the
area.

Issues of concern which were raised were:
     overdevelopment spoiling what tourists have come to see;
     impact on local roads and infrastructure and amenities being inaccessible;
     tourist sites in other parts of the area should not be forgotten;
     concern regarding unacceptable roads and traffic conditions in the Alton area to serve
      Alton Towers. Care must be taken over further growth at Alton Towers, particularly until
      the link road is installed and in operation
     note that the Churnet Valley Tourism Corridor passes through Leekbrook, which is an
      area where the industrial development of small units is incompatible with its
      surroundings.
     Boltons Copperworks site spoils a central point in the designated tourism corridor –
      needs sensitive redevelopment;
     concern that Staffordshire County Council have not carried out many rights of way and
      highway improvements as promised through Consall;

Many respondents have also made suggestions for improvements or further expansion of the
Corridor:
     Further concentration on the historical aspect of the area – heritage centre;
     Construction of a Canal Marina at the bottom of Ladderedge;
     Improve the bridleways, cycle links and footpaths - around Bradnop, from Meerbrook to
      Roaches;
     Include Rudyard as it is linked to Leek already by the disused railway track.
     Make better use of canals and towpaths - Caldon Canal with its Leek arm could and
      should become important
     Support for Uttoxeter Canal restoration that will run from Froghall through Oakamoor
      onto SCC owned land to Denstone then into East Staffs as this will bring rural
      regeneration from Froghall to Uttoxeter.
     Provide amenity for less obtrusive leisure pursuits like walking, cycling, boating and a
      scenic railway;
     Manage extra car traffic on single track roads and parking for walkers and cyclists.
     Extend the Corridor to Biddulph
     The Churnet rail line could be brought into Leek with links into the town centre.




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      The canal areas near Leek could be rejuvenated. Local small-businesses aimed at the
       tourist (restaurants/cafes/ antiques/ gifts) could thrive. A hotel aimed at the tourists
       could fit in with the environment and create employment opportunities.
      Should not support the building of new "chain" hotels, but would support small, locally
       owned hotel and B&Bs etc.
      Film companies, corporate events, the possibilities are endless.
      Extend to include the Canal to the Western border, up the Leek branch and the
       Churnet Valley Railway to the Peak border on the A53. This will support the extension
       of the railway and the canal, the provision of a marina for the canal (in the Endon/
       Longsdon area) and the provision of more tourist accommodation on the boundary of
       the Peak.
      Extend east of Alton and into East Staffordshire District.
      Strategy should pay particular regard to the role of Alton and its hinterland having
       regard to the availability of land suitable to accommodate appropriate tourist facilities
       and short and longer stay tourist accommodation whilst not adversely impacting on the
       most sensitive locations within the corridor.
      Quality of the area needs to be improved to attract visitors.
      A good range of holiday accommodation will be necessary to support the increased
       tourists - abandoned and derelict properties should be brought into use;
      Further parking is required at the steam rail museum.
      The Churnet Valley Tourism Corridor should be made a highlight of the Staffordshire
       Moorlands but it should also pave the way for other existing freight and public corridors
       such as the Creswell - Cheadle corridor.
      Cheadle should be included in this as it has not been able to benefit from the Peak
       District rural funding - it needs a dedicated T.I.C/museum. Over emphasis of the
       Corridor should not cause other leisure/tourist initiatives to be overlooked e.g. tean
       valley way, foxfield colliery.
      A future rail link for commuters to Macclesfield should be considered this would
       stimulate employment, retail and housing in the Leek area.
      Consider allocating Moneystone Quarry as a strategic development site in the
       emerging Site Allocation DPD given its key location in the Churnet Valley Tourism
       Corridor and proximity to Oakamoor and Whiston. It is considered that development at
       Moneystone Quarry could deliver significant sustainable economic benefits and make a
       significant contribution towards rural diversity, tourism, recreation and leisure
       objectives.
      Offers the opportunity to develop links and extend the existing network of green space
       and provide green corridors.

1 individual suggests that the Churnet Valley should be designated as an AONB and is
looking to the Council for support for its designation.

Responses from statutory consultees and local organisations were also generally supportive
of the proposal. Rushton Spencer Parish Council considered it a good idea to encourage
the railway but resist other development in the valley between Froghall and Leek to preserve
natural beauty in the area. Kingsley Parish Council suggest the need for greater liaison
between Railway authorities, Canal authorities and any future development at Bolton Copper
Works. All parishes which the proposed Tourism Corridor passes through need to be kept
informed of any developments. Ipstones Parish Council comment that the Churnet Valley
Tourism Corridor appears blind to the opportunity that the Bolton's site offers. Tourist related
retail and then leisure come last on the list of possible future uses of the site. Peak District
National Park consider that policies for tourism could also be related more strongly to the
strategic context of the nearby National Park.

Alton Towers Resort Operations Ltd welcome the Council's proposals to designate a
"Major Sustainable Tourist Corridor" in the Churnet Valley between Leek and Alton. In
particular Alton Towers supports the provision of additional visitor accommodation and the
sensitive expansion of Alton Towers. However consider that the third bullet point of
paragraph SS6c(5) should be amended to: "support improvements to the principal access



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routes to Alton Towers via the villages of Farley and Alton". The amended text will promote
improvements from all existing access points rather that just from the Denstone Road link.

Oakamoor Action Group do not consider the southern expansion of the Churnet Valley
Railway beyond Oakamoor Tunnel to be appropriate nor do they consider the southern
expansion of the Uttoxeter Canal from Froghall to be appropriate. Suggest a marina at
Froghall.

Churnet Valley Railway (1992) PLC support the intention to identify the Churnet Valley as a
major tourism and recreation corridor. Agree that there are significant recreational assets in
the Churnet Valley, including the Churnet Valley Railway itself including both the active
railway and the former railway corridor. In particular support the aim of increasing the
recreational and tourism potential in the Churnet Valley, the provision of new tourism facilities
and accommodation and a possible extension to the Churnet Valley Railway where it is
practical and feasible to do so. This can compliment other recreational and operational
infrastructure to form part of the assets serving the community, business and visitors to the
area. English Welsh & Scottish Railways also support the corridor as a means of
protecting the rail corridor within the local authority's area of responsibility. British
Waterways support the proposal but suggest a Caldon Canal tourism corridor should also be
considered.

National Trust recognises the potential of the valley to support sustainable tourism but
consider that there is a need to protect and enhance the landscape and environment of the
valley. Are disappointed that the preferred options document mentions no alternative
approaches to the Churnet Valley. An example of an alternative approach could be a
sustained focus on reinforcing landscape character. It is not stated whether the "Masterplan"
referred to in policy SS6c will be an Area Action Plan or a Supplementary Planning Document
- consider that an Area Action Plan should be produced to allow the detailed policies for the
valley to be established with full stakeholder engagement, sustainability appraisal and
independent scrutiny. An AAP would also have additional weight and formal standing. Are
also most concerned that further expansion of Alton Towers has the potential to harm the
landscape of the area and the registered historic park - this is too important and contentious a
matter to be left to SPD. Feel that strategic biodiversity and landscape enhancement should
be made objectives of the Churnet Valley Tourism Corridor, if that proposal is taken forward.

Natural England comment that there are many SSSIs designated for semi natural ancient
woodlands, neutral and acid grasslands in the Churnet Valley, which should be recognised at
SSS6c. There is a need to recognise and protect the designated sites and the river valley as
wildlife corridors so they are not compromised by visitors or development. English Heritage
reserve their position on the proposed „sensitive expansion of Alton Towers‟ until have further
information in the form of the forthcoming SPD. The second bullet point in this section should
also refer to „heritage‟. Environment Agency have no objections in principle to this Tourism
Corridor provided that there is no increase in flood risk at any point. Would seek reductions in
flood risk wherever applicable or possible.

Staffordshire County Council support „improvements to the Caldon Canal‟ - advise that a
Conservation Area Appraisal for the Caldon Canal be produced to inform works to this
important route through the District. It should be noted that Alton Towers is identified as
being Grade 1 on the English Heritage Register of Special Historic Parks and Gardens.
Consequently English Heritage should be fully consulted on any future plans. Staffordshire
Police comment that this is a significant priority to encourage wider tourism in the area and
will need sensitive balance with the attractions of Alton Towers.

Government Office for the West Midlands welcome the commitment to supporting the
improvements to the Alton Towers to Denstone road link and other alternative means of
access to Alton Towers. Question whether the Churnet Valley Tourism Corridor gets a high
enough profile being part of SS6c.

Advantage West Midlands comment that the proposal supports the W Midlands Visitor
Economy Strategy and will extend the tourist offer of the region.


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Comments from Consultation and Stakeholder Events

There was general support from the Parish Council Workshops for this initiative, as long as
it is sensitive, some concern was expressed that there was a risk of too much emphasis on
tourism and needs of villagers being secondary. Some specific concerns were also made
regarding footpath provision around Consall, traffic and road infrastructure (particularly in
relation to Alton Towers) and need to ensure tourism is of the right sort and of an appropriate
scale. At the Public Consultation Events there was general support for the proposal but
concern was expressed by some regarding traffic and road infrastructure implications and
suggestion of a Heritage Centre in the Churnet Valley.


Further Evidence and Other Issues
No further evidence or other issues have been identified relating to the Churnet Valley
Tourism Corridor.


Officer Response
The level of support for the Churnet Valley Tourism Corridor initiative is very encouraging as
are the large number of suggestions made for improving and extending the initiative. It is
understandable that some respondents have strong concerns regarding its implementation
and the potential impact on local roads and the intrinsic qualities of the Valley. However, the
Policy makes it clear that any development should demonstrate strong sustainable
development principles and be sensitive to the landscape and biodiversity of the area.

Policy SS6c is intended only to establish the principles of the Churnet Valley Tourism Corridor
initiative – identifying the appropriate forms of development and measures which are
supported. As stated in the Policy, a Masterplan will be produced to guide the detailed
planning of the corridor – this will address many of the specific suggestions made in the
responses including identifying suitable areas for development which would be taken forward
through the Site Allocations DPD. The comment from the National Trust regarding the lack of
consideration for other opportunities such as a sustained focus on reinforcing landscape
character is noted. Whilst it is not considered appropriate to suggest this as an alternative as
it would not be consistent with the vision for the District, it is considered that there should be a
stronger emphasis on landscape character enhancement and greater recognition of the need
to protect the designated nature conservation sites and the river valley as wildlife corridors so
they are not compromised by visitors or development and to help reinforce the special
qualities of the area. It is also acknowledged that the restoration of the Uttoxeter canal should
be incorporated as an option to be further explored through the Masterplan (including
potential conflict with proposals to extend the Churnet Valley Railway) and that any
redevelopment of the Boltons Copperworks at Froghall needs to be an integral part of the
tourism corridor and that this should be made more explicit. It is also considered that there
should be additional reference to the need for complimentary highway improvements of
access routes and other alternative means of access to serve any significant developments.

It is anticipated that the Masterplan will be produced during 2009 and will itself be subject to
sustainability appraisal and consultation before being adopted as a Supplementary Planning
Document. The suggestion by the National Trust for an Area Action Plan (AAP) is not
however supported. Whilst the Churnet Valley Tourism Corridor initiative would fall within the
scope and purpose of an AAP as defined in PPS12, the production of an AAP would
represent a very significant area of work for the Council which could take up to 3 years to
complete. Furthermore, it is considered that an AAP would not add significantly in terms of
value to the planning guidance which could be achieved through an SPD. It is accepted,
however, that having a separate policy for the Churnet Valley Tourism Corridor would help
provide a stronger and clearer strategic context for any subsequent Masterplan and SPD and
also give the initiative a higher profile within the Core Strategy.



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It is noted that there is concern regarding the impact of the continued expansion of Alton
Towers. However, this is a key tourist facility for the District and the region which is
acknowledged as such in the RSS and the Core Strategy Vision and its continued
development as a viable and commercially successful resort based attraction needs to be
recognised and supported. An updated SPD will guide its future development in a way which
seeks to minimise any adverse effects on the area and the local community and this should
be incorporated into the Policy. The provision of the Alton – Denstone road link should also
continue to be investigated as part of any Transportation Study for Alton Towers.

With regard to the suggestion that the Churnet Valley be designated as an AONB (Area of
Outstanding Natural Beauty), this would clearly have significant implications for its future
management and development. It is considered that it would be inappropriate at this stage
for the Council to give any commitment to such a move (the designation of which is in any
case one of the discretionary powers of Natural England) until such time as further work has
been undertaken through the Masterplan to assess the area and evaluate the implications of
any AONB designation.

The extent of the Churnet Valley Tourism Corridor is indicated only diagrammatically on the
Key Diagram and the Masterplan will define its coverage more precisely. The Masterplan
would also give an opportunity to consider linkages to facilities and areas outside the Churnet
Valley, such as those parts of the Caldon canal east of Cheddleton, the Peak District and
parts of East Staffordshire. Notwithstanding this, the suggestion to extend the broad extent of
the Corridor to include Rudyard is considered appropriate in view of the range of
complimentary tourism and leisure facilities and the cycle and footpath links it provides.


Suggested Changes
1. Add following new policy SS7 (Churnet Valley Tourism Corridor):

    „The Churnet Valley shall be identified as a major sustainable tourism corridor.
    Within this corridor the following forms of development and measures will be
    supported:
           o short stay and long stay visitor accommodation;
           o tourist facilities and services;
           o extension of the Churnet Valley Railway;
           o links to strategic footpaths/cycle routes;
           o improvements to the Caldon Canal;
           o the potential for restoration of the Uttoxeter Canal;
           o the redevelopment of the Bolton Copperworks site at Froghall (see
              Policy SS6c);
           o the sensitive expansion of Alton Towers
           o measures to enhance its landscape character and to protect the
              designated nature conservation sites and the river valley as wildlife
              corridors

    Any development should demonstrate strong sustainable development principles
    and be sensitive to the heritage, landscape and biodiversity of the area.
    Complimentary highway improvements of access routes and measures to support
    other alternative means of access will be required to serve any developments
    which generate significant demand for travel.

    A Masterplan will be produced to define the detailed extent of the corridor and
    guide the detailed planning and management of the corridor.

    Further development at Alton Towers shall be considered against guidance set out
    in a Supplementary Planning Document. This shall include, as appropriate,
    measures to improve the principal access routes to Alton Towers via the villages of
    Farley and Alton and the provision of the Alton – Denstone road link.‟



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2. Add following Reasons and Justification:

    The Churnet Valley, running from Rudyard Lake and Tittesworth Reservoir through Leek,
    Cheddleton, Froghall and Oakamoor to Alton, is an area of significant landscape, wildlife
    and heritage value with a number of existing well-established tourist and visitor
    attractions.     The Churnet Valley Tourism Corridor is a major development and
    management initiative which will provide a strong focus for sustainable rural regeneration
    across the District and a significant sub-regional asset as well as complementing and
    easing pressures on the neighbouring Peak District National Park. The aim will be to
    focus opportunities for further appropriate visitor accommodation and tourist facilities
    along the corridor, improve and develop links between existing facilities and activities so
    that they are benefiting from each other, and maintain and establish links with regional
    tourism facilities, such as the National Cycle network and Staffordshire Way. This will be
    supported by measures to improve access by public transport, walking and cycling into
    the countryside.

    The expansion of the Churnet Valley Railway and the continued sensitive growth of Alton
    Towers phased with measures to improve access will be a key element of this corridor.
    Any expansion of Alton Towers will be determined through a SPD which is currently being
    prepared. This will also address the implementation of the Denstone and Alton Relief
    Road (part of the proposed route falls within the Moorlands) so that traffic through these
    areas associated with Alton Towers can be relieved. The LTP still supports the
    development of this route in principle. However, tourism development must not be at the
    expense of the special qualities of the Staffordshire Moorlands which draw so many
    people to the District in the first place. A very sensitive approach to the provision and
    expansion of facilities and accommodation will be required. The proposed Masterplan will
    provide the framework for achieving this and will be adopted as Supplementary Planning
    Guidance.




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SS7 - Blythe Bridge Regional Investment Site
Introduction
Policy SS7 seeks to safeguard the Blythe Bridge Regional Investment for high quality
development falling within Use Class B1 and where appropriate B2 uses to meet regional
economic needs. Question 26 requested comments on any of the policies in the Preferred
Options Core Strategy.


Summary of Comments

Comments from Questionnaires and Correspondence

There were only 2 responses made relating to this policy.

St Modwen Developments Ltd strongly support the inclusion of the policy in the Core
Strategy. They are however concerned regarding the detailed wording of the policy which
requires development to be in accordance with the adopted Development Brief which was
originally drafted in 1995 and approved in 1997. Whilst the underlying principles of the
Development Brief are still relevant they consider that detailed design guidance is over
prescriptive and based on design guidance that is now out of date with current Government
advice and guidance. Consider that it would be wholly appropriate to review and update the
Development Brief. Also recommend that the wording of Policy SS7 should not prohibit
alternative uses that fall outside Class B1 Use and that a degree of flexibility should be
included to facilitate, in addition to Class B1 Uses, an appropriate mix of Class B2 and Class
B8 Uses, in order to help generate employment opportunities important to the local and
regional economy particularly given the scale of the Regional Investment Site. In addition
recommend that the wording of Policy SS7 also makes allowances for some ancillary uses
such as provision of on site support services and facilities for future occupiers and employees
(which fall outside the above use classes).

The Highways Agency is concerned that the draft policies have not yet been informed by a
transport evidence base and could therefore be considered unsound at examination. PPS12
states that a Core Strategy should be supported by evidence of what physical, social and
green infrastructure is needed to enable the amount of development proposed, and to be
considered sound, the policies must be deliverable. Paragraph 4.28 of PPS12 highlights the
importance of obtaining agreement from key stakeholders in terms of the deliverability of the
Core Strategy. With this in mind, the Highways Agency wishes to flag potential 'delivery'
issues that may arise from the development near the A50 and the implementation of Policy
SS7.


Further Evidence and Other Issues
The Employment Land Study 2026 Update (September 2008) identifies a need for 24
hectares of employment land for the District up to 2026. It comments that there is also
potential to meet part of the demand in the regionally significant employment site at Blythe
Bridge, although they recommend the intensification of existing employment sites should be
prioritized in the first instance.


Officer Response
This site was identified in the Staffordshire Structure Plan and the adopted Staffordshire
Moorlands Local Plan as a „Premium Employment Site‟ and has the benefit of an adopted
Development Brief. The emerging RSS Review also continues to recognise the site as a
major strategic employment site for North Staffordshire proposing its inclusion as a „Regional


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Investment Site‟. The site also does have an extant outline permission for employment
development as well as detailed permission for an access road and for development of part of
phase 1. It is not accepted therefore that there are any potential issues regarding delivery of
the site.

In terms of appropriate uses, the emerging RSS Review clearly states that developments on
RIS will be strictly controlled “falling within Classes B1 and, where appropriate, B2”. It
considers that warehousing-only developments (i.e. B8) should not be permitted on these
sites. It is not therefore considered appropriate to include B8 uses in the policy.

It is however acknowledged that the Development Brief is now over 10 years old and may no
longer be appropriate for controlling further future development in the light of more recent
government guidance and changing economic and transport needs. It is therefore considered
proper that the brief should be reviewed which will also give an opportunity to address the
scope for accommodating other supporting uses as well as re-assessing highways and
transport requirements. A minor amendment to the policy to reflect this is therefore
suggested.


Suggested Changes
1. Renumber as Policy SS8

2. Amend policy (page 83) to read: “The Regional Investment Site at the junction of the
   A50 with the Blythe Bridge bypass shall be safeguarded for high quality
   development falling within Classes B1 and where appropriate B2 of the Use
   Classes Order to meet regional economic needs. Development will be strictly
   controlled to ensure that it supports the objectives set out in the RSS and accords
   with the adopted or any subsequently revised Development Brief.

3. Add following text to Reasons and Justification: “In the light of more recent government
   guidance and changing economic and transport needs since the original development
   brief was adopted in 1997, the brief should be reviewed which will also give an
   opportunity to address the scope for accommodating other supporting uses as well as re-
   assessing highways and transport requirements.”




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DEVELOPMENT CONTROL POLICIES

SD1 - Sustainable Development
Introduction
Pol SD1 is the single Policy broadly dealing with sustainable development in the Core
Strategy. As it broadly addresses tackling climate change through sustainable resource use, it
covers many aspects:- sustainability of location; brownfield versus greenfield development;
contamination remediation; renewable energy generation installation (both stand alone- and
incorporated-); location and orientation of such development; sustainable construction
techniques; pollution control, and flood risk.


Summary of Comments

Comments from Questionnaires and Correspondence

There were around 30 responses either specifically addressing the SD1 Policy, or as
miscellaneous comments pertaining to climate change/sustainable development. About 40%
were qualified criticisms; 13.33% were qualified support, 43.33% were neutral comments.

Positive comments included: that the Policy is a good planned response to climate change,
that the brownfield v greenfield development target was supported; in particular the general
approach to brownfield and sustainable sites, being prioritised, subject to the acknowledged
“exceptions” to this approach. The approach at avoiding high flood risk areas was supported,
as was the general support towards renewable energy developments.

Most comments were from statutory consultees many of which were critical of some
elements of the policy. The Environment Agency consider Policy SD1 is not adequate and
needs to re-written to make it clearer. Also there needs to be a Sustainable Drainage Policy
(SUDS) incorporated within the document concerning surface water drainage. They also
made a number of other suggestions that site contamination be investigated by developers
before - not during - an application. They requested specific reference be made to the 2000
Water Framework Directive (which governs water quality across Regions). It was opined that
a water cycle study would be beneficial to the evidence base.        They also argue there is
significant mention of climate change in the Core Strategy, but it is not clear how this has
influenced the plan and what specific actions / measures are being put in place, both in
relation to proposed development and mitigating the effects for existing development. Further
to their written response the EA suggest the Stoke on Trent Sustainable Development Policy
as a good practice example. They also point out that contamination needs to be considered
before an application, not after. They suggest the Water Framework Directive be referenced
and also suggest a Water Cycle Study would be beneficial.

The Government Office for the West Midlands urge that Pol SD1 not repeat national and
regional policy, and to consider what it adds to national guidance.

The National Trust was critical that the first para qualifies its stance with the words "where
this is consistent with other policies" because this is interpreted as being subordinate to other
Core Strategy Policies, and therefore, it would appear, inconsistent with PPS1 and PSS1
Supplement on Climate Change:- as these make important references to sustainable
development being the core planning principle, not other policy. They also argue SD1 Part (6)
policy wording is ambiguous on the level of development at which the requirement for on-site
renewable energy provision applies - the RSS revision advises that planning authorities may
use lower thresholds where appropriate [ie lower than the SD1 wording suggests]. Further,
PPS 1 (paragraph 26) advises that the type and size of development to which the policy is
applied should be set by planning authorities based on evidence-based understanding of the
feasibility and potential for renewable and low carbon energy. The NT therefore suggest that

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a lower threshold than 10 dwellings is needed for the District, as more than a quarter of
housing completions within it are anticipated to come from windfall sites (Policy SS4), which
will generally be of 9 dwellings or fewer (Policy H1).

Natural England welcomes consideration of the landscape and reference to the Landscape
Character Assessment. However they expect the policy to explicitly protect the setting of the
Peak Park and also the visual view from within the Park boundary. For this reason they
recommend that the SD1 Part (4) be amended to read “particularly having regard to the
Landscape Character Assessment (taking into account both individual and cumulative effects
of similar proposals) and the setting of the Peak District National Park”.

The Highways Agency feel Policy SD1 fails to recognise the role that public transport can
play in achieving sustainable development. English Heritage argue the reuse of existing
buildings is a sustainable option and should be highlighted under SD1Part (3). They argue
renewable energy technologies can have direct and indirect implications for the historic
environment, therefore the policy should also address the historic environment in its criteria,
for example section (4) third bullet point. United Utilities consider they should have been
referred to under para 8.2.12 in the reasoned justification, as their functions cover part of the
District - and they have identified hydraulic capacity issues [this para makes reference to
contributors to strategic flood risk assessment].

However Advantage West Midlands were supportive of the requirement for the sustainable
use of resources in all new development (having regard to the sustainability checklist for the
West Midlands region). Staffordshire County Council consider the Policy in general
conformity with national guidance; they also accept that the Phase II RSS is draft therefore
the SD1 Policy itself may need to change in future. However (like the National Trust) argue
that an evidence base should be produced which would allow for the adoption of locally set
targets in relation sustainable development, in line with PPS1 Climate Change Supplement,
PPS22, and RSS Section D [Pol EN1?]. They also argue that an additional bullet point be
added in the Policy [not stated where] to say “Ensuring development benefits from safe and
convenient sustainable transport links and Travel Plans where appropriate”.

Other comments and issues raised included:
 (housing) densities should not be increased
 Policy does not specify which areas renewable energy schemes would be supported.
   Policy is “slow to embrace renewables”
 That Policy should be amended to refer to the "…most sustainable locations for
   development proposed" ie to recognise that different forms of development require
   varying locations, some of which are suited to the rural areas eg sustainable tourism
 There needs to be a balance between promoting sustainable development and the
   economy. Therefore it is argued that the requirements placed on 'all new development'
   require careful consideration; further, it is not clear if there are exceptional developments
   to which this policy would not apply.
 District Council has no control over sustainability - its actions will make no material effect
   on environment and climate change. However counter-view that “climate change is a
   theory unsupported by many academics”.
 The word 'sustainable' is peppered throughout the document - it is used in many different
   contexts. Questions therefore whether SMD understands it means.
 A survey should be carried out about a wind farm at the top of Biddulph Moor: new ideas
   on energy will take years to develop so action is needed now.
 Comments that old buildings should be re-used, especially long term vacant ones.
   Planning requirements should require that conversion incorporate green measures eg.
   windows to heat and bring light into building so less electric lighting needed etc.
 However counter-view that there is too much emphasis on retention of old buildings. The
   best examples should be retained but many old buildings are „ugly‟ and uneconomical.
   Such buildings do not meet current Building or Planning Regulations, and would be better
   replaced with something better designed.
 All development proposals should be in line with the principles espoused in the
   Sustainable Communities Act.
 Building sites in flood plains should not be considered.

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   Emphasis on using reclaimed materials.
   Emphasis should be put on developing brownfield sites before any development in open
    countryside is considered. Keep open greenfield sites for wildlife and recreation. Should
    be even greater emphasis on brownfield sites before greenfield sites can be considered.
    55% target [2017-1026] was argued to be to low.

Comments from Consultation and Stakeholder Events

Leek Town Council, YOMAC and the Older Persons‟ Forum felt that brownfield sites
should be developed before/instead of greenfield sites. This was either expressed with regard
to some „local site‟, or as a more general sentiment [Biddulph Neighbourhood Forum /
Biddulph Town Council]. Some had concerns over development of greenfield sites within
urban areas eg public open space, play areas. Local Strategic Partnership questioned how
would greenfield sites be considered when there are nature conservation interests.

At the Parish Workshops comments were made regarding the desirability of co-locating
housing alongside services, so as to reduce the need to travel, on sustainability grounds. It
was also questioned whether there is provision for renewable energy development within
Core Strategy with a specific suggestion that energy be generated from river flow and that
water butts, (to conserve water) solar panels and wind turbines should be provided on new
housing development.


Further Evidence and Other Issues
The Climate Change Act 2008‟s main aim is to improve carbon management in the UK and
help transition to a low carbon economy. It does this by setting new legally binding targets:-
UK Green house gas emission reductions of 80% by 2050, and reductions in CO2 emissions
of at least 26% by 2020 (against 1990 baseline): an increase on previous legislation. It will do
this by setting consecutive 5-year targets (“budgets”) – which will be subject to review. Other
relevant measures include reference to a “Community Energy Savings Programme”;
facilitation of domestic emissions trading schemes; measures on biofuels; and powers to
introduce pilot financial incentive schemes in England for household waste. A consequence
of this act may be that regional targets for reduced energy use/reduced carbon emissions
expressed in RSS would be liable to (upward) change: it is argued the suggested changes to
the wording of the Policy provide this flexibility.

PPS1 strongly suggests that local renewable energy targets/thresholds are based on up to
date relevant evidence; this is backed up by the Planning and Energy Act 2008. This allows
LPAs to “impose reasonable requirements” for developments to derive a percentage of
energy from locally sourced renewable, or low carbon, sources; and that LPAs can impose
energy efficiency standards exceeding Building Regulations. However these requirements
“must not be inconsistent with relevant national policies”. Further to this, the District Council
is considering taking part in a joint Staffordshire renewable energy study. The results of
this would inform both the most feasible types of renewable energy generation, and the most
viable locations, which would in turn inform the application of local thresholds/targets. See
references in the Officer Response.

The Sustainable Communities Act 2007 came into force in October 2008. This has the
effect putting a duty on the Secretary of State to promote the sustainability of communities via
allowing residents (via Local Authorities) to suggest practical changes to law or policy. There
are a many criteria (“Schedule Matters”) to which suggestions can be made, including:-
(f) “measures to conserve energy and increase the quantity of energy supplies which are
produced from sustainable sources within a 30 mile radius of the region in which they are
consumed”;
(j) “measures designed to decrease emissions of greenhouse gases”;
(m) “measures to increase the use of local waste materials for the benefit of the community”;
and most importantly
(l) “planning policies which would assist with the purposes of this Act”.


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Although the Act post-dates most climate change/sustainable development guidance with
respect to LPAs it is considered Pol SD1 does broadly – with other Policies in the Core
Strategy – promote sustainable patterns of living. The District must now recognise that under
Matter (l) the Secretary of State may be pressurised into changing planning policy (or the
planning framework) for this end.

The Community Infrastructure Levy forms Part 8 of the 2008 Planning Bill. According to
DCLG the Bill will allow LPAs to apply the levy to fund sub-regional infrastructure (over and
above planning fees). The nature of these schemes will be identified in the RSS, so that
LDFs can identify them at the local level. A wide definition of „community infrastructure‟ is
suggested ie transport, schools, health centres, flood defences, play areas etc, such that
“development can be…made sustainable”. Clearly this has implications on not only Part(1) of
this Policy, but also other Core Strategy Policies eg T1, SS6a-c.

The Natural Environment and Rural Communities Act 2006 largely affects nature
conservation interests, so is explained in more detail in the Natural Environment section.
However note that it includes Provisions to amend the flood defence byelaw-making powers
of the Environment Agency, Local Authority and Internal Drainage Board to allow them to take
nature conservation into account when determining consent for flood defence works.


Officer Response
It is clear that a high proportion of the comments were criticisms although many suggested
minor text amendments or were on technical grounds; and the vast majority were from
“statutory consultees”, who because of their statutory duties have particular interest in this
area.

The Policy was drafted as a „catch all‟ to address many (interrelated and complex)
sustainability issues, and (in line with PPS12 advice at the time) was intentionally concise,
and intentionally a single policy; as was its position as one of the „earlier‟ policies ie straight
after the „Spatial Strategy‟. This was in order to establish sustainability principles such as
location, land status etc from the outset so the developer is in no doubt, although there will be
interrelationships with many other (later) Policies. Because of this there are examples of
overlap with the content (and officer response) to other policies.

It is not for the District Council to question the existence of climate change: its role is to work
towards achieving commitments at the national level (cascaded down to Regions and
Districts) for example arising from EU legislation. The District‟s Policy actions can make a
difference on climate change at the local level – it is considered there is great scope for small-
scale efficiencies incorporated in most developments, aside from the potential for larger scale
„stand alone‟ schemes, to affect reduction of carbon emissions. Whilst no definition of
“sustainability” is provided, and whilst it can have economic and social connotations,
according to context; the SD1 Policy clearly refers to the environmental aspiration of
combating climate change.

Understandable concerns that greenfield development be a last resort (or avoided), must be
weighed against situations where a developer (or District Council making an allocation) has
no choice but to select a greenfield site. Importantly policy SD1 (and other Policies, such as
those in the Rural Strategy) do not rule out greenfield development, rather require that more
sustainable alternatives have been prior investigated. The proportion of housing on brownfield
sites overall amounts to 60% over the whole plan period - this reflects local circumstances,
and ultimately matches national guidance (PPS3 para 41) and – consequently – the RSS
policy CF5. The approach in urban areas would be to seek brownfield sites first; however, a
greenfield urban site may be a more sustainable option than even a brownfield site outside
the built up area - all material factors would need to be considered. However the District
Council would not normally sanction the loss of POS/play areas in urban areas without very
compelling reasons (and compensatory measures would also be required under National
Policy and other Core Strategy Policies). Similarly, the development of sites with nature
conservation interest („interests of acknowledged importance‟) would require exceptional

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justification (and compensatory measures) under PPS9 etc. Refer also to Policies NE1 with
regards habitat creation; and C2 regarding play area creation.

In response to concerns that the District Council is slow to embrace renewable energy, much
of the guidance (and legislation) is relatively recent (PPS22, 2004; PPS1, 2005 etc), and often
generic in nature. Therefore the new LDF is the first opportunity to apply this guidance. The
District Council is currently engaging with neighbouring authorities regarding the potential
preparation of a joint Staffordshire renewable energy study for its evidence base to inform
Local Plan Policy (and planning decisions) in the form of an SPD: this would be one of the
first such studies in the country.

Policy SD1 embraces national guidance (PPS22 etc) in that renewable energy schemes are
in general supported, subject to other (landscape, amenity etc) criteria. In line with this
guidance, it does not specify preferential types of renewable energy, nor preferential locations
(or apply a sequential test): as to do so would be unduly onerous in the absence of local
evidence which could genuinely legitimate such an approach; however the abovementioned
joint renewable energy study would qualify as such evidence. In the case of new-build
development in greenbelt locations, whilst there is general support under this Policy,
greenbelt policy (PPG2 etc) still prevails. Under the Policy on-site or incorporated features in
new development (water butts, solar panels, mini-turbines etc) would either be required
(under Part (6)), or if not required, then supported (subject to design/amenity criteria). The
specific suggestions for energy generation from river flow, and wind farms would also fall
within Part (4) of the Policy, so would therefore be supported subject to the same general
considerations. The reclamation of building materials is also covered under Part (7). Whilst
there is understandable concern about development in the floodplain, Part (9) does not rule
this out; rather that it be a „last resort‟ before more sustainable options. However schemes
within the floodplain could of course be refused with recourse to Part (9).

It is also considered that the District Council‟s position towards sustainable tourism, and other
forms of development which may occur in the countryside, is made clear in policies R2, E3
and SS6c which all impose „sustainability‟ as a central factor in determining whether a
proposal of any kind would be appropriate. It is not agreed that a proposal is automatically
acceptable in a remote location just because it pertains to tourism, or even agriculture.

It is also acknowledged that there needs to be a balance between promoting sustainable
development and delivering development which is viable and supports the economy.
Therefore it is suggested that appropriate text be incorporated into the policy and the
Reasons and Justification to recognise this.

In response to the comments of the Government Office for the West Midlands that the
Policy not merely reproduce national/regional policy it is considered that overall the Policy is
successful in summarising a raft of national guidance as it applies to the Moorlands, covering
most subjects which pertain to climate change in a single policy. In the absence [at the time of
writing] of local evidence which might inform to the contrary, the Policy relies on draft RSS
instructions with respect to requirements for on-site renewable energy/low carbon emissions
and sustainable construction techniques etc. In respect of the Environment Agency
concerns regarding the wording of the policy it is accepted that the Policy could be more
clearly worded to overcome not only potential changes within the RSS requirements but also
changes to terms of reference/ nomenclature – see Suggested Changes below. With regard
to comments that site contamination be investigated by developers before - not during - an
application the Policy does not (and should not) go into this level of detail, as these
procedural matters are dealt with under the GDPO and EIA Regulations. However, textual
amendments are proposed to para 8.2.5 in the reasoned justification to clarify this. With
regard to the request that specific reference be made to the 2000 Water Framework Directive
(which governs water quality across Regions), as pollution control legislation operates
separately to the planning system, it would be inappropriate to include this within the Policy.
However textual amendments to para 8.2.10 in this respect are suggested. With regard to
undertaking a water cycle study, the levels of growth proposed for the District in the RSS are
not considered to necessitate this.



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With regard to the criticism from both the National Trust and Staffordshire County Council
that there is no local background evidence which might justify different renewable
energy/carbon reduction requirements (targets and thresholds), or locational differentials in
the Policy, against the RSS, it is acknowledged that this would be beneficial. However this
information is not necessary for the District Council to proceed:– para 26(vi) of PPS1 states
that LPAs “should…ensure that..Policies are based on analysis and evidence..”; however
clearly “should” does not mean “must”, and it does not specify that such evidence be locally
specific (as opposed to Regionally based). The para continues: “…where justifiable on the
basis of the evidence available, a precautionary approach to proposals for development may
be necessary”. In fact the Policy is deferring to the RSS requirements in the absence of local
information, so this is a “precautionary approach” (and the qualifications to Part (4) of the
Policy are also of a precautionary nature). Also note the aforementioned proposed joint
Staffordshire renewable energy study which would provide additional future evidence in this
respect. It is also suggested that the Staffordshire Moorlands is not the only LPA presently not
privy to such evidence, for reasons described above - ie owing to the recentness of not only
LDF preparation in general but also Climate Change Policy/Regulations. Additionally Policy
EN1 (Energy Generation) in the RSS only refers to the preparation of “locational guidance” for
renewable energy generation by LPAs “as necessary”. However it is conceded that the Policy
should more clearly refer to how any subsequent locally derived evidence, in addition to
national/regional policy would affect requirements, including threshold levels – see Suggested
Changes below. It is also accepted that the Council may wish to decrease relevant
thresholds to remedy this situation, particularly as there is no provision for in lieu financial
contributions for non-qualifying schemes, unlike the Transport Policies etc . Lower thresholds
would need to be justified by local evidence. Therefore the policy wording will be amended to
refer to such local evidence. The Reasons and Justification will also be amended to make it
clear that alternative thresholds may result from such evidence – see Suggested Changes
below.

In terms of other suggestions it is accepted that the reference to being „consistent with other
policies‟ is not necessary as any proposal must accord with all relevant policies and it does
not therefore need to be explicitly stated in this Policy.

The request from Natural England that landscape character considerations be more explicitly
referred to the Peak National Park, with additional text in part (4) is also accepted. The
request from United Utilities to include reference to them in para. 8.2.12 is also accepted.

There was support for applying on-site renewable features into existing [historic] building
conversions as well as new-build – on the one hand this would contribute to combating
climate change; however whilst this is supported by the Policy, it must be balanced against
design/heritage considerations. In response to the comments of English Heritage that more
explicit reference be made to re-using [historic] buildings it is considered that para 8.2.5 in the
reasoned justification, and the Appendix H Glossary already make it clear that brownfield
sites may include [historic] buildings. However, it is conceded that reference in Part 4 of the
Policy to “interests of acknowledged importance” would include listed buildings and
conservation areas, but not necessarily all historic sites [again refer to Glossary]. For this
reason changes are suggested to Part (4); but also amendments to text in Parts (6) and (7) to
refer to the practicality of applying on-site energy generation to schemes, which by extension
would include historic conversion schemes. The Council will soon be preparing a Design SPD
covering this issue, which would also qualify as “local evidence” under the latter sections.
Whilst generally supported in national policy, there may be situations where the preservation
of an historic building is either not justified, or unviable on planning grounds. This is better
dealt with under the “Design and Conservation Policies” Section, and policies DC2 and R2.
However, even total redevelopment from demolition would qualify as “brownfield”
development under SD1 Policy.

The contention from the Highways Agency and Staffordshire County Council that more
reference be made to sustainable transport, as a function of sustainable development is
acknowledged and relevant changes are therefore suggested (refer also to the Transport
Section).  However a second suggestion that additional text be inserted: “Ensuring
development benefits from safe and convenient sustainable transport links and Travel Plans


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where appropriate” is not agreed with, as it is considered that these issues are more properly
addressed under Pol T1 in the Transport Section.

Suggested Changes
                 st
1.   Amend 1 paragraph of Policy SD1 (page 85) to read: “The Council will require all
     development to make sustainable use of resources, help to minimise any
     environmental and amenity impacts and adapt to climate change., where this is
     consistent with other policies”.
                 st
2.   Amend 1 bullet point of item no. 1 of Policy SD1 to read: “a previously developed site
     performs poorly in sustainability terms and could not be made otherwise
     acceptable.”
                 st
3.   Amend 1 bullet point of item no. 4 of Policy SD1 to read: “the degree to which the
     scale and nature of a proposal reflects the capacity and sensitivity of the
     landscape to accommodate the development, particularly having regard to the
     Landscape Character Assessment and impact on the Peak District National Park
     (taking into account both individual and cumulative effects of similar proposals);
                 th
4.   Amend 4 bullet point of item no. 4 of Policy SD1 to read: “the impact on the amenity of
     residents and other interests of acknowledged importance, including the historic
     environment”.
            th
5.   Add 5 bullet point to item no. 5 of Policy SD1 to read: “the degree to which individual
     proposals conform to any subsequent local evidence regarding the feasibility of
     different types of renewable energy at different locations across the District”

6.   Amend item no. 6 of Policy SD1 to read: “Requiring that all new development, as a
     minimum, complies with the on-site renewable energy targets set out in national
     guidance and the RSS (or as future local or regional evidence may dictate) and
     takes positive measures to reduce carbon emissions to the levels set out in the
     RSS and, where appropriate, provides the necessary environmental infrastructure
     required to support it, unless it can be demonstrated that it would not be practical
     or viable to do so.”

7.   Amend item no. 7 of Policy SD1 to read: “Requiring that all new development should
     be designed so as to incorporate the best environmental practice and sustainable
     construction techniques appropriate to the type and size of development. New
     development should, as a minimum, meet the sustainable design and construction
     requirements set out in the RSS (or as future local or regional evidence may
     dictate) unless it can be demonstrated that it would not be practical or viable to do
     so..”

8.   Add new item no. 10 to read: “All new developments to incorporate the use of
     Sustainable Urban Drainage Schemes (SUDS) as per the requirements of the RSS,
     (or as future local or regional evidence may dictate)”

9.   Add new following paragraph at beginning of Reasons and Justification to Policy SD1:
     „The Government have made it clear that sustainable development is the core principle
     underpinning land use planning, in PPS1 and other guidance. In particular the Stern
     Review (October 2006) identified that human activity is changing the world‟s climate, with
     profound and rising costs to the natural environment, concluding that action is needed
     now to avoid the worst of these costs.‟

10. Add following new sentence in paragraph 8.2.5 of Reasons and Justification to Policy
    SD1: „In some cases a developer may be required to submit pre-application evidence as
    to the presence of contamination across the site, under the 1999 Environmental Impact
    Regulations, before a planning application can be determined.‟



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11. Add following new sentence in paragraph 8.2.6 of Reasons and Justification to Policy
    SD1: “Travel and remoteness as planning considerations are more fully dealt with under
    separate Core Strategy Policies: T1, C1, R1 etc”.

12. Amend last sentence of paragraph 8.2.7 of Reasons and Justification to Policy SD1 to
    read: “The Council is proposing to assess the scope for setting local targets which, if
    established, will be incorporated into this policy, for example local evidence may justify
    the setting of lower thresholds/higher targets in future. However it is recognised RSS or
    local requirements may affect the viability of individual projects. For this reason Parts (6)
    and (7) of the Policy provide more flexibility with reference to “viability‟

13. Add following additional sentence at end of paragraph 8.2.8 of Reasons and Justification
    to Policy SD1: “The viability of different forms of renewable energies, within different
    areas of the District, may in future be informed by further local evidence, which may take
    the form of an SPD”.

14. Add following new sentence to paragraph 8.2.11 of Reasons and Justification to policy
    SD1: “The District Council will continue to keep abreast of relevant evidence affecting
    pollution and flood risk in its District, such as the requirements of the 2003 Water
    Framework Directive, as per RSS Pol QE9.”

15. Add „United Utilities‟ in list of agencies identified in para. 8.2.12 of Reasons and
    Justification to policy SD1.




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E1, E2 and E3 - Economy and Employment
Introduction
There are 3 policies in the Preferred Options Core Strategy relating specifically to the
economy and employment. Policy E1 identifies the general locations for different types of
employment development. Policy E2 establishes measures th safeguard those existing
established employment sites and premises which are most likely to be capable of supporting
the local economy whilst policy E3 seeks to positively support the important role that tourism
and culture plays in the local economy. Question 26 requested comments on any of the
policies in the Preferred Options Core Strategy.


Summary of Comments

Comments from Questionnaires and Correspondence

Policy E1 (New Employment Development)

There were 13 responses made relating to Policy E1. Some were generally supportive of the
policy, but there were also concerns raised that new development outside the urban zones do
not improve the local economy, that the reference to 'all proposals' is too constraining and
unreasonable and that the requirement for training agreements is equally onerous and not
really a planning consideration. It was also commented that the policy does not explicitly
support employment growth in the rural areas. A broad range of employment sites within both
urban and rural areas should be promoted. The recognition of the benefits of tourism to the
local economy particularly through the sustainable development within the Churnet Valley
Tourism Corridor are also absent.

The Sport England suggest that new employment development should also be designed to
encourage an active workplace - green travel, work place gyms. Advantage West Midlands
welcome the inclusion of policies to safeguard existing viable employment locations and
provide a range of new employment sites in sustainable locations.

There was some concern regarding the references to large-scale office developments. The
Government Office for the West Midlands comment that large-scale office developments
should also be located in Town Centres. The West Midlands Regional Assembly suggest
that a cross reference be included to emerging RSS policy PA13B within the supporting text,
in particular the criteria for assessing large scale office developments outside of strategic
centres. There is a need to ensure that the employment policies are brought in line with
general town centre policies in terms of office location. The City of Stoke-on-Trent express
concern that the policies are at odds with Planning Policy Statement 6 and Regional Spatial
Strategy Phase II revision which both state that offices are town centre uses and are subject
to the sequential approach to site selection.

Policy E2 (Existing Employment Areas)

There were only 5 responses made relating to Policy E2 generally welcoming the policy of
safeguarding appropriate employment sites and premises. 1 respondent considered that the
policy needs to be flexible to allow for the redevelopment of sites that are no longer suitable
or viable for employment use and that it is unclear how funding to support off-site employment
provision would operate - suggested that the forthcoming Developer Contributions SPD set
out clearly the details of levels of funding and how this would be applied in each case.

Advantage West Midlands welcome inclusion of policies to safeguard existing viable
employment locations and provide a range of new employment sites in sustainable locations.
Staffordshire Police suggest the inclusion of the word 'secure' within the second bullet on
page 92 so that it would read 'good quality, secure, modern accommodation'


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Policy E3 (Tourism & Cultural Development)

There were 12 responses made relating to Policy E3.

4 respondents made specific reference to the Churnet Valley Tourism Corridor in the context
of Policy E3:
      1 respondent considered that conversions only should be allowed in the green belt.
       Another respondent suggested adding to "Support will be given to clusters of
       attractions, particularly within the Churnet Valley", the market towns and along the
       Caldon Canal.
      1 respondent, whilst broadly supporting the wording of the policy particularly in respect
       of bullet 3 which comments upon tourist accommodation, considered that a flexible
       approach should be adopted in the development of such facilities and that the policy
       itself and supporting text should specifically state that accommodation outside of
       settlements will support the Churnet Valley Tourism Corridor and tourism generally
       given its recognised importance to the local economy.
      1 respondent, whilst also supporting the policy particularly the reference to clusters of
       attractions in the Churnet Valley, considers that it could be further strengthened
       through the addition of specific support for measures to stimulate and enhance the rural
       economy, supporting the extension of the Churnet Valley Railway line for example. The
       policy ought to be clarified to demonstrate support for tourism development by starting
       "New tourism and cultural development will be generally supported and will be
       assessed..." Comments also that the third bullet point to the policy is out of step with
       the overall approach to the Core Strategy and the Churnet Valley Tourism Corridor as it
       seeks to restrict the scale of new tourist accommodation outside the defined
       settlements to conversion of existing buildings or new buildings of a non permanent
       nature which seriously undermines the viability of any significant proposals and the
       ability of the District to achieve its economic and social objectives - it does not appear
       to recognise major previously developed sites or existing employment locations some
       of which are outside settlement boundaries but which have performed a very valuable
       role in the past. Limiting new tourism accommodation in this way will limit the quality
       and market appeal of accommodation that can be provided, the breadth of tourism offer
       and the investment that can be made. Suggest therefore, that these limitations be
       deleted along with the corresponding reference in 8.3.17.
      1 respondent considered that clusters of attractions in the Churnet Valley are NOT
       appropriate - basic facilities only should be provided to enable visitors to enjoy its
       unspoilt natural beauty.

Alton Towers Resort Operations Ltd generally support Policy E3 but does however have
detailed comments to make about the draft Policy E3, particularly with regard to visitor
accommodation and the provision of hotels at Alton Towers whose location need to be
intrinsically linked to the Alton Towers site and cannot be provided within the development
boundaries of existing settlements. Assume the draft Policy E3 does not relate to proposals
for new tourist accommodation within the "Major Sustainable Tourist Corridor". The Tourist
Corridor is covered by Policy SS6c(5) which specifically supports short and long stay visitor
accommodation. To avoid any potential confusion/conflict would suggest that the third bullet
point of Policy E3 is amended: "With the exception of the area covered by the Major
Sustainable Tourist Corridor, outside the development boundaries of settlements new tourist
accommodation will...". Also request that an additional paragraph is added to draft Policy E3
that recognises the need for existing tourist facilities, such as Alton Towers, to sensitively
expand and enhance their facilities. The suggested additional text will then complement the
Council's draft Policy for the creation of the "Major Sustainable Tourist Corridor in the Churnet
Valley (draft Policy SS6c(5)).

The National Trust express concern that policies E3 and SS6c establish too much
encouragement of tourism development with too little in the way of environmental protection
and nothing on environmental enhancement. This will result in a failure to deliver Spatial
Objectives SO2 and SO9. The Sports Council question whether this policy includes or
excludes sport and recreation. If it includes then would also contribute to increasing physical
activity and improving health and well-being as well as supporting local economy.

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The Theatres Trust object as it is not clear in the policy or supporting text what is meant by
„cultural development‟ - no specific examples are given. Also, there is no protection and
promotion of existing facilities for tourism and culture. Comment that cultural services and
tourism are inter-dependent, with tourists attracted by museums, theatres, heritage sites, arts,
sport, entertainment venues, festivals and events and although there is no dedicated theatre
in the District, arts and cultural activities can make a major contribution to the vitality of town
centres, especially the evening economy, and are significant elements of any District‟s
cultural infrastructure. Future development of the villages and towns could well include a
theatrical provision for community halls, a new arts centre or indeed amateur theatre, and
policies should be in place to promote and protect such objectives.

British Waterways comment that support should also be given to clusters of tourist/cultural
development by the Caldon Canal. Strongly object to the restriction of such development to
conversion of existing buildings in green belt/open countryside which goes well beyond PPG2
requirements and is unduly restrictive. New marinas, for example, often need small scale
new buildings to accommodate essential facilities and there is rarely a suitable building
available to convert. Policy E3 needs to be amended to remove conflict.

Peak District National Park consider that the Core strategy vision and policies for tourism
could also be related more strongly to the strategic context of the nearby National Park as
discussed in RPG8 Policy 12 and to the National Park purpose for enjoyment and
understanding.

Comments from Consultation and Stakeholder Events

There was general support from the Parish Council Workshops for the promotion of tourism,
as long as it is sensitive. At the Public Consultation Events there was general support for
tourism but concern was expressed by some regarding traffic and road infrastructure
implications.

At meeting with North Staffordshire Bodies it was questioned where the evidence is regarding
demand/need for different employment types and how it relates to the strategy. There was
some concern over out-of-centre office development.


Further Evidence and Other Issues
The Employment Land Study Update (September 2008) indicates that on the existing sites
vacancy level in the District remains low at around 2.4%, although a lack of newer premises
including those which could attract higher value industries, is a common theme of the District.
A shortage of suitable small scale premises under 100 square metres is also identified.


Officer Response

Policy E1

The main concern in relation to policy E1 relates to office developments and in particular the
reference within bullet point 3 to large-scale office developments which some respondents
consider is not in accordance with national and regional planning guidance. In this respect
PPS6 „Planning for Town Centres‟ identifies offices as a town centre use and seeks to direct
new office development to town centre locations whilst the emerging RSS Phase 2 Review
                                                                           2
(Policy PA13) allows only for large-scale office development (of 5,000m gross and above)
outside strategic centres were specific criteria are met. The preference in the Core Strategy
is for new office developments to be located in town centres (which is recognised in Policy
TC1) and it is therefore considered appropriate that this should also be stated within policy
E1. However, it is considered that there may be instances where a need cannot be satisfied
in a town centre and it would therefore be appropriate for it to be located on the edge of the


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town centre or in an existing or proposed employment area and therefore the policy should
also allow for this. With regard to large-scale office developments, the policy requirements for
these are already set out in the RSS (Policy 13B) and therefore to avoid confusion it would be
appropriate to delete reference to this in policy E1 but to include a cross-reference to the
relevant RSS policy in the Reasons and Justification. This would not however preclude the
Council from considering allocation appropriate sites for office development provided the
conditions in RSS Policy 13B are met.

With regard to the other comments, whilst not referring to the rural areas, it is intended that
policy E1 should also apply to development in rural areas, which is also covered more
specifically in policy R1. It is considered however that it would be helpful to make this clearer
in the policy itself and include a cross-reference to policy R1 in the Reasons and Justification.
With regard to the benefits of tourism and the Churnet Valley Tourism Corridor for the local
economy, this is already recognised in Policy E3.

The requirement for a contribution towards training and employment support is a measure
which has been pursued by other local authorities and reflects the Employment Land Study
and the Economic Strategy which identify skills and training shortages. This is also a measure
which the All party Urban Development Group has recently urged planning authorities to
support. Further guidance on how this would operate would be set out in the proposed
Development Contributions SPD. A reference to this SPD should therefore be included within
the supporting Reasons and Justification.

The suggestion from the Sport England for development to be designed to encourage an
active workplace is acknowledged but it is considered more appropriate to include this within
the design policy DC1.

Policy E2

The concern regarding the lack of clarity over how funding to support off-site employment
provision would operate is noted and it is accepted that the forthcoming Developer
Contributions SPD should set out clearly the details of how this would be applied. A cross-
reference to this SPD would therefore be appropriate within the Reasons and Justification.
The suggested amendment by the Staffordshire Police is also noted, however whilst crime
prevention is a legitimate planning concern with new development it is considered
unreasonable to include security as a consideration for the retention of existing employment
buildings as the Council would have no means of assessing this.

Policy E3

One of the main concerns with regard to policy E3 is the overlap and consistency with the
Churnet Valley Tourism Corridor policy. It is accepted that the wording of Policy E3,
particularly in respect of tourism accommodation, does not fully reflect the more positive
approach to promoting further attractions and visitor accommodation in the Churnet Valley in
Policy SS6c (new policy SS7). Some amendment to Policy E3 would therefore be
appropriate to ensure it is consistent with and cross-referenced to new Policy SS7. However,
this should not be at the expense of the intrinsic qualities of the local landscape and careful
consideration needs to be given to their cumulative impact on environmental assets and
infrastructure. Appropriate consideration of these factors needs therefore to be addressed in
the Masterplan to be produced for the Churnet Valley Tourism Corridor.

In response to the comments of the Sports Council, this policy does include informal
recreational and countryside pursuits which contribute to increasing physical activity and
improving health and well-being. A reference to this within the Reasons and Justification
would be appropriate. In response to the comments by British Waterways, the policy would
allow for clusters of attractions elsewhere, such as on canals – further clarification of this
would be appropriate. It is not however accepted that the policy is over-restrictive on tourist
facilities in the green belt and open countryside as the policy only seeks to restrict visitor
accommodation to conversions or non-permanent buildings (subject to the amendments
proposed below).


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In response to comments from the Peak District National Park, it is considered that the
proposals for developing tourism in the District are consistent with the emerging East
Midlands RSS8 Review which requires that Local Authorities and other relevant public bodies
in areas adjacent to the National Park should consider whether there is potential for further
tourism development that could ease pressures on the Park itself. It is considered however
that it would be beneficial to express within the Reasons and Justification more strongly the
relationship with the National Park in terms of tourism.

The comments from the Theatres Trust are noted and it is accepted that there should be
greater clarification and recognition of the role of cultural development which may include
museums, theatres, heritage sites as well as arts, sport and entertainment venues – a
separate bullet point specifically covering cultural facilities is therefore suggested. The
protection of cultural facilities is covered by Policy C1 which includes measures to prevent the
loss of community facilities. In this respect there needs to be further clarification in the
Reasons and Justification to Policy C1 that „community facilities‟ includes cultural facilities.


Suggested Changes

Policy E1 (New Employment Development)
               rd
1. Amend 3 bullet point of Policy E1 (page 90) to read: “New business developments
   (use classes B1 (a, b and c)) should be located in existing or proposed employment
   areas or in or on the edge of town centres. Preference will be given to town centre
   locations for all office developments unless ancillary to another use. Large-scale
   office developments should be in sustainable locations with good public transport
   access.     Elsewhere business developments will only be permitted for the
   expansion of existing businesses or for small-scale developments provided they
   would not have an unacceptable impact on the amenities, character or appearance
   of the area.”

2. Add following text to Reasons and Justification to Policy E1: “Large-scale office
                         2
   developments (5,000m gross or more), not otherwise allocated, will need to accord with
   the conditions for such development outside the strategic centres as set out in policy
   PA13B of the emerging RSS Phase 2 Review”.

3. Add following text to Reasons and Justification to Policy E1: “More detail on agreements
   with developers to contribute towards training programmes and employment support and
   employment access schemes and on off-site contributions for employment contributions
   will be provided in an SPD on Developer Contributions. This SPD will contain additional
   information on when agreements may be needed, what they will seek to cover, levels of
   contribution and how they will operate.”

Policy E2 (Existing Employment Areas)

No Changes

Policy E3 (Tourism and Cultural Developent)
               st
1. Amend 1 bullet point of Policy E3 (page 94) to read: “Support will be given to clusters
   of attractions, particularly within the Churnet Valley Tourism Corridor in
   accordance with Policy SS6c SS7, where they meet the objectives above and do
   not result in a cumulative detrimental impact.”
               rd
2. Amend 3 bullet point of Policy E3 to read: “Outside the development boundaries of
   settlements new tourist accommodation will:
       a. be of a scale which can be easily accommodated into the local landscape in
          a sustainable manner;
       b. be limited to the conversion of existing buildings (in accordance with other
          policies in the Core Strategy Policy R1), or

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         c. in exceptional circumstances be of a non-permanent nature e.g. log cabins.

    Within the Churnet Valley Tourism Corridor permanent new tourism
    accommodation of an appropriate scale to complement existing attractions will be
    supported where there is a demonstrable need which cannot be met in other ways.
    Within the Green Belt new tourist accommodation will be limited to the conversion
    of existing buildings only.”

3. Add following new bullet point to policy E3: “Support will be given to the provision of
   new cultural facilities in town centres and villages to meet the needs of local
   communities and visitors.”
                st
4. Amend 1 sentence of para 8.3.15 of Reasons and Justification to Policy E3 to read:
   “This policy positively supports the important role that tourism and culture plays in the
   economy of the Staffordshire Moorlands and the contribution it makes to increasing
   physical activity and improving health and well-being.”

5. Add following text to para 8.3.15 of Reasons and Justification to Policy E3: “Clusters of
   attractions should be related to existing visitor and tourist facilities or to features such as
   canals and strategic footpaths.”

6. Add following text to para 8.3.16 of Reasons and Justification to Policy E3: “A Tourism
   Study is proposed to be undertaken which will identify where there is scope for further
   provision of tourist attractions and accommodation and the nature of that provision.”
7. Add following text to para. 8.3.16 of reasons and Justification: “Within the Churnet Valley
   Tourism Corridor the provision of further short and long stay visitor accommodation is
   particularly supported. Whilst in the main this should be within existing buildings or of a
   non-permanent nature, some new permanent visitor accommodation may be appropriate
   – the Masterplan will provide further guidance on suitable sites and scale.”

8. Add following new paragraph to Reason and Justification to Policy E3: “The District has a
   close link with the Peak District National Park in terms of tourism and the policy seeks to
   encourage and promote tourism opportunities that could ease pressures on the Park
   itself, provided this would not increase pressure on areas of biodiversity interest. This is
   in accordance with policy 11 in the emerging East Midlands RSS.”




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H1, H2 and H3 - Housing
Introduction
There are 3 policies in the Preferred Options Core Strategy relating specifically to housing.
Policy H1 seeks primarily to ensure that an appropriate mix and range of housing is provided
to meet the needs of existing and future residents. Policy H2 sets out the requirements for
providing affordable and local needs housing, whilst policy H3 reflects guidance requiring
local authorities to meet identified needs for gypsies and travellers. Question 26 requested
comments on any of the policies in the Preferred Options Core Strategy.


Summary of Comments

Comments from Questionnaires and Correspondence

Policy H1 (New Housing Development

There were 16 responses made relating to Policy H1. Some were generally supportive of the
policy, but there were also a number of concerns raised from those who responded:

1. The suggestion that the mix should be negotiated by reference to the Strategic Housing
   Market Assessment considered unduly rigid - the mix should be negotiated having regard
   to a broader, more flexible, range of considerations;
2. More flexibility is required in terms of the Lifetime Homes standard in order to ensure that
   development opportunities are not lost because of problems with viability;
3. Concerned that the housing densities and whether or not car parking is provided will be
   subjected to government diktat;
4. The requirement to provide for mix or to meet lifetime home standards on sites of 10+
   dwellings considered purely arbitrary and fails to have regard to the market in terms of
   meeting customer's needs. Should provide policy incentives such as relaxing affordable
   housing requirements;
5. Suggest that seek to achieve Code for Sustainable Homes a minimum of Level 3 but
   increasing towards Level 6 later on in the life of the Core Strategy. Also should seek to
   ensure that new housing is developed in accordance with appropriate national guidance
   such as Building for Life.
6. New energy saving measures should be our first priority.
7. Para 8.4.4 [with respect to Policy H1] refers to the importance of addressing special
   needs of the elderly, but makes no reference to the needs of the disabled. Further, para
   8.4.8 in the reasoned justification does not refer to the needs of the disabled, in addition
   to the needs of the elderly.
8. Any new housing should be 'green' - restoration of existing properties should take priority.
   Community health and well being can be maintained and enhanced by ensuring existing
   green spaces, with open aspects and landscape views, are preserved.

Ipstones Parish Council comment that small villages should be included for some infill
development, but also that there should be no large developments in either large villages or
small villages. Any development should incorporate mix size and style of housing. Would like
to see some mixed sized/style houses in Foxt and Ipstones - but no estates. Infill is
preferable. Dilhorne Parish Council consider that the density of development would be
detrimental to the character of the village and certainly don't want new settlements outside the
boundary of the village. Deep concerns that any multi-house development would change the
character of the historic village forever. As the village is a 'ribbon development' (with limited
infill) tandem developments would be totally inappropriate.

West Midlands RSL Planning Consortium consider that if the housing policies are to
remain robust over the lifetime of the framework the Council must be continuously proactive in
monitoring the housing market within the District by liaising with the local housing authorities.
This will allow the Council to seek to negotiate an appropriate level of affordable housing on

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emergent sites that is capable of meeting the needs of the community. New developments
should provide a mix of tenure and size of units to reflect the local need and character of the
local area based on evidence of need demonstrated in the Strategic Housing Market
Assessment and Housing Needs Survey. Providing a mix of tenure and size of units across
new developments should be encouraged through the Core Strategy in order to provide for a
balanced community. Staffordshire Police comment in respect of all 3 policies that careful
consideration in this area for expansion due to economy is a key issue.

Policy H2 (Affordable Housing)

There were 27 responses made relating to Policy H2. Many of the responses expressed
concern regarding the requirement to provide 50% affordable housing on sites over the
threshold on the grounds that it would impact on the viability of developments making them
uneconomic to develop thereby reducing the amount of affordable housing coming forward
and that there should be more flexibility to take into account local circumstances and viability,
particularly in the current housing and financial climate. Other issues raised of concern were:

1. Other means should be explored in order to meet the overall demand for affordable
   housing.
2. The percentage split between social rented and other forms of housing should be a
   matter to be negotiated having regard to demand and not prescribed at this stage in such
   a long plan period.
3. The trigger of 5 homes before affordable housing is required is arbitrary and set too low
   having regard to economies of scale, market conditions, the cost of development or the
   housing market.
4. If set at a realistic level a commutable sum towards affordable housing in more
   sustainable town locations is a better option for sites in larger and smaller villages.
5. Affordable should equate with quality of build and design.
6. There should be a de minimus exemption to small developments, without which continual
   small grain regeneration will be stifled.
7. The provisions of the current SPD on affordable housing should be retained, whereby the
   Council can waive the requirement for affordable housing and other financial contributions
   for regeneration and Listed Building projects where it is demonstrated that the costs of
   such will impact critically on the viability of the project.
8. The idea that sites under the threshold should be required to contribute to affordable
   housing is breaking new ground and is not considered to have justification in terms of
   national guidance.
9. The identification of local need in para. 8.4.16 is considered too narrow and needs to be
   expanded.

There were no comments made regarding the alternative lower threshold suggested in the
Core Strategy.

Dilhorne Parish Council comments that Dilhorne's infrastructure is poor (no post office, shop
and an infrequent bus service) which not bode well for future social housing. Rushton
Parish Council agree with promoting local needs affordable housing. Endon with Stanley
Parish Council stress that it is vital that community based, local occupancy needs are met.

West Midlands RSL Planning Consortium comment that are pleased to see that the
proposed split of 70% social rented and 30% intermediate housing reflects evidence from the
Council's Strategic Housing Market Assessment. However, it is also important to recognise
that although RSLs will continue to strive to maximise the social element, with a relatively high
overall target of affordable housing without grant there needs to be flexibility over the tenure.
There will also be parts of the District where intermediate housing has a particularly important
part to play. Would also strongly recommend that a specific rural exceptions policy is included
allocating land in rural communities for 100% affordable housing in and on the edge of
villages. In addition to the above, consider that the following issues should be addressed in
the Core Strategy: (1) Credible district wide and sub district wide affordable housing targets
should be set. (2) A local definition of affordable housing should be set encompassing
intermediate and social rented housing and taking full account of local relationships between


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house prices and incomes. (3) The opportunities for affordable housing should be maximised
in the right locations. (4) There should be a reasonable amount of flexibility regarding design
and development control standards, densities etc to assist in achieving affordable housing. (5)
The provision of affordable housing is recognised per se as both a positive material planning
consideration and planning benefit. (6) Recognition should be given to the advantages of
working with RSLs and a suitable flexible approach should be adopted towards S106
agreements. (7) Policies should be included that maximise the reuse of empty properties for
affordable housing. (8) Housing demand factors should be taken into account. There is likely
to be a continuing demand for family housing and this should be considered. (9) Regular
monitoring of the progress in meeting housing needs should take place.

At the Parish Council Workshops there was strong support for affordable and local needs
housing for young people in all villages and support for the higher 50% requirement in larger
villages (and lower size thresholds generally). However there were queries as to how this
housing would be provided, and would the Core Strategy address the different types of
housing needed in different rural locations. Concerns were expressed that affordable housing
thresholds could be „avoided‟ by developers, through „piecemeal‟ development [although a
future SPD will address this]. Some felt the [recently suspended] local needs Policy should be
re-introduced. There was also discussion around rural „phasing‟ – ie there needs to be
scrutiny to avoid some of the larger villages using up all the rural requirement. Other housing
comments included that densities/design characteristics should respect existing character.

Policy H3 (Gypsy & Traveller Sites)

There were only 4 responses made relating to Policy H3.

Heine Planning welcome the Policy but comment that it needs to be updated to include
reference to the findings of the GTAA, ODPM Circular 1/2006 and emerging RSS policy. It is
unclear if policy is concerned with residential or transit sites or both. Some criteria listed may
not be relevant to transit site provision. The needs of transit sites could be different to those of
residential sites. Policy does not set out the sequential test for the identification of suitable
sites. As the GTAA has identified a need, it should (a) identify suitable site(s) and (b) set out
the criteria for determining planning applications and unexpected demand. It is unclear what
weight will be given to 'considerations' and what 'well located on the highway network' means.
It is also considered unreasonable to expect sites to be accessible to shops etc on foot, by
cycle or public transport. The requirement that sites should not be detrimental to amenities of
adjacent occupier is too vague. Such criteria will just be used to thwart proposals. The Court
Of Appeal has held that it cannot be right to view the use of land for the purpose of a Gypsy
site as inherently creating harm to neighbouring uses. A caravan site is not of its nature likely
to produce difficulties for neighbours if properly planned. Many sites are located next to other
land uses - including residential land uses. The final criteria is also considered too vague and
open ended. If there are other known interests of acknowledged importance they should be
listed. Justification to policy notes that these are often contentious issues. For this reason
policy needs to be worded positively and without ambiguity.

1 member of the public comments that it was reported in the press that a preferred site for
travellers would be in Biddulph but there is no mention of this in the Biddulph section of the
core Strategy.

Friends, Families and Travellers Association comment that it is glad that the council will
make provision through the Site Allocations DPD. Question whether a single site may be
appropriate and draw attention to Circular 1/2006 which indicates one of its aims as being the
increase of private provision. Given that the preference of many Gypsies and Travellers are
for small family sites then allocations should seek to meet the multiplicity of need which could
mean a number of small sites. The use of the word „genuine‟ is invidious and is not applied to
any other group whose needs are met through the planning system, it should not be used.
FFT is glad that criteria will be set out in the core strategy to aid site selection and to judge
applications arising from any unforseen needs. In preparing a policy the council should pay
particular attention to advice in paras 32 and 53 of Circular 1/2006 which refer to fair and
reasonable criteria in such policies. The Core Strategy should also pay due regard to the fact


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that Gypsy and Traveller sites managed or owned by the local authority or registered social
landlord are also types of 'affordable housing. This should be considered when preparing
policies on planning obligations. It should also be remembered that land affordability issues
may result in difficulties for Gypsies and Travellers wishing to establish private sites. Delivery
issues need to be considered. The local authority should also consider guidance in regard to
Travelling Showpeople which mirrors that for Gypsies and Travellers.

Comments from Consultation and Stakeholder Events

A number of comments were made at the Parish Council Workshops relating to rural housing.
It was generally considered that there was a need for affordable housing particularly for
younger people with support for lowering of threshold in rural areas and increasing target.
Concern was expressed about sites being developed in piecemeal fashion. There was
support for the re-introduction of local needs housing, but a need to specify criteria for local
needs policy. Another issue was the lack of choice for older people in rural areas needing
smaller properties or sheltered housing. There was a common view that RSL housing still
has stigma, should be spread out in larger developments. The design of housing was
considered a big issue in terms of a lack of consistency, small size, not in keeping with
surroundings – concern over high densities changing character of villages, loss of garden
land.

At Cotton Parish Council and Rushton Parish Council meetings there was support for
local needs restriction arising from concern about rural house prices. Leek Town Council
suggested that affordable housing targets needed to be reconsidered. At Werrington
Neighbourhood Forum concern was expressed about affordability of future properties -
would support re-introduction of the local needs policy.

Meeting with Moorlands Housing considered affordable rural housing to be a major issue,
commuted sum payments considered a way of funding more affordable housing. Support
lowering of thresholds in rural areas. Particularly supportive of measures to create more
affordable housing although have some concerns as to whether it would be viable to deliver
50% on sites. At a meeting with North Staffordshire PCT comment was made that in
Cheadle, the level of new development proposed is likely to result in need for couple of extra
GPs. At a meeting with North Staffordshire bodies it was suggested that it may be better to
have a range of affordable housing targets related to viability. Need to make explicit how the
affordable housing targets are derived - how much is from new build and how much from
other sources. The Peak Park Planning Authority outlined how they were tackling provision
of affordable housing in Peak District through buying existing stock rather than developing
new housing.

A number of housing issues were raised at the meeting of bodies responsible for older
people. There was support for lifetime homes and also lifetime neighbourhoods. It was
considered that housing where wardens are available on site is liked by older people as they
can provide support for each other. Staffordshire County Council are keen to increase extra
care schemes in the Moorlands - would be looking for around 300 extra care units across
Leek, Cheadle and Biddulph over the next 5 years. Additionally, the provision of more
sheltered housing schemes would be supported by the County but there is reliance on
providers e.g. Moorlands Housing. The County are looking to cater for a range of needs and
to support people staying in their own homes where possible. It was considered that all
housing should have large elements of adaptability to enable people to stay in their own
homes for as long as possible. It was also considered that affordable housing must be in
perpetuity so that affordable homes are not lost. This would enable families – older people
and their adult children to live close together and provide support. There was strong support
for affordable housing for local people. It was considered that such housing would be best
provided mixed with other housing within the community.




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Further Evidence and Other Issues
                                                     th
Housing Land Supply calculations for 30 September 2008 indicate a significant fall in
development rates from 261 (for year 2007/8) to 73 (for a half year period during year
2008/9). This represents a 56% drop in the rate of development.

An Affordable Housing Viability Assessment has been undertaken by consultants. This
demonstrates that only up to 40% affordable housing could be delivered in towns but up to
50% would be viable in larger villages. However, the viability of delivering these targets
would be dependent on the level of other infrastructure contributions being sought and in
some cases it would only be possible to deliver such high proportions of affordable housing if
no other contributions were required. It also indicates that the level of provision would be
much less on brownfield sites, particularly in the towns due to the higher levels of on-site
development costs. It should also be noted that the assessment is based on assumed
average house prices over the plan period and does not take into account the current the
recent fall in house prices.

The Gypsy and Traveller Needs Assessment Study completed in December 2007
identifies a need for 2 residential and 2 transit gypsy and traveller pitches in the District to
2021. The Phase 3 Review of the RSS which is currently underway will address and identify
needs for gypsy and traveller pitches across the West Midlands.

The 2008 Matthew Taylor Report considered the implications of housing provision in rural
areas and found that the high cost of homes coupled with low wages of rural workers are
creating affordability pressures that threaten the future of rural communities.


Officer Response

Policy H1

The provision of a housing mix needs to be informed by up-to-date evidence which should
include the SHMA. It is acknowledged however that housing needs may also be informed by
other factors, such as available supply and market demand, and therefore the policy should
be amended to reflect this. It is also considered that the policy should give clearer guidance
on considerations for housing mix and that further more detailed guidance on appropriate
dwelling mixes should be given in the Site Allocations DPD.

The provision of Lifetime Homes is justified by the high level of current and future older
people in the District and also evidence of high levels of households with long term limiting
illnesses. This requirement is in accordance with PPS1 and the government‟s Code for
Sustainable Homes. It is considered therefore that the Council should continue to seek a
20% provision but that in the interests of flexibility the supporting text should recognise that in
exceptional circumstances this may not be practicable or appropriate. It is acknowledged that
the needs of the disabled should also be referred to within the Reasons and Justification.

In terms of meeting the Code for Sustainable Homes and Building for Life standards, Policy
H1 requires all new dwellings to meet the requirements set out in the RSS, Policy SR3 of
which sets out those requirements. In order to clarify what those requirements are it is
considered that these should be set out in the supporting text. The need for energy saving
measures and „green‟ housing are recognised already within the Core Strategy within policies
SD1 and SC2.

With regard to the design and density of new housing, Policy H1 makes it clear that it should
be compatible with the site and its location and with the character of the surrounding area.
There will also be more guidance on this in the proposed Design SPD.




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Policy H2

The requirement to provide 50% affordable housing is well founded on evidence from the
SHMA whilst the viability study recently undertaken by Halcrow confirms that this level of
provision, unsupported by grant, can be achieved but only in some areas. It is recognised
that in many areas and types of sites it would not be viable to deliver this level of affordable
housing even with a buoyant housing and financial market. There may also be a need to
waive the requirement for affordable housing for regeneration and Listed Building projects
where it is demonstrated that the costs of such will impact critically on the viability of the
project. The Policy needs therefore to be sufficiently flexible to allow for varying levels of
affordable housing contribution across the District particularly where the constraints of a site
or the costs would not permit the full requirement being delivered. It is therefore considered
that the policy should be amended to refer to „targets‟ of 40% in the urban areas and 50% in
larger villages and to incorporate a clause which allows for lower levels where it can be
demonstrated that site constraints or costs would make achieving the full quota unviable. The
Council is also drafting a Housing Delivery Supplementary Planning Document (SPD), which
when finalised will be used to inform and advise developers on the detailed application of the
Affordable Housing Policy. The requirements of this Policy also do not rule out other sources
of affordable housing coming forward as part of any development which would contribute to
the targets (e.g. RSL development) and this should be clarified within the policy.

It is also considered that the thresholds for sites requiring affordable housing should be set at
15 dwellings (0.5 hectares) in the towns and at 5 dwellings (0.16 hectares) in the larger
villages as these reflect the guidance in PPS3.

The requirement for dwellings below these thresholds to make a financial contribution to the
provision of affordable housing has been adopted by other local authorities (e.g. South Hams)
and there is no reason why all dwellings should not make some contribution to meeting the
affordable housing needs of the District. The mechanism for achieving this will be set out in
the Housing Delivery SPD but is likely to involve a sliding scale of contribution. However, it is
considered that, as with sites above the threshold, the policy should be flexible to ensure that
the requirement does not compromise the viability of sites.

The comments made by the West Midlands RSL Planning Consortium are noted and it is
considered these have to a large extent already been addressed within the Policy. The
Housing Delivery SPD will also cover many of the issues raised which are not considered
appropriate to be addressed within the Core Strategy. It is considered however that there
should be further elaboration of the rural exceptions policy (bullet point 5) to set out the
circumstances under which such schemes would be permitted.

The general support for restricting housing in smaller villages and other rural areas to
affordable or local needs is encouraging. It is considered that there is justification for its use
in rural areas where there is strong evidence of high house prices relative to the earnings of
local workers which is excluding many local people for the local housing market. The Housing
Delivery SPD will set out more precisely the definition of local needs and how it would
operate. It is also considered that it would be helpful to clarify in the Reasons and
Justification that local needs housing can include live-work units.

Policy H3

This policy has been based on the North Staffordshire Gypsy & Traveller Needs Assessment
and the advice in Circular 01/06. It is a criteria based policy setting out considerations for
identifying sites and determining planning applications which is considered to be worded
positively and is sufficiently flexible to address a range of circumstances. It is acknowledged
that further information should be included regarding the findings of the Gypsy & Traveller
Needs Assessment as it affects the District. It is also considered that in order to better accord
with Circular 01/06 and good practice in terms of policies being fair, reasonable and inclusive
the word „genuine‟ should be removed from the first sentence. Removal of reference to sites
being „well located on the highway network‟ is also accepted as being appropriate as this is
already covered by policy T1. It is also accepted that the reference to interests of


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acknowledged importance not being prejudiced by the proposal should be more specific. It is
not accepted however that the Core Strategy should be specifically identifying sites as this is
more appropriately done through the Site Allocations DPD which will allocate sites for all
forms of housing.

It is also accepted that the policy should also relate to sites for travelling showpeople to reflect
the advice in Circular 04/07 – indeed the requirement in the North Staffordshire Gypsy &
Traveller Needs Assessment for gypsy and traveller sites is inclusive of plots for travelling
showpeople. However, as sites for travellers, particularly travelling showpeople, frequently
require storage and parking for larger vehicles it is considered appropriate that the reference
to sites not being detrimental to the amenity of the amenity of adjacent occupiers should
remain.


Suggested Changes

Policy H1 (New Housing Development)

1. Amend 2nd bullet point of Policy H1 (page 97) to read” Housing proposals of 10
   dwellings or more will be required to provide a range of dwelling types a mix of
   housing in terms of size, type and tenure on the site. The final mix will be
   negotiated with the developer based on the local housing needs identified in as
   informed by the Strategic Housing Market Assessment and other relevant factors
   such as available supply and market demand.”

2. Amend para. 8.4.8 of Reasons and Justification to Policy H1 to read: “Housing for special
   groups will also be needed to meet the future increase in elderly persons across the
   District and the needs of those with a learning or physical disability – this may be in the
   form of sheltered housing, extra care homes or supported housing.”

3. Add following additional sentence to paragraph 8.4.9 of Reasons and Justification to
   Policy H1: “The requirement of 20% of all new dwellings to be built to Lifetime Homes
   standard must be met in all cases unless a developer can demonstrate exceptional
   circumstances where this may not be practicable or appropriate.”

4. Add details of the requirements for sustainable design and construction from Policy SR3
   of the RSS within the Reasons and Justification.

Policy H2 (Affordable and Local Needs Housing)

1. Amend bullet point item no. 1 of Policy H2 (page 99) to read: “In the towns, residential
   developments of 15 dwellings (0.5 hectares) or more shall provide a minimum
   target of 50% 40% affordable housing on-site from all sources. The actual level of
   provision will be determined through negotiation taking into account development
   viability and other contributions.”

2. Amend bullet point item no. 2 of Policy H2 to read: “In the larger villages, schemes
   residential developments of 5 dwellings (0.16 hectares) or more shall provide a
   minimum target of 50% affordable housing on-site from all sources. Exceptionally
   this may be provided through a commuted sum payment in lieu. The actual level of
   provision will be determined through negotiation taking into account development
   viability and other contributions.”

3. Amend bullet point item no. 4 of Policy H2 to read: “In all areas on residential
   developments below the above thresholds, a financial contribution will be required
   towards meeting the affordable housing needs of the local area. Such provision
   will be determined through an SPD and will take into account development viability
   and other contributions.”



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4. Amend bullet point item no. 5 of Policy H2 to read: “In or on the edge of villages, small
   schemes for 100% affordable housing will be allocated in the Site Allocations DPD
   or will be permitted on suitable unidentified sites which are well related to services
   and facilities and where a demonstrable need exists within the local area which
   cannot otherwise be met by means of provision in the plan.”

5. Add following additional sentence to end of paragraph 8.4.16: “Local needs housing may
   also include live/work units as defined in the glossary.”

Policy H3 (Gypsy and Traveller Sites)

1. Amend first sentence of Policy H3 (page 101) to read: “Provision for gypsies and
   travellers will be made through the allocation of a site in the Site Allocations DPD if
   required to meet a genuine and proven need.”
               th
2. Delete 4 bullet point of Policy H3 referring to sites needing to be well located on the
   highway network.
                th
3. Amend 8 bullet point of Policy H3 to read: “Interests of acknowledged importance
   should not be prejudiced Sites or features of natural, historic or archaeological
   value should not be harmed by the proposal.”

4. Add reference within Reasons and Justification to Policy H3 to clarify that policy also
   relates to travelling showpeople. Also include further details of North Staffordshire Gypsy
   & Traveller Needs Assessment requirements for the District.




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TCR1 and TCR2 - Town Centre & Retailing
Introduction
The town centre and retailing policies seek to protect and enhance the vitality and viability of
the town centres. They also cover retail development outside town centres. The consultation
at the Issues and Options stage asked for views on the amount and location of new retail
development in Leek and Cheadle. The Draft Preferred Options policies take into account the
response to the consultation and national retail planning guidance. Policy TCR1 sets out a
series of criteria to protect and enhance the vitality and viability of the town centres including
focusing key town centre uses (like retailing, offices, leisure and cultural facilities) within the
town centres, supporting improvements to the town centre environment and protecting the
retail function in the heart of the town centres. Policy TCR2 covers retailing outside the town
centres in terms of bulky goods and types of retailing acceptable outside town centres and in
rural areas. Consultation on the Draft Preferred Option Town Centre and Retailing Policies
asked for comments on the contents of these policies (Q26).


Summary of Comments

Comments from Questionnaires and Correspondence

Policy TCR1 (Development in the Town Centres)

There were 13 comments made regarding Policy TCR1, mainly from consultees and
organisations raising specific points. Issues raised by members of the public and other
organisations were:
     Morrisons store in Newcastle Road, Leek should be recognised as an established
        retail destination and that it should be identified as part of a District Centre, though it
        is noted that this issue will be considered as part of the forthcoming Site Allocations
        DPD.
     In more general terms, the Core Strategy should place greater emphasis on meeting
        retail needs in all the main towns, to underpin and deliver the regeneration needed.
     In terms of a marketing exercise to support a change of use, an appraisal by a local
        estate agent ought to be sufficient.
     Policy should emphasise the significant weight to be attached to regeneration
        benefits in assessing retail proposals. In this District, the extent of retail needs and
        regeneration benefits are so significant that policy should specifically state this and
        allow for regeneration benefits to be considered as overriding against the PPS6 tests.
     Agrees that major development should incorporate measures to encourage more
        sustainable patterns of transport. Public transport is at present disorganised and not
        integrated. Need a public transport plan for the District.

In terms of the statutory consultees, the following made specific comments in response to the
policy. Staffordshire Police would like to see a minor amendment to the policy, to include
the word „safely‟ within point 1. They also consider that secure by design and architectural
crime prevention should be key aspects to sit along a clear strategy of exactly what
businesses are being sought and what type of retail space is preferred. The Sports Council
question whether sections 1 and 8 of the policy include sport and recreation under leisure
and/or culture. The Theatres Trust consider that town centres are the heart of communities
and an expression of their culture and identity and as well as shops they should provide a
range of suitable functions for leisure, recreation and cultural activities centred on restaurants,
pubs, clubs, theatres, cinemas, libraries and museums. They also consider that it would be
appropriate for villages generally to provide entertainment, leisure and cultural facilities of an
appropriate scale and kind to serve their roles and catchments.




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Policy TCR2 (Retailing Outside Town Centres)

There were 5 comments made regarding Policy TCR2, which were mixed. Issues and
criticisms raised by members of the public and other organisations were:
       Do not want any more bulky goods retail provision in Leek. Such development
         detracts from town centres. Any retail development must be on or very near the Town
         Centres.
       Morrisons store in Newcastle Road, Leek should be recognised as an established
         retail destination and that it should be identified as part of a District Centre, though it
         is noted that this issue will be considered as part of the forthcoming Site Allocations
         DPD.
       Policy should emphasise the significant weight to be attached to regeneration
         benefits in assessing retail proposals. In this District, the extent of retail needs and
         regeneration benefits are so significant that policy should specifically state this and
         allow for regeneration benefits to be considered as overriding against the PPS6 tests.

Just one statutory consultee commented on this policy. Staffordshire Police consider that
secure by design and architectural crime prevention should be key aspects to sit along a clear
strategy of exactly what businesses are being sought and what type of retail space is
preferred.

Comments from Consultation and Stakeholder Events
In terms of stakeholder workshops and meetings, town centre and retailing issues were
raised. At the meeting with young people, they considered that there were several parts of
Leek which are untidy and would benefit from redevelopment. The bus station and Smithfield
Centre as a whole was mentioned as needing environmental improvements and improved
occupiers of the shops as there was not considered to be enough to attract young people
here in terms of the retail offer. It was generally agreed that the vacant pubs in Leek are
unsightly particularly the Sea Lion, Talbot and White Lion which are boarded up. It was felt
that this does not create a good impression of the town. Most young people stated that
improvements to Leek town centre are required. Examples were – more clothes shops, less
antique shops and charity shops. It was stated that the town centre needs to be made more
attractive to visitors and residents. It was considered that a more centrally located car park to
serve Leek Town Centre would be useful.

There were no additional comments different from those made above regarding town centres
and retailing from members of the public who attended the consultation days.


Further Evidence and Other Issues Identified
The Staffordshire Moorlands Retail Study Supplementary Impact Analysis confirms the
need for additional large convenience stores in Leek and Cheadle and the need for a
quantitative and qualitative improvement in comparison floorspace in Leek including further
provision for bulky goods retailing. The impact of additional convenience and comparison
goods retailing on neighbouring centres is also assessed and it is demonstrated that there will
be no significant impact.


Officer Response

Policy TCR1

It is not considered appropriate to identify the Morrisons store in Leek as being part of a
District centre. Annex A of PPS6 defines District Centres as „groups of shops often
containing at least one supermarket and a range of non-retail services such as banks,
building societies and restaurants as well as local public facilities such as a library.‟ The



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Morrisons store is a stand alone store and not part of a group of shops and facilities as
described above so there is no justification for such a designation.

It is considered that the Core Strategy does place adequate emphasis on meeting retail
needs in the towns. Policy SS5 (Towns) is one of the overarching spatial strategy policies
specifying the amount of development including retail floorspace to be provided in the District
in the plan period and as stated in that policy the forthcoming Site Allocations DPD will
allocate sites to deliver this level of retail development.

It is agreed that an appraisal by a local estate agent is likely to form part of marketing
evidence. However, it is not considered that an appraisal alone without marketing having
taken place would be sufficient evidence to support the loss of an A1 retail unit within a
primary shopping frontage.

It is not agreed that the policy should allow for regeneration benefits to be considered as
overriding against the PPS6 tests when assessing retail proposals. Major regeneration
opportunities have been identified in the Core Strategy and include the Churnet Works area at
Macclesfield Road, Leek. Policy SS5a lists potentially suitable uses for this area as being
employment, residential, retail and leisure. It is not considered that the regeneration of this or
any other area listed is dependant on new retail development and consequently there is no
justification for undermining Government retail planning guidance in the policy.

In response to the comment about public transport, although reference is made to the
accessibility of town centres by sustainable means of transport, there are specific transport
policies elsewhere in the document (T1 and T2) which cover sustainable transport including
public transport. In terms of the comments made by Staffordshire Police, the importance of
safety in town centres is acknowledged and minimising the risk of crime is covered in part 6 of
the policy. Ensuring new developments are safe is also covered elsewhere in the Core
Strategy in Policy DC1 (Design Considerations). Therefore it is not considered that inserting
the word „safely‟ into part 1 of Policy TCR1 is necessary. It is agreed that secure by design
and architectural crime prevention are significant and these are covered by the design policy
DC1. In terms of details like the type of retail space and specific businesses who may come
to the towns, the Core Strategy is a strategic document which just specifies the amount of
retail floorspace required in each town. The forthcoming Site Allocations DPD will allocate
sites for this development and planning applications (which must take into account design
considerations in Policy DC1) will determine these details.

In response to the Sports Council‟s query, parts 1 and 8 of the policy are not intended to
cover most sport and recreation, only those more intensive uses. These parts of the policy
follow national planning guidance set out in PPS6 which requires authorities to concentrate
key town centre uses in town centres so as not to undermine their vitality and viability.
Clearly there are aspects of sport and recreation like playing pitches and children‟s play areas
which are not purely town centre uses and need to be distributed throughout the District so in
these cases the policy does not apply. The leisure and cultural facilities referred to in the
policy as town centre uses include cinemas, restaurants, nightclubs, health and fitness
centres, indoor bowling centres, theatres, museums, galleries and hotels. The comments
made by the Theatres Trust regarding the role of town centres are acknowledged. In terms of
their comments regarding provision of entertainment, leisure and cultural facilities of an
appropriate scale in villages, this is covered elsewhere in the document under Policy C1
(Creating Sustainable Communities), which is supportive of proposals to provide new
community facilities. In response to similar comments made in respect of Policy SS1, it is
suggested that a definition of leisure and cultural facilities be included in the glossary.

In response to the comments made at the meeting with young people, town centre
masterplans are due to be prepared for Leek and Cheadle which will be adopted as
Supplementary Planning Documents. These will look at the potential for improvements to
these town centres both in terms of environmental improvements, regeneration of areas /
sites (including vacant buildings) and improvements to the retail offer. The need for additional
retail floorspace in Leek is acknowledged and covered elsewhere in the report under SS5



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(Towns). In terms of car parking, part 5 of the policy allows for further parking facilities in and
around the town centres.

It is recognised that in view of the current economic situation, trading conditions are difficult
for high street retailers. There have been recent vacancies (both retail and financial /
professional services) created in the towns, most notably the site of the former Woolworths
store in Leek. With this in mind it is considered appropriate to amend the wording of policy
TCR1 to give greater flexibility and consistency with the policy approach in the Biddulph Town
Centre Area Action Plan (AAP) in relation to changes of use to non-retail uses in primary
frontages. The suggested policy amendment below uses the same wording as the Biddulph
Town Centre AAP. The wording in the reasons and justification explains what is meant by a
concentration. The requirement for a marketing exercise to demonstrate that that there are
no retail uses which could occupy an A1 unit is now included as part of the reasons and
justification. The sentence about double fronted units with a single occupier being counted as
a single unit is not considered necessary as a result of re-wording the policy and is now
covered in the reasons and justification.

Policy TCR2

The amount of bulky goods retail provision in Leek has been informed by the Council‟s District
Wide Retail Capacity Study and the recent update. This issue is covered elsewhere in this
report under the SS5 (Towns) policy. In terms of the locations of new retail development in
Leek, policy TRC2 follows national guidance set out in PPS6 by stating a preference for town
centre and then edge of centre sites. The policy only allows for development on other sites to
meet this identified need when these options have been fully explored. The identification of
sites will take place in the forthcoming Site Allocations DPD. The comments regarding the
Morrisons store in Leek, regeneration needs outweighing national retail planning guidance
and the response by Staffordshire Police have been addressed above in the response to
Policy TCR1.

It is considered that as it stands the policy does not adequately allow for the allocation of
major new convenience retail development in Leek and Cheadle outside of the town centre if
it cannot be accommodated on town centre sites. Suitable and available town centre sites in
both towns are at a premium. However, in line with Government guidance, the policy clearly
states that the town centre is the preferred location for such development and then edge of
town centre sites and only where there are no sequentially preferable locations would sites
outside of these areas be considered for retail development. Amendments to the policy are
suggested below to reflect this.

It is also considered that the policy would benefit from an additional paragraph to emphasise
that major retail proposals (of 500m2 gross or more) which are not allocated in the Site
Allocations DPD will not be permitted in order to protect the vitality and viability of the town
centres unless the proposal can be demonstrated to be acceptable under national and
regional planning policies. A new paragraph to reflect this is included in the suggested
changes section.


Suggested Changes

Policy TCR1 (Development in the Town Centres)

1. Amend item no. 9 of Policy TCR1 in the first paragraph under the heading „Primary
   Frontages‟ (page 105) to read: „In primary frontages, proposals for changes of use to
   A1 retail will be supported. Proposals which would result in the loss of an A1 use
   and would create a concentration of 3 or more adjacent non-A1 uses, will not be
   supported. Double fronted units with a single occupier will be counted as a single
   unit. Development falling within other use classes will only be permitted where it
   will not create a concentration of non-shopping uses and result in an unacceptable
   change in the retail character of the immediate area or have an adverse effect on
   the vitality or viability of the town centre.‟

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2. Delete the following second paragraph under the heading „Primary Frontages‟: „Where a
   proposed change of use from A1 retail would not create a concentration, a
   marketing exercise to demonstrate that there are no retail uses that could occupy
   the unit will be required to accompany the planning application.‟

3. Amend paragraph 8.5.14 of the Reasons and Justification to Policy TCR1 to read: „The
   safeguarding of the retail function at the heart of Leek and Cheadle town centres is
   considered to be a crucial factor in maintaining their vitality and viability, so in line with
   PPS6 guidance, primary and secondary shopping frontages will be defined in the Site
   Allocations Development Plan Document. In order to control the loss of all A1 retail units
   in primary frontages, where there is no concentration issue (which under the terms of the
   policy would preclude a change of use), a marketing exercise is required in line with the
   SPD. This approach ensures that when any A1 unit becomes available in the primary
   shopping area, there is an opportunity for it to be taken up firstly by another A1 use and
   only when there is no reasonable prospect of this happening would a change of use be
   considered. It is considered that in the designated primary frontage if a proposed change
   of use to a non-A1 use would result in three or more adjacent units in non-A1 use then
   this would create a concentration, and would be unacceptable. In some locations within
   the primary frontage, the creation of two non-A1 use units opposite a single non-A1 unit
   or where there is a significant A1 frontage (i.e. larger units in prominent positions) the
   change of use may also be unacceptable. Where the units are near a street junction, the
   presence of non-retail units around the corner may also be a material factor. If significant
   numbers of non-A1 uses are clustered in a part of the Primary Frontage, even if they are
   not adjacent, this may also constitute a concentration, particularly if this occurs towards
   the pedestrianised part of Derby Street in Leek or central High Street (particularly the
   southern side) in Cheadle – the busiest part of the town centres. Additionally it is
   recognised that the retail character of an area can be adversely affected by particular
   concentrations of non-A1 uses. In considering applications for non-A1 uses in an A1 unit
   in the primary frontage, evidence of marketing to demonstrate that there are no retail uses
   that could occupy the unit will be required. In secondary frontages a more flexible
   approach will be taken as it is recognised that a diversity of uses can be accommodated
   in such areas.‟

Policy TCR2 (Retailing Outside Town Centres)

1. Amend the first paragraph of Policy TCR2 (page 108) to read: „The Council will
   facilitate new bulky goods identify sites for significant retail provision in Leek and
   Cheadle to meet the local need identified in the Retail Study Policy SS5.
   Preference will be given to town centre and then edge of centre sites. for all major
   retailing. Where there are no sequentially preferable sites available, sites outside
   the town centres in highly accessible locations will be identified in the Site
   Allocations DPD‟.

2. Insert a new paragraph after the first paragraph of Policy TCR2 to read: „Other major
                              2
   retail proposals (of 500m gross or more) will not be permitted outside town
   centres in order to protect the vitality and viability of the town centres, unless the
   proposal can be demonstrated to be acceptable under national and regional
   planning policies‟.

3. Amend the third paragraph of Policy TCR2 to read: „Within the towns but outside town
   centres and in the larger villages identified in Preferred Policy SS6a new or
                                                         2
   extended convenience retail units of up to 500m gross floor space to serve
   everyday local shopping needs and improve access to retail facilities at a local
   level will be promoted and supported, provided that they complement but do not
   adversely impact upon the vitality and viability of the three town centres, are in
   sustainable locations.‟ and where the proposal is in accordance with PPS6.




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4. Amend the first sentence of paragraph 8.5.17 of the Reasons and Justification to Policy
   TCR2 to read: „Evidence from the Staffordshire Moorlands Retail Study (2006)
   demonstrates a need for further bulky goods retail floorspace in Leek and Cheadle.‟

5. Amend the third sentence of paragraph 8.5.17 of the Reasons and Justification to Policy
   TCR2 to read: „Consequently, where necessary, in line with the sequential test set out in
   PPS6, the Council will identify highly accessible sites outside the town centres to
   accommodate bulky goods retailing significant retail provision.‟

6. Amend the first sentence of paragraph 8.5.19 of the Reasons and Justification to Policy
   TCR2 to read: „The policy allows for small scale convenience retail development for local
   needs in accordance with the hierarchy of centres identified in Policy SS3 policies SS5
   and SS6a, to ensure that retail facilities outside of town centres complement rather than
   undermine their vitality and viability.‟




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DC1, DC2 and DC3 - Design & Conservation
Introduction
The design and conservation policies seek to promote local distinctiveness by means of good
design and the conservation, protection and enhancement of historic, environmental and
cultural assets along with the District‟s landscape and the setting of its settlements. The
consultation at the Issues and Options stage asked for views about the general quality of
design in the Staffordshire Moorlands and types of buildings which would benefit from further
design guidance. The Draft Preferred Options policies take into account the response to the
consultation and national guidance. Policy DC1 sets out design criteria relating to new
development to reinforce local distinctiveness and positively contribute to the area. Policy
DC2 covers the protection and enhancement of the historic environment. Policy DC3 sets out
measures to protect and enhance the local landscape and setting of settlements.
Consultation on the Draft Preferred Options Design and Conservation Policies asked for
comments on the contents of these policies (Q26).



Summary of Comments

Comments from Questionnaires and Correspondence

Policy DC1 (Design Considerations)

There were 12 comments made regarding Policy DC1, mainly from consultees and
organisations raising specific points. Concerns and issues raised by members of the public
and other organisations were:

        Needs greater emphasis on landscaping, greenery planting and the use of reclaimed
         materials particularly local items. Great attention should be paid to the setting of new
         buildings. Feel uneasy that we will be capable of insisting on good design particularly
         at the cheaper end of the market.
        The design policies need to be more robust. There is some confusion between well
         designed and well built. Consider that the Local Planning Authority should provide
         detailed guidance in the case of development of a major site and development of a
         sensitive site (e.g. large green field sites, sites in a historic setting etc.) It would be
         appropriate for a Parish Design Statement to be produced for each of the 3 towns
         and also rural parishes as all of these locations have a different and distinct
         character. Each of the 3 towns could lead and promote the production of these for
         their town.
        Unsympathetic design features e.g. wooden noise barriers alongside the Biddulph
         bypass have a negative visual impact.

In terms of the statutory consultees, most made specific comments in response to the policy.
Staffordshire Police are generally supportive of the policy and suggest some minor additions
to wording and changes to references made in the „reasons and justification‟ text which are
dealt with in the „suggested changes‟ section below. Sport England state that design
consideration should include the objective of Active Design. The National Trust consider
that the sustainable construction techniques and design concepts referred to are or should be
intended to provide adaptation to climate change. Natural England supports the inclusion of
this policy. The organisation makes reference to its accessible natural green space standards
in terms of new development and proposes that this standard is used in green infrastructure
planning for all development as a contribution to the creation of sustainable communities.
Additional wording to the policy is suggested to reflect this. Natural England proposes the
following amendment to bullet point 3 of the policy: „Create appropriate Green Infrastructure
within all development and make provision for networks of multi-functional new and existing
green space, both public and private‟. Biddulph Town Council would like to see more
robust design policies and give examples of local schemes they consider to be poor quality


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like part of the Victoria Business Park and housing on Meadows Way. They would like to see
different supplementary planning documents on design for the three towns to reflect their
individual characteristics and suggest producing its own design policy for Biddulph. They also
queried whether there is capacity to increase the housing density in the urban area.
Staffordshire County Council consider that the retention and conservation of historic street
furniture should also be encouraged as part of any appropriate development and that this
should be supported by the rationalisation of existing signage, the minimisation of street
markings, use of appropriate surfacing and associated highway improvements as
documented within the „Streets For All Manual: West Midlands‟ jointly published by the
Department of Transport and English Heritage (2005). They consider that reference should
be made to this in the policy and that the guidance should be referred to in the „Supporting
Guidance and Evidence‟ section. They consider that details from buildings on Local Lists
should also be used to inform the Council‟s Design SPD. English Heritage consider that the
proposed use of concept statements (referred to in paragraph 8.6.9) for allocated and large
unidentified sites should be closely informed and linked to a robust consideration of the
historic environment of the sites and their surrounding areas.

Policy DC2 (The Historic Environment)

There were 5 comments made regarding Policy DC2, mainly from consultees and
organisations raising specific points. Concerns and issues raised by a member of the public
were:

        The design policies need to be more robust. There is some confusion between well
         designed and well built.
        Consider that the Local Planning Authority should provide detailed guidance in the
         case of development of a major site and development of a sensitive site (e.g. large
         green field sites, sites in a historic setting etc.)
        It would be appropriate for a Parish Design Statement to be produced for each of the
         3 towns and also rural parishes as all of these locations have a different and distinct
         character. Each of the 3 towns could lead and promote the production of these for
         their town.

In terms of the statutory consultees, most made specific comments in response to the policy.
The National Trust point out that the Heritage Protection Bill is likely to proceed through
Parliament during the lifetime of the Core Strategy reforming the structure and terminology of
heritage designations. They would like to see this reflected both in the policy wording and the
reasons and justifications. Staffordshire County Council advises that areas of historic
landscape character be included within the „historic environment and interests of
acknowledged importance‟. They acknowledge that the historic landscape is clearly identified
within item 2 of the policy but as it is an element within the West Midlands Regional Spatial
Strategy (RSS) Policy QE1, they consider that it should be emphasised within the introductory
text. They consider that the preparation of a local list should be complemented by the
inclusion of appropriate protection and enhancement policies within the LDF. They also
consider that information from Conservation Area Appraisals should be used to provide
design details, and help to shape the Staffordshire Moorlands Design SPD in line with RSS
Policy QE5 C. English Heritage supports the inclusion of the policy and makes a variety of
recommendations to strengthen it. They would like to see the opening paragraph refer to the
settings of designated assets, and also recognise that the historic environment extends
beyond individual assets to the historic character of the wider landscape and townscape e.g.
„… archaeological remains, their settings, and the historic character of the landscape.‟ They
consider that an additional point should be included on the historic character of the landscape
and referring to the use and application of the County‟s Historic Landscape Characterisation
(HLC) and a cross–reference to policy DC3. They query whether the last part of point 3
(viability and planning benefits outweighing loss) is appropriate at this level and whether it
would it be better dealt with in the Design SPD? They consider that in the box on supporting
guidance and evidence, reference should also be made to PPS1, the county HLC and Historic
Environment Records. They also state that the rural heritage of the District could usefully be
expanded on in the reasoned justification drawing on the ongoing historic farmstead mapping
and characterisation project and make reference to comments on policy R1.

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Policy DC3 (Landscape and Settlement Setting)

There were 5 comments made regarding Policy DC3, mainly from consultees and
organisations raising specific points. Concerns and issues raised by a member of the public
and organisations were:

        Query what resisting inappropriate development means and what retaining the lands
         open and undeveloped appearance means.
        There is a need to secure development within the District as a means of supporting
         and diversifying the economy in line with Policy R1. Suggest therefore that Policy
         DC3 be amended so as to recognise that development might also be acceptable in
         exceptional circumstances. Request that the last paragraph of point 4 be amended as
         follows: "4...In exceptional circumstances, limited development of areas of visual
         open space may be acceptable where this will bring about over-riding improvements
         to the open space itself or where other over-riding factors justify the development".
        The policy could be expanded to include reference and support to the design of new
         Green Infrastructure, particularly through the Churnet Valley Tourism Corridor.

In terms of the statutory consultees, just one raised a specific issue in relation to this policy.
English Heritage support the inclusion and broad aims of the policy but require further
information on the scope of this study, particularly its consideration of the historic
environment, before they can fully endorse its approach. They consider that the character of
the landscape is fundamentally influenced by its cultural and historical development – as
evidenced by the County wide Historic Landscape Characterisation study. They point out that
this is complementary to the landscape character assessment and work has been progressed
by the County Council on integrating the two. They request confirmation that the Historic
Landscape Characterisation and other core data sets such as the County Council‟s Historic
Environment Record have been taken into account.

Comments from Consultation and Stakeholder Events
In terms of stakeholder workshops and meetings, the issue of design and conservation was
raised at some of these. At the Blythe Bridge Neighbourhood Forum it was considered by
a number of people that a vacant pub in the village should be preserved because of historic
interest or as a local landmark or because it is a community facility. At the Parish Council
workshops there were a number of views expressed about design including concerns about
a lack of consistency and that new affordable houses are too small for the occupants and lack
sufficient garden space. It was considered by some that design should be in keeping with its
surroundings but modern design should not necessarily be rejected and that the use of local
materials is important in village residential schemes.

There were no additional comments different from those made above regarding design and
conservation from members of the public who attended the consultation days.


Further Evidence and Other Issues
In 2008, the District Council commissioned consultants to undertake a landscape and
settlement character assessment of the Staffordshire Moorlands to form a key part of the
evidence base for the Core Strategy and forthcoming Site Allocations DPD. The study is split
into three sections covering landscape character, settlement setting and review of visual open
space designations. The landscape character section provides an up to date and integrated
description of the Staffordshire Moorlands landscape identifying key landscape characteristics
(including historic landscape characterisation), key planning and land management issues
and capabilities and sensitivities of the landscape to development and change. The
settlement setting assessment includes identification of the distinctive qualities of individual
settlements taking account of views, townscape setting, visually prominent landscape
features, the presence of any „natural‟ limits to development and an assessment of peripheral
areas of settlements to consider whether they could accommodate development without


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compromising landscape character. The visual open space section reviews the designated
visual open space in the District and makes recommendations as to which should be retained
and any new designations considered to be appropriate.

A Design SPD will shortly be commissioned which will provide detailed guidance for
developers on all aspects of design including design features and materials which are locally
distinctive to parts of the Staffordshire Moorlands. A draft of this document will be available
for consultation later this year.


Officer Response

Policy DC1

This policy seeks to be all embracing highlighting those matters which need to be considered
rather than setting out detailed requirements. It is agreed that appropriate landscaping, use
of local materials and the setting of new buildings are important elements of good design and
it is considered that this is adequately covered in the policy wording. Further details will be
provided in the forthcoming Design SPD to assist developers in achieving good locally
distinctive design. It is considered appropriate that design considerations apply to all new
developments including those at the cheaper end of the market. The Design SPD will provide
detailed guidance on the characteristics of each town and the rural areas to ensure that
locally distinctive design is highlighted. Paragraph 8.6.9 of the Reasons and Justification
section accompanying this policy refers to the use of „Concept Statements‟ for large sites to
identify their characteristics. The use of these documents will also guide developments on
major sites. It is acknowledged that unsympathetic design features can have a negative
visual impact on an area.

The minor changes to the supporting guidance and evidence and the reasons and justification
suggested by Staffordshire Police are agreed as are the principles of Active Design set out by
Sport England. The suggested changes section below covers these additions to the policy,
reasons and justification and supporting guidance and evidence sections. In line with the
National Trust‟s comments, the sustainable construction techniques and design concepts
referred to in bullet point 4 of the policy are intended to adapt to climate change. It is
considered that a minor wording change in the policy would be appropriate to clarify this. This
is dealt with in the suggested changes section below. The comments made by Natural
England about the importance of green infrastructure planning are acknowledged.            It is
considered appropriate to re-word the third bullet point of the policy to reflect the comments,
though slightly differently from that suggested. With regard to Natural England‟s suggestion
regarding green infrastructure it is considered that the most appropriate amendment to the
wording in order to best incorporate it with the other elements is „create, where appropriate,
attractive, functional, accessible and safe public and private environments which incorporate
public spaces, green infrastructure including making provision for networks of multi-functional
new and existing green space (both public and private), landscaping, public art and „designing
out crime‟ initiatives;‟ The reference to all development has not been included because the
green infrastructure element will not be applicable to all types of development.

The comments made by Biddulph Town Council are noted. It is not considered necessary to
produce three different supplementary planning documents on design. The forthcoming
Design SPD will provide detailed guidance on the characteristics of each town and the rural
areas to ensure that locally distinctive design is highlighted. The issue of housing densities is
covered elsewhere in the report under the analysis of Policy H1 covering new housing
development.

The comments made by Staffordshire County Council regarding consideration of the „Streets
for All‟ publication are acknowledged and it is suggested that reference is made to this
guidance in the supporting guidance and evidence section as requested. In terms of
including reference in the policy itself, it is considered that this is covered in general in bullet
point one of the policy, particularly „detailing and materials appropriate to the character of the
area‟ and consequently a reference to the document including some of the areas it covers

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would be more appropriate in the „reasons and justification‟ section which supports the policy.
It is agreed that details from buildings on Local Lists should be used to inform the District
Council‟s Design SPD. It is also agreed with English Heritage that concept statements should
be closely informed and linked to a robust consideration of the historic environment of the
sites and their surrounding areas. Additional wording is suggested for the „reasons and
justification‟ section to reflect this in the suggested changes below.

In terms of the comments made at the Parish Council Workshops about design, it is intended
that the forthcoming Design SPD will result in a consistent approach to the design of new
developments in the Staffordshire Moorlands. The guidance will cover principles for the
design and layout of new houses. The policy wording covers the design of new
developments in terms of respecting the site and its surroundings. It is agreed that modern
design should not necessarily be rejected and, as reflected in the policy wording, that
materials appropriate to the character of the area should be used.

Policy DC2

The point raised about a local design statement being produced for each town has been dealt
with above in the response to Policy DC1. In terms of the suggestion about production of
detailed guidance in the case of the development of a major and / or sensitive site, this issue
is addressed in paragraph 8.6.9 of the Reasons and Justification section supporting Policy
DC1 where the District Council states an intention to promote the use of „Concept Statements‟
to identify the characteristics of a site and express the sense of place that new development
should create.

It is not agreed that the contents of the Heritage Protection Bill should be reflected in the
policy wording and reasons and justification section because in early December 2008, the bill
was dropped from the Queen‟s Speech so it is uncertain as to if or when legislation will
change. It is however agreed that reference to areas of historic landscape character be
included within the introductory text to the policy and this is addressed in the suggested
changes below. It is considered that the Core Strategy contains appropriate protection and
enhancement policies to complement a local list. It is also agreed that information from
Conservation Area Appraisals should be used to help shape the forthcoming Design SPD.

The policy wording changes suggested by English Heritage are considered appropriate and
are covered in the suggested changes section. It is not agreed that the wording in part 3 of
the policy about viability and planning benefits outweighing loss would be better dealt with in
the Design SPD. It is considered important to refer to this issue within the policy. The rural
heritage of the District is covered elsewhere in the document as part of Policy R1. In terms of
referring to the County Council‟s Historic Landscape Characterisation study, this has been
done in the reasons and justification section. The study has been used to inform the District
Council‟s Landscape & Settlement Setting Assessment, which is referred to in Policy DC3
and it is considered more appropriate to make reference to this in the reasons and justification
section of this policy (refer to suggested changes for the wording).

In terms of the comments from the Blythe Bridge Neighbourhood Forum about preservation of
a vacant pub in the village, where buildings are not listed or within a conservation area, there
is no automatic protection in place preventing clearance and redevelopment of sites,
particularly as the re-use of brown field sites is in line with Government policy. The District
Council has an adopted Local List SPD in place which enables buildings of local value to be
identified with a view to retaining them. However, such buildings would not have statutory
protection.

Policy DC3

In response to the query about the meaning of „inappropriate development‟ and „retaining the
land‟s open and undeveloped appearance‟, the wording in the policy is in the context of visual
open space (VOS). Key purposes of visual open space (designated undeveloped land within
an urban area) are to form a visual break between development and protect attractive views



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so an example of inappropriate development would be built development which would
compromise this such as housing and industry.

It is not considered necessary to amend the policy to allow development on land designated
as visual open space in exceptional circumstances because the policy wording already covers
this issue. Visual open space designations will be determined in the forthcoming Site
Allocations DPD.      In identifying VOS, consideration will be given to the need and
appropriateness of development on these areas.

The issue of new green infrastructure is included below in the suggested changes to policy
DC1. The Churnet Valley Tourism Corridor is the subject of a separate policy (SS7)
elsewhere in the report. In response to the comments made by English Heritage, it is
confirmed that the Historic Landscape Characterisation work undertaken by the County
Council has been incorporated into the District Council‟s Landscape and Settlement
Character Assessment and additionally the County Council‟s Historic Environment Record
has been taken into account when producing the document.

In response to comments made by the National Trust regarding Policy SS6c, „other rural
areas‟, stating that the policy could be stronger on safeguarding the landscape of the Peak
District National Park from the effects of development within the plan area, this is addressed
in the suggested changes to this policy. It is considered that this topic area is best covered in
the landscape and settlement setting policy. The wording suggested by the National Trust
has been used with the addition of the word „conserving‟ to further strengthen the policy.


Suggested Changes

Policy DC1 (Design Considerations)

1. Amend the third bullet point of Policy DC1 (page 111) to read: „create, where
   appropriate, attractive, functional, accessible and safe public and private
   environments which incorporate public spaces, green infrastructure including
   making provision for networks of multi-functional new and existing green space
   (both public and private), landscaping, public art, and „designing out crime‟
   initiatives and the principles of active design;‟

2. Amend the fourth bullet point of Policy DC1 to read: „incorporate sustainable
   construction techniques and design concepts for buildings and their layouts to
   reduce the local and global impact of the development, particularly on by adapting
   to climate change, in accordance with policy SD1;‟

3. In paragraph 8.6.7 of the Reasons and Justification to Policy DC1 add a second sentence
   to read: „Green infrastructure can be defined as a network of multi-functional open
   spaces, including formal parks, gardens, woodlands, green corridors, waterways, street
   trees and open countryside. It performs a valuable role in the District‟s towns and villages.
   A Green Infrastructure Study will be undertaken to consider how the green spaces relate
   to one another in the District and where there may be opportunities to extend them.‟

4. Amend paragraph 8.6.8 of the Reasons and Justification to Policy DC1 to read
   „Assessment of potential impacts from new developments at the earliest possible stage of
   the design process will assist in identifying problems to be overcome. Applicants are
   advised to refer to the Government guidance entitled “By Design” (the companion to
   PPS1). Detailed guidance on issues of security and public safety in the public realm can
   be found in Circular 5/94 – Planning out Crime Safer Places: The Planning System and
   Crime Prevention and in Secured by Design (www.securedbydesign.com) produced by
   the police. A Design and Access Statement will be required to accompany proposals for
   development with accurate illustration of the proposal and its relationship with its
   surroundings including crime prevention considerations. A further useful reference point
   is the „Streets for All Manual: West Midlands‟ produced by the Department of Transport
   and English Heritage. This contains guidance on the retention and conservation of

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    historic street furniture, rationalisation of existing signage, minimisation of street
    markings, use of appropriate surfacing and associated highway improvements. The
    principles of active design set out by Sport England promote opportunities for sport and
    physical activity in the design and layout of development.‟

5. In paragraph 8.6.9 of the Reasons and Justification to Policy DC1, add a new sentence at
   the end to read „Where applicable, the statements should be closely informed and linked
   to a robust consideration of the historic environment of the sites and their surrounding
   areas.‟

6. Amend text in the „Supporting Guidance and Evidence‟ box by deleting reference to
   „Circular 5/94 'Planning Out Crime' and replacing with the updated guidance 'Safer
   Places: The Planning System and Crime Prevention', (ODPM/Home Office). Add a new
   document to the list „Manual for Streets (DCLG/ Department for Transport, 2007)‟.

7. Add two further documents to the supporting guidance and evidence section: „Streets for
   All Manual: West Midlands – Department of Transport & English Heritage (2005)‟ and
   „Active Design – Sport England‟

Policy DC2 (The Historic Environment)

1. Amend the first paragraph of Policy DC2 (page 113) to read: „The Council will
   safeguard and, where possible, enhance the historic environment, areas of historic
   landscape character and interests of acknowledged importance, including in
   particular scheduled ancient monuments, significant buildings (both statutory
   listed and on a local register), the settings of designated assets, conservation
   areas, registered historic parks and gardens, registered battlefields and
   archaeological remains by:‟

2. Add following new sentence after the second sentence to paragraph 8.6.11 of the
   Reasons and Justification to Policy DC2: „The historic environment also extends beyond
   individual assets to the historic character of the wider landscape.‟

3. Add following new sentence to end of paragraph 8.6.13 of the Reasons and Justification
   to Policy DC2: „Staffordshire County Council has undertaken a countywide Historic
   Landscape Characterisation project which was taken into account when producing the
   District Council‟s Landscape & Settlement Setting Study (refer to Policy DC3).‟

4. Add further documents to the supporting guidance and evidence section: „PPS1
   „Delivering Sustainable Development‟‟, „Historic Environment Record by Staffordshire
   County Council‟

Policy DC3 (Landscape and Settlement Setting)

1. Add following new item no. 5 to Policy DC3 (page 114): „Recognising and conserving
   the special quality of the landscape in the Peak District National Park, and ensuring
   that development does not adversely affect the wider setting of the national park.‟
   (The existing item no. 3 will become 4 and the existing item no. 4 will become 5.)

2. In paragraph 8.6.16 of the Reasons and Justification to Policy DC3 add additional
   wording to the final sentence to read: „The Council has undertaken a Landscape
   Character Assessment in order to identify character features in the District which should
   be used to inform planning decisions taking into account Staffordshire County Council‟s
   Historic Landscape Characterisation study.‟




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C1 & C2 - Sustainable Communities
Introduction
The sustainable communities policies seek to apply the key Government principle of ensuring
that new development contributes to the creation of safe, liveable and mixed communities
with good access to jobs and key services for all the population. The consultation at the
Issues and Options stage asked whether the District Council should aim to support
community facilities in towns and villages and asked respondents to identify which ones and
where. Also, the public were asked whether public open space in the towns and villages
should be protected from development. In response to the comments received and in order
for the policies to be consistent with national guidance, at Draft Preferred Options the policies
sought to create sustainable communities and promote the provision of high quality
recreational open space. Policy C1 protects existing community facilities, ensures that there
will be adequate infrastructure in place to serve new development, supports the relocation of
uses no longer compatible with their surroundings and requires high quality design and
layouts in new developments. Policy C2 promotes the provision of high quality recreational
open space by implementing and supporting schemes that will protect and improve the
quantity, quality and accessibility of open space and outdoor sports, leisure and children‟s
play facilities throughout the District. Consultation on the Draft Preferred Option Sustainable
Communities Policies asked for comments on the contents of these policies (Q26).


Summary of Comments

Comments from Questionnaires and Correspondence

Policy C1 (Creating Sustainable Communities)

There were 8 comments made relating to Policy C1, mainly from consultees with general
support expressed for the policy. No criticisms of the policy were made by members of the
public.

In terms of the statutory consultees there was support for the policy from Sport England who
made additional suggestions to strengthen the policy. They consider that it should be linked
to RSS Policy SR2, Part 2 should also refer to relevant strategies, Part 3 needs to be
consistent with PPG17 in relation to open space, sports and recreation facilities, Part 5 should
require replacement facilities to be equivalent or better and Part 6 should refer to Active
Design. The Theatres Trust has some objections to the policy as it stands. They support
the content of the policy but suggest that the title is changed to „community facilities‟, arguing
that making communities more sustainable would incorporate many more elements than just
community facilities. They also request that a definition of the term community facilities is
included in the glossary and they suggest specific wording which could be used, namely
„community facilities provide for the health, welfare, social, educational, leisure and cultural
needs of the community’ as they consider that this covers all eventualities. Biddulph Town
Council made a general point that they would like to see a more aggressive use of money
from developer contributions. Staffordshire Police support part 6 of the policy about the
reduction of crime and fear of crime through design in new development. They consider that
this is consistent with one of the initial comments in the Safer Places document when it
acknowledges that, 'Sustainable communities…are well-designed places where people feel
safe and secure; where crime and disorder, or the fear of crime, doesn't undermine the quality
of life or community cohesion'. United Utilities query whether 'utility infrastructure' should
also be stated in the policy.

Policy C2 (Sport, Recreation and Open Space)

There were 12 comments made regarding Policy C2, mainly from consultees and
organisations with a majority expressing some general support though many raised specific


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points. Criticisms made and issues raised by members of the public and other organisations
were:
     Need to be flexible in the approach and implementation of this policy. Needs to be a
        case by case assessment of development proposals to judge whether the
        recreational value added by improvement and management measures would make
        an overall reduction in size of an open space acceptable.
     The Core Strategy should take every opportunity to promote access to facilities by
        public transport and by alternatives to the car, such as cycle routes, Staffordshire
        Way and public rights of way. The policy should be expanded to include text to
        ensure that new recreation facilities are supported by alternatives to the car.
     Develop social and recreational areas that cater for modern type activities e.g. BMX
        skateboards.

         In terms of statutory consultees and local organisations, there was a mixed response
         to the policy. The Woodland Trust supports the inclusion of the policy and has
         developed a woodland access standard to complement Natural England‟s access to
         green space standard. Using the standard, they have calculated that the Staffs
         Moorlands has below average accessibility in smaller woodlands but above average
         accessibility for larger woodlands in comparison with the county and region. They
         consider that this larger woods accessibility level could usefully form the basis of a
         vibrant green infrastructure network. They would like to see the Woodland Access
         Standard used as a tool to inform the Core Strategy and relevant Supplementary
         Planning Documents. Sport England support the general principles of the policy but
         consider that its scope is not entirely clear. They consider that it should also include
         indoor facilities and strongly recommend that the policy, SPD and standards should
         be comprehensive for all open space, sports and recreation facilities. They also
         consider that the policy should seek that all new sports facilities are fit for purpose in
         their design. The National Trust object to the policy as it stands because they
         consider that it does not adequately address the need to improve the quality and
         extent of natural open spaces, including those to which there is no public access, that
         serve valuable functions as habitat or landscape and in the provision of ecosystem
         services. They consider that the policy will not deliver spatial objective SO2 nor bring
         about the improvement sought under SO9. Biddulph Town Council has stated that
         they would not like to see public open space being lost to housing development.
         Staffordshire County Council states that there are important links between this
         document and the County Council‟s recently published Rights of Way Improvement
         Plan (ROWIP) which establishes a framework for managing the rights of way network
         across the County and public access to the countryside over the next 10 years. The
         Staffordshire Moorlands area is acknowledged in the ROWIP as being an area where
         demand for public access is high. In partnership with other stakeholders, the County
         aim to manage and improve public access in the Staffordshire Moorlands area.
         Parks and Countryside comment that levels of new development proposed will
         result in the need for the provision of more open space amenities in the District.
         Policy needs revision to cover a wider range of facilities (not just playing pitches and
         play areas) and the threshold for developer contributions should be reviewed to
         include smaller developments of less than 20 dwellings.

Comments from Consultation and Stakeholder Events

In terms of stakeholder workshops and meetings, the issue of community facilities and
infrastructure was raised at several of these. At the Blythe Bridge Neighbourhood Forum
the preservation of a vacant pub as a community facility was raised. At the Cheadle
Neighbourhood Forum, the issue of infrastructure being in place first to support new
development was raised. Views were expressed at both Tean Neighbourhood Forum and
Werrington Parish Council meeting that these areas would benefit from further community
facilities (retailing and leisure, respectively). Werrington Parish Council also considered that
the document does not take into account the number of public houses closing and being
allowed to be converted to residential use. At the meeting concerning older people,
community facilities were considered to be very important and views were expressed that
they should be supported. The group considered that buildings like schools, particularly in

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rural areas could be used for several purposes in recognition that few communities can
sustain a variety of facilities in separate buildings. At meetings with young people, it was
considered that there are some deficiencies in facilities for this group e.g. a larger skate park,
bowling alley and cinema in Leek.

There were no additional comments different from those made above regarding community
facilities, infrastructure or public open space from members of the public who attended the
consultation days.



Further Evidence and Other Issues
The Sustainable Communities Act 2007 came into force in October 2008. This has the
effect putting a duty on the Secretary of State to promote the sustainability of communities via
allowing residents (via Local Authorities) to suggest practical changes to law or policy. There
are a many criteria (“Schedule Matters”) to which suggestions can be made, including (a) “the
provision of local services”; (d) “measures to promote reasonable access by all local people to
a supply of food that is adequate in terms of both amount and nutritional value”; (g)
“measures taken to reduce the level of road traffic including, but not restricted to, local public
transport provision, measures to promote walking and cycling and measures to decrease the
amount of product miles” (h) “the increase in social inclusion….”; and most importantly (l)
“planning policies which would assist with the purposes of this Act”. It is considered that
Policy C1 does broadly – with other Policies in the Core Strategy – promote sustainable
patterns of living. The District must now recognise that under Matter (l) the Secretary of State
may be pressurised into changing planning policy (or the planning framework) for this end.

The Community Infrastructure Levy forms Part 8 of the 2008 Planning Bill. According to
DCLG the Bill will allow Local Planning Authorities to apply the levy to fund sub-regional
infrastructure (over and above planning fees). The nature of these schemes will be identified
in the RSS, so that LDFs can identify them at the local level. A wide definition of „community
infrastructure‟ is suggested i.e. transport, schools, health centres, flood defences, play areas
etc, such that “development can be…made sustainable”. Clearly this has implications on not
only Part 4 of this Policy, but also other Core Strategy Policies.

A PPG17 audit of all types of open space, indoor and outdoor facilities is currently being
undertaken. This document will assess the quantity, quality and accessibility of the following:
outdoor sports facilities (e.g. playing pitches, tennis courts), indoor facilities (swimming pools,
sports halls), parks and gardens, natural and semi-natural open space, amenity green space,
provision for children and young people, allotments, cemeteries and churchyards and civic
spaces. It will also establish local standards for local space provision to inform a review of the
SPD. A Playing Pitch Strategy is also being undertaken which will provide more detailed
data regarding provision and future need which will be fed into the outdoor facilities element
of the audit.


Officer Response

Policy C1

The general support expressed for Policy C1 is acknowledged. In terms of the response from
Sport England, the West Midlands Regional Spatial Strategy forms part of the development
plan for the Staffordshire Moorlands so it is considered that adequate linkages between this
Core Strategy policy and emerging RSS policy already exist. Specific reference to service
providers‟ particular strategies in the policy is not considered to be necessary as the policy,
once adopted, will be in place for a long period of time and some service providers have
strategies which are reviewed on a very regular basis (e.g. annually) so this would quickly
become out of date and would not increase the soundness of the policy. In relation to the
view that part 3 of the policy needs to be consistent with PPG17 in relation to open space,
sports and recreation facilities, loss of such facilities is covered in the other policy within this


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section, C2 (Sport, Recreation and Open Space). Policy C1 deals with loss of other
community facilities like public houses, shops and post offices. A different approach has
been taken to resist the loss of these facilities with the requirement for a viability appraisal
including a marketing exercise. It is not considered necessary to repeat any elements of
Policy C2 within Policy C1 as they are complementary. It is not considered appropriate to
require replacement facilities to be equivalent or better in part 5 of the policy. This primarily
relates to employment uses so equivalent facilities may not be appropriate in a new location.
The relocation itself is likely to result in improved employment units in a more suitable location
though it is not considered appropriate to make this a requirement in the policy. Reference
has been made to active design in Policy DC1 „Design Considerations‟ so it is not considered
necessary to repeat this in Policy C1.

In response to the Theatres Trust comments, it is not considered appropriate to change the
title of the policy to „community facilities‟ because there are other elements to the policy such
as infrastructure provision, design and regeneration all of which contribute to the creation of
sustainable communities. It is accepted that a definition of the term „community facilities‟
could be included in the glossary and this is covered in the response to Policy SS1. In
relation to comments made by the Theatres Trust in response to Policy E3, clarification that
„community facilities‟ includes cultural facilities is considered to be appropriate in the reasons
and justifications section of Policy C1.

The comments made by Biddulph Town Council and Staffordshire Police in relation to this
policy are noted. It is considered appropriate to make reference to the „Safer Places‟
document produced by the Government in the supporting guidance and evidence section of
the policy. In response to United Utilities suggestion it is considered appropriate to include
clear reference to utility infrastructure in the policy. The word „service‟ in the first sentence of
part 4 of the policy was intended to cover this but it is accepted that this is not particularly
clear. The suggested amendment is covered in the suggested changes section.

In response to comments made at Blythe Bridge Neighbourhood Forum and by Werrington
Parish Council the importance of public houses as community facilities is acknowledged and
the policy wording resists the loss of such facilities unless nearby alternatives are available or
there are no financially viable options for retention of the facility. It is considered that part 4 of
the policy adequately addresses the issue raised at the Cheadle Neighbourhood Forum. In
terms of the comments made at Tean Neighbourhood Forum and by Werrington Parish
Council relating to the need for more community facilities in those areas, part 1 of the policy is
supportive towards the development of new facilities. In response to the comments from the
meeting concerning older people, it is agreed that multi-use of facilities is an option and this is
reflected in part 1 of the policy. In response to the comments by young people about the
need for a cinema in Leek, Policy TCR1 would be generally supportive in principle of such a
development.

Policy C2

In response to the comment about adopting a flexible approach and implementation of this
policy, it is the intention of Policy C2 to assess the need for sport, recreation and open space
provision on a case by case basis based on proven deficiency.

In response to comments made by Sport England and Parks and Countryside, it is intended
that this policy and the Supplementary Planning Document (SPD) does not just cover playing
pitches and play areas but all the types of open space sports and recreation facilities,
including indoor facilities included in the PPG17 audit. This should be made clear by
amendments to wording of the Policy and the reasons and justification.

In response to the comment from Sport England, it is considered that an additional bullet point
that seeks that all new sports facilities are fit for purpose could be accommodated without
contradicting the overall intent of the policy.

In response to the comment regarding greater promotion of access to facilities by public
transport and by alternatives to the car such as cycle routes and public rights of way, it is


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considered that „local transport infrastructure‟ includes these means and it would over
complicate the policy by adding additional wording to the text. It is however considered that a
sentence could be added to the reasons and justification to clarify this.

In response to comments from young people and another respondent, BMX and skateboard
facilities are considered within the „Provision for children and young people‟ section of the
PPG17 audit. Indoor bowling facilities will be considered within the Indoor Sports Facilities
section. The outcome of the PPG17 audit will inform decisions on the quantity, quality and
accessibility of provision for children and young people and indoor sports facilities and
establish local standards. These will be included within the SPD which will be used a basis
for determining the open space requirement for planning applications or alternatively the
amount of contribution payable in lieu of that provision into the Council‟s Open Space Fund.
In response to the comment from Parks and Countryside the current threshold of 20 dwellings
will be reviewed through the SPD.

In response to Biddulph Town Council‟s concerns Policy C2 protects existing areas of open
space, recreational land and buildings including fields and amenity open space unless
equivalent and suitable alternative provision is made or that it does not result in a deficiency.
Developers will be required to provide various types of open space as an integral part of any
proposed scheme and also make contributions to other types of open space where relevant.

The response from the Woodland Trust regarding support for this policy is welcomed,
however the suggestion that the Council adopts the „Woodland Access Standards‟ is not
accepted. PPG17 states that „open space standards are best set locally‟ and the PPG17
audit will set local standards and include full justification for „natural and semi natural open
space‟ which includes woodland and also urban forestry, scrubland, grasslands, wetlands,
nature reserves and wastelands.

In response to the National Trust, this policy is not intended to cover open space to which
there is no public access. The protection and enhancement of biodiversity resources are
covered by Policy NE1.


Suggested Changes

Policy C1 (Creating Sustainable Communities)

1. Amend the wording to the first sentence of item no. 4 of Policy C1 (page 117) to read:
   „Only permit new development where the utility, service, transport and community
   infrastructure necessary to serve it is either available, or will be made available by
   the time it is needed.‟

2. Amend first sentence in paragraph 8.7.7 of the Reasons and Justification to Policy C1 to
   read: „Community facilities such as village halls, village shops and post offices, schools,
   colleges, nurseries, places of worship, health services, convenience stores, libraries, and
   public houses and cultural facilities such as theatres and arts centres play an important
   role in community life in the Staffordshire Moorlands.‟

3. Add a new reference in the supporting guidance and evidence box to read: 'Safer Places:
   The Planning System and Crime Prevention', (ODPM/Home Office).

Policy C2 (Sport, Recreation and Open Space)
                nd
1. Amend 2 paragraph of Policy C2 (page 120) to read: „Where there is a proven
   deficiency, qualifying new residential development will be expected to make
   provision, or a contribution towards provision of open space, sports and recreation
   facilities which are necessary and reasonably related in form and scale in
   accordance with the adopted minimum standards set out in the Open Space, Sport
   and Recreation SPD.‟


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               st
2. Amend 1 bullet point of Policy C2 to read: „Existing areas of open space, recreational
   land and buildings including school playing fields and amenity open space will be
   protected from development, unless equivalent and suitable alternative provision is
   made which is at least as accessible and at least equivalent in terms of size,
   usefulness, attractiveness and quality, is capable of being maintained adequately
   through management and maintenance agreements or that it does not result in a
   deficiency an assessment has been undertaken to demonstrate the facility is
   surplus to requirements. Sites over 0.2 hectares will be identified in the Site
   Allocations DPD.‟
               nd
3. Amend 2 bullet point of Policy C2 to read: “New sport, recreation and open space
   facilities should:
          be located in accessible locations and supported by the local transport
           infrastructure;
          protect the residential amenity of the area;
          be of an appropriate quality, scale and form compatible with the local area,
           especially if the site is located outside the settlement boundary in the open
           countryside;
          not harm interests of acknowledged importance; and
          be designed so that they are fit for purpose.‟

4. Amend paragraph 8.7.14 of Reasons and Justification to Policy C2 to read: „Open space
   in the Staffordshire Moorlands forming a network of green infrastructure, is important to
   both residents and visitors and this policy promotes and safeguards many types of open
   space. The Sustainable Community Strategy and the Council‟s Sport and Physical
   Activity Strategy recognise the importance of good quality open space, sports and
   recreation facilities in tackling obesity and improving the quality of life and health of
   communities. An updated Sports and Physical Activity Strategy will identify the future
   needs of the District by reflecting the outcome of the PPG17 audit n terms of will inform
   decisions on the quantity, quality, and accessibility of recreational open space, sports and
   recreation facilities provision. establish local standards for open space provision to inform
   a review of the SPD. The glossary includes examples of the types of recreation facilities
   and open space included in the Audit.‟

5. Amend paragraph 8.7.15 of Reasons and Justification to Policy C2 to read: „The Council
   will establish local standards for all types of provision within an updated Open Space,
   Sport and Recreation SPD. This will also be used to set use the local space standards in
   the SPD as a basis for determining the open space, sports and recreation facilities
   requirement for planning applications or alternatively, the amount of contribution payable
   in lieu of that provision into the Council‟s Open Space Sports and Recreation Facilities
   Fund. The allocation of new sites for sport and recreation will take place in the Site
   Allocations DPD.‟

6. Amend paragraph 8.7.16 of Reasons and Justification to Policy C2 to read: „New sport,
   recreation and open space facilities should be in an accessible and sustainable location
   and carefully assessed so that they do not have a detrimental impact on the local area,
   especially if they are proposed on the edge of a settlement in the open countryside.
   Opportunities to promote access to facilities by public transport and by alternatives to the
   car such as recreational routes, cycleways and bridleways etc should be maximised.‟

7. Add the following definition of „Open Space, Sports and Recreation Facilities‟ in the
   glossary: „Open Space includes parks and gardens, natural and semi-natural open space
   (e.g. woodlands, nature reserves), amenity green space (e.g. green spaces in and around
   housing), allotments, cemeteries and churchyards, civic spaces and provision for children
   and young people (e.g. play areas, skate parks, informal kickabout areas). Sports and
   recreation facilities include outdoor sports facilities (e.g. playing pitches, bowling greens,
   tennis courts) and indoor facilities (e.g. swimming pools, sports halls).




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R1 and R2 - Rural
Introduction
The rural policies set out the type of development which will be supported in the rural areas
outside of the towns and villages. They seek to sustain the rural economy and enhance the
quality of the countryside. Policy R1 supports rural diversification and identifies the
requirements for development. R2 establishes the forms of residential development that are
acceptable in rural areas. The part of the policy on conversions of rural buildings seeks to
establish a balance between achieving rural diversification and enabling appropriate
residential development where it enables the provision of affordable housing or helps to meet
an identified local need which cannot be met elsewhere. The consultation at draft preferred
options stage asked for views on the contents of the draft policies.


Summary of Comments

Comments from Questionnaire and Correspondence

R1 (Rural Diversification)

There were 12 comments made relating to policy R1 generally supporting the policy.
However a number of concerns and issues were raised:
 Decisions for change of use for conversions of rural buildings to commercial uses should
  be taken on an individual basis.
 Policy should further reflect the Rural Area Vision which recognises the role sustainable
  tourism and the re-use of major redundant sites in the countryside will have in
  regenerating the rural areas and diversifying the rural economy. Suggest that the policy is
  modified to have regard to the benefits tourism can bring to rural areas and include
  positive measures to facilitate rural economic growth (through the re-use of major
  redundant sites in the countryside for example).
 Should be a strict rule preventing development where the access is less than 4 metres and
  strict enforcement of use of new farming buildings so they do not become barn
  conversions i.e. if no longer used for that purpose they should be demolished or be
  standing for over 50 years before it can be developed. Also prevent erosion of openness
  by disallowing hedgerows being put on Green Belt boundaries.
 5 objections to the last paragraph, regarding the policies support for the re-use of buildings
  for tourism uses and the requirement that this should not undermine other tourism
  enterprises, stating that this would be charter for third parties to object on competitive
  grounds.

In terms of the statutory consultees there was support for policy R1 from Advantage West
Midlands for the fact that clear reference is made to reuse of redundant buildings for
commercial purposes and provision of new employment opportunities. The Agency
highlighted the Redundant Building Grant Scheme that they currently offer. British Waterways
support the policy but state that policy E3 needs to be amended to remove conflict. English
Heritage recommends that in the first paragraph that the following is included, “and sustains
the heritage.” They also highlight the work that they are completing to compile a county-wide
mapping and characterisation project of historic farmsteads, which is part of a region-wide
programme of projects. They recommend that this ongoing work is referred to in the reasoned
justification. The work should also inform the proposed Design SPD.

There were 11 comments made regarding policy R2 with the majority raising specific points
and/or concerns regarding rural conversions
 Strict enforcement of use of new farm buildings so they do not become barn conversions.
   If they are no longer used for that purpose that purpose they should be demolished or left
   standing for 50 years before they can be developed.



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   Strongly opposed to what is effectively a ban on conversion for residential use. For a
    variety of reasons think affordable or local needs housing is a non starter with the types of
    buildings and locations that would be converted for this purpose. Suggest therefore the
    Rural Policy require considerable modification to bring about a more sensible, realistic
    and less restrictive policy.
   There were also 5 objections to the policy in its present form with the reason given that
    many rural buildings are not suitable in terms of size for affordable housing. There should
    in the first instance be a preference for local need but an element of market housing
    should be allowed.
   The reuse of existing rural buildings has an important role in contributing towards rural
    housing targets, helping meet the needs of rural communities for commercial
    development tourism and recreation opportunities.
   Replacement dwellings should not be restricted to the size of the existing building this is
    impracticable.
   Should be some flexibility for a replacement dwelling.

The West Midlands Regional Assembly has suggested that sufficient scope exists within
policies SS6a and SS6b to enable rural local housing needs to be accommodated without
resorting to areas outside of development and infill boundaries (Policy R2). The policy as
currently expressed would appear to increase the potential for increased level of isolated
dwellings in the open countryside.

Comments from Consultation and Stakeholder Events
At the Parish Council workshops support was expressed for employment development to take
place in the rural areas. It was stated that businesses in rural areas should be encouraged to
provide local employment and that local businesses needing to expand should generally be
allowed to do so. The representatives do not have a problem with live/work units as long as
they are sensitively located. In Rushton there was concern expressed about the number of
agricultural workers dwellings being built in the countryside. There were no other comments
received at these events that are not already mentioned above in the comments from
questionnaire and correspondence.


Further Evidence and Other Issues
It is proposed that a Tourism Study will be undertaken for the District. An element of the
proposed study is to research the position of the existing tourism economy in the District and
to assess what potential there is for further growth and, identify areas where there is concern
that the market has the potential to become or already is saturated.

Mathew Taylor, MP for Truro was asked by the Prime Minister to conduct a review on how
land use planning can better support rural businesses and deliver affordable housing. The
Taylor Review (2008) identifies that rural communities face pressures affecting their
sustainability from restrictive planning practices, a low supply of housing (particularly
affordable housing) to meet local needs, and very high house prices which are unaffordable in
relation to local wages. It states „Our rural communities can only prosper and survive if we
nurture a living, working countryside. Yet the countryside is under intense pressure.‟ (pg 8) It
goes on to say, „This destructive combination of high cost homes and low rural wages is
putting rural housing out of the reach of many who work in the countryside.‟ (pg 8)


Officer Response

Policy R1

The main concern regarding Policy R1 relates to the last sentence regarding undermining
other tourism enterprises and it is acknowledged that this could raise objections regarding
competition which are not planning issues. It is also considered that the current wording of


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the policy is too inflexible and difficult to enforce. Deleting this last sentence would not detract
from the thrust of the policy which is to promote rural diversification. However, it is
considered that reference needs to be made within the Reasoned Justification to a Tourism
Study which will be used to identify where there is scope for further provision and the nature
of that provision which will help inform decisions on applications for tourism uses in order to
ensure supply matches demand. The comments of English Heritage regarding including
reference to sustaining the heritage is accepted and reference should be made in the
supporting text to the characterisation project of historic farmsteads being carried out.

Policy R2

With regard to Policy R2 the main concern clearly relates to the requirement in the last bullet
point for the conversions to residential being for affordable or local needs housing. The local
needs criterion of the policy is intended to ensure that any rural conversions in the open
countryside outside the town and village development boundaries is only granted either to
enable provision of affordable housing or to provide housing for local need (local needs
housing can be market housing in line with policy H2 which defines local need as being for a
person or family currently working in the community or needing to work in the community and
will be subject to a local occupancy condition or it may include live/work units). Allowing
conversions to residential use where there is not a local need in the open countryside would
undermine the overall development approach and result in unnecessary development which
would more appropriately be accommodated within villages.

In response to the concerns of the West Midlands Regional Assembly it is acknowledged that
most housing development in the rural areas should be in villages where the services and
facilties exist to support them or they can enhance the sustainability of a village and this is
reflected in the overall strategy. However, there are forms of housing which are still
appropriate in other rural areas such as conversions, dwellings for an essential local need
and affordable housing schemes which are supported in national planning guidance and it is
important that the policy does allow for these. Unfortunately, policy R2 as currently worded is
not sufficiently clear in this respect and an amendment to the wording is therefore suggested.

From the responses received to the consultation, it is apparent that clarification of the policy
requirements is needed and it is suggested that the supporting text is amended. It is also
recognised that in some cases rural buildings may not be suitable for conversion for
affordable housing purposes. Rather than the building itself being converted for affordable
housing purposes, a financial contribution towards off site affordable housing provision could
be made.

It is considered that the comments made regarding the replacement dwelling policy are
credible and there should be some flexibility on size. The current Local Plan allows for
„modest‟ increase in size however there have been some difficulties with interpretation of
„modest‟. It suggested that the policy wording is amended to allow some limited flexibility on
size of the replacement dwelling through the addition of the word “significantly” however it
needs to be ensured that any increase in size that is permitted does not exceed what would
have been acceptable for an extension to the existing dwelling under the extensions element
of the policy. This needs to be explained in the supporting text along with a reference to the
need to consult the Design SPD.


Suggested Changes

R1 (Rural Diversification)

1. Amend first paragraph of Policy R1 (page 123) to read, „All development in the rural
   areas outside the development boundaries of the towns and villages will be
   assessed according to the extent to which it enhances the character, appearance
   and biodiversity of the countryside, promotes the sustainable diversification of the
   rural economy, facilitates economic activity, and meets a rural community need
   and sustains the heritage.‟

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               th
2. Amend 5 paragraph of Policy R1 to read: „Priority will be given to the re-use of rural
   buildings for commercial enterprise, including tourism uses, where the location is
   sustainable and the proposed use does not harm the building‟s character and/or
   the character of its surroundings. Tourism uses for such buildings will be
   supported where it will contribute positively to the rural economy and is near to an
   existing settlement and would not undermine other tourism enterprises‟

3. Add following additional paragraph to Reasons and Justification to Policy R1: „Tourism
   also plays an important role in diversifying the rural economy and the proposed Tourism
   Study will be used to identify where there is scope for further provision and the nature of
   that provision which will help inform decisions on applications for tourism uses in order to
   ensure supply matches demand.‟

4. Add following additional paragraph to Reasons and Justification to Policy R1:
   „Staffordshire County Council is currently completing a county-wide mapping and
   characterisation project of historic farmsteads, which is part of a region-wide programme
   of projects. The aim of the project is to provide the evidence base to inform decisions on
   the sustainable management of this valuable resource – both in terms of its economic
   benefits as well as contribution to the essential character and identity of Staffordshire‟s
   rural landscapes.‟

Policy R2 (Rural Housing)

1. Amend first paragraph of Policy R2 (page 125) to read: “Other than sites allocated for
   housing development in the Site Allocations DPD, only the following forms of
   housing development will be permitted in the rural areas outside the settlement
   and infill boundary of the towns and the villages”

2. Amend bullet point 1 of Policy R2 to read: „Housing development where it is for
   affordable housing or to meet an identified local need which cannot be met
   elsewhere, in accordance with Preferred Policy H2‟

3. Amend bullet point 2 of Policy R2 to read: „A new dwelling that is essential to
   accommodate meets an essential local need, such as accommodation for an
   agricultural, or forestry or other rural enterprise worker, where the need for such
   accommodation has been satisfactorily demonstrated and the proposal meets the
   criteria in PPS 7 Annex A and that need cannot be accommodated met elsewhere.

4. Amend third bullet point of Policy R2 to read: „Proposals for replacement dwellings,
   provided they do not exceed the size and mass of the original dwelling
   (outbuildings should not be included as part of the existing size and mass of the
   dwelling) have a significantly greater detrimental impact on the existing character
   of the rural area then the original dwelling or result in the loss of a building which
   is intrinsic to the character of the area‟

5. Add following additional paragraph to the Reasons and Justification to Policy R2: “It is
   essential that all applications for planning permission for new dwellings in the countryside
   are scrutinised thoroughly to avoid non-essential housing development. In the case of
   occupational dwellings the proposal will be required to meet the criteria for such dwellings
   in Annex A of PPS7.”

6. Add following additional paragraph to the Reasons and Justification to Policy R2: „In the
   case of rural building conversions, enabling affordable housing can, in appropriate cases,
   be in the form of a financial contribution towards off-site affordable housing provision
   rather than the building itself being converted for affordable housing purposes. Local
   needs housing can be market housing in line with policy H2 provided it is for a person or
   family currently working in the community or needing to work in the community or they
   can be for live/work units as defined in the Glossary.‟




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7. Add to the Supporting Guidance and Evidence pg 123 and 125 „English Heritage and the
   Countryside Agency (2006) „Living buildings in a living landscape: finding a future for
   traditional farm buildings‟ and „English Heritage and the Countryside Agency (2006)
   „Historic Farmsteads. Preliminary Character Statement: West Midlands Region.‟




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NE1 - Natural Environment
Introduction
Policy NE1 sets out the Council‟s approach to the natural environment and is required to
deliver the spatial objective 9 – to protect and improve the character and distinctiveness of the
countryside and the diversity of wildlife and habitats.


Summary of Comments

Comments from Questionnaires and Correspondence
There were 10 responses made relating to the natural environment policy, 7 of which were
from statutory consultees.

Comments from others included support for the inclusion of the policy and a recommendation
that consideration is given to the creation of linkages between habitats and green spaces.

There was a significant level of support for this policy from statutory consultees, although a
number of additions and changes have been suggested as summarised out below.

Sport England commented that the value of natural environment areas for sport should be
recognised e.g. climbing, water sports and that the use will need to be managed to ensure
there is not a conflict.

The Environment Agency fully support the policy requirement of „ensuring development
produces a net gain in biodiversity and enhances features of interest and provides for their
management.‟ They identify that there are sites which have historically been developed and
the river channel seriously degraded through bank and channel works. They would like to see
the re-enforcement of the idea that where redevelopment is proposed for a site that has a
river or floodplain through it then these should be restored as part of any site redevelopment.
The watercourses should be naturalised and any floodplain restored as a biodiversity
resource, in other words the developed area would have to be pulled away from the
watercourse and floodplain which would be a biodiversity and recreational asset of the site.

Natural England welcomed the inclusion of the policy. They raised five key points. The first is
that in taking forward local biodiversity enhancement work LDF documents should include
local opportunities maps that take account of regional and local targets for habitats and
species outlined in the Regional Spatial Strategy and Local Biodiversity Action Plan.
Secondly, they consider NE1 should be revised to make clear distinctions between the
hierarchy of international, national, regional and locally designated sites as set out in PPS 9
paragraphs 7,8 and 9. Thirdly, they note the reference to the position regarding European
sites. Paragraph 6 PPS 9 „the most important sites for biodiversity are those identified through
international conventions and European Directives and those of specific policies in respect of
sites do not need to be included in the Core Strategy.‟ Natural England advises that point 1 be
amended in line with PPS 9. However the LPA should identify such sites on proposals maps
and cross-refer to the statutory protection given to the sites. They recommend that „any
development likely to have a significant effect on a European site should be assessed in
accordance with the Habitats Regulations.‟ Fourthly, they consider Policy NE1 point 4 should
be amended to follow the sequence of „avoidance, mitigation and compensatory measures‟ as
set in PPS9 paragraph 1 „ensuring that any unavoidable impacts are appropriately mitigated
against and compensated for.‟ Finally, they recommend the addition of a point which
specifically safeguards those habitats and species of principal importance for the
conservation of biodiversity‟ and identifies opportunities to enhance them as referred to in
paragraphs 11 and 16 of PPS 9. The habitat types are those identified in the Countryside and
Rights of Way Act 2000 section 74 list. The following amendment is proposed as an additional
point „Protecting and enhancing habitats and species of principal importance for the



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conservation of biodiversity‟ as identified in the Countryside and Rights of Way Act 2000
section 74.‟

Staffordshire County Council commented that the wording of the policy addresses PPS9
and RSS requirement in most areas but there are omissions including they suggest that the
BEA should be included on the Key Diagram. They highlight PPS9 paragraph 12 which
advises that local authorities should protect and aim to repair and enhance ecological
networks through planning policies and to the PPS1 Planning and Climate Change
Supplement paragraph 24. In selecting land for development planning authorities should take
into account "the effect of development on biodiversity and its capacity to adapt to likely
changes in climate". Paragraph 9 advises that spatial strategies should recognise that the
distribution of habitats and species will be affected by climate change. Policy wording should
be amended to account for this planning guidance.

Parks and Countryside comment that there should be a general presumption against
allocating development sites on land classed as a County Site of Biological Importance (SBI)
and that the impact of allocation sites where they are adjacent SBIs also needs to be
assessed. There may be a need to create buffer areas of undeveloped land between
proposed allocation sites and development. Where SBI sites have public access, future
access in relation to the allocation site should be planned so that it does not have adverse
impacts that damage the intrinsic biodiversity value of the SBI. They also comment that there
should be a presumption against development on sites that are located on UK or Staffordshire
Biodiversity Action Plan priority habitats. Sites containing these habitats, where existing
information is available, are likely to be designated with SBI status. Where no information is
available further survey and assessment is required to determine potential status and assess
impacts. They also recommend that sites that lack biodiversity baseline information would
require a basic survey to inform whether sites are appropriately selected as allocation sites for
housing or employment (details of the survey requirements are set out in the full response).

The Woodland Trust expressed the view that there should be a specific reference to
woodland and forestry in the Policy, to reflect the many quality of life benefits this can deliver.
They state this should focus on „no more loss of ancient woodland‟. Comment that many
ancient trees are not formally recorded, and the Woodland Trust and Ancient Tree Forum are
running a national project to identify and map ancient trees so they can be protected and
enhanced for the benefit of all. The Woodland Trust would like to see Policy NE1 include
protection of ancient, veteran and notable trees. They state that an increase in native
woodland cover is required for the multitude of benefits it can deliver for both landscape and
biodiversity and for quality of life. Comment that objective WC1 of the West Midlands
Regional Forestry Framework proposes a significant increase in woodland cover.

The National Trust have stated that NE1 nor C2 adequately address the need to improve the
quality and extent of natural open spaces, including those to which there is no public access,
that serve valuable functions as habitat and landscape and in the provision of ecosystem
services . As it stands, the two policies will not deliver spatial objective SO2 nor bring about
improvement sought under SO9.

The Peak District National Park Authority highlights the East Midlands Regional Plan
requirements that (West Midlands) local authorities should, in plans, policies and proposals,
conserve and enhance the Peak District National Park. It also states at 8.23 that the status of
the statutory designation "must be reflected by the level of protection given to them in
development plans".

Consultation and Stakeholder Events
There were no comments made specifically in relation to this policy at the stakeholder
workshops and meetings and there were no comments made from members of the public
who attended the consultation days. The Local Strategic Partnership questioned how
would greenfield sites be considered when there are nature conservation interests.




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Further Evidence and Other Issues
The Natural Environment and Rural Communities Act 2006 aim is to achieve a rich and
diverse natural environment and thriving rural communities, through modernised and
simplified arrangements for delivering Government policy. The Act implements key elements
of the Government‟s 2004 Rural Strategy. Section 40 of the Natural Environment and Rural
Communities Act 2006 states, „Every public authority must, in exercising its functions, have
regard, so far as is consistent with the proper exercise of those functions, to the purpose of
conserving biodiversity.‟


Officer Response
It is noted that both Natural England and Staffordshire County Council in their responses
to the consultation have highlighted that LDF documents should include local opportunities
maps that take account of regional and local targets for habitats and species as outlined in
the Regional Spatial Strategy and Local Biodiversity Action Plan. The Issues and Evidence
Base Background Report Version 2, September 2008, recognised this issue and identified the
steps that the Council intends to take to address it. At the time it was not felt that the
information needed to be included as an element of the Core Strategy policy, as it was felt
that this work may be taken forward through an SPD and that point 2 of the policy would be
sufficient to enable an SPD to be produced at a later stage. In light of comments made it is
suggested that amendments are made to the policy including using the Core Strategy text
suggested by Natural England and the West Midlands Biodiversity Partnership in the
document „Enhancing Biodiversity across the West Midlands.‟ In addition in the reasons and
justifications an explanation of the Council‟s intention to produce an opportunities map should
be detailed, in a similar form to the text already included in the Issues and Evidence Base
Background Report Version 2, September 2008.

With regard to the suggestion that the Key Diagram should identify the Biodiversity
Enhancement Area (BEA), the authority has concerns as to the impact this would have on the
clarity and interpretation of the Key Diagram as the BEA covers the majority of the District.
Furthermore, the BEA is identified in the RSS which forms part of the Council‟s LDF.
Reference will be made to the RSS diagram „Quality of the Environment‟ (page 98 of the
adopted RSS). Consideration will however be given as to whether the BEA can be identified
on the key diagram in a meaningful way. The Key Diagram does show the concentration of
significant nature conservation sites in the District, which includes Special Protection Areas,
Special Areas of Conservation and Sites of Special Scientific Interest.

In response to Natural England‟s comment that any development likely to have significant
effect on European sites should be assessed in accordance with the Habitats Regulations, an
Appropriate Assessment has been carried out on the emerging Core Strategy. Natural
England‟s comment regarding Paragraph 6 PPS 9 is acknowledged but it is felt that the part
of the policy (bullet point 1) relating to European sites should remain, as the Appropriate
Assessment of the Core Strategy produced in May 2008 assessed policy NE1 as being
necessary to safeguard against possible negative effects on European Sites. It also
contributes to the reports assessment that the policies within the Core Strategy generally
provide a positive framework for conservation and enhancement of the District‟s biodiversity,
including the Natura 2000 sites. The suggested addition of a point on protecting and
enhancing habitats and species of principal importance for the conservation of biodiversity is
however accepted. The comments regarding need to make clear distinctions between the
hierarchy of international, national, regional and locally designated sites is also accepted as is
their suggested amendment to point 4 to follow the sequence of avoidance, mitigation and
compensatory measures. The Environment Agency had offered their support for point 4 in its
current form, however, it is felt that the amendments to point 4 and 5 suggested by Natural
England place an expectation for development to promote enhancement of biodiversity and in
addition promote the restoration and/or recreation of biodiversity and should therefore be
satisfactory to the Environment Agency. It is not felt that further details of measures to be
incorporated in development proposals would be appropriate in the core strategy as the


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potential opportunities for maintenance, enhancement, restoration and/or recreation of
biodiversity need to be assessed on a case by case basis.

The opportunities map that is to be produced and the Staffordshire Biodiversity Action Plan
should be used to guide biodiversity enhancement measures to be included in development
proposals as appropriate to the nature and scale of development proposed and other
environmental interest. Furthermore, the Site Allocations DPD will set requirements for
specific sites based on the specific circumstance of the site and the nature and scale of
development proposed. Defra (2007) „Guidance for Local Authorities on Implementing the
Biodiversity Duty‟ states „Site Specific Allocation Development Plan Documents (DPDs), Area
Action Plans and Local Development Plan policies and allocations should be used to identify
where enhancement opportunities lie, and what actions need to be taken to enhance
biodiversity. Land can be identified for biodiversity creation, restoration or improvements,
linked to strategic objectives of the Core Strategy.‟ The Site Allocations DPD has an
important role to play in providing biodiversity benefits from development. Site survey work
will be undertaken to inform the Site Allocations DPD. However the Phase I Surveys need to
be carried out in spring – summer and a meeting has already taken place with the Parks and
Countryside to discuss the nature of the survey work that needs to be undertaken to inform
the production of the Site Allocations DPD. It is intended that the survey constraints would
form part of the site specific policies and be used to inform the drawing of site boundaries.
Potential biodiversity enhancements could also be suggested as part of the site survey and
be fed into site specific policies in the Site Allocations DPD.

In response to Parks and Countryside comments, the Landscape and Settlement Character
Assessment and the public response, Area 4 in Leek, which included an SBI designation, is
recommended not to be taken forward.

In response to the comments made by Natural England, Parks and Countryside and
Staffordshire County Council regarding the hierarchy of designated sites, it is considered that
bullet point 2 of the policy is amended to more clearly reflect the hierarchy. Implementing the
changes to bullet point 4 of the policy, as suggested by Natural England, will also clearly set
the criteria for judging development proposals that are likely to cause significant harm either
directly or indirectly to geological or biological assets including ancient woodland.

In response to the Sport England‟s comments, sport, recreation and open space is
something which is addressed in Policy C2. It is considered however that an additional bullet
point could usefully be added recognising the value of the natural environment for sport and
leisure activities and the need to manage such activities to ensure there is no conflict.

In response to the comments made by The National Trust, Sport England and Staffordshire
County Council it is acknowledged that specific reference should be made to green
infrastructure in both policy NE1 and C2 and this is addressed in the suggested changes for
this policy and policy C2. Green infrastructure has a number of potential benefits for both
people and biodiversity and is defined in the „Green Infrastructure prospectus for the West
Midlands‟ as „the network of green spaces and natural elements that intersperse and connect
our cities, towns and villages. It is the open spaces, waterways, gardens, woodlands, green
corridors, wildlife habitats, street trees, natural heritage and open countryside.‟ This definition
should be included in the Glossary to the Core Strategy.

In response to the issues raised by the Woodland Trust on the need to make specific
reference to the protection of ancient woodland, it is acknowledged that ancient woodland is a
valuable biodiversity resource for its diversity of species and for its longevity as woodland. In
line with PPS 9 requirements that, „Local planning authorities should identify any areas of
ancient woodland in their areas which do not have statutory protection.‟ the Site Allocations
DPD proposals map will identify these. PPS 9 paragraph 9 states that local planning
authorities, “should not grant planning permission for any development that would result in its
loss or deterioration unless the need for, and benefits of, the development in that location
outweigh the loss of woodland habitat.” An amendment to NE1 to bring it in to line with
national guidance is therefore suggested. It is felt that no further detail regarding aged or



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veteran trees is required as PPS 9 paragraph 10 already sets the requirements for
development proposals and it is not necessary for the Core Strategy to repeat this.

In response to the comments made by the Peak District National Park Authority it is felt
that in order for the policy to take appropriate account of the biodiversity and geological
resources of neighbouring authorities a reference should be made to neighbouring authorities
in the policy.



Suggested Changes
1. Amend first sentence of Policy NE1 (page 128) to read: „The biodiversity and
   geological resources of the District and neighbouring areas will be protected and
   enhanced by positive management and strict control of development by:‟

2. Amend item no. 2 of Policy NE1 to read: „Protecting, and enhancing designated sites
   of national and local biodiversity and geological importance. national, regional and
   locally designated sites. In particular supporting opportunities to increase
   grassland and heathland habitats including supporting the Countdown 2010 –
   Enhancing Biodiversity in Northeast Staffordshire project objectives. Meeting the
   objectives and targets in the UK and Staffordshire Biodiversity Action Plan. The
   Council will not permit any development proposal which would directly or
   indirectly result in significant harm to geological and biodiversity conservation
   interests including ancient woodland unless it can be demonstrated that:
           a. there is no appropriate alternative site available; and
           b. all statutory and regulatory requirements relating to any such proposal
               have been satisfied; and
           c. appropriate conservation and mitigation measures are provided; or if it
               is demonstrated that this is not possible
           d. the need for, and benefit of, the development is demonstrated to clearly
               outweigh the need to safeguard the intrinsic nature conservation value
               of the site and compensatory measures are implemented,‟

3. Delete item no. 5 of Policy NE1 and replace with the following new item no. 5::
   „Development should promote the appropriate maintenance, enhancement,
   restoration and/or re-creation of biodiversity through its proposed nature, scale,
   location and design. The local biodiversity opportunity map, in conjunction with
   the Staffordshire Biodiversity Action Plan, should be used to guide biodiversity
   enhancement measures to be included in development proposals as appropriate to
   the nature and scale of development proposed and other environmental interest, in
   particular supporting opportunities to increase grassland and heathland habitats
   including supporting the Countdown 2010 – Enhancing Biodiversity in Northeast
   Staffordshire project objectives, the Weaver Hills Partnership and targets in the UK
   and Staffordshire Biodiversity Action Plan.‟

4. Delete item no. 6 of Policy NE1 and replace with the following new item no. 6:
   „'Protecting and enhancing habitats and species of principal importance for the
   conservation of biodiversity as identified in Section 41 of the Natural Environment
   and Rural Communities (NERC) Act 2006, recognising and implementing
   appropriate measures to take account of the fact that habitats and species will be
   affected by climate change and will need opportunities to adapt to a changing
   environment‟

5. Add following additional item no. 7 to Policy NE1: „Recognising the value of the natural
   environment for sport and leisure activities and the need to manage such activities
   to ensure there is no conflict.‟

6. Add following additional item no. 8 to Policy NE1: „Ensuring the provision and
   protection of green infrastructure networks in line with Policy DC1.‟


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7. Amend Reasons and Justification to Policy NE1 to make reference to the RSS Diagram
   Quality of the Environment – Areas of Enhancement showing the Area for Concentrated
   Biodiversity Enhancement and to the proposals map for the Site Allocations DPD to show
   the location of designated sites of international, national, regional and local biological and
   geological importance and ancient woodland.

8. Amend paragraph 8.9.3 of Reasons and Justification to Policy NE1 to read: „Much of the
   District is covered by national and local nature conservation designations. The Key
   Diagram shows the concentration of significant nature conservation sites in the District,
   which includes Special Protection Areas, Special Areas of Conservation and Sites of
   Special Scientific Interest. The Site Allocations DPD proposals map will identify the
   location of designated sites of international, national, regional and local biological and
   geological importance. The extent of the Biodiversity Enhancement Area (BEA) is shown
   on page 98 of the RSS „Quality of the Environment – Areas of Enhancement‟ with the
   BEA covering the majority of the District. A separate SPD will be produced containing the
   Opportunities Map.‟

9. Delete paragraph 8.9.4 of Reasons and Justification to Policy and replace with following:
   „Guidance produced by the West Midlands Biodiversity Partnership and Natural England
   (2008) „Enhancing Biodiversity across the West Midlands‟ wishes every LDF to contain a
   local opportunity map for biodiversity. The Council intends to produce an SPD containing
   the opportunities map and future targets for restoration and creation of new habitats, and
   creating and restoring linkages between important habitat areas. The guidance states
   “The opportunity map should utilise local survey information to highlight areas of
   biodiversity importance, particularly focusing on regional and local biodiversity action plan
   priorities, in accordance with Regional Policy QE7, but also taking advice from Local
   Biodiversity Partnerships to ensure that priorities are up to date and locally relevant.‟

10. Add following additional paragraph 8.9.7 to Reasons and Justification to Policy NE1 :
    „Defra has produced „Guidance for Local Authorities on Implementing Biodiversity Duty‟
    which states „The creation and improvement of Green Infrastructure in urban and rural
    areas and the countryside in and around towns can help to deliver multiple benefits for
    biodiversity, landscape, and health and recreation. Policy NE1 and DC1 seek to support
    green infrastructure provision.‟

11. Add to Supporting Guidance and Evidence Defra (2007) „Guidance for Local Authorities
    on Implementing the Biodiversity Duty‟ and Natural England and West Midlands
    Biodiversity Partnership (2008) „Enhancing Biodiversity across the West Midlands‟

12. Add following definition of „Green Infrastructure‟ in glossary: „The network of green spaces
    and natural elements that intersperse and connect the towns and villages. It is the open
    spaces, waterways, gardens, woodlands, green corridors, wildlife habitats, street trees,
    natural heritage and open countryside.‟

13. Amend supporting text to make reference to the Natural Environment and Rural
    Communities Act 2006.




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T1 and T2 - Transport
Introduction
Affecting sustainable travel is a major component of achieving sustainable development in
two ways; firstly by directing development such that populations and jobs, facilities etc are
close to one another – reducing the need to travel; and secondly by improving the opportunity
to use non-car modes (and the integration between modes) such that people chose to use
cars less. The Planning process can directly affect the former, and indirectly the latter. Pols
T1 and T2 set out the District Council‟s approach to achieving this.



Summary of Comments

Comments from Questionnaires and Correspondence
There was overlap between responses to Pol T1 and Pol T2 - for this reason they have been
grouped together. There were approximately 26 responses, with some respondents making
more than one comment.

Positive or suggestions included support for improving public transport and affecting modal
shift, eg walking and cycling networks; there should be [battery] charging facilities for electric
cars in future car parks; support for protection and re-use of existing railway routes (both
public- and heritage-lines). Also suggestion for certain new lines. There was a suggestion of
new Leek bypass from Rudyard-Leekbrook and that all District residents should have
reasonable access to Leek, as the District headquarters. Other suggestions were that a bus
route subsidy system needs reconsideration, suggested park and ride site between Stoke on
Trent and Alton Towers, and existing/disused canals should be protected.

Concerns raised were that roads around Leek must be improved; there should be more
support for public transport to combat car use, especially in rural areas; and traffic
management is an important omission from the Core Strategy.

Over half of comments were from statutory consultees. The Churnet Valley Railway
Company generally supported the railway measures in Pol T2. English Welsh & Scottish
Railways are keen that local authorities adopt policies that encourage the development of
railfreight. The District contains one of the longest disused railway lines in England [Stoke-
Leekbrook-Oakamoor-Caldon Lowe] – this should be protected for potential re-opening in
future. Oakamoor Action Group argue priority should be given to more efficient public
transport in rural areas.


The Highways Agency supports development that promotes sustainable methods of
transport and suggests this could be achieved with reference to including the use of travel
plans, car parking standards and the use of DfT Circular 2/07 and DfT/DCLG guidance on
Transport Assessments. They expressed concern that the issues and objectives relating to
sustainable transport have not been fully reflected within the policies outlined in the Preferred
Options - eg Policy T1.1 appears to conflict with the principles of DfT Circular 2/07. Also
concerned that the draft policies have not yet been informed by a transport evidence base
and could therefore be considered unsound at examination. Also expressed concerns that the
Core Strategy seeks to rely on the Agency for delivering the relevant aims and objectives of
the document, as outlined in Chapter 9. Whilst PPS 12 advocates engagement of key
stakeholders, it is the responsibility of the LPA to deliver the aims and objectives of the Core
Strategy. They welcome the reference to the CIL and the developer contributions towards
infrastructure provision – transport infrastructure should be a beneficiary of these.

Staffordshire County Council comment that policy T1(3) refers to national and regional
parking guidance, whereas PPG13 is not comprehensive and regional guidance encourages


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local authorities to produce their own local standards. Also comment that paras. 8.10.3 &
8.10.13 suggest LTP funding is allocated in a reactive manner to existing population
distributions whereas it is allocated countywide in accordance with the shared objectives. It is
suggested that the following additional bullet point is added to T2 “Seek to secure Travel
Plans in connection with development proposals where appropriate.

Sustrans support T1 and comment that a plan would be beneficial showing Cycle Route 55
(west Biddulph), and how the Council intends to develop walking and cycling routes especially
linking to the Potteries. Also comment that there should be improved bus services linking
urban areas with Churnet Valley Corridor (with consideration for tourists eg allowing cycle
carry-on). Cycle hire schemes are also supported.

Comments from Consultation and Stakeholder Events

Biddulph Neighbourhood Forum – it was commented that there were flaws with the
recently introduced traffic flow measures in Biddulph town centre.          Blythe Bridge
Neighbourhood Forum – comments about traffic congestion in Blythe Bridge and Cheadle
and how further development would exacerbate this. Also questioned whether development of
Regional Investment Site near Blythe Bridge would make village traffic worse. Cheadle
Neighbourhood Forum – it was commented that infrastructure (roads etc) should be
improved before allowing further development in the town. Also argued that bypass needs to
be built.

Older People‟s Meeting comment that Leek would benefit from a bypass. The view of
service providers is that older people‟s housing, such as extra care housing, is similarly better
located in non-remote locations where there is access to shops, bus routes, and community
facilities (and where relatives may live already); which is better for care staff who must live
nearby.

Parish Workshops - views were expressed that infrastructure issues need investigating
before development considered, in areas like Churnet Valley/Kingsley/Froghall/Oakamoor.
Also how will development in one area affect road traffic in another (eg Churnet Valley
Corridor would affect Oakamoor)? There should be network of safe public footpaths around
Churnet Valley (and Consall). Support for extension of Churnet Valley Railway. Concern over
future growth of Alton Towers without road improvements. Calls for integrated transport
system with improved connections; as public transport in rural areas is very poor (especially
in evenings) – needs improving especially given elderly population forecast to rise. Some
recent bus service cuts. Support for protecting disused railway lines for future use. Criticism of
zero-parking housing schemes, as this generates on-street parking.

North Staffs PCT Meeting – the approach of the PCT is to minimise the need to travel to
access services as much as possible (eg remote monitoring of patients). Youth Groups
(High Schools and YOMAC) – general comments that its best to locate new housing where
existing facilities are, to reduce need to travel. Existing bus services were criticised as being
too expensive or not running at best times. Suggestion that Leek-Stoke railway line could be
re-opened for public use.


Further Evidence and Other Issues
The Climate Change Act 2008‟s main aim is to improve carbon management in the UK and
help transition to a low carbon economy. It does this by setting new legally binding targets:-
UK Green house gas emission reductions of 80% by 2050, and reductions in CO2 emissions
of at least 26% by 2020 (against 1990 baseline): an increase on previous legislation. It will do
this by setting consecutive 5-year targets (“budgets”) – which will be subject to review. A
consequence of this act may be that RSS sustainable transport policy measures in future
become stronger.

The Sustainable Communities Act 2007 came into force in October 2008. This has the
effect putting a duty on the Secretary of State to promote the sustainability of communities via

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allowing residents (via Local Authorities) to suggest practical changes to law or policy. There
are a many criteria to which suggestions can be made, some of which directly or indirectly
relate to transport:-
   (a) “the provision of local services”
   (b) and (d) relate to increasing the provision of locally produced goods/food for local people
   (g)”measures..to reduce the level of road traffic including..local public transport provision,
   measures to promote walking and cycling and measures to decrease the amount of product
   miles” [for the latter see also (b) and (d) above]
   (j) “measures designed to decrease emissions of greenhouse gases”; and most importantly
   (l) “planning policies which would assist with the purposes of this Act”.
Although the Act post-dates most climate change/sustainable development guidance with
respect to LPAs it is considered policies T1 and T2 do broadly, with other policies in the Core
Strategy, promote sustainable patterns of living; although many of the schedule matters are of
course beyond the remit of an LPA.

The Community Infrastructure Levy forms Part 8 of the 2008 Planning Bill. According to
DCLG the Bill will allow LPAs to apply the levy to fund sub-regional infrastructure (over and
above planning fees). The nature of these schemes will be identified in the RSS, so that
LDFs can identify them at the local level. A wide definition of „community infrastructure‟ is
suggested (including highways and transport) such that “development can be…made
sustainable”. Clearly Pol T1 (Part (2)) and other Core Strategy Pols.



Officer Response
It is encouraging that there was much support for many of the Pol T1/T2 measures, eg
improving public transport provision, encouraging modal shift, protecting/re-using railway lines
etc. The position of service providers such as PCTs and older people‟s housing providers with
respect to the location of developments, is welcomed – this is broadly the Council‟s approach
as set out in the first paragraph of policies T1 and SD1. Many comments related to matters
outside the Authority‟s control however (eg bus services) – policy T2 largely covers these.

It is not agreed that a fundamental assessment of existing road infrastructure across the
District should take place before finalising broad areas and the rural hierarchy in the Core
Strategy. The findings of the Development Capacity Study were used to inform the Preferred
Options - this analyses larger settlements including an “accessibility” component (covering
public transport travel times, distances to bus stops, and accessibility to „A‟ roads). Also it
must be noted that the Highways Agency (etc) were consulted over the current Preferred
Option during Issues and Options. The specific highway requirements for each resultant
allocation will be examined during the next Site Allocations DPD stage, as will its „knock on‟
effects upon other areas. It is considered this is a sufficient evidence base as required by
PPS12 regarding the preparation of Core Strategies. Also policy T1 Part (1) is clear that
development generating traffic above acceptable levels in any part of the District would have
to overcome this via contributions etc. In the „smaller villages‟ future development will largely
be limited to infill development anyway; and site allocations in towns and larger villages will be
„prioritised‟ according to highways capacities and other considerations. It is also not agreed
that policy T1 Part (1) contradicts DfT Circular 2/07: Planning and the Strategic Road
Network. The circular sets out the Highway Authority‟s duties when considering the impact of
LDFs and planning applications upon the strategic road network. Para 23 states that
“development should be promoted at sustainable locations” – clearly policies T1 and SD1
seek to achieve this. Policy T1 relates to the wider road network so would not affect trunk
roads at all except possibly the A50. Where future applications/proposed allocations might
affect the functioning of the SRN the District Council would of course consult with HA in line
with the aims of the circular and PPS12. However this point needs to be made more clear in
the R&J.

It is not agreed that the Core Strategy is reliant on the Highways Agency for delivering the
relevant aims and objectives of the Core Strategy in Chapter 9 – the Highway Agency‟s
involvement is limited to that of maintaining „A‟ roads (ie the A50 only). The Spatial Strategy
is not predicted to have any significant impact on that road, with the possible exception of

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traffic generated by future development on the Blythe Bridge RIS (see Pol SS7) which already
has the benefit of outline planning permission.

Perceptions of poor public transport services across the District do seem to be borne out by
evidence. For example the Development Capacity Study‟s modelling suggests the main
corridors between the District‟s towns and certain larger villages benefit from reasonably
regular services, but the remainder of the District is poorly served. Analysis of bus services in
the six „Local Area Profiles’ across the District seems to corroborate this. Unfortunately bus
service provision (and subsidies thereto) is beyond the control of the District Council, although
policy T1 sets out the circumstances where development proposals are liable to contribute to
its improvement.

Integration between transport modes is largely covered in the Local Transport Plan as a duty
of the County Council (and partners); however qualifying developments may be liable to make
planning contributions under policy T1. Wider traffic management can include a number of
elements used in conjunction to reduce car use– eg highway space re-allocation, car parking
control etc. Whilst local level “travel demand” is referenced in Reasons and Justification, it is
conceded wider „traffic management‟ as a concept is not referenced in the Reasons and
Justification. Additional text is therefore proposed under Suggested Changes below.

Whilst railfreight is not specifically referenced in the Policies, the Council would support its
growth if this would result in reduced vehicular traffic – it is accepted policy T2 Part (6) could
be made clearer to refer to this. In certain circumstances the Council would also support the
extension of existing rail routes – where there would be identified benefits in terms of reducing
vehicular traffic (or if there were economic/ recreational benefits), although this would have to
be balanced against other planning considerations.

Road improvements are the responsibility of other agencies so the District Council cannot act
except when levering planning contributions. There were various calls for new roads or
bypasses throughout the District: these would have to be justified by need and deliverable in
terms of resources – as laid out in Pol T2 Part (1). Further, proposals for new park and ride
facilities would have to be carefully considered along with stakeholders and balanced against
other considerations (eg greenbelt impacts). The Policy framework for park and ride facilities
is set out in the RSS (polices T5-T6), therefore there is no need to include this in the Core
Strategy.

It is not agreed that further reference to promoting travel plans needs to be made in policy T2,
as this is adequately referenced under policy T1 (last bullet). For clarification these are no
longer referred to us green travel plans – policy T1 last bullet should therefore be amended
accordingly. Further the suggestion that all development benefits from safe and convenient
sustainable transport links is already referenced under Parts (1 & 2) Pol T1. It is agreed that
reference to the LTP funding in paras 8.10.3 & 8.10.13 (as being allocated in a reactive
manner to existing population distributions) may be misleading - this is recommended to be
reworded. It is also accepted that PPG13 parking standards are incomplete, and that regional
guidance encourages local authorities to produce their own local standards – this could be
made clearer in the Policy. Although maximum parking standards were sometimes criticised
(for encouraging on-street parking) this is a longstanding planning principle dating back to
PPG13 designed to limit car use.

It is conceded the policies do not refer to the additional benefits that enhanced non-car modes
have for accessing the countryside and leisure opportunities. This will be added in the
                                                                      st
Reasons and Justification. Finally, it is acknowledged that the 1 paragraph of policy T1 as
worded to suggest that proposals which have beneficial transport impacts would automatically
be supported is slightly misleading as other considerations are also important. Textual
amendments are therefore proposed below.




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Suggested Changes

Policy T1 (Development and Sustainable Transport)

1. Amend first paragraph of Policy T1 (page 131) to read: „The Council will promote and
   support development which reduces reliance on the private car for travel journeys,
   reduces the need to travel generally and helps deliver the priorities of the
   Staffordshire Local Transport Plan, where this is consistent with other policies.
   This will be delivered by:‟

2. Amend item no. 3 of Policy T1 to read: “Referring to maximum parking standards as
   laid out in national and regional guidance, or any parking standards that may be
   produced locally”

3. Amend last bullet point of Policy T1 to read: “Actively promote green travel plans”.

4. Add following sentence to end of paragraph 8.10.4 to Reasons and Justification to Policy
   T1: “The Policy aims to benefit not only work-related travel but also that for shopping,
   leisure and recreation etc.”

5. Amend first sentence of paragraph 8.10.6 to Reasons and Justification to Policy T1 to
   read: “The Council will continue to work closely with the Highways Authority to ensure the
   coordination of proposals within the LDF and the Local Transport Plan; and in the case of
   proposals affecting the SRN closely involve the Highways Agency such that it can
   undertake its duties as set out in DfT Circular 2/07: Planning and the Strategic Road
   Network.”

6. Add following additional sentence to paragraph 8.10.9 to Reasons and Justification to
   Policy T1: “Developers will also need to demonstrate that their proposals incorporate the
   principles of sustainable transport as reflected in the policies of the Regional Transport
   Strategy and detailed in the Regional Spatial Strategy.”

Policy T2 (Other Sustainable Transport Measures)

1. Amend item no. 6 of Policy T2 to read: “seek to minimise the environmental impact of
   freight road transport and to work with Staffordshire County Council and other
   partner organisations to agree designated lorry routes, and freight handling
   facilities and greater rail use.”

2. Amend first sentence to paragraph 8.10.13 to Reasons and Justification to Policy T2 to
   read: “Whereas the LTP funding streams work in a reactive manner to existing population
   distributions, are allocated Countywide in accordance with the shared objectives, the
   LDF must decide broadly where future population is distributed.”




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Miscellaneous Comments
A number of comments were made which do not relate to any particular section or policy of
the Core Strategy. These are summarised below.

   Content of the Core Strategy – Generally there was support for the content and clarity of
    the Core Strategy and many considered that it is a comprehensive and detailed planning
    strategy which has taken into account the needs and views of as many sectors of the
    population as possible and that the draft policies as a whole are sensible. However,
    some considered that the document lacks specific proposals it would have been easier to
    comment on concrete proposals. Whilst they are generally satisfactory as broad outlines -
    there are few specifics. Other comments were that the area is not planned as a whole;
    policies need to be considered together; it is difficult to plan as far forward as 2026,
    although agree that in some areas this is necessary due to the inherent time lag in getting
    projects to maturation; and that other factors, mainly national, will affect any plan.
   Questionnaire Form – Whilst there was praise for the format and content of the brochures
    and forms, a few considered that the form was confusing and not detailed/relevant to
    particular areas, which may affect individuals greatly. Also that a large percentage of
    people (especially older) have no access to the internet or understand this form. Some
    questioned the cost of producing and sending out documents.
   Consultation – There were a number of comments regarding the consultation process
    suggesting the need for continued involvement of local residents and that planning policy
    generally needs to work with the community to implement the Core Strategy. Other
    comments were that consultation is appreciated although many previous consultations
    have come to nothing; appreciate consultation but worried that the results will not be
    incorporated; should react to constructive comments. It was suggested that let 6th form
    students see the Policy proposals as they will be the generation who have to live with
    these policies and making planning a discussion topic in schools. There were some
    specific comments made regarding the Biddulph consultation - would prefer a public
    meeting in Biddulph for questions to be answered so that others know what is going on;
    consider that there has been no widespread information to the residents of Biddulph
    about the consultation; concerned that none of the residents were invited via post to the
    meeting that took place in Biddulph on the 8th October; should be open to the opinions of
    all residents of Biddulph by way of regular updates on these matters e.g. open meetings.
   Evidence – There were only a few comments regarding the evidence base - objecting to
    the fact that proposed policies are founded on background evidence like the PPG17 Audit
    and Strategic Housing Land Availability Assessment which are incomplete and not
    published for inspection by the public and that it is not possible to make informed
    comments about many of the policies without access to this information. Questioned
    what part „village action plans‟ play in Core Strategy evidence base.
   Flexibility – Some respondents commented that the key is flexibility and responding to
    market forces. When this plan was written no one foresaw the present economic
    situation. Other comments were that as have no control over the economy, employment
    or sustainability need to keep to basics which you can do something about; feel overall
    priority is for the Council to give value for money; there is a risk that such long term
    proposals without any review built in would not give any flexibility to respond to changing
    needs or to make smaller scale adjustments. The plan must be flexible enabling
    developers, planners and the local community to consider development before going for a
    planning application.
   Key Diagram – Comments relating to the key diagram were that the canal should be
    highlighted because of its potential as a leisure and tourism resource; should show cycle
    routes; and that it should show Biological Enhancement Areas.
   General Issues – Other general comments made were that supply and demand from
    younger people should be met first; there should be more support for local self-
    sustainable communities, not outside bodies; should let Leek people create their own
    inward investment; priority should be for self-build and improving village housing and
    opening up all village schools; we should retain our independence as an Authority; would
    like to see more of an emphasis on how we can build better communities and not just a
    consideration of housing and employment with a brief consideration of sport and PCT


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    developments; all development proposals should be in line with the principles espoused
    in the Sustainable Communities Act; and various comments pertaining to the knock on
    effects of Peak Park Authority‟s action on this authority (eg with respect to affordable/local
    needs housing).

Government Office for the West Midlands: Pleased that have taken on board many of their
comments on earlier draft. Consider the documents clearly set out, easily readable and well
presented. Staffordshire Moorlands are also to be commended on their engagement with
stakeholders, particularly the 'Big Debate'. Comment that the evidence base for the Core
Strategy requires that there needs to be an Appropriate Assessment in place by publication of
the draft submission. Pleased to see Appendix A (Implementation and Monitoring Plan) and B
(Infrastructure Plan) included in the document. To be effective should show how all
components of the strategy can be delivered, by which organisation and when and also
indicate how infrastructure will be delivered. May therefore need more detail as the Core
Strategy gets firmed up. The number of policies proposed are reasonable for a Core Strategy.

Planning Inspectorate: No comments on Core Strategy but set out guidance and advice on
next stage of publication and submission.

Staffordshire County Council: Make comment in respect of the Sustainability Criteria that
were used to guide the selection process being generally in conformity with PPS1 CC
paragraphs 23-24. The planning authority may wish to ensure that consequent to the
production of the PPS that a sufficient evidence base exists to have properly informed the
selection process and that climate change has been afforded sufficient weight within the
process.


Officer Response
It is acknowledged that some may find the Core Strategy too general and strategic. There is
no prescribed detailed format for a Core Strategy but the structure and content must meet key
requirements in Government guidance. The key essentials of a Core Strategy are a vision,
strategic objectives, a strategy to deliver the vision and means of monitoring and
implementation. It is not intended to set out detailed proposals for sites but to provide an
overall framework and policy guidance. The Site Allocations DPD will allocate specific sites
and define boundaries.

In terms of the forms and brochures, these were produced to be easy to understand and
complete by focussing on key issues and proposals but also giving an opportunity for other
comments to be made. There were also officers on hand at the consultation days to assist in
completing the forms or taking notes of residents views without the need to complete forms.
The costs of producing and distributing the forms and brochures was from within the LDF
budget and did not incur any additional funding.

With regard to the consultation. the Council endeavours to be as inclusive as possible during
consultations, with recourse to resource implications. It would not be practical or cost
effective to consult all residents; however the Council undertook rigorous consultation with in
line with its Statement of Community. This also included widespread newspaper and website
publicity. As part of its commitment to involve the community, Officers also attended all
District-wide CVS Neighbourhood forums around the consultation window; wrote to all District
Parish Councils with a view to attending their Parish meetings, and invited all these Parish
Councils to Council organised (and Officer-staffed) „Parish Workshops‟ to discuss the
proposals. Additionally the Council conducted „outreach‟ meetings with various “hard to
reach” groups including with young, older and disabled groups (and invites were sent to other
organisations). It was also considered more appropriate to have staffed consultation days
where residents could speak to officers on a one-to-one basis rather than open discussions or
public meetings.

In response to comments regarding the evidence base, all of the completed evidence has
been made available on the website. However, because of their comprehensive and detailed

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Draft Preferred Options Core Strategy Consultation Responses Report               February 2009



nature some studies have taken longer to complete but their findings have still informed the
preparation of the Core Strategy. With regard to Village Action Plans, where available the
Council welcomes their inclusion within its LDF evidence base to inform policies and
proposals.

The issue of flexibility to adapt to changing circumstances is recognised as being important to
having a robust and sound document and is acknowledge and addressed throughout the
Core Strategy with measures incorporated to monitor changes and react to them through plan
reviews of supplementary planning documents.

With regard to the key diagram, this is a general and diagrammatic illustration of the main
proposals and policy constraints. It is not considered necessary to identify all features such
as canals and cycle routes as these would be better shown on a detailed Proposals Map to
be produced as part of the Site Allocations DPD. With regard to the suggestion that the Key
Diagram should identify the Biodiversity Enhancement Area (BEA), the authority has
concerns as to the impact this would have on the clarity and interpretation of the Key Diagram
as the BEA covers the majority of the District.

In terms of the general issues raised, it is considered that many of these have been
addressed within the Core Strategy, whilst others are considered more appropriate for
consideration in the Sustainable Communities Strategy which deals with over-arching issues.
In terms of the Peak Park Planning Authority, the Council does work closely with it both in
terms of ensuring consistency of planning policies and also in its role as a housing enabler.

The comments from GOWM are noted and welcomed. With regard to the Appropriate
Assessment, this has been undertaken and completed. It is also intended to produce a full
Implementation Plan to accompany the Submission document and to update the Appendices.
It is also intended to update the Sustainability Appraisal in respect of the policies and site
selection process.

Suggested Changes
1. Update appendix A to Core Strategy (Implementation & Monitoring Plan)

2. Update appendix B to Core Strategy (Infrastructure Plan)




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