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					LDF Core Strategy Preferred Option – Draft                          December 2007




                                     CORE STRATEGY
                                 PREFERRED OPTION
                                             (DRAFT)


This report sets out officer proposals for the Preferred Option of the LDF Core
Strategy. It summarises the responses to the consultation on the Core Strategy
and also the proposed requirements of the revised Regional Spatial Strategy as
they relate to each of the different elements of the Core Strategy. It outlines
suggested changes to the challenges, vision and objectives and sets out a
preferred developed approach. It also puts forward proposed Core Policies for
consideration.




December 2007

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LDF Core Strategy Preferred Option – Draft                              December 2007




Contents

Summary of Key Changes and Policy Proposals                        3


Challenges                                                         6


Vision                                                             8


Aims and Objectives                                                10


Development Approach                                               12


Core Strategy Policies

         Spatial Strategy                                          18
         Sustainable Development                                   33
         Economy and Employment                                    39
         Housing                                                   43
         Town Centre and Retailing                                 49
         Design and Conservation                                   56
         Sustainable Communities                                   61
         Tourism, Culture, Recreation and Leisure                  65
         Rural                                                     70
         Natural Environment                                       75
         Transport                                                 79


Appendix

A        Key Diagram                                               84

B        Summary of Proposed Development Levels                    85

C        Summary of Responses from Specific Consultation Bodies,   86
         Groups and Forums

D        List of All Respondents                                   138




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LDF Core Strategy Preferred Option – Draft                                     December 2007




SUMMARY OF KEY CHANGES AND POLICY PROPOSALS
   No major changes to overall vision, but some additions to emphasise supporting safe
    centres, improved transport opportunities, better links with the rest of North
    Staffordshire, safeguarding historic heritage and landscape, contribution of tourism to
    the economy, affordable housing and addressing needs of young and elderly

   Four broad aims proposed (Maintaining a quality environment and special places;
    Encouraging a strong, prosperous economy; Creating sustainable, self-sufficient
    settlements; Meeting the needs of our communities) in order to give greater
    emphasis to the main principles which will underpin the Core Strategy and the
    priorities identified by respondents and the Council. No significant changes to the
    objectives themselves.

   Preferred development approach focuses development on the 3 market towns of
    Leek, Cheadle and Biddulph and the larger villages, but allows for limited
    development in other settlements to meet local needs.


   Managed rate of housing development from rising to 320 dwellings/annum by 2016
    and falling to 288 by 2026 with constraint on areas near to MUAs to reflect RSS
    requirements.

   Increased housing development rate in Cheadle to reflect growth aspirations and
    reduced development rate in Biddulph and rural areas to reflect strategic constraints.

   Spatial Strategy policies establish a settlement hierarchy and level and type of
    development appropriate for each settlement category. Also identifies major
    regeneration opportunities at Cornhill, Churnetside Business Park, Leek and
    Cheadle Town Centres and Biddulph East and in the countryside at Bolton
    Copperworks, Froghall and Anzio Camp as well as need for strategic transport
    improvements on A520 to A53 access road link, Leek; A521, Cheadle; and Alton
    Towers – Denstone link.

   Green Belt will be maintained, but its detailed boundaries will be reviewed to ensure
    that its purpose in separating the urban areas and maintaining their identity is
    consistent with the need to promote sustainable patterns of development around
    settlements.

   Core Policies seek to be proactive and aspirational – fewer policies, but more
    comprehensive, more locally distinctive and with emphasis on value judgements.

   Sustainable development policies cover two subject areas, resource use and the
    linked issue of climate change, setting out range of measures to achieve national
    and regional targets. Preference to development on previously developed land in
    allocating land for development and determining planning applications - targets:
    2006-2016 65%, 2017-2026 55%. Stronger pollution and flood control measures
    established.




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LDF Core Strategy Preferred Option – Draft                                       December 2007



   Employment policies seek to provide a wide portfolio of employment sites to
    accommodate different sized operations at different locations across the district.
    Support for starter units and offices within towns and larger villages and for
    expansion of existing firms, including major firms. Stronger criteria set for retention
    of existing employment sites where appropriate.


   Housing policies seek to ensure appropriate range and type of housing is provided
    and set higher standards for quality, sustainable housing. A minimum of 1700
    affordable housing units will be provided between 2006 and 2026 distributed
    between the towns and rural areas Affordable housing targets increased to 50% on
    sites of 15+ dwellings (0.5 ha+) in towns and 50% on sites of 5+ dwellings (0.16 ha+)
    in larger villages. In smaller villages and other rural areas all housing must be either
    affordable or meet a local need. Also requirement for all development below
    thresholds to make financial contribution.


   Town centre and retailing policies concentrate on maintaining vitality and viability of
    town centres by positive management measures, particularly supporting
    enhancement and regeneration of the shopping and town centre environment,
    promoting their tourism potential and maintaining local distinctiveness by supporting
    proposals which help retain, attract or expand the provision of independent retailers.
    Primary and secondary frontages established to maintain strong retail core. Support
    for local shopping facilities.


   Greater prominence for design and heritage considerations, not just in terms of
    resisting inappropriate development but also measures to promote locally distinctive,
    creative and sensitive design solutions to future developments. New measures to
    protect the setting of settlements based on settlement characterisation studies.
    Need for masterplanning of major areas recognised.


   Support for proposals which protect, retain or enhance existing community facilities
    in towns and villages and new measures to resist proposals involving loss of local
    facilities. Requirement to incorporate the infrastructure required as a result of any
    scheme, or make provision for financial contributions.



   Continued protection for existing areas of recreational land and buildings including
    school playing fields and amenity open space from development. Areas to be
    identified in the Site Allocations DPD.


   Tourism policies give particular support to developing the potential of the canal
    network, the potential of the cycling network, the evening/night-time economy and
    high quality tourist accommodation. Continued development of Alton Towers
    supported subject to it being accommodated satisfactorily within the natural
    environment and being supported by adequate transport infrastructure.




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LDF Core Strategy Preferred Option – Draft                                     December 2007



   Rural policies focus on diversifying rural economy and maintaining rural communities
    as well as enhancing the character, appearance and biodiversity of the countryside.
    Support for development which contributes to the wider rural economy, particularly
    development of land and food related businesses, and the limited expansion or
    redevelopment of an existing business for employment uses provided that it would
    not cause unacceptable harm to the countryside or prejudice other rural needs.
    Stronger support for re-use of rural buildings for commercial enterprises.


   Move away from SLA designation to more locally based assessments of landscape
    character. Also range of measures established to protect and enhance biological and
    geological resources.


   More proactive transport policies supporting development which reduce reliance on
    the private car for travel journeys, reduce the need to travel generally and help
    deliver more sustainable settlement patterns. Development which generates
    significant demand for travel or is likely to have significant transport implications
    required to contribute to improved public transport provision and provide proactive
    facilities and measures to support sustainable transport modes. Measures which
    promote better accessibility, create safer roads, reduce the impact of traffic, or
    facilitate highway maintenance promoted and supported.




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LDF Core Strategy Preferred Option – Draft                                      December 2007




CHALLENGES

Responses to Consultation on Issues and Options

-   Many considered that the challenges identified were comprehensive and relevant to
    the District
-   Some identified very specific issues and challenges for particular towns
-   Broader challenges where many considered there should be greater emphasis
    where – addressing needs of young people who are leaving District; catering for
    rising elderly population; management of traffic and road improvements; energy
    efficiency; better public transport; affordable/low-cost housing; infrastructure needs of
    development (in particular schools, leisure facilities); promotion of tourism; recreation
    and sport; protection of natural environment, wildlife and countryside; conservation of
    historic environment and rural heritage; issue of policing and crime; ensuring
    coordination with other authorities, accountability and consultation; flexibility to
    accommodate more growth if needed and meeting demands, securing regeneration
    of underused areas.

RSS

Preferred Option for the RSS Revision has now been agreed. Key challenges identified
as being adopting positive measures to address the relative decline in the Regional
economy in both urban and rural areas; reversing the movement of people and jobs
away from the Major Urban Areas and ensuring there is a greater equality of opportunity
for all; tackling road and rail congestion; and achieving a more balanced and sustainable
pattern of development across the Region, including the rural areas. Proposes 6,000
dwellings for Staffordshire Moorlands between 2006 and 2026 and 18 hectares of
employment land between 2006 and 2021.

Officer Comment

The challenges need to be those which are most significant for the District and which
can be addressed through the LDF. They also need to be ones which are supported by
evidence. On the whole these are considered to be adequately covered but some
additional references are considered appropriate in relation to the needs of young
people, infrastructure needs, the importance tourism and conservation of the area‟s
heritage and securing regeneration of underused areas. Also need to reflect latest RSS
Preferred Option requirements and challenges.

Suggested Amendments to Challenges

   Meeting requirements for housing and employment provision set out by regional
    Government. The Preferred Option for the revised West Midlands Regional Spatial
    Strategy requires sufficient land to be identified to accommodate a minimum of 6,000
    houses between 2006 and 2026. In connection with this we need to tackle high
    levels of in-migration and manage the rate of development so as to meet local needs
    and aspirations and avoid undermining the regeneration of the MUAs.

   Ensuring accessibility to services and determining the best pattern of provision and
    distribution of development across the District, which is sustainable, reflects the role


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LDF Core Strategy Preferred Option – Draft                                    December 2007



    of the different settlements and is not compromised by inadequate availability of
    infrastructure.

   Adapting to changes in population structure, in particular rising elderly population
    and declining household size and meeting the social and economic needs of the
    younger population to enable them to stay in the District.

   Ensuring a balanced housing market meeting the needs of all current and future
    residents, in particular ensuring housing is affordable and of a high quality

   Enabling the economy to diversify and modernise and reducing out-commuting by
    increasing the range of higher skilled jobs available and providing suitable range of
    available sites to support new businesses, encouraging existing businesses to thrive,
    and protecting suitable existing employment land

   Improving the market towns and enabling them to continue to thrive as service
    centres, expanding the convenience and comparison retail offer in town centres,
    addressing qualitative deficiencies, and regenerating underused or poor quality
    areas

   Achieving qualitative improvements in recreation and sports leisure activities and
    providing activities and facilities for younger people.

   Tackling social exclusion in rural areas and lack of access to facilities, addressing
    consequences of changes in farming practices and continued need for rural
    diversification

   Continuing to protect, manage and enhance the quality of the District‟s physical,
    natural and historic environment including its biodiversity. Capitalising on the built
    and natural assets of the District and its heritage and increasing the benefits of
    tourism

   Tackling climate change - promoting renewable energy initiatives and waste
    reduction schemes for developments, encouraging low/zero carbon homes,
    minimising flood risk and demand for natural resources

   Accommodating development in a sustainable way which minimises impact on
    environment and provides maximum social and economic benefits, makes places
    safer and healthier and also promotes high quality locally distinctive design and
    public realm

   Securing the regeneration or reuse of underused areas and buildings where this will
    help to secure improvements to the local economy, environment and community
    needs and maintain local distinctiveness.

   Addressing transport - ensuring maximum accessibility to development sites and
    allowing for alternative modes of travel as well as looking at management measures
    such as provision of car parking and reducing congestion




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LDF Core Strategy Preferred Option – Draft                                       December 2007




VISION
Responses to Consultation on Issues and Options

-   Generally significant support for the vision
-   Some consider it unrealistic, unattainable or needs delivery
-   Several consider should be more emphasis on tourism (jobs and heritage), balanced,
    affordable range of housing, town centre regeneration, better travel/transport
    (particularly public transport), local distinctiveness and historic heritage, creation of
    sustainable, high quality employment, needs of elderly and younger people;
    community safety; local skills; quality of life, protecting landscape
-   Large number of other specific individual requests – bypass for Leek; car parking
    charges; reduced traffic; better public transport; protect green sites; higher
    educational standards; retention of green belts; no out-of-town shopping; conversion
    of mills to modern needs; local food production; reuse of disused railway lines;
    awareness of differences; encouraging responsibility, neighbourliness and respect;
    clean and tidy; power plant within the District to generate power for the population;
    grow trees on disused farm land; facilities at Birchall Playing Fields in need of
    improvement; tidy up main approaches to towns; more local, quality shops; craft
    businesses; better recreational and leisure facilities; multi-story car park

RSS

Preferred Option for the RSS Revision proposes the following principles for its vision for
the West Midlands Region:
- Opportunities for all to progress and improve their quality of life;
- An advanced, thriving and diverse economy;
- Urban and rural renaissance is successfully being achieved;
- Diverse and distinctive cities, towns, sub-regions and communities; distinctive;
- High quality natural and built environment;
- An efficient network of integrated transport facilities and services which meet the
    needs of both individuals and the business community in the most sustainable way.

Officer Comment

It is important that the vision is kept general and not too specific therefore many of
individual suggestions would be inappropriate. It is considered that no major changes to
the overall vision are required, but some additions to emphasise supporting safe centres,
improved transport opportunities, better links with the rest of North Staffordshire,
safeguarding historic heritage and landscape, contribution of tourism to the economy,
affordable housing and addressing needs of young and elderly would make the vision
better reflect local aspirations and will also better accord with the Council‟s priorities and
Community Plan and with the proposed RSS Vision. Also reference to specific places
and more on role of larger villages in rural areas should be added to reflect preferred
option on development strategy (see below).




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LDF Core Strategy Preferred Option – Draft                                     December 2007



Suggested Amendments to Vision

The vision for Staffordshire Moorlands is that it will be recognised as a vital part of a
regenerated North Staffordshire in terms of its connections, its economic contribution, its
rich built historic and natural heritage and its distinctive character.

We will have sustainable and balanced urban and rural communities which have an
excellent quality of life with access to appropriate, affordable and desirable housing,
suitable local jobs, a range of recreational, cultural and leisure opportunities and high
quality public services and facilities.

The needs of all sectors of the community, in particular the young and elderly, will be
better met through more sustainable development with a higher degree of local self-
sufficiency, reducing our impact on the environment and making more efficient use of
resources. 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 and
tourism.

Our market towns of Leek, Cheadle and Biddulph will remain the focus of the Moorlands
and will become more self-sufficient. They will be distinctive and unique in terms of their
character and the quality and range of shops, services and facilities they provide for both
residents and visitors. Their town centres will be welcoming, safe and appealing and will
retain their significant historic heritage and distinctiveness which makes them special
places, as well as being prosperous and vibrant, catering for the needs of both the town
and its hinterland. Underused and poorer quality areas will have been regenerated and
transformed to provide new opportunities for growth and investment and redundant
buildings brought back into new uses. Access will be improved between market towns
and with their surrounding settlements with greater opportunities to travel by means
other than the car.

The rural areas will have viable, attractive villages and smaller settlements which will
continue to foster appropriate, sensitive growth and vitality to support rural living and
work. The larger villages will be the rural centres for services, facilities and jobs but
other settlements will also be sustained, with priority given to affordable housing to meet
local needs. The richness of the District‟s landscape and its biodiversity will continue to
be valued and protected in a way which sensitively accommodates the needs of farmers,
rural businesses, visitors and residents.

The economy of the Moorlands will have undergone a significant change with more
diversified and higher quality employment provision better meeting the skills and needs
of its local workforce. There will be a more flexible and proactive approach to
employment development, raising the District‟s economic fortunes by exploiting its
assets, local skills and opportunities and addressing deficiencies and disadvantages.
Tourism will be a key element in the diversification of the District‟s economy and will also
contribute significantly to raising the environmental quality and the regeneration of the
District.




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LDF Core Strategy Preferred Option – Draft                                       December 2007




AIMS AND OBJECTIVES
Responses

-    Wide range of comments made for additions to the objectives, many of which relate
     to specific requirements for specific areas
-    Number of changes suggested to wording
-    In response to top 3 priorities, those which emerged as strongest priorities were
     objectives 3 (develop the economy), 4 (provide housing that is affordable, desirable
     and meets needs), 5 (ensuring vitality and viability of the towns), 8 (promote local
     distinctiveness) and 9 (protect and improve countryside)

Officer Comment

It is considered that the objectives remain broadly reflective of the needs of the District
and the aspirations of those consulted subject to some minor additions and changes.
However, in order to give greater emphasis to the main principles which will underpin the
Core Strategy and the priorities identified by respondents and the Council in its
Corporate Plan, it is considered that they should be targeted at four broad aims with the
objectives beneath them. It is also considered that objective 2 needs to broadened to
encompass other sustainability principles and similarly that objective 6 should be
broadened to refer to rural „areas‟ rather than just „settlements‟.

Suggested Amendments to Objectives

The vision will be delivered through the following broad aims and more
detailed objectives:

Aims:

    Maintaining a quality environment and special places
    Encouraging a strong, prosperous economy
    Meeting the needs of our communities
    Creating sustainable, self-sufficient settlements

Objectives:

1.       To make provision for the overall land-use requirements for the District,
         consistent with the Regional Spatial Strategy, and the role of Staffordshire
         Moorlands within North Staffordshire and the role of each settlement.
2.       To create a District where development minimises its impact on the environment,
         helps to mitigate and adapt to the adverse effects of climate change and makes
         efficient use of resources.
3.       To develop and diversify in a sustainable manner the District‟s economy and
         meet local employment needs in the towns and villages.
4.       To provide new housing that is affordable, desirable, well-designed and meets
         the needs of residents of the Moorlands.
5.       To ensure the long-term vitality and viability of the three market towns.



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LDF Core Strategy Preferred Option – Draft                                      December 2007



6.       To maintain and promote sustainable rural areas and communities settlements
         with access to services for all.
7.       To support and enhance the tourism, cultural, recreation and leisure
         opportunities for the District‟s residents and visitors.
8.       To promote local distinctiveness by means of good design and the conservation,
         protection and enhancement of historic, environmental and cultural assets
         throughout the District.
9.       To protect and improve the character and distinctiveness of the countryside and
         the diversity of wildlife and habitats
10.      To deliver sustainable, inclusive, healthy and safe communities
11.      To reduce the need to travel and or make it safer and easier to travel to jobs and
         key services by more sustainable forms of transport




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LDF Core Strategy Preferred Option – Draft                                    December 2007




DEVELOPMENT APPROACH
Responses to Consultation on Issues and Options

-   Main preference was for option 1 (town based growth – 35%). Options 2 (towns and
    larger villages – 23%), 3 (distributed development – 21%) and 4 (focused
    development – 22%) had marginally less support.
-   In respect of town-based development option, the majority support development
    being spread amongst all of the towns. Some suggest should be related to
    infrastructure, population, housing need, demand. There were no strong preferences
    for development in any one town. Some concerns regarding amount of development
    in Biddulph and impact on Green Belt.
-   In respect of town and larger village based development option, following settlements
    mentioned most - Cellarhead, Tean, Waterhouses, Cheddleton, Werrington,
    Ipstones, Froghall, Alton, Caverswall, Endon, Brown Edge, Kingsley, Rudyard,
    Blythe Bridge. Some opposed any expansion of villages.
-   In respect of distributed development there was a variety of views with many not
    wishing to see any development in smaller villages and others supporting limited
    development, particularly for younger people.
-   Suggestions of targets for focused development include areas of deprivation,
    brownfield sites, Bolton Copper Works Froghall, old mills and factories
-   In response to the question on controlling the supply of housing, the majority of
    respondents (54%) supported a system where only a set number of houses a year
    are granted permission with the exception of affordable or regeneration shcmes,
    whilst 36% supported limiting development to certain parts of the District. Only 10%
    suggested other means or wanted no controls.
-   Advantage West Midlands consider option 1 (town based) most fully accords with
    West Midlands Regional Economic Strategy; regeneration opportunities especially
    on brown field land under option 4 (focused development) should also be
    considered, where they represent a sustainable solution. In terms of village viability
    it is recognised that some development appropriate in scale and nature may be
    required in village locations.
-   English Heritage recommend that the Council‟s and County Council‟s conservation
    and archaeological officers are involved in determining and developing the preferred
    approach.
-   Natural England would encourage options that contribute to the delivery of
    sustainable development, as set out in PPS 1 „Delivering Sustainable Development‟
-   United Utilities support option 1 in terms of use of existing utility infrastructure
-   West Midlands Regional Assembly consider that the Preferred Option for the District
    should reflect the requirements of RSS Policies RR3 and RR4 and the guidance in
    para 5.15 to 5.19 on development in Market Towns, villages and in the open
    countryside and should also reflect RSS Policies PA14 and PA15.
-   Bagnall and Werrington Parish Councils all prefer option 1 (town based)
-   Cheddleton, Endon, Ipstones, Kingsley, Oakamoor Parish Councils all prefer option
    3 (distributed development)
-   Forsbrook Parish Council support option 4 (focussed development)
-   Heaton Parish Council considers that the majority of development should be focused
    in Leek, Cheadle and Biddulph, with other development in larger villages in the Leek
    and Cheadle area




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LDF Core Strategy Preferred Option – Draft                                       December 2007



Regional Spatial Strategy Context

The Spatial Strategy of the Preferred Option for the RSS Revision can be broadly
summarised as:
- enabling all parts of the Region to meet their own needs, in a mutually supportive
   and sustainable way
- focusing attention on efforts to increase the attractiveness of the Major Urban Areas
   (MUAs) although some settlements and local authorities in the surrounding Shires
   are anticipated to provide housing beyond their own generated needs
- focusing new development in and adjacent to towns which are most capable of
   balanced and sustainable growth acknowledging that some peripheral development
   may need to be considered
- promoting key role for market towns and larger villages in achieving rural
   renaissance
- expecting need for a degree of restraint within the wider North Staffordshire housing
   market area so as to encourage investment in those areas in greatest need
- identifying Biddulph and Leek as Local Regeneration Areas where the aim will be to
   improve the longer term economic prospects of the towns.
- It identifies a need to provide 6000 new homes (net) in the District between 2006 and
   2026 and 18 hectares of additional employment land between 2006 and 2021.
- Phasing of new housing is required to ensure that there is, overall, an increasing
   level of housing provision in the period up to 2016 whilst new employment land
   should provide a rolling 5 year reservoir.

Officer Comment

In the light of the responses and the RSS strategy and the evidence of development
capacity, it is considered that the Preferred Development Approach should be one which
focuses development on the 3 market towns of Leek, Cheadle and Biddulph and the
larger villages but allows for limited development of other settlements to meet local
needs. The proposed preferred development approach could be described as
combining the positive impacts of the Town and Large Village based development along
with enabling smaller villages to develop in a sustainable way to meet their own local
needs including meeting local housing requirements.

This is considered to be the most sustainable option which would enable development to
be focused on regeneration and targeted opportunities in areas of highest accessibility
and where it could be supported by existing infrastructure or could best facilitate
infrastructure improvements and where it could achieve high levels of affordable
housing. It is a realistic and balanced approach which recognises the needs of both
urban and rural areas, increases opportunities to utilise brownfield sites and minimises
the need for major green belt/countryside changes. As well as supporting the
regeneration of towns, this approach helps rural settlements maintain services and
facilities and would ensure that the local needs of rural areas are continued to be met.
This option would also accord well with the RSS spatial strategy, performs best in the
sustainability appraisal and is supported by the evidence base.

In the light of the RSS requirement to restrain development in those areas nearest to the
North Staffordshire conurbation, the evidence of development capacity and opportunities
for growth, and to reflect the vision and aims to create more self-sufficient settlements, it
is considered that the development approach should also limit growth in Biddulph and


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LDF Core Strategy Preferred Option – Draft                                     December 2007



parts of the rural areas and increase growth in Cheadle. This also accords with the
approach of restricting housing development in the adopted Biddulph Town Centre Area
Action Plan.

Preferred Development Approach

-   Leek, Cheadle and Biddulph as the focus for development in the District
    accommodating bulk of District‟s housing and employment needs in scale with their
    individual infrastructure capacity and needs, economies, characters, constraints and
    their future roles and relationships;
-   A network of larger villages with sufficient employment, services and public transport
    provision and capable of acting as rural service centres will be locations for bulk of
    rural area‟s needs, targeted to provide for local need, with affordable housing, shops,
    local services, community facilities and low impact businesses of a scale and nature
    appropriate to those settlements and which would not act to undermine support for
    the 3 main towns;
-   Limited development in smaller villages principally for local housing needs and rural
    diversification;
-   Countryside areas outside market towns and villages, including hamlets and other
    small settlements, will be subject to strict control over development with emphasis on
    meeting essential rural needs, promoting environmental enhancement including
    landscape and biodiversity, and encouraging appropriate economic diversification.
-   Increased housing development rate in Cheadle to reflect growth opportunities and
    need to create more self-sufficient settlement.
-   Reduced development rate in Biddulph and rural areas to reflect strategic constraints
    near to North Staffordshire conurbation.
-   Major developed areas in countryside will be identified where appropriate range of
    uses would be permitted to support rural needs.
-   Development principles:
    o Priority to brownfield and underused sites but allowing for peripheral expansion
        where it will bring infrastructure benefits or more sustainable forms of
        development;
    o Development will be targeted to provide a sustainable mix of homes, businesses,
        shops, leisure, health, education and other uses, creating a balance that
        increases self-sufficiency, resolves existing problems where this is feasible and
        helps to meet local needs;
    o Major development focused on regeneration opportunities or where it will achieve
        infrastructure benefits;
    o Environmental assets to be protected and enhanced focusing on local
        distinctiveness, biodiversity, heritage and settings;
    o Enhance town centres as main service providers for District with accessible, vital
        and viable locations for a vibrant mix of uses, and as public transport hubs.

Preferred Development Levels

Housing

Housing development levels are based on the District requirement as set out in the
Submission RSS Phase 3 Review which is 6,000 net additional dwellings between 2006
and 2026. The apportionment of housing development between the sub-areas of the
District is based on the preferred development approach focusing on the growth of the


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LDF Core Strategy Preferred Option – Draft                                                   December 2007



towns and larger villages reflecting the anticipated future role of each settlement as well
as the availability of brownfield sites and environmental constraints on development in
some areas. It also reflects the growth aspirations for Cheadle where increased levels
of housing provision are proposed and the need to restrain development near to the
MUAs with reduced levels of housing provision in Biddulph and the rural areas. In view
of the high level of past completions and current commitments it is necessary to deduct
these from the required provision in order to obtain a net requirement for the purpose of
future allocations.
Area           Amount         Required        Annualised          Completions and          Net
                                                                               1                       2
                              Provision       Development         Commitments              Requirement
                                              Rate
Leek               30%        1800            90                  749                      1051
Biddulph           20%        1200            60                  271                      929
Cheadle            25%        1500            75                  164                      1336
Rural              25%        1500            75                  687                      813
Total                         6000            300                 1871                     4129

Note:    1: Comprises of completions since 1/4/96 and sites with planning permission or under construction
         as at 30/9/07 net of any losses
         2: Net requirement to be found from allocations and windfall development between 1/10/07 and
         2026



Employment

Employment development levels are based on the District requirement as set out in the
Submission RSS Phase 3 Review which is 18 hectares between 2006 and 2021. The
distribution of employment provision takes account of the role and function of each
settlement, the proposed housing development levels and the existing workforce
distribution. New employment provision is primarily focused in the market towns, close to
the local populations and sustainable transport networks to allow for easy access and to
support the principle of self-containment. The higher proportion of employment
development in the rural areas reflects the higher workforce levels and opportunity for
growth in the rural areas.


Area                        Amount                                Required Provision
Leek                         30%                                        5.4 ha
Biddulph                     20%                                        3.6 ha
Cheadle                      20%                                        3.6 ha
Rural                        30%                                        5.4 ha
Total                                                                   18 ha


Retail

The need for new retail development is based on advice in the Retail Study, which
showed capacity for additional convenience and comparison goods floorspace (gross) in
the towns of Leek, Cheadle and Biddulph up to 2016. This was based on upon available
expenditure arising from current and projected population within their respective
catchment areas and market share adjustments to address current retail under-
performance. It does not take account of population increases as a result of additional



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LDF Core Strategy Preferred Option – Draft                                      December 2007



building that has or may take place which would be over and above the trend line
projections.

                        Retail (additional convenience and comparison
                        goods). Maximum provision (gross).
Leek                    2,975m2 convenience
                        9,204 m2 comparison
                        7,186 m2 bulky goods comparison
Biddulph                3,831m2 convenience
                        4,835 m2 comparison
                        4,115 m2 bulky goods comparison
Cheadle                 2,564m2 convenience
                        2,945 m2 comparison
                        2,882 m2 bulky goods comparison


Preferred Development Approach for Local Areas

Leek

Leek will be an increasingly important service centre for its population and the District
and will strengthen its role. The priority will be to improve and enhance the quantity and
quality of retail provision in the town centre and promote its role as a tourist attraction,
building on its heritage and built environment assets. The rate of housing development
will be increased from a past average of 57 dwellings/annum to 90 dwellings/annum and
there will be new employment areas created to reflect the significant role Leek will play
in encouraging a strong, prosperous economy and meeting the District‟s needs. The
emphasis will be on making the most of opportunities for brownfield development
through appropriate reuse of surplus mill buildings as well as regenerating underused
and surplus areas to meet future needs. However, some limited greenfield development
for housing within and on the edge of the town in highly accessible areas will also be
necessary. Employment provision will be seeking to support existing businesses and
encourage new business into the town through redevelopment of existing and provision
of new sites.

Biddulph

Biddulph will continue to maintain its role as a service centre for its residents and those
in outlying rural areas. Significant growth and change will take place within the town
centre through implementation of proposals in the Area Action Plan, including a new
town centre supermarket and non-food retailing next to the bypass in order to make the
town more self-sufficient. Suggested levels of new housing development will decrease
from a past average of 71 dwellings/annum to 60 dwellings/annum in order to limit
impact on the adjacent N. Staffordshire MUA and reflecting the environmental
constraints on expansion of the town‟s development boundaries. It is anticipated that
the majority of the development would be on brownfield and greenfield sites within the
current development boundary. The promotion of Biddulph as a „Garden Town‟ will be
supported. Employment provision will continue to be a priority to meet the needs of
local businesses and continue to attract new businesses with further expansion to the
south.



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Cheadle

Cheadle will enhance and strengthen its role as a service centre for the local population
including those in its rural hinterland under all of the options. The town centre will be
strengthened, particularly in terms of new retail development whilst preserving the town‟s
distinctive and unique character. The rate of housing development will be increased
significantly from a past average of 42 dwellings/annum to 60 dwellings/annum with new
employment areas created reflecting the need to strengthen Cheadle‟s role in the
District, bring forward infrastructure improvements through development and create a
more self-sufficient town. In view of the limited brownfield development opportunities in
the town, the bulk of development will need to be on greenfield sites within and on the
edge of the town in areas where infrastructure improvements could be created.
Employment provision would be improved to provide more local employment
opportunities through new employment sites. Improvements to the towns main transport
corridors will also be a high priority.

Rural Areas

The rural character of the Moorlands encompassing both the open countryside and its
unique built environment in the villages will continue to be preserved and the contrast
between villages and landscape within the rural areas will be recognised. The rural
areas will maintain an important role within the District in terms of providing homes and
jobs for local needs. The focus for development will be on the larger villages which,
together with the towns, will be the main service providers for the rural areas. The rate
of housing development will be decreased from a past average of 85 dwellings/annum to
75 dwellings/annum reflecting the emphasis of the strategy to focus the bulk of new
development in the towns and the need for strategic restraint in those areas neares to
the North Staffordshire conurbation. New development will be on a range of brownfield
and greenfield sites targeted to support existing services and facilities primarily in and on
the edge of the larger villages and varying in scale depending on the size of each
settlement. Some major regeneration opportunity sites will also be developed in the
rural areas. In the smaller settlements development will be limited to that which meets
local needs and essential rural activities. Employment development would be limited to
small scale schemes and reuse of existing sites.




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CORE STRATEGY POLICIES
SPATIAL STRATEGY POLICIES

Objective

To make provision for the overall land-use requirements for the District, consistent with
the Regional Spatial Strategy, the role of Staffordshire Moorlands within North
Staffordshire and the role of each settlement.

Officer Comment

The Spatial Strategy policies should reflect the preferred vision and development
approach and provide the spatial context for all other policies, establishing the Council‟s
overall approach to development, the level of future provision, housing management
measures and the distribution of development. In particular it should establish the
settlement hierarchy and level and type of development appropriate for each settlement.

Policy SS1 - Spatial Strategy

The spatial strategy for Staffordshire Moorlands, as shown on the Key Diagram, is
to:

1. Focus housing and employment development in and on the edge of the towns
   and larger villages of the District which are able to provide sustainable growth
   that reflects their current scale and function, their future role and increases
   their self-sufficiency;
2. Create opportunities for employment growth in key, highly accessible
   locations which is balanced with housing development;
3. Regenerate areas of significant surplus, underused or derelict land;
4. Manage housing growth in a way which ensures continuous delivery of high
   quality housing to meet demand and local needs but which is supported by
   adequate infrastructure provision and does not undermine the regeneration of
   the N. Staffordshire conurbation;
5. Encourage development in the town centres of Leek, Biddulph and Cheadle
   which will strengthen and enhance their role as the District‟s main centres;
6. Foster appropriate, sensitive growth in the rural areas to support continued
   rural living and work with an emphasis on providing affordable housing for
   local needs;
7. Prioritise the use of previously development land in built up areas but allow for
   peripheral expansion which brings about community and infrastructure
   benefits;
8. Maintain the role and function of the Green Belt;
9. Increase accessibility within the District between towns and their hinterland
   and to major surrounding strategic centres.

The Council will expect the development and use of land to contribute positively
to the social, economic and environmental improvement of the Staffordshire
Moorlands District. Changes should maintain the distinctive character of the
Staffordshire Moorlands, its individual towns and villages and their settings, and


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LDF Core Strategy Preferred Option – Draft                                      December 2007



protect and enhance the natural and built environments of the District. New
development should achieve high quality, sustainable environments for the
present and future generations.

Reasons and Justification

The spatial strategy will seek to support and deliver the overall vision and objectives for
Staffordshire Moorlands and contribute towards achieving the wider aspirations of the
North Staffordshire sub-region as a whole. It is considered that the broad thrust of the
spatial strategy is in line with the Council‟s Community Strategy and the aims and
objectives of the existing regional spatial strategy (RSS), and in particular the emerging
RSS Review. The spatial strategy must also reflect the guiding aims of meeting the
needs of our communities, creating sustainable, self-sufficient settlements, encouraging
a strong, prosperous economy and maintaining a quality environment and special
places. The Strategy is therefore one which balances the need to make adequate
provision for homes, jobs and services with the need to protect and enhance the
District‟s considerable natural and heritage assets in the most sustainable way.

It has the benefits of supporting the retention of local services and facilities in the most
sustainable locations and maximizing the use of existing infrastructure and resources. It
also provides opportunities which are more likely to be of interest to the private sector
and therefore capable of being delivered and shows a clear commitment to the
regeneration of the towns and their increased self-sufficiency. It also provides for local
needs in the rural areas and allows for development to take place in locations which
reduce the need for people to rely on their cars to travel

It will however require the development of greenfield sites on edges of town although
brownfield development will remain a priority. Some areas will also be subject to greater
impact from development, but the role of this strategy and more detailed Local
Development Documents is to examine these impacts and do whatever is possible to
minimise them.

The development strategy is illustrated on the Key Diagram.

Policy SS2 - Future Provision of Development

Provision will be made for at least 6000 additional dwellings (net of demolitions) to
be completed in Staffordshire Moorlands (excluding the Peak Park) during the
period 2006 to 2026. This will be phased at the average development rates to
achieve the net additional dwelling completions set out below. Sufficient
deliverable land will be identified to provide at least 5 years of development at all
times.

Period                                  Annual Development Rate   Net Dwelling Completions
2006 – 2007                             260                       260
2007 – 2011                             300                       1200
2011 – 2016                             320                       1600
2016 - 2021                             300                       1500
2021 – 2026                             288                       1440




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Provision will be made for at least 18 hectares of additional employment land in
Staffordshire Moorlands (excluding the Peak Park) during the period 2006 – 2021.
Sufficient deliverable land will be identified to provide at least 6 hectares of
employment land at all times.

Provision will be made for new retail, transport, recreational, community and
tourism facilities and services to meet the identified needs of settlements within
Staffordshire Moorlands (excluding the Peak Park) up to 2026.

Reasons and Justification

The submission version of the West Midlands RSS Revision requires an average rate of
housing development in Staffordshire Moorlands of 300 dwellings per annum for the
2006-26 period amounting to 6,000 dwellings over the plan period. This level of
provision is demand-based which will be sufficient to meet local needs over the plan
period and includes an element for continued in-migration as a contribution to meeting
the wider needs of the North Staffordshire housing market area. This level of provision
will also enable the Council to address the high level of affordable housing need from
existing and future households and facilitate the need for regeneration and increased
self-sufficiency in the market towns and larger villages.

Policy CF4 of RSS Revision requires an increasing rate of development to 2016 and a
lower rate thereafter. The above table reflects this with 2006/7 based on actual
completions and increasing levels of development to 2016. Post-2016 a decreasing rate
of development is proposed to avoid over-provision

In accordance with PPS3, the Council will ensure that there is a 5 year supply of
deliverable housing land at all times based on the appropriate annual development rates
for the period. The Council will seek to achieve this through a „plan, monitor, manage‟
approach to the phased release of allocated sites and the granting of permissions on
unidentified (windfall) sites. However, due to the scale of existing housing commitments
the rate of development in the 5 years to 2011 is heavily subject to the market.

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). The rate of development is based on a requirement to
maintain a 5 year supply of deliverable of employment land 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.

Provision will also be made for new retail, transport, recreational, community and tourism
facilities and services to meet the identified needs of settlements. This will be achieved
through developer requirements on housing sites, partnership working with service
providers and the Council‟s Sports and Playing Field Strategies. New retail
requirements to 2016 will be in accordance with the capacity levels identified in the
Retail Study. A review of the Retail Study will be undertaken prior to 2016 to establish
capacity beyond 2016.



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LDF Core Strategy Preferred Option – Draft                                     December 2007



As the housing and employment land requirements are derived from the emerging RSS
which is currently still to be subject to examination, it is possible that the final RSS
requirements may change from that submitted. In such circumstances the Core Strategy
will need to be amended to reflect those changes before it is adopted. However, 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
changes providing they are not significant. 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.

Policy SS3 - Managing the Release of Housing Land

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 SS4.
The adequacy of supply will be assessed and monitored through the Housing
Land Availability Assessment and the Annual Monitoring Report. Where deemed
appropriate, measures will be used to adjust the delivery of housing by bringing
forward or holding back development in accordance with the SPD.

Allowance will be made for an assumed contribution from unidentified (windfall)
sites towards the net housing requirement of 25% in urban areas and 30% in rural
areas.

In those parts of the District nearest to the North Staffordshire conurbation 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
conurbation.

Reasons and Justification

The Council has a responsibility to manage the rate of housing development in order to
to ensure that there is a continuous supply of housing land over the plan period and to
ensure that the long term delivery of housing is not undermined. In order to ensure that
housing development is in accordance with the spatial strategy the Council will not only
manage the overall supply for the District but also the distribution of development
between the towns and the rural areas.

The allocations in the Site Allocations DPD will be the key to the delivery of the housing
requirement but it is expected that between 25% and 30% of new housing development
will also come forward from unidentified (windfall) sites. This level of windall
development reflects historic levels of development on such sites and also the capacity
for such provision as identified in the SHLAA. It accords with policy CF10Biii of the
emerging RSS Revision and is considered important to the delivery of a range and
variety of housing sites across the District.

Measures to manage the rate of development will be established within the „Housing
Delivery‟ SPD and the rate of development will be continually assessed and monitored to
advise on the need to take appropriate action to adjust the delivery of housing. This may
involve bringing forward sites through the granting of permission for further unidentified



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LDF Core Strategy Preferred Option – Draft                                       December 2007



sites or it may require holding back development through the refusal of permission on
unidentified sites. It may also involve addressing the phasing of allocations.

An Annual Monitoring Report and bi-annual Housing Supply Schedules will be produced
which will contain housing trajectories and assessments of the 5, 10 and 15 year supply
of housing. Many of the factors influencing the delivery of housing are beyond the control
of the local planning authority or the development industry. The role of monitoring will be
important in assessing the actual performance in terms of delivery of this and other parts
of the development strategy.

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 those areas around Biddulph, Endon, Werrington and Blythe Bridge. 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. 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.

Policy SS4 - Distribution of Development

Development will be distributed between the towns and rural areas as set out
below and will be focused primarily on land within the development boundaries of
settlements, as defined in the Site Allocations DPD and on the Proposals Map. In
identifying land for new development or in considering planning applications,
development shall be compatible with the settlement hierarchy in terms of scale,
density and use as set out in policies SS5 and SS6 below.

                                             Housing                  Employment
Leek                                          30%                          30%
Biddulph                                      20%                          20%
Cheadle                                       25%                          20%
Rural Areas                                   25%                          30%

Reasons and Justification

The distribution of development reflects the spatial strategy and will guide the provision
of housing and employment for the whole of the plan period. The use of proportional
distributions will enable the Council to monitor and manage overall development in each
of the towns and the rural areas to ensure that it is realising the spatial strategy and to
make adjustments to net requirements in the event of evidence of increasing demand or
as a result of any changes to the overall requirements for the District arising from
changes to the RSS. However, should very significant changes to the overall
requirements for the District be necessary, then a pro-rata distribution of development
may not be appropriate or feasible, having regard to the level of constraints around the
towns. In those circumstances it may be necessary to review the distribution.

In order to protect the countryside which is important to the character of the Moorlands
and maintain sustainable settlements, development boundaries will be defined which will



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LDF Core Strategy Preferred Option – Draft                                       December 2007



limit the extent of development. Outside of the development boundaries there will be
strict control on development to meet defined needs and to facilitate the appropriate
redevelopment of existing developed sites. Development boundaries will be subject to
review through the Site Allocations DPD in order to ensure that they can endure for the
plan period of the Core Strategy.

The settlement hierarchy seeks to ensure that development is delivered in accordance
with the spatial strategy by identifying which settlements are suited to greater or lesser
levels of development. The status of each category of settlement, a list of those
settlements included within them and the development principles and levels of
development which apply to each category are set out in policies SS5 and SS6. In
considering sites for development regard should be had to the hierarchy to ensure that
the appropriate scale and type of development is provided in each settlement and other
rural areras.

SS5 - Towns

The following are identified as towns:

         Leek
         Biddulph
         Cheadle

These settlements will accommodate the bulk of the District‟s housing,
employment and retail needs, distributed as follows:

                        Housing (net         Employment        Retail (additional convenience
                        dwelling             (additional       and comparison goods).
                        completions          employment land   Maximum provision up to 2016.
                        2006 -2026)          2006 – 2021)
Leek                    1800                 5.4 hectares      2,975m2 convenience
                                                               9,204 m2 comparison
                                                               7,186 m2 bulky goods comparison
Biddulph                1200                 3.6 hectares      AAP Proposals
Cheadle                 1500                 3.6 hectares      2,564m2 convenience
                                                               2,945 m2 comparison
                                                               2,882 m2 bulky goods comparison

The following development principles will apply to these settlements:

   Development shall primarily meet the needs of each town and its local market
    in terms of housing and shall support existing businesses and provide
    opportunities for new enterprises and businesses as well as expanding the
    service sector to meet local needs in terms of employment provision.

   Their role as principal service and retailing centres for the District shall be
    strengthened through the sensitive enhancement and expansion of their town
    centres and, where appropriate, the provision of additional bulky goods
    retailing on the edge of the centre and through improved accessibility.




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LDF Core Strategy Preferred Option – Draft                                     December 2007



   Needs will be met primarily on allocated sites within and on the edges of the
    settlement, as defined in the Site Allocations DPD.

   Additionally, up to 25% of housing needs and local employment, retail, leisure
    or service uses will be permitted on unidentified (windfall) sites within the
    development boundaries of these settlements, as defined on the Proposals
    Map, provided that adequate services, facilities and infrastructure are available
    or can be made available as a result of the development.

   Residential development and redevelopment on windfall sites will be permitted
    up to an indicative maximum scheme size of 9 dwellings only. Exceptionally
    larger schemes may be permitted where it would provide over-riding affordable
    housing, employment, regeneration, conservation or infrastructure benefits
    and it would not undermine delivery of the spatial strategy.

   New development shall give priority to the reuse and regeneration of existing
    redundant, underused or surplus sites and premises and shall reflect and
    enhance each town‟s special character and heritage and help strengthen their
    role as a tourist attraction.

   The Council will encourage mixed use developments on larger redevelopment
    sites and within or near to the more accessible town centre locations.

   Major regeneration opportunities and related infrastructure improvements will
    be identified through the Site Allocations DPD at:
           o Cornhill, Leek
           o Churnetside Business Park, Leek
           o Leek Town Centre
           o Cheadle Town Centre
           o Biddulph Town Centre (in accordance with AAP)
           o Biddulph East

   Any development on the edge of the town shall respect the setting of the town
    and be in locations which are highly accessible and relate well to existing
    services and facilities or provide opportunities for infrastructure
    improvements.

Reasons and Justification

The 3 towns of Leek, Biddulph and Cheadle are the largest settlements in the District
accommodating 50% of the Districts population and the majority of the District‟s
services and facilities. The spatial strategy seeks to focus future growth in these
settlements and to strengthen their role as principal service centres.

The housing and employment requirements are based on the distributions set out in
policy SS4 taking account of completions since 2006 and current commitments to give a
net residual requirement to be met through allocations and further planning permissions
on unidentified (windfall) sites. The retail requirements are based on the capacity figures
identified in the Retail Study (2006). The figures for housing, employment and retail are
targets for the appropriate plan period and will be monitored through the Annual



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LDF Core Strategy Preferred Option – Draft                                    December 2007



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 the plan
period.

The policy allows for development or redevelopment of land to come forward within
Development Boundaries which is appropriate to the needs, capacity and character of
each settlement. However, in order to ensure that residential development is not
promoted in unsustainable locations, the acceptability of developments above 9
dwellings is dependent on there being significant benefits and/or existing facilities and
services being improved. In such cases developer contributions will be sought to obtain
the necessary improvements.

The Development Boundaries of these settlements will be drawn to accommodate future
growth including where appropriate peripheral expansion and also to protect the
surrounding countryside and green belt from further encroachment. Where settlements
lie within or adjacent to the green belt, development within the Development Boundaries
will not be subject to green belt policy.

Areas identified for major regeneration or infrastructure improvements are those where
there are known opportunities for change or enhancement and opportunity to
accommodate a range of uses to address local issues and needs.

SS6 – Rural Areas

The rural areas comprise of the following development categories:

        Larger villages
        Smaller villages
        Other rural areas
        Major developed areas in the countryside

In total these will provide for around 1500 new dwellings between 2006 and 2026
and 5.4 hectares of employment land between 2006 and 2021 in accordance with
the development approaches for each category set out in policies SS6a – SS6d
below.

Reasons and Justification

The rural areas outside of the Peak District make up over two-thirds of the plan area in
terms of land coverage and contain nearly half of the plan area‟s population. The
majority of this area is undeveloped countryside which is of high landscape quality and
has poor accessibility. However, the rural areas also includes a diverse mixture of large
and small villages, hamlets and scattered development as well as some major
developed areas. In order to ensure that development in the rural areas reflects the
spatial strategy this policy establishes the different development categories and the
overall level of housing and employment development which will be provided.




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LDF Core Strategy Preferred Option – Draft                                  December 2007



SS6a - Larger Villages

The following are identified as larger villages:

   Alton
   Biddulph Moor
   Brown Edge
   Caverswall & Cookshill
   Upper Tean
   Cheddleton
   Endon
   Blythe Bridge & Forsbrook
   Ipstones
   Kingsley
   Oakamoor
   Waterhouses
   Werrington & Cellarhead

These settlements will accommodate the bulk of new dwellings and employment
land for the rural areas.

The following development principles will apply to these settlements:

   Development within these settlements shall provide for the bulk of the local
    housing needs of the rural areas and also for limited employment needs of a
    scale and type appropriate to each settlement having regard to local needs
    (including those of its local market), infrastructure capacity and character.

   Their role as rural service centres shall be retained and enhanced through
    appropriate development which supports and increases the services and
    facilities available to the rural areas.

   Needs will be met primarily on allocated sites within and, exceptionally, on the
    edges of the settlement or in established employment areas, as defined in the
    Site Allocations DPD.

   Additionally, up to 30% of housing needs and small-scale local employment,
    retail, leisure or service uses will be permitted on unidentified (windfall) sites
    within the development boundaries of these settlements, as defined on the
    Proposals Map, provided that adequate services, facilities and infrastructure
    are available or can be made available as a result of the development.

   Residential development and redevelopment on windfall sites will be permitted
    up to an indicative maximum scheme size of 9 dwellings only. Exceptionally
    larger schemes may be permitted where it would provide over-riding affordable
    housing, employment, regeneration, conservation or infrastructure benefits
    and it would not undermine delivery of the spatial strategy.




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LDF Core Strategy Preferred Option – Draft                                    December 2007



   New development shall give priority to the reuse and regeneration of existing
    redundant, underused or surplus sites and premises and shall reflect and
    enhance each village‟s special character and heritage.

Reasons and Justification

The larger villages are the most sustainable settlements in the rural areas which
generally have a population of at least 1,000 and have good access to a secondary
school (either within the village or accessible by good public transport) employment
opportunities, contain a primary school, food shops (including a small supermarket), post
office, surgery and have good public transport services to a market town. These villages
also have an important role in terms of serving and supporting their immediate
surrounding rural areas and smaller villages. It is important therefore that they are
sustained and promoted as service centres.

The policy allows for development or redevelopment of land to come forward within
Development Boundaries which is appropriate to the needs, capacity and character of
each settlement. However, in order to ensure that residential development is not
promoted in unsustainable locations, the acceptability of developments above 9
dwellings is dependent on there being significant benefits and/or existing facilities and
services being improved. In such cases developer contributions will be sought to obtain
the necessary improvements.

The Development Boundaries of these settlements will be drawn to accommodate future
growth including where appropriate peripheral expansion and also to protect the
surrounding countryside and green belt from further encroachment. Where settlements
lie within the green belt, development within the Development Boundaries will not be
subject to green belt policy.

SS6b - Smaller Villages

The following are identified as smaller villages:

   Bagnall
   Blackshaw Moor
   Boundary
   Bradnop
   Checkley
   Consall
   Cotton
   Dilhorne
   Draycott
   Foxt
   Froghall
   Heaton
   Hollington
   Hulme
   Kingsley Holt
   Leekbrook
   Longsdon


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LDF Core Strategy Preferred Option – Draft                                       December 2007



   Lower Tean
   Meerbrook
   Rudyard
   Rushton Spencer
   Stanley
   Stockton Brook
   Wetley Rocks
   Whiston
   Winkhill

The following development principles will apply to these settlements:

   Development within these settlements shall provide only for very limited
    development which enhances community vitality or meets a local social or
    economic need of the settlement and its hinterland.

   Development shall be on unidentified (windfall) infill or redevelopment sites for
    residential schemes of up to a maximum of 5 dwellings or small scale rural
    businesses within the Infill Development Boundaries of these settlements, as
    defined in the Site Allocations DPD.

Reasons and Justification

Smaller villages generally have a poor range of services and facilities and it is often
necessary for local residents to travel outside the village for most of their daily needs.
These villages generally lack any food shops, have no primary school and may not have
a permanent post office or a village hall or meeting place.

Development on a large scale would be unsustainable in these villages, as it is will
generate a disproportionate number of additional journeys outside the village and may
undermine the spatial strategy. However, it is recognized that there is a need to meet
local needs in these settlements for housing and other economic or community
purposes. This will be strictly controlled, both in terms of its scale and type in order to
ensure that the character and life of the settlement is not undermined. Housing in
particular will be required to be either affordable or meet an identified local need which
cannot be met elsewhere in accordance with policy H2.

These settlements will continue to be subject to Green Belt or countryside policies but in
addition some limited infilling and redevelopment is considered acceptable. In order to
restrict development an Infill Development Boundary will be defined around these
settlements within which appropriate development only will be allowed of a small scale.
These boundaries will be more tightly drawn then Development Boundaries to
accommodate infilling or redevelopment but to restrict peripheral expansion.

SS6c – Other Rural Areas

The other rural areas comprise the countryside and the green belt outside of the
settlement boundaries of the towns and villages, as defined in the Site Allocations
DPD, including those small settlements and dispersed developments not
identified above.


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LDF Core Strategy Preferred Option – Draft                                     December 2007




Development in these areas will be strictly controlled and limited to small scale
development comprising:

   The replacement, sub-division or extension of an existing dwelling;

   The conversion or redevelopment of a non-residential rural building;

   Development necessary to meet the needs of agriculture, forestry, recreation,
    tourism or other rural enterprise;

   Limited expansion or redevelopment of an existing authorised business for
    employment uses;

   The diversification of an existing farm enterprise;

   Rural exceptions affordable housing or community facilities which meet a local
    need, where that need cannot be met in a settlement within the hierarchy. In
    such cases the development should be in a sustainable location close to an
    existing serviced settlement;

In very exceptional circumstances larger developments may be permitted on
previously developed land or buildings in the rural areas where this would bring
positive overall benefit to the rural area, is in a sustainable location and would not
undermine wider strategic objectives or the principles of the green belt.

Provision for renewable energy generation should be of a scale and design
appropriate to its location.

Reasons and Justification

The concept of sustainability argues in favour of concentrating most development in or
adjoining existing built-up areas. However, there can be cases where some development
and diversification of use in the countryside can be beneficial and sustainable. For
instance, some farm businesses may benefit from diversification and an increased
number of visits to the countryside can help the rural economy. However this needs to
be appropriate to the character of the countryside which also needs to be sustained.

Where development in the countryside is justified, the preference will be for the re-use or
redevelopment of existing buildings. All development in these areas will be strictly
controlled, both in terms of its scale and type in order to ensure that the character and
role of the countryside and the green belt is not undermined. Housing in particular will
be required to be either affordable or meet an identified local need which cannot be met
elsewhere in accordance with policy H2.

Within these areas there are some smaller settlements and hamlets which are not
identified in Policy SS6c as „Small Villages‟ because their predominantly open character
and loose-knit nature makes infilling and the definition of an Infill Development Boundary
inappropriate. New housing in these settlements and hamlets will be similarly restricted
to re-use and redevelopment or to



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The development of renewable energy sources will also often be in rural areas but such
development will almost always have an environmental cost. Whilst there is support at a
national policy level for developing renewable energy schemes in rural areas (PPG 22
„Renewable Energy‟), it is also recognised that any such proposals must be weighed
against the continuing commitment to protect the environment. The scale and design of
such schemes will therefore be of paramount importance.
SS6d - Major Developed Areas in the Countryside

Major regeneration opportunities will be identified for the following major
developed areas in the countryside through the Site Allocations DPD at:

   Copperworks, Froghall
   Anzio Camp, Blackshaw Moor

Development of these areas shall be complementary to and not undermine the
role of the towns and larger villages nor shall it undermine wider strategic
objectives. It shall also avoid or minimise environmental impacts and congestion
and safeguard and enhance natural and cultural assets.

Development that facilitates the appropriate redevelopment of other major
developed sites will be supported where the proposed development brings
positive benefits to the area and measures are implemented to minimise
environmental impacts including traffic generated. Such proposals will be
expected to provide supporting information that demonstrates clearly that the
redevelopment will complement the overall development strategy for the District.

Reasons and Justification

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 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. 2 such areas have been
identified at:

   Bolton Copperworks, Froghall
   Anzio Camp, Blackshaw Moor

The extent and nature of future development of both of these sites will be identified
through the Site Allocations DPD.

Policy SS7 - Green Belt

The Green Belt within Staffordshire Moorlands will be maintained but its detailed
boundaries will be reviewed to ensure that its purpose in separating the urban
areas and maintaining their identity is consistent with the need to promote
sustainable patterns of development around settlements in or on the edges of the




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Green Belt. Strict control will continue to be exercised over inappropriate
development within the Green Belt as defined by Government policy.

Reasons and Justification

The Green Belt serves a number of purposes which are derived from Government
guidance (PPG2) and the Staffordshire Structure Plan. The Green Belt keeps land open
and free from development over a long period, which extends beyond the plan
period, in order to give assurance that its boundaries will endure. National policy on
Green Belts is set out in PPG2 and will apply to the whole of the Green Belt.

The Green Belt within Staffordshire Moorlands forms part of the North Staffordshire
Green Belt prepared by Staffordshire County Council and adopted in 1983 and
subsequently incorporated into the adopted Staffordshire Moorlands Local Plan. The
broad extent of the Green Belt will be reviewed through the RSS Phase 3 Revision.
However it is considered unlikely that any significant changes to the boundary of the
Green Belt in Staffordshire Moorlands will be identified in view of its importance in
supporting the renaissance of the North Staffordshire conurabation. Minor changes to
the boundaries may however be necessary to ensure that the development needs of
settlements can be accommodated in the most sustainable way. The Site Allocations
DPD will review its boundary in tandem with the identification of sites for development to
ensure that its purpose in separating the urban areas and maintaining their identity is
consistent with the need to promote sustainable patterns of development around
settlements in or on the edges of the Green Belt.

Policy SS8 – Strategic Transport Improvements

The Council will support and promote improvements to the following major
transport corridors. Development will not be permitted which is likely to prejudice
the improvement of these corridors:

     A520 to A53 Access Road Link, Leek
     A521/A522, Cheadle
     Alton Towers and Denstone link

Reasons and Justification

    These corridors are considered by the Council to be of strategic importance and their
    improvement is essential to the delivery of the spatial strategy for the reasons detailed
    below:
         A520 to A53 access road link, Leek – Leek is a key trip attraction which, coupled
          with all key classified roads converging on the town centre, does lead to
          congestion on the A523(T), A53 and A520. The latter runs to the east of the
          Cornhill site.which is identified in Policy SS5 as a major opportunity for
          redevelopment and related infrastructure improvements providing a new east-
          west link between the A520 Cheddleton Road and the Barnfield Industrial estate,
          to allow easier access across the southern side of the town, and to relieve
          pressure on Junction Road.




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        A521/A522, Cheadle – a number of major roads converge on Cheadle where the
         roads are narrow and junctions poor resulting in traffic congestion, poor road
         safety and environmental damage. A Cheadle Inner Bypass was identified in
         previous LTPs but was subsequently withdrawn. Whilst some junction
         improvements have been implemented, there remains a strong need to
         investigate and identify other potential solutions to improve traffic flows through
         the town particularly in the light of the growth aspirations for the town. This
         should be done in conjunction with proposals for development in order to ensure
         that they can be adequately resourced and delivered. The Council will press for
         their subsequent inclusion within the County‟s LTP.

        Alton Towers and Denstone link - The approach roads to Alton Towers are
         generally narrow and pass through a number of villages which makes them
         unsuitable for the high volumes of traffic associated with the theme park. The
         Council has always supported the construction 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. It is envisaged that funding
         and implementation of the route will be addressed through „Alton Towers‟ SPD.

Policy SS9 – Blythe Bridge Regional Investment Site

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 Development Brief.

Reasons and Justification

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 continues to recognize the site
as a major strategic employment site for North Staffordshire proposing its inclusion as a
„Regional Investment Site‟. The Council will therefore ensure that it continues to be
safeguarded for this purpose. In view of its strategic role, the site does not count
towards the employment requirement for the District.




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SUSTAINABLE DEVELOPMENT POLICIES

Objective

To create a District where development minimises its impact on the environment, helps
to mitigate and adapt to the adverse effects of climate change and makes efficient use of
resources.


Responses to Consultation on Issues and Options

-   60% of respondents considered that the use of renewable energy in the District
    should be a high priority and a further 21.5% considered that it should be a medium
    priority. Only 8% considered it should be a low priority, whilst 10.5% made other
    comments.
-   65% considered that new development should be required to generate a proportion
    of its energy requirements from renewable resources. Of these over 60%
    considered that this should be in all new development whilst nearly 30% considered
    that it should be just major developments
-   In response to the question on which forms of renewable energy would you like to
    see in the Moorlands –
    o small-scale solar panels (30.0%)
    o large-scale biomass (24.6%)
    o large-scale hydroelectricity (19.0%)
    o small-scale wind turbines (14.7%)
    o large-scale windfarms (11.8%)
-   Nearly 62% considered that brownfield land should always be used in preference to
    greenfield land, even if the greenfield land is in a more appropriate location, whilst
    17% disagreed and 16% gave a qualified yes.
-   Nearly 75% of respondents considered that the Council should aim only to allow
    development to take place in settlements with little or no risk of flooding. Only 11%
    disagreed.
-   In response to the question of whether development be allowed on sites with a low-
    medium risk of flooding if measures are taken to remove the risk, 36% said yes, 33%
    said no and 16% said yes but qualified
-   Of the positive comments some pointed to examples of design elements- supposedly
    successful elsewhere - which would reduce/eliminate flood risk (eg building on stilts).
    However negative comments pointed to the uncertainty generally of building within
    floodplains; to insurance/compensation costs of flooding; or the impacts
    ‘downstream’ of development on floodplains in the Moorlands.

Regional Spatial Strategy Context

-   Policy SR1 of the RSS Revision requires authorities to “ exploit opportunities to
    develop/use renewable energy to supply both new and existing development; and
    reduce the need to travel” requiring that authorities mitigate and adapt to …climate
    change; and in relation to flooding, avoid development in flood zones, protect
    essential infrastructure against flooding, and promote the use of sustainable urban
    drainage systems.




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-   Policy SR3 requires all new development to minimise resource demand and
    encourage the efficient use of resources such as water, energy and material; and
    incorporate climate-proofed developments and sustainable buildings. It establishes
    targets for reducing carbon emissions and securing higher standards of energy
    efficiency for new homes and for on-site generation from renewable or low carbon
    energy equipment.
-   Policy CF5b sets the overall West Midlands RSS target for housing development on
    previously developed land at 60% in non-MUA areas which includes Staffordshire
    Moorlands.
-   Policy CF4b instructs that previously developed land should normally be phased for
    construction early on in the plan period, and prior to the phasing of Greenfield sites.

Officer Comment

The need to respond proactively to the issue of climate change is a major challenge for
the District and planning has a key role to play in ensuring that development minimises
its impact on the environment, helps to mitigate and adapt to the adverse effects of
climate change and makes efficient use of resources. The responses support the need
for measures to secure greater use of renewable energy sources of an appropriate type
and to prioritise the use of brownfield land as well as preventing development on areas
at risk of flooding.

Other issues of concern which need to be addressed are the impact of pollution from
activities such as industrial uses and commercial or other activities, particularly where
these would be detrimental to residential amenity.

Policy SD1 – Use of Resources

The Council will require all development to make sustainable use of resources
and help to minimise its impact on climate change, where this is consistent with
other policies. This will be achieved through the following measures:

   Giving preference to development on previously developed land in the most
    sustainable locations in allocating land for development and determining
    planning applications, except where:
    o a previously developed site performs poorly in sustainability terms;
    o development upon a previously developed site would cause harm to some
       asset of acknowledged importance (eg environmental/historical/cultural
       etc) or if it would create an unacceptable flood risk;
    o the proposal relates to the provision of development on a greenfield site
       which cannot be accommodated on a previously developed site in the
       locality, or which would provide overriding benefits e.g. affordable
       housing, infrastructure benefits

   Managing housing development to achieve the following previously developed
    land targets:
       o 2006-2016 - 65%
       o 2017-2026 - 55%.

   Supporting or promoting proposals that remediate brownfield sites affected by
    contamination, where this is consistent with other policies.


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   Ensuring that all development makes efficient use of land, with particular
    regard to residential development in accordance with the density targets set
    out in policy H1.

   In line with national and regional guidance, promote inclusion of energy
    generation from renewable sources by:
    o supporting both small- and large scale renewable energy schemes, either
         where they form part of proposed new developments, or where they could
         be incorporated into existing ones, subject to design and amenity
         considerations;
    o supporting new stand-alone renewable energy developments subject to
         design and amenity considerations. The scale and nature of the proposal
         shall reflect the capacity and sensitivity of the landscape to accept the
         proposed renewable technology, as well as taking into account any
         impacts upon amenity of residents;
    o requiring that development is located and designed to minimise energy
         needs and to take advantage of maximised orientation to achieve the
         energy savings set out in the RSS;
    o requiring that all new development complies with the on-site renewable
         energy targets set out in national guidance and the RSS and takes positive
         measures to reduce carbon emissions to the levels set out in the RSS;

   Requiring that all planning applications the Council receives 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 be supported by site waste management plans to meet
    the requirements set out in the RSS. Design that can secure opportunities for
    sustainable waste management eg kerbside recycling and community
    recycling will be encouraged.

Reasons and Justification

This Policy covers two subject areas, resource use, and the linked issue of climate
change. It deals with the use of land to ensure that the most efficient use is being made
of land and buildings to minimise the use of greenfield sites and with sustainable design
and construction measures to ensure that buildings minimise their use of non-renewable
resources and are adaptable to the changing climatic conditions predicted for and
beyond the plan period. These measures are consistent with the Community Strategy
and the Corporate Plan which highlight tackling climate change as a major issue to be
addressed in the District.

National and regional policy and guidance promotes the use of previously developed
land for development and the efficient use of land. The District contains many older
settlements, many of which contain buildings and sites which could be re-used. Some of
these have a history of contamination due to industrial legacy. Many of these sites are
either quite central, or located in smaller settlements, where accessibility is not an issue
(or could via planning contributions be made more accessible). The Housing Land
Availability Assessment indicates that at least 60% of new housing could be built on
previously developed land.



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However there may still be circumstances where the re-use of a brownfield site over
greenfield may not be appropriate, for example on sustainability grounds (there are
many remote brownfield sites in the District). This is in line with the RSS Revision
which in para 6.36 states “…LDD preparation will need to balance the requirement for
making efficient use of brownfield land against the requirement to build in sustainable
locations”.

This part of the Policy is in line with Community Strategy ambition 1 which relates to
environmental protection/improvement (because of emphasis towards urban/brownfield
sites and remediation); and therefore ambition 4 (urban regeneration).

The policy also proposes a stepped target for development of housing on previously
developed land with higher levels in the first half of the plan period in accordance with
the RSS Revision (Policy CF4b) recognising that the development of the most suitable
PD sites is more likely to be realised earlier on in the Plan period, and the identification
of less suitable sites (whether on sustainability or Greenfield grounds) later. The target
proposed exceeds that of the RSS Revision to 2016 and overall gives an average for the
plan period of 60% in line with the national target for housing development set out in
PPS3.of 60% on previously developed land.

National guidance also promotes greater energy efficiency generation generally, and
recent guidance on climate change (‘Planning and Climate Change’ - supplement to
PPS1) sets out how Planning Authorities should encourage (or require) this to happen
more. Like much of the UK the District has a generally old housing stock alongside
more recent housing. There is therefore vast potential to implement energy efficiency
measures (eg solar panels, wind turbines, better insulation) into existing developments,
which the Policy promotes. The Policy also promotes such measures, as appropriate, in
new developments.

The most relevant targets for renewable energy generation are laid out in the Energy
White Paper (2003), and national planning guidance such as PPS22 (2004) and PPS1
(2005). These set out the Government‟s target to realise 10% of UK electricity
generation through renewables by 2010 – and 20% by 2020. In the meantime all
“substantial new development” should generate 10% of its energy on-site or from some
other non-mains source. The RSS also sets a target for on-site renewable features
within new developments. The Policy sets standards for on-site renewable energy,
energy savings and carbon emissions consistent with those proposed in the RSS
Revision (see box below) which are considered appropriate to this District.

As with national guidance the Policy also gives wholesale support to new renewable
energy development (eg wind farms) without differentiating between forms. The District
does have natural characteristics (eg wind currents, high river flows) which could make
this viable – either now, or due to future technology. However, the policy also
recognises that their siting and design requires careful consideration to protect the
landscape and townscape without precluding the supply of any type of renewable
energy.
.




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    RSS Revision Sustainable Design and Construction Requirements
    All new homes meet at least level 3 of the Code for Sustainable Homes and considering the
    potential for securing higher standards of energy efficiency for new homes at level 4 before 2013
    and zero carbon level 6 before 2016. Offices and other non-domestic buildings should aim for
    10% below the target emission rate of the current Building Regulations by 2016;
    All new medium and large scale development (greater than 10 residential units or 1,000 square
    metres) incorporate renewable or low carbon energy equipment to meet at least 10% of the
    development’s residual energy demand. Local authorities may use lower thresholds for the size
    of developments and set higher percentages for on-site generation where considered
    appropriate;
    Maximising the potential for decentralised energy systems such as combined heat and power
    and community heating systems based on renewable and low-carbon energy;
    Promoting the use of local and sustainable sources of materials, and the preparation of Site
    Waste Management Plans to ensure that at least 25% of the total minerals used derives from
    recycled and reused content;
    Requiring that all new homes meet or exceed the water conservation standards in level 4 of the
    Code for Sustainable Homes, that offices meet the BREEAM offices scale, and that other
    buildings achieve efficiency savings of at least 25%;



Policy SD2 – Pollution and Flood Control

The Council will ensure that the effects of pollution (air, noise, water, light) and
flooding, on both humans and environmental assets are avoided, or mitigated
when this is not possible, through the following measures:

      Pollution Control Measures

     resisting development likely to cause pollution near to existing pollution-
      sensitive development (such as housing) and the location of pollution-
      sensitive development near to existing polluting developments, where the
      nature of the pollution would unacceptably impact on amenity, both at present
      and also having taken into account future sources of pollution;

     resisting any development that would in the Council‟s opinion contribute to
      significantly increased air, water, light or noise pollution which would be
      environmentally unacceptable;

     supporting improvements to local air quality.

      Flood Control Measures

      development within the flood risk areas should first seek to make use of areas
       at no or low risk to flooding before areas at medium and higher risk, where
       this is viable or possible and compatible with other polices aimed at achieving
       a sustainable pattern of development.

      development which is acceptable (in terms of PPS25) or otherwise
       exceptionally justified within areas at risk of flooding must be subject to a
       satisfactory level 2 flood risk assessment; and be designed and controlled to



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     mitigate the effects of flooding on the site and the potential impact of the
     development on flooding elsewhere in the floodplain. The assessment shall
     take into account cumulative as well as individual environmental impacts, and
     shall take account of climate change.

Reasons and Justification

This Policy deals with issues of pollution and flood risk. Pollution not only can negatively
impact on the quality of life of people, but can also contribute to climate change (impact
on ozone etc) and adversely impact on biodiversity assets (which can also affect „wealth
creation‟).
National guidance on pollution has sought to minimise or mitigate the impacts of
pollution, whilst balancing this against the imperatives for economic activity which
generate it (PPS1). PPS23 goes further by establishing the precautionary principle and
sets out matters to be considered in preparing Local Development Documents and
taking decisions on individual planning applications. The Council will apply these
principles to any development where pollution considerations may arise.

The Moorlands has a wet climate and within it there are significant corridors along rivers
identified as being within flood risk zones. The questionnaire responses indicate acute
public concerns to flooding generally. Development patterns can have distorting effects
on the water cycle and drainage systems (for example, artificial features such as
hardstanding, new roads and pavements can create channels of surface run-off).

A level 1 Strategic Flood Risk Assessment has been undertaken of the District. In
accordance with PPS25, areas of „low‟, „medium‟ and „high‟ risk have been mapped
using data collected from the Environment Agency, Staffordshire Moorlands District
Council, Severn Trent Water, the Highways Agency and British Waterways. This has
included information on flooding from rivers, surface water (land drainage), groundwater,
artificial water bodies and sewers. This provides the basis for the Sequential Test to be
applied. The Council will apply the Sequential Test to all sites within the „high‟ and
„medium‟ risk flood zones to demonstrate that there are no reasonably available sites in
areas with less risk of flooding that would be appropriate to the type of development or
land use proposed. If there is an area of overlap between the site boundary and area at
risk of flooding, this should be utilised as an opportunity to reduce flood risk within the
site, by using waterside areas for recreation, amenity and environmental purposes.
Where the need to apply the Exception Test is identified, if the Council considers that
there are an insufficient number of suitable sites for development, the scope of the
SFRA could be widened to a Level 2 assessment.




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ECONOMY AND EMPLOYMENT POLICIES

Objective

To develop and diversify in a sustainable manner the District‟s economy and meet local
employment needs in the towns and villages.

Responses to Consultation on Issues and Options

-   In response to question 17 on how can the Council ensure there is sufficient
    employment land available for local needs, the response was fairly evenly split. 53%
    considered protecting existing employment sites and premises for employment use
    and 47% considered allocating additional employment sites in suitable locations to
    meet the demands of modern businesses. However, some respondents selecting
    the first option considered that although it was preferable to protect existing
    employment sites, some would not meet the demands of modern businesses and
    may not be in the right location.
-   In response to question 18 on what approach should be taken in the allocation of
    new employment sites, the majority of respondents thought that these should be
    provided on a smaller number of sites rather than 1 or 2 larger sites. Around 10% of
    respondents considered that a mixture of large and small sites should be provided.

-   Advantage West Midlands stressed the importance of having an appropriate supply
    of employment land in the right location, whilst increasing the re-use of brownfield
    land. In rural areas like the Moorlands in order to be sustainable, it is likely that new
    employment sites will be smaller in size and mainly located in the market towns on
    brownfield sites where possible. Existing employment sites should be retained
    where they remain suitable and are accessible.

Regional Spatial Strategy Context

-   Phase 2 Revision (Oct 2007) makes stronger links between housing distribution and
    employment distribution.
-   Puts forward a five-year „reservoir‟ approach aimed at quantifying future employment
    land requirements. At any point in time during the WMRSS period (2006 – 2021) the
    Council would need to demonstrate that there is a portfolio of readily available
    employment sites (i.e. sites with no major development constraints) which is the
    equivalent of the reservoir figure. Districts would also need to maintain a bank of not
    readily available sites (i.e. land with development constraints) which would be
    brought forward through the plan period to top-up readily available supply.
-   For the Staffordshire Moorlands the WMRSS Revision is suggesting a total
    requirement of 18 hectares of employment land between 2006 and 2021.

Employment Land Study (2006)

-   The Staffordshire Moorlands property market is localised and static.
-   District is behind in providing employment facilities and needs to expand from
    manufacturing base to allow the economy to modernise.
-   It is believed that one in ten jobs are linked to the larger employers such as JCB and
    the two building societies.



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-   Need to protect suitable employment sites identified in the study.
-   Need to take a more proactive role to stimulate private sector investment by making
    sites available to enable manufacturing base to diversify.
-   Encourage more farm diversification.

Officer Comment

The provision of employment land of the right type and in the right place is a key issue
for the Core Strategy. The Employment Land Study has highlighted the need for the
local economy to rely less on the manufacturing industry and to stimulate the private
sector by making more sites available. The Study particularly indicated the need for
starter units and the potential for offices.

Although there is concern that employment sites are being lost to residential
development it is acknowledged that not all sites remain suitable for such use. In order
to retain as many sites as possible developers should be looking to retain the site in
employment use first, then fully consider a mixed-use scheme and only in exceptional
circumstances justify a residential scheme.

Policy E1 – To Develop the District‟s Economy

Development should provide for a wide portfolio of employment sites to
accommodate different sized operations at different locations across the district.
These employment sites should support the priorities and measures identified to
deliver the Council‟s Economic Strategy.

Development will be assessed according to the extent to which it provides for
high quality, sustainable employment sites making efficient use of land and to
which it meets identified business needs, having regard to the location of the
development, the characteristics of the site and the economics of provision.

In addition:
 Within the towns and larger villages employment provision should particularly
    be made for:
       o starter units and
       o offices (B1a and B1b uses).

   Outside of the settlement boundaries of the towns and villages, employment
    development comprising either limited expansion of firms of their existing
    premises, limited redevelopment of existing sites or the conversion of rural
    buildings will be permitted provided that development will not be visually
    intrusive or harm interests of acknowledged importance. Within the Green
    Belt particular regard will be had to the impact of development on their
    openness.

   The expansion of existing major businesses will be permitted provided that
    additional development is complementary to and not undermine the role of the
    towns and larger villages nor shall it undermine wider strategic objectives. It
    should also avoid or minimise environmental impacts and congestion and
    safeguard and enhance natural and cultural assets.



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   All employment development should be an appropriate use and scale, have no
    impact on amenity and not harm interests of acknowledged importance.

Reasons and Justification

This Policy will ensure that there is a choice of sustainably located employment sites,
attractive to developers and operators and appropriate to market needs. The
Employment Land Study identified a need to follow successful examples such as the
Victoria Business Park, and opportunities to encourage more start-up businesses and
embrace new technologies in order to diversify the District‟s economic base away from
industrial to office markets.

This policy supports local businesses many of which are located outside main
settlements or designated industrial estates, are within rural locations or are tightly
hemmed in by housing or other development. For these businesses wishing to expand
and remain on their current sites, there needs to be a careful balance between
protecting the countryside or surrounding land uses, maintaining the openness of the
green belt and allowing these firms to provide the additional floorspace that they require.

Expansion and consolidation land and premises need to be provided for larger
occupiers. This will be particularly important for established businesses in the area that
are planning to expand locally or respond to changing market circumstances. In meeting
these needs, it will be necessary for this policy to be complemented by on-going
dialogue and consultation, in particular with major employers in the area to identify not
only land-use requirements but transportation and economic development strategies that
may be required.

Policy E2 – Existing Employment Sites

Employment areas (falling within Use Classes B1, B2 or B8) that:

        are well located to the main road and public transport network; and
        provide, or are physically and viably capable of providing through
         redevelopment, good quality modern accommodation attractive to the
         market without harm to the amenity of nearby residents; and
        are capable of meeting a range of employment uses to support the local
         economy;

will be safeguarded for such purposes.

Redevelopment of such sites for housing, retail or other non-employment uses
will not be permitted unless:
      the site is identified in the Site Allocations DPD for redevelopment; or,
      it can be demonstrated that the site would not be suitable or viable for
       continued employment use having regard to the above criteria; and,
      full consideration has been given to a mixed use redevelopment scheme;
       and,
      substantial planning benefits are proposed which would outweigh the loss
       of the site for employment use.




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Reasons and Justification

Government policy guidance for development to take place on previously-developed
land has meant that many of the existing employment sites have become under
considerable pressure from the threat of residential development. Applicants often
argue that there is no demand for an existing employment site or that its retention or its
redevelopment for new employment uses is not a viable option. It is accepted that in
some cases this is true. However, it needs to be recognised that employment land is a
finite resource and once it is lost, it is effectively lost for good. Although the retention or
redevelopment of a site for employment use may not be viable at a particular time, the
economics of development may change over time and its redevelopment for
employment uses may become a viable proposition in the future.

The Council will continue to resist proposals including the loss of employment land by
proposing a sequential approach towards planning applications. This would initially
involve retaining appropriate and viable employment sites. Where a lack of demand can
be demonstrated by an appropriate marketing exercise and where the retention of a site
in employment use can clearly be shown to be unviable, the potential for mixed-use
development should be explored incorporating an element of employment uses within
the development.

The Employment Land Study highlights some opportunities on underused sites, derelict
buildings and for mixed use developments. Mixed-use development is considered to be
beneficial in contributing to sustainable development and provides the opportunity to
build business units which might otherwise not be viable. Permitting some residential
development on employment sites for example can help to raise land value and
generate additional revenue to bring forward sites with known problems that are costly to
resolve.

Locating housing and employment developments close to each other has added benefits
of potentially helping to reduce the amount of traffic, congestion and pollution from work
to home travel. This is particularly so with „live-work‟ units – purpose built units where
the occupier of a studio, office or workshop lives in a flat attached to the place of work.




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LDF Core Strategy Preferred Option – Draft                                      December 2007




HOUSING POLICIES

Objective

To provide new housing that is affordable, desirable, well-designed and meets the needs
of residents of the Moorlands.

Responses to Consultation on Issues and Options

-   Over 63% of respondents agreed that affordable housing was needed and should be
    provided in both towns and villages whilst a further 30% gave a qualified yes either in
    towns or villages or depending on their affordability. Only 7% considered affordable
    housing was not needed.
-   Just over half of respondents (55%) considered that either half or more housing
    should be affordable whilst 34% considered a small proportion of affordable housing
    only was appropriate.
-   In response to the question on whether sites should be specifically allocated for
    affordable housing, only 27% were in favour, the majority being against this on the
    grounds that it would create „ghettos‟, favouring more mixed residential
    developments
-   In response to the question on whether densities should be increased so that more
    housing can be accommodated on sites, only 16% considered that they should be
    increased, whilst over half (54%) disagreed and a further 30% considered that they
    should only be increased in certain circumstances, depending on the location, type of
    housing, or as required by national guidance.

Regional Spatial Strategy Context

-   Preferred Option RSS Review requires LDFs to set out the general mix of types of
    accommodation that need to be built in a particular area
-   Requires the delivery of 500 affordable dwellings per annum minimum in the North
    Housing Market Area and that LDFs set out targets for amount of affordable housing
    to be provided including separate targets for intermediate and social-rented housing.
    Also supports lower site thresholds, rural exceptions sites and the option of 100%
    affordable allocations for small rural settlements.
-   Demand for affordable housing from newly arising households for Staffordshire
    Moorlands estimated at 95/annum of which 68% social rented.
-   Also requires that all new housing meets the CABE Building for Life „good‟ standard
    and that all developments greater than 10 units meet the „very good‟ standard

North Staffordshire Housing Market Assessment

-   Draft Report Identifies a significant need for affordable dwellings for Staffordshire
    Moorlands to meet current and future needs to 2026.
-   Indicates significant projected increase in older persons housing market
-   Most significant growth in demand for housing is for 1 or 2 bedroomed
    accommodation
-   Greatest need for affordable housing is for social rented – discounted housing for
    sale and, to a lesser extent, shared equity housing not likely to be affordable for
    those in need



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Officer Comment

The provision of affordable housing remains one of the priorities of the Council and of
the LDF. There is considerable evidence and support to justify an increase in the quota
for affordable housing provision from the current 33%. The HMA findings would suggest
a 100% affordable housing target, however this is considered unrealisitic as it would not
allow a sustainable housing market to be maintained. An increase to 50% however
could be justified and has been supported in other adopted Core Strategies. Of equal
importance is the need to ensure that an appropriate range and type of housing is
provided which meets identified needs, including special needs, and promotes higher
quality, more sustainable housing design and layout. Notwithstanding the concern with
respect to increasing residential densities, this has been Government Policy for over a
decade, recognised as a „sustainability‟ measure at least in terms of land efficiency.
However, it is considered that there is scope to promote a suitable range of densities
which are appropriate to their locality.

Policy H1 - Range and Type of Housing

Development should provide for a mix of housing sizes, types and tenure
including a proportion of affordable housing as set out in policy H2, and where
appropriate housing for special groups, to meet the needs of the current and
future population.

All development will be assessed according to the extent to which it provides for
high quality, sustainable housing making efficient use of land and to which it
meets identified local housing market needs, having regard to the location of the
development, the characteristics of the site and the economics of provision.

In addition:
 Within the towns and larger villages provision should particularly be made for
    smaller house types of 1 – 3 bedrooms.

   Housing for special groups, particularly for the elderly, will be encouraged
    within the towns. These should meet a genuine and proven local need and
    demand and be of a scale and in a location which is appropriate to its needs.

   Housing proposals of 10 dwellings or more will be required to provide a range
    of dwelling types on the site. The final mix will be negotiated with the
    developer based on the housing needs identified in the housing market
    assessment.

   All housing development should be at the most appropriate density compatible
    with the site and its location, and with the character of the surrounding area.
    This will generally be within the range of 40 dwellings per hectare or more in or
    on the edge of town centres , 30 – 40 dwellings per hectare in other urban
    areas and villages and 20 – 30 dwellings per hectare in remoter rural areas.

   All new dwellings should meet the CABE Building for Life „good‟ standard.




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   On schemes of 10 dwellings or more at least 20% of all new dwellings should
    be built to “Lifetime Homes” standard.

   All new dwellings must be of sufficient size to provide satisfactory levels of
    amenity for future occupiers whilst respecting the privacy and amenity of
    existing occupiers.

   All new dwellings must meet the sustainability requirements set out in the RSS
    and policy SD1.

Reasons and Justification

This policy is primarily to ensure that an appropriate range and mix of housing –
including affordable housing – is provided to meet the needs of the existing and future
population. It reflects the guidance in PPS3 ‟Housing‟ and the RSS to achieve mixed
and balanced communities and to make efficient use of land.

The range, type and mix of affordable accommodation required on development sites
will be determined by a combination of the results of housing market assessment,
information from the waiting lists, consideration of existing housing stock, local housing
market information as well as any other available information including the constraints of
sites.

The provision of smaller house types in the towns and larger villages is justified by
evidence of the Housing market Assessment which identifies the greatest growth in
demand being from smaller households and a lack of such housing across the District.

Housing for special groups will be needed to meet the future increase in elderly persons
across the District – this may be in the form of sheltered housing, extra care homes or
supported housing.

In order to address the needs of a changing population, Lifetime Homes must be a
component of all future larger schemes. The cost of implementing the Lifetime Homes
standard is not high and it will benefit all future occupiers as well as making homes more
adaptable and future-proof.

Further guidance on these types of housing will be set out in an accompanying „Housing
Delivery‟ SPD.

Density requirements will vary across the District to reflect the character and
sustainability of different areas. Higher densities are considered appropriate near to
town centres where densities are generally much higher and there is greater
accessibility to services and facilities whilst in the remoter rural areas lower densities are
considered more appropriate to reflect their character and poorer supporting
infrastructure. All development including higher density development will be required
to incorporate a high standard of design of buildings, streets and spaces.




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Policy H2 - Affordable Housing

A minimum of 1700 affordable housing units will be provided 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 in the open market. This
will be provided as follows:

Settlement                                       No. of Affordable Housing Units
Leek                                             450
Biddulph                                         400
Cheadle                                          550
Rural                                            300

This will be achieved through the following measures:

   Residential developments of 15 dwellings (0.5 hectares) or more shall provide
    a minimum target of 50% affordable housing on-site from all sources.

   In the larger villages, schemes of 5 dwellings (0.16 hectare) or more shall
    provide a minimum target of 50% affordable housing on-site. Exceptionally
    this may be provided through a commuted sum payment in lieu.

   In the rest of the rural areas, including smaller villages, all housing should
    either be affordable or meet a local need which cannot be met elsewhere,
    unless there are exceptional circumstances which dictate otherwise.

   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.

   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 where a demonstrable need exists which cannot otherwise
    be met by means of provision in the plan.

   Schemes proposing 100% affordable housing will be targeted to those areas in
    greatest need.

   In areas of low demand or where the stock does not meet and is not capable of
    meeting local housing market needs consideration will be given, in
    consultation with local communities, to options for renovation/improvement or
    redevelopment schemes to create more sustainable and balanced housing.

   Unless circumstances dictate otherwise and in agreement with the Council,
    70% of all affordable dwellings provided on each site should be social rented
    housing with the remainder being intermediate housing.

In considering the proportion and type of affordable housing to be provided on-
site, regard shall be had to identified local needs, the location of the development,
the characteristics of the site and economics of provision.


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All affordable housing should meet the Council‟s definition of affordable housing
and be subject to eligibility and price restrictions in perpetuity as set out in the
SPD.

Housing to meet a local need will be subject to a local occupancy condition.

Reasons and Justification

The limited supply of, and high demand for, housing in Staffordshire Moorlands has led
to high prices and rents. It is now extremely difficult for local people on low incomes and
increasingly those on middle incomes to afford a home of their own. Unless more
affordable housing is provided, there is a danger that those on lower and middle
incomes, particularly the young, will be forced to leave the district in increasing numbers.
As a result, our communities will be damaged and the district‟s age and social structure
will become even more biased towards the elderly and the wealthy.

The provision of affordable housing is of great concern amongst local people and is a
high priority of the Council and the RSS. The Housing Needs Assessment demonstrates
a significant need for affordable housing in the District which exceeds the District‟s
average annual development rate requirements. This policy therefore seeks to increase
the provision of affordable housing across the District through a range of measures.

The threshold and minimum target for affordable housing provision are intended to
ensure that adequate provision is made both in urban and smaller rural settlements to
help address this need and ensure that a sustainable housing market is maintained
which will deliver the range of housing needed to help meet market demand as well
affordable housing needs. All development involving the provision of housing which
meet the thresholds will be required to make provision for affordable housing unless
there are exceptional circumstances why this would not be possible. An assessment of
the viability of sites where affordable housing is required is being undertaken to ensure
that the requirements are not too onerous.

The Housing Needs Assessment also indicates that intermediate housing, in the form of
discounted housing for sale and shared equity, is unlikely to be affordable by those in
need.

The majority of any affordable housing that is likely to be provided will mostly be on
allocated sites in or on the edges of the main market towns. Affordable Housing
provision will also be contributed to by windfall schemes, net gains from conversions;
new provision of non self contained household spaces, and long term vacant properties
brought back into use.

In the rural areas it is anticipated that the bulk of the provision of affordable houses will
be in the larger villages, either on allocated sites or on windfall sites. Because of the
smaller scale of development in the rural areas a lower threshold is considered
justifiable. In the remoter rural areas and smaller villages the very limited scope for new
dwellings is such that all new housing should be restricted to that which is affordable or
meets a local need other than in exceptional circumstances e.g. enabling development.
A local need is defined as being for a person or family currently living or working in the



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LDF Core Strategy Preferred Option – Draft                                       December 2007



community or needing to work in the community and will be subject to a local occupancy
condition.

Given the high level of need for affordable housing which is unlikely to be met through
on-site provision there is justification for requiring other housing below the threshold to
make a financial contribution to support provision elsewhere. These requirements will
be established in a supporting SPD.

Schemes which offer 100% affordable housing will need to be targeted to those areas in
greatest need as identified by the Council in order to ensure that those areas are not
disadvantaged by lower levels of housing development.

Policy H3 - Gypsy and Traveller Sites

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.

The following considerations will be taken into account in the determination of
applications for gypsy and traveller sites:
       o Safe and convenient vehicular and pedestrian access to the site should
          be provided.
       o The site must be large enough to provide for adequate on site facilities
          for parking, storage, play and residential amenity.
       o The site should be well located on the highway network.
       o The site should have safe and convenient access to schools and local
          facilities.
       o The site should not be detrimental to amenities of adjacent occupiers.
       o Adequate levels of privacy and residential amenity for occupiers should
          be provided.
       o Interests of acknowledged importance should not be prejudiced by the
          proposal.

Reasons and Justification

Recent legislation and guidance from the government has indicated a commitment to
taking steps to resolve some of the long standing accommodation issues for members of
the Gypsy and Traveller communities. This legislation has an overarching aim of
ensuring that members of the Gypsy and Traveller communities have equal access to
decent and appropriate accommodation options akin to each and every other member of
society.

The need for sites for gypsies and travellers within Staffordshire Moorlands will be
identified through the North Staffordshire Gypsy and Traveller Accommodation Needs
Assessment. Where there is an identified need proposals for the allocation or creation
of such sites will be assessed against this policy, taking into account the spatial
regeneration and environmental protection objectives of this strategy, and other relevant
criteria set out in the Core Strategy.




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LDF Core Strategy Preferred Option – Draft                                     December 2007




TOWN CENTRE AND RETAILING POLICIES

Objective

To ensure the long-term vitality and viability of the three market towns.

Responses to Consultation on Issues and Options

-   89% considered that there should be further retail development in Leek - 16%
    considered there should be a large amount and 73% considered there be a limited
    amount of additional retailing in Leek.
-   In term of where new retail development in Leek should be located, 55% considered
    in should be town centre sites only, 37% considered it should be on edge of town
    sites and 8% considered it should be on the outskirts of the town. Edge of centre
    sites were considered appropriate where it involved the redevelopment of brownfield
    sites, for larger site requirements where no better located alternatives available, for
    stores like Currys and B & Q, to develop vacant sites, or to cut the amount of
    transport needed in the town.
-   95% considered that there should be further retail development in Cheadle - 22%
    considered there should be a large amount and 73% considered there be a limited
    amount of additional retailing in Cheadle.
-   In term of where new retail development in Cheadle should be located, 49%
    considered in should be town centre sites only, 45% considered it should be on edge
    of town sites and 6% considered it should be on the outskirts of the town. Edge of
    centre sites were considered appropriate where there are enough developers to
    retain shoppers in the town and to reduce congestion in the town.

Regional Spatial Strategy Context

-   The Preferred Option RSS Review considers the Staffordshire Moorlands town
    centres to be non-strategic. Local Authorities are required to identify non-strategic
    centres and develop retail policies to meet local needs. Local Authorities are
    required to be pro-active in encouraging appropriate development to maintain and
    enhance their function as town and district centres, in particular, convenience
    shopping, local service and facility provision and day-to-day comparison shopping.
-   Any proposals for an increase of 10,000 square metres gross or more of comparison
    retail floorspace in a non-strategic centre have to be accompanied by evidence to
    demonstrate:
     there is a clear local need for the scale of development proposed;
     the proposal would not have an adverse impact upon or put at risk the delivery of
        development within a strategic centre;
     there is satisfactory public transport access to the centre from all parts of its
        catchment area either already in existence or to be provided as part of the
        proposal.
-   RSS policy limits out of centre retail development to less than 10,000 square metres,
    with smaller scale comparison retail schemes to be carefully considered in light of
    Government guidance.
-   Policy RR3 from the existing RSS promotes market towns as a means of
    regenerating rural areas including developing shopping and other key services and




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LDF Core Strategy Preferred Option – Draft                                       December 2007



    facilities within the town centre where suitable sites exist. Where no such sites are
    available it states that shopping development should be subject to PPS6 tests.

Retail Capacity Study (2006)

A comprehensive District wide Retail Capacity Study was undertaken in 2006 on behalf
of the Council by consultants. In terms of Leek and Cheadle, the study concludes that a
significant amount of Leek and Cheadle residents and people living within the Leek and
Cheadle catchment areas are not using the town for their main shopping and instead are
choosing to shop outside the District. Data collected from a catchment telephone survey
and street survey of town centre users indicates that both towns need to improve their
retail offer in both quantitative and qualitative terms to attract local shoppers. In terms of
Leek, the retail study demonstrates that there is a need for up to around 2975m 2
additional gross floor space for convenience (i.e. food retailing), 9204m2 gross floor
space for comparison (non-bulky) and 7186m2 gross floor space for comparison (bulky)
up to 2016. In terms of Cheadle, the retail study demonstrates that there is a need for
up to around 2564m2 additional gross floor space for convenience (i.e. food retailing),
2945m2 gross floor space for comparison (non-bulky) and 2882m2 gross floor space for
comparison (bulky) up to 2016.

The retail study also identifies a significant level of food and non-food retail capacity in
Biddulph. This is dealt with through retail allocations for a new supermarket facing on to
the High Street and a new non-food retail park to the west of the bypass as part of the
Biddulph Town Centre Area Action Plan Development Plan Document (adopted in
February 2007).

Officer Comment

It is important to maintain and improve the long term vitality and viability of the three
Staffordshire Moorlands market towns as they are the main service centres for their
populations and the surrounding rural hinterlands. Both national guidance and the draft
Regional Spatial Strategy require local authorities to be pro-active in the development of
town centres by focusing retail, office, leisure and cultural development within them and
actively planning for their growth and enhancement to meet the needs of all members of
the community. Development of town centre uses outside of town centres is controlled
through sequential testing i.e. considering town centre sites first and only where this is
not possible, edge of town centre locations and exceptionally out of centre sites with
good transport links.

Results from the issues and options consultation show that the vast majority of people
would like to see further retail development in Leek and Cheadle on town centre or edge
of centre sites. Policies for development in Biddulph town centre are set out in the
Biddulph Town Centre Area Action Plan, adopted by the Council in February 2007.

Policy TCR1 - Development in the Town Centres

The vitality and viability of the town centres of Leek and Cheadle (defined on the
Proposals Map of the Site Allocations DPD) will be protected and enhanced by
positive management as follows:




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LDF Core Strategy Preferred Option – Draft                                 December 2007



        focusing and promoting retailing as well as other key town centre uses
         such as offices, leisure and cultural facilities within the town centres where
         they contribute to vitality and viability;

        identifying major town centre redevelopment opportunities in Leek and
         Cheadle through the Site Allocations DPD;

        supporting positive measures to enhance and regenerate the shopping and
         town centre environment and promote their tourism potential;

        enhancing local distinctiveness by supporting proposals which help retain,
         attract or expand the provision of independent retailers in the town centres
         including niche markets;

        ensuring new development is well related to pedestrian shopping routes;

        ensuring there are adequate parking facilities in suitable locations in and
         around the town centres and good access to the town centres by those
         using public transport, cycling or walking;

        setting out design principles to improve and enhance the distinctive
         heritage of the town centres including minimising the risk of crime (refer to
         Policy DC1 and the design SPD);

        promoting housing on upper floors within the primary shopping areas and
         elsewhere in the town centres where this does not jeopardise their vitality
         and viability;

        only permitting new retail, leisure, office and other key town centre uses
         outside town centres where they are consistent with the approach set out
         in PPS6 in terms of need, scale, sequential approach to site selection,
         impact on other centres, including those beyond the district boundary, and
         accessibility and are consistent with the West Midlands Regional Spatial
         Strategy policies for non-strategic centres;

        protecting the retail function in the heart of the town centres by
         designating primary and secondary shopping frontages (defined in the Site
         Allocations DPD)

         Primary Frontages

         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.

         Where a proposed change of use from A1 retail would not create a
         concentration a marketing exercise in line with the SPD to demonstrate that




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LDF Core Strategy Preferred Option – Draft                                        December 2007



         there are no retail uses that could occupy the unit will be required to
         accompany the planning application.

         Proposals for residential use at ground floor level in primary frontages will
         not be supported.

         Any non-A1 use must be complementary to adjacent shopping uses in
         terms of its operational characteristics and retain a display frontage
         appropriate to a shopping area.

         Secondary Frontages

         In secondary frontages, development falling within other use classes will
         be permitted where it will contribute to the vitality and viability of the town
         centre.

Proposals relating to Biddulph Town Centre will be assessed against policies in
the Biddulph Town Centre Area Action Plan Development Plan Document
(adopted February 2007). Proposals for town centre uses in Biddulph outside the
AAP boundary will be assessed in accordance with part i) of this policy.

Reasons and Justification

The market towns of Leek, Cheadle and Biddulph are the main centres in the
Staffordshire Moorlands, serving residents of the towns themselves and their large rural
hinterlands. It is recognised both locally and nationally that our town centres are very
important to the social, economic and environmental well being of the District. It is
considered crucial to maintain and improve their long term vitality and viability so that
they are attractive places to shop, work, visit and invest in. In line with national guidance
set out in Planning Policy Statement (PPS) 6 „Planning for Town Centres‟, and the
Preferred Options of the West Midlands Regional Spatial Strategy Review this policy
states how the Council will plan proactively for the town centres by focusing growth and
development within them to meet the needs of all members of the community in terms of
retailing and other facilities, whilst at the same time preserving their unique local identity.

This policy approach ties in with the vision of the Staffordshire Moorlands Draft
Sustainable Community Strategy 2007 – 2020, which states that „by 2020…..our vibrant
market towns will be home to a range of successful retail, visitor and knowledge based
businesses‟.

Evidence from the Staffordshire Moorlands Retail Study (2006) highlights the importance
of enhancing Leek and Cheadle town centres, particularly in terms of retail offer to
encourage more sustainable travel patterns. Survey work undertaken as part of this
study with the local population through both in centre interviews and telephone surveys
has revealed that there are gaps in the provision of both convenience and comparison
goods causing significant numbers of Staffordshire Moorlands residents to regularly
shop outside the District.

The policy contains a whole range of measures to maintain the vitality and viability of our
town centres. Retailing and other key town centre uses like offices, leisure uses such as
hotels and cinemas and cultural facilities like those connected with performance and the


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arts should ideally be focused in town centres. However, as the District has a thriving
tourist industry it is recognised that when special circumstances dictate, hotels in
particular may need to be located outside town centres. Retailing and other key town
centre uses will only be permitted outside town centres, where proposals are consistent
with national guidance in PPS6 and regional guidance in the West Midlands Regional
Spatial Strategy review.

Whilst the Core Strategy provides an overarching strategy for the future development of
the town centres, the subsequent Site Allocations Development Plan Document and the
adopted Biddulph Town Centre Area Action Plan specifically identify opportunities for
major redevelopment in all three town centres.

Examples of measures to enhance the town centres which could be considered are
improvements to traffic management, possible pedestrianisation and improvements to
the public realm such as greening the town centres. Retaining and enhancing local
distinctiveness has strong local support with residents and businesses alike not wanting
our historic market towns to become „clone towns‟. Supporting independent traders and
niche markets (such as antiques in Leek) is a positive way of doing this. Relating new
development to pedestrian shopping routes is a positive way of linking it into the town
centre and ensuring that it is successful.

It is extremely important to ensure that our town centres, which are our key service
centres for a large rural hinterland, are accessible by a choice of means of transport as
well as to pedestrians. It is recognised that a proportion of town centre users travel by
private transport and need convenient parking places to encourage them to use the town
centres rather than go to other centres outside the District.

Good design is particularly important in our town centres in order to retain
distinctiveness, attract visitors and also ensure that key areas and buildings are user
friendly for the whole community. The fear of crime is an important issue which can be
tackled by good design, for example through town centre lighting. The SPD on design
and Policy DC1 cover this in more detail.

Upper floors in our town centres are not used to their full capacity. There is a local need
for housing in accessible locations as well as the other benefits residential use could
bring, such as security outside normal working hours and assisting with the development
of the evening economy.

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 where there is no reasonable prospect of this happening would a change of use be
considered. 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.




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This policy primarily covers the development of Leek and Cheadle town centres, as
Biddulph town centre is the subject of a separate DPD, an Area Action Plan (AAP)
adopted in February 2007. However, all development proposals for town centre uses in
Biddulph outside the AAP boundary will be carefully considered against national
guidance in PPS6 and the West Midlands Regional Spatial Strategy review.

Policy TCR2 – Retailing Outside Town Centres

The Council will facilitate new bulky goods retail provision in Leek and Cheadle to
meet the local need identified in the Retail Study. 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.

Outside town centres and in the larger villages identified in Policy SS3b new or
extended convenience retail units of up to 500m2 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.

In smaller villages and other rural areas (identified in Policies SS3c & SS3d)
proposals for small scale village shops including farm shops in sustainable
locations to serve everyday local shopping needs will be supported.

Reasons and Justification

Evidence from the Staffordshire Moorlands Retail Study (2006) demonstrates a need for
further bulky goods retail floorspace in Leek and Cheadle. It is recognised that there are
limited sites in the town centres to accommodate the amount of floorspace identified.
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.

It is recognised that in accordance with sustainability principles and guidance set out in
PPS6 and the West Midlands Regional Spatial Strategy, it is important for residents to
have easy access to a network of local centres to meet their day to day shopping needs
both in urban and rural areas in addition to town centres. This serves the needs of the
less mobile and minimises the transport needs of rural residents. This also ties in with a
key theme in the Staffordshire Moorlands Draft Sustainable Community Strategy 2007 –
2020 about responding to the needs and aspirations of an older population. One
challenge identified as part of this is „providing the opportunity for our oldest residents to
continue living in rural communities‟ and access to services including local shopping for
day to day needs would help to achieve this challenge.

The policy allows for small scale convenience retail development for local needs in
accordance with the hierarchy of centres identified in Policy SS3, to ensure that retail
facilities outside of town centres complement rather than undermine their vitality and
viability. It covers facilities in neighbourhood areas in the towns as well as village shops.
Farm shops can also meet a demand for local produce in a sustainable way, contributing
to the rural economy. Such establishments often do not require planning permission
where they are ancillary to another use. Where permission is required, care will be


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taken to ensure that they do not undermine existing easily accessible convenience
shopping available to the community.




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DESIGN AND CONSERVATION POLICIES

Objective

To promote local distinctiveness by means of good design and the conservation,
protection and enhancement of historic, environmental and cultural assets throughout
the District.

Responses to Consultation on Issues and Options

-   Whilst many respondents considered that design quality in Staffordshire Moorlands
    was generally good, particularly with regard to refurbished buildings, the majority
    (55%) considered that there was still a need to improve the general quality of design
    using more traditional materials and ensuring buildings are in sympathy with area‟s
    heritage. There was also concern for design of modern new homes and desire for
    more sustainable development.
-   Main types of building which considered should benefit from further design guidance
    were housing developments, town centre buildings, industrial buildings, houses and
    mill buildings

Regional Spatial Strategy Context

-   Preferred Option RSS Review requires LDFs to ensure that all new buildings are
    designed and constructed to highest possible environmental standards and to work
    towards achievement of carbon neutral developments
-   The RSS Review also sets out detailed requirements for meeting different standards

Officer Comment

The built environment of the District is one of its greatest assets and is valued by its
residents and visitors. It is vital therefore that the core policies give sufficient
prominence to design and heritage considerations, not just in terms of resisting
inappropriate development but also promoting creative and sensitive design solutions to
future developments. The setting of its settlements is also valued and there is a need to
address this through the core strategy.

Policy DC1 - Design Considerations

All development shall be well designed and reinforce local distinctiveness by
positively contributing to and complementing the special character and heritage
of the area in line with the Council‟s Design SPD. In particular, new development
should:

   be of a high quality and add value to the local area, incorporating creativity,
    detailing and materials appropriate to the character of the area;

   be designed to respect the site and its surroundings and promote a positive
    sense of place and identity through its scale, density, layout, siting,
    landscaping, character and appearance;




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   create, where appropriate, attractive, functional and safe public and private
    environments which incorporate public spaces, landscaping, public art and
    „designing out crime‟ initiatives;

   incorporate sustainable construction techniques and design concepts for
    buildings and their layouts to reduce the local and global impact of the
    development particularly on climate change;

   protect the amenity of the area, including residential amenity, in terms of
    satisfactory daylight, sunlight, outlook, privacy and soft landscaping;

   provide for safe and satisfactory access and make a contribution to meeting
    the parking requirement arising from necessary car use;

   demonstrate that existing drainage, waste water and sewerage infrastructure
    capacity is available, and where necessary enhanced, to enable the
    development to proceed;

   ensure where appropriate equality of access and use for all sections of the
    community.

Reasons and Justification

Good design is a key element of sustainable development, so the Council will promote a
high standard of design which is locally distinctive and reinforces the unique character of
its individual settlements. A high quality, well designed, development can enhance the
sense of place and identity of an area and can bring significant benefits to the local
environment and economy. In this way, new development can have a positive impact on
the lives of local people and visitors to the District.

Guidance on those features and characteristics which make the Moorlands so unique
and how design can complement and reflect this will be provided through the Design
SPD.

A Design Statement will be required to accompany proposals for development with
accurate illustration of the proposal and its relationship with its surroundings.

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 and in Secured by Design produced by
the Police.

In order to help identify the characteristics of a site the Council will promote the use of
„Concept Statements‟ for allocated and large unidentified sites. Concept Statements,
developed by the Countryside Agency, are a simple, clear expression of the key of place
that new development should create. They explain how the policies and objectives of
the Core Strategy will apply to a specific site in order to deliver the best possible




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economic, social and environmental benefits. They are less detailed then an SPD but
more informative for developers and the community then A DPD.

Policy DC2 – The Historic Environment

The Council will safeguard and where possible enhance the historic environment
and interests of acknowledged importance, including in particular scheduled
ancient monuments, significant buildings (both statutory listed and on a local
register), conservation areas, registered historic parks and gardens, registered
battlefields and archaeological remains by:

   resisting development which would harm or be detrimental to the special
    character and historic heritage of the District‟s towns and villages and those
    interests of acknowledged importance;

   promoting development which sustains, respects or enhances buildings and
    features which contribute to the character or heritage of an area and those
    interests of acknowledged importance through the use of conservation area
    appraisals, design statements, archaeological assessments, characterisation
    studies and masterplanning;

   preventing the loss of buildings and features which make a positive
    contribution to the character or heritage of an area through appropriate reuse
    and sensitive development unless their retention is not viable or there would
    be substantial planning benefits to outweigh the loss.

Reasons and Justification

The historic environment of Staffordshire Moorlands is a resource for which the District is
renowned. It includes a range of buildings, gardens and structures many of which are
statutorily protected. This policy seeks to ensure that sites and areas of particular
heritage value are both safeguarded for the future and, where possible, enhanced both
for their own heritage merits and as part of wider heritage regeneration proposals.
Conservation areas and buildings that are statutorily listed are protected under national
legislation guidance. Additionally the Council is in the process of adopting a SPD which
will outline procedures for identifying local buildings not statutorily protected but
considered appropriate for retention.

This policy identifies a range of measures which the Council will use to promote
sensitive development which will contribute to the character or heritage of an area and
those interests of acknowledged importance. In addition proposals for sites and areas of
heritage importance, including sites identified under local listing, should adhere to the
design guidance to be set out through the proposed Design SPD and any relevant
Conservation Area management plans.

Policy DC3 – Settlement Setting

The Council will protect and where possible enhance the setting of settlements in
the Staffordshire Moorlands by:




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   identifying and promoting the visual setting and special qualities of the
    District‟s towns and villages through settlement character assessments

   resisting development which would harm or be detrimental to the setting of a
    settlement and important views into and out of the settlement as identified in
    the settlement character assessment;

   promoting development which reinforces and enhances the setting of the
    settlement as identified in the settlement character assessment;

   identifying through the Site Allocations DPD and protecting from inappropriate
    development, areas of visual open space where the intention will be to retain
    the land‟s open and undeveloped appearance. Where appropriate the Council
    will seek public access agreements with the land owners and seek proposals
    for the enhancement or improvement of these areas. In exceptional cases,
    limited development of areas of visual open space may be acceptable where
    this will bring about overriding improvements to the open space itself.

Reasons and Justification

The setting of settlements is considered important to the character of the Moorlands
and the special qualities of its towns and villages. This policy seeks to ensure that
new development respects and reinforces these qualities. Characterisation Studies
are seen as a positive way of identifying and highlighting the importance of an area and
its setting which will form a significant piece of evidence to support both the allocation of
sites in the LDF and the day-to-day control of development.

Visual open space are areas of land which are not essential as „public‟ open space but
which perform valuable functions within towns and villages, for example by forming a
visual break between development, protecting attractive views and enhancing the setting
of a public amenity. Such areas can contribute significantly to the character of
settlements and should therefore be kept free from most development. The
Characterisation Studies will identify such areas.

Policy DC4 - Masterplanning

The Council will prepare, or require to be prepared, masterplans for Leek and
Cheadle town centres and major redevelopment areas to provide a development
framework and indicate principles of good design and locally distinctive areas,
prior to the approval of any significant proposals for these areas.

Reasons and Justification

Masterplanning is a tool for dealing with major change in a defined physical area. They
set out proposals for buildings, spaces, movement and land use in three dimensions and
match these aspirations with an implementation strategy. This policy seeks to promote
the use of masterplanning for the town centres of Leek and Cheadle to ensure that
development opportunities are properly coordinated in a way which will address the
needs, characteristics and context of the area and delivery the necessary projects. The
Council; also wishes to encourage the use of masterplanning for other major



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redevelopment areas to ensure that schemes are visionary, deliverable and properly
integrated with the spatial strategy for the area. Further guidance on the process of
producing masterplans is set out in „Creating Successful Masterplans:a Guide for
Clients‟ available from CABE.




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SUSTAINABLE COMMUNITIES POLICIES

Objective

To deliver sustainable, inclusive, healthy and safe communities.

Responses to Consultation on Issues and Options

-   95% of respondents considered that the Council aim to support community facilities
    in towns and villages. Only 5% disagreed.
-   A wide variety of responses have been made to the question of which ones and
    where, naming a whole range of community facilities such as those used for sport,
    playing fields, meeting places, youth clubs, outdoor activities, town and village halls,
    day centres, church halls, post offices, improved bus services to village facilities,
    greater use of existing facilities at schools and colleges, doctors, schools, leisure
    centres, play groups, play house, cinema, sailing club, mobile services, youth
    centres, adult learning centres, public toilets, swimming pools, theatre, gyms, canals,
    community cafes.
-   Some respondents named specific facilities in specific settlements as follows; village
    hall in Tean, theatre and arts centre in the 3 towns, Leek in particular was mentioned
    several times, facilities in all 3 towns for all age groups, Draycott Primary School as a
    village hall, facilities at Haregate, Biddulph East, Hammersley Hayes, Endon school
    could be used for young people out of hours, community centre in Cheddleton, need
    for Jehovah‟s Witness facility in Cheadle, more retail facilities in Blythe Bridge,
    facilities needed in all towns and villages including those that don‟t presently have
    any. Some respondents mentioned using existing facilities like schools in a multi
    functional way to serve the local community. A comment was made about existing
    community facilities not having enough publicity.

Regional Spatial Strategy Context

-   Relevant policy at a regional level is covered in the existing RSS and Phase 2
    Revision, currently at Preferred Options stage. Policy SR2 – „Creating Sustainable
    Communities‟, part of the revision document, requires local authorities to make
    provision for a full range of spatial requirements needed to create sustainable
    communities such as housing for local need, employment, creation of attractive, well
    designed, adaptable, safe and secure developments, necessary services and social
    infrastructure to meet the needs of the population, a comprehensive green
    infrastructure, necessary public transport infrastructure and environmental
    infrastructure.
-   Policy QE3 in the existing adopted RSS requires development plans to promote the
    creation of high quality built environments and in particular securing high quality
    townscape whilst respecting local character, promoting public art, incorporating
    sustainability considerations such as use of renewable energy, assessing and
    minimising the impacts of noise and light pollution as a result of development,
    creating safer environments which discourage crime and promoting community
    safety.
-   Policies RR3 and RR4 in the existing adopted RSS relate to rural areas in the West
    Midlands. RR3 focuses on the importance of regenerating market towns through
    means such as improving the natural, built and historic environment, improving



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    access to health facilities and encouraging the multi purpose use of land and
    buildings for community purposes. Policy RR4 focuses on rural services in terms of
    improving their range and quality, taking into account the likely implications of new
    development on the provision of services and facilities, including the extent to which
    new development may help to support the provision of local services. The policy
    also covers the need to retain essential community services and to facilitate and
    provide for appropriate new and innovative forms of service delivery.

Officer Comment

Creating sustainable communities, i.e. 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, is a key principle of Government planning guidance and
regional planning policy. It is particularly important in rural areas like the Staffordshire
Moorlands where accessibility to facilities and services by transport modes other than
the private car can be limited.

An overwhelming majority of respondents to the issues and options consultation
consider that the Council should aim to support community facilities in our towns and
villages and a wide variety of examples have been named.

The provision of infrastructure improvements to serve new development through
developer contributions is a long standing planning principle which also assists in
creating sustainable communities along with regeneration of areas and sites in need of
improvement which may no longer be compatible with their surroundings. High quality
design of buildings and layout schemes is a specific way to ensure access to all and
reduce crime and the fear of crime, to assist with the creation of sustainable
communities at a local level.

Policy C1 - Creating Sustainable Communities

In order to create sustainable communities at a local level the Council will:

   Support proposals which protect, retain or enhance existing community
    facilities (including multi use schemes) or provide new facilities. New facilities
    should preferably be located within defined built up areas where they are most
    accessible. In exceptional cases facilities may be located adjacent to these
    areas where it can be demonstrated that this is the only practical option and
    where a site is well related to the existing settlement.

   Safeguard land required for the provision of facilities to meet existing and
    future community needs, as identified by service providers.

   Resist proposals involving the loss of community facilities unless:
     i)    an alternative facility of the same type is available or can be provided in
           an accessible location in the same locality; or
     ii)   a viability appraisal including a marketing exercise by a qualified
           professional demonstrates that there are no options for continued use
           as a community facility which are financially viable in line with the SPD
           AND it can be demonstrated that loss of the facility would not
           disadvantage local residents.


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   Only permit new development where the service, transport and community
    infrastructure necessary to serve it is either available, or will be made available
    by the time it is needed. All development proposals must therefore either
    incorporate the infrastructure required as a result of the scheme, or make
    provision for financial contributions and/or land to secure such infrastructure
    or service provision at the time it is needed, by means of conditions or a
    planning obligation in line with the Council‟s Developer Contributions SPD;

   Support the relocation of uses which are no longer compatible with their
    surroundings due to negative amenity issues such as noise or accessibility
    where an alternative suitable site can be secured, subject to the requirements
    set out in Policy E2 in order to facilitate regeneration;

   Require development proposals to incorporate high quality locally distinctive
    design features and layouts that will reduce crime and the fear of crime and
    support inclusive communities, particularly in terms of accessibility and
    functionality in line with the Council‟s Design SPD;

   Require major new development to be accessible by a choice of means of
    transport.

Reasons and Justification

Creating sustainable communities, i.e. 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, is a key principle of Government planning guidance and
regional planning policy. It is particularly important in mainly rural Districts like the
Staffordshire Moorlands where accessibility to facilities and services by transport modes
other than the private car can be limited.

The vision of the Staffordshire Moorlands Draft Sustainable Community Strategy 2007 –
2020 focuses heavily on achieving an excellent quality of life in the District. The strategy
identifies „supporting the quality of community life‟ as a major strand in order to achieve
the vision. Clearly, availability of and access to services is a major part of this as well as
reducing the fear of crime. Other major strands of the Community Strategy identified to
achieve the vision which relate to the creation of sustainable communities are „investing
in our children and young people‟ and „responding to the needs and aspirations of an
ageing population‟.

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 play an important role in community life in the Staffordshire Moorlands.
The loss of such facilities can have a widespread negative impact on the community,
particularly the old and the young who live in rural areas and may have limited access to
alternative facilities. Access to such facilities for those who live in rural areas is
addressed in Planning Policy Statement 7 „Sustainable Development in Rural Areas‟. In
line with this Government guidance, the policy seeks to support the retention of
community facilities, particularly where their loss would leave gaps in provision and
thereby disadvantage local residents i.e. result in them being unable to easily access a



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similar facility elsewhere. Where an alternative facility of the same type already exists or
the lost facility is replaced in the same locality so that it is accessible to all members of
the community, this could mitigate the loss. Each proposal will be judged on its own
merits. It is recognised that there are occasions where particular uses may become
financially unviable. In such cases, a thorough marketing exercise (in line with the SPD)
must take place and all options for continued use as a community facility (such as a
multi use scheme) must be thoroughly explored.

The policy is supportive of proposals to protect, retain and enhance facilities including
their innovative delivery through the multi purpose use of buildings like schools and
village halls, where the benefits of economies of scale can be realised. Where new
build facilities are proposed, accessibility for all members of the community will be a key
factor in judging the planning application. Suitable land identified by service providers
for the provision of community facilities will be allocated in the Site Allocations DPD.

An important part of creating sustainable communities is the provision of the necessary
infrastructure to serve new development (such as roads, accessibility by public transport,
schools and public open space), where this is lacking. Otherwise, new development can
put a strain on existing facilities and disadvantage both existing and new residents in an
area. This is recognised by the Government as a development cost to be met by the
landowner or developer. Full details of the Council‟s requirements will be produced in an
SPD.

In relevant cases, supporting the relocation of uses no longer compatible with their
surroundings can bring benefits to the local community by allowing more appropriate
development to take place through regeneration. For example, a heavy industrial use
could be replaced by a light industrial use or residential development. Each proposal will
be judged on its merits and where employment land is involved, in conjunction with the
requirements set out in Policy E2.

Good design is such an integral part of a successful development scheme.
Development proposals must incorporate features to minimise both crime and the fear of
crime (in line with the SPD) as this is an issue of concern, particularly amongst older
people in the District. Inclusive design features such as those which allow access to all
should also be part of new development schemes in line with the design SPD.

In accordance with sustainability principles, major new development must be accessible
by a choice of means of transport so that all members of the community are able to
access it.




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TOURISM, CULTURE, RECREATION AND LEISURE POLICIES

Objective

To support and enhance the tourism, cultural, recreation and leisure opportunities for the
District‟s residents and visitors.

Responses to Consultation on Issues and Options

-   In response to whether the Council should aim to protect public open space in the
    towns and villages from development, over 96% agreed and 3% agreed unless there
    is a surplus of open space.
-   In response to whether there should be any exceptional circumstances whereby
    public open space is built on e.g. for affordable housing, 75% considered no. 23%
    considered yes but the majority of these qualified their response with exceptional
    circumstances such as affordable housing, surplus of provision, better provision
    close by, and only if local people agreed. Four respondents suggested building on
    Birchall Playing Fields.

Regional Spatial Strategy Context

-   Policy PA10 states that development plans should generally encourage both the
    improvement of existing provision as well as the creation of new facilities, subject to
    the capacity of infrastructure and the environment. It specifically supports:
        o the Staffordshire Moorlands parts of the Peak Park,
        o Alton Towers,
        o the canal network,
        o significant historic sites, buildings and gardens; and
        o indoor and outdoor sports.
-   Policy QE4 requires local authorities to undertake assessments of local need and
    audits of provision and develop appropriate strategies for greenspace and to create
    and enhance urban greenspace networks.

PPG17 Audit

PPG17 requires local authorities to carry out a full audit of open space across the District
to allow the Council to identify specific needs and quantitative or qualitative deficits or
surpluses of open space, sports and recreational facilities in the area. It also advises
that local authorities should set their own standards of provision for a range of open
space.

The Council has an open space survey which is key to the operation of the current public
open space SPG and has undertaken other studies such as the Playing Pitch Strategy
(2003 - 2018) and the Play Strategy (2007 – 2012). These need to be incorporated into
a full PPG17 audit which will be undertaken in early 2008 to inform the submitted Core
Strategy and a review of the Public Open Spaces SPD.

The types of open space that will be included are:
    Parks and gardens
    Natural and semi-natural urban green spaces



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        Green corridors, including river and canal banks
        Outdoor sports facilities
        Amenity green space
        Provision for children and teenagers
        Allotments
        Cemeteries and churchyards

Tourism Strategy & Staffordshire Destination Management Partnership (DMP)

-   Tourism makes a significant contribution to the local economy and which brings
    benefits to local people through the generation of jobs and support of local services.
-   Need to:
       o develop the „distinctiveness‟ of the District and the three towns;
       o increase overnight visitors who contribute more to the local economy;
       o develop the potential of canals and cycling network;
       o increasing the quality of tourism products and the standard of
            accommodation;
       o balancing need of visitors with the environment and local communities; and
       o improving access to facilities and services for all visitors.

Officer Comments

Open space, including play areas, playing fields or parks are seen as being particularly
important to local residents and should be protected from development. Although the
Council has an open space survey, Play Strategy and a Playing Pitch Strategy, Sport
England state that it is essential that a full PPG17 audit is undertaken

Tourism still plays an important role in the economy of the Staffordshire Moorlands.
Various documents give support to developing the canal and cycling network and also
trying to attract overnight visitors to the Moorlands. Alton Towers still attract large
amounts of visitors to the District and will be dealt with by means of an SPD.

Policy TR1 – Tourism and Cultural Facilities

The Council will support new and existing tourism, visitor and cultural proposals
where they:
 are accessible by a range of means of transport and can be supported by the
   local transport infrastructure;
 of an appropriate quality, scale and character compatible with the local area;
 protect the residential amenity of the area; and
 do not harm interests of acknowleged importance.

Support will also be given to clusters of attractions where they meet the
objectives above and do not result in a cumulative detrimental impact.

Particular support will be given to developing;
        the potential of the canal network;
        the potential of the cycling network;
        the evening/night-time economy; and



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             high quality tourist accommodation particularly where this will increase
              the range of size and type.

In addition:
 New tourism attractions attracting large numbers of people should be located
    in highly accessible locations, and preferably within the towns unless the
    attraction requires a countryside location or setting.

   Outside the development boundaries of settlements new tourist
    accommodation will:
       o of a scale which can be easily accommodated into the local landscape
           in a sustainable manner;
       o in exceptional circumstances be of a non-permanent nature e.g. log
           cabins; or
       o be limited to the conversion of existing buildings (in accordance with
           other policies in the Core Strategy).
    Within the Green Belt new tourist accommodation will be limited to the
    conversion of existing buildings only.

   Outside the Green Belt permission will be granted for sites for camping and
    touring caravans provided they are well screened, sited and designed and
    have good access. Small camping sites may be appropriate in the Green Belt
    provided they do not prejudice the „openness‟, there is appropriate screening
    and any necessary facilities can be accommodated within existing buildings.

The Council remains supportive of the continued development of Alton Towers
subject to it being accommodated satisfactorily within the natural environment
and being supported by adequate transport infrastructure and accessible by a
range of means of transport. Detailed development considerations will be
provided by a separate SPD.

Reasons and Justification

This policy positively supports the important role that tourism plays in the economy of the
Staffordshire Moorlands. It is essential that all new tourism, visitor and cultural
proposals that are located outside settlement boundaries should be in sustainable
locations and carefully assessed so that they do not have a detrimental impact on the
local area. Support is also given to clusters of attractions where they do not result in a
cumulative detrimental impact. Clusters of attractions offer linked trips, employment
opportunities and can also support other means of transport to the car.

The areas listed in part three of the policy as needing particular development are
supported by strategies such as the Tourism Strategy and the Staffordshire Destination
Management Partnership (DMP) Structure and Delivery Programme 2005 – 2008.
Development of the canal and cycling networks are also identified in the RSS.

Existing tourist accommodation in the Staffordshire Moorlands is generally small scale
family-run businesses, usually rurally located, often in converted buildings. The area
has a relatively high proportion of self-catering types of accommodation and very few
hotels and serviced accommodation. At present a very low proportion of visitors to the



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Moorlands stay overnight and supply is particularly low in the three towns. Particular
attention should be made to the quality of new tourist accommodation.

Outside settlement boundaries new tourist accommodation will be limited to the
conversion of existing buildings and in exceptional circumstances non-permanent
buildings meaning that the landscape can be returned to its previous state. Sites for
touring caravans and camping sites will be granted providing they meet the criteria set
out in the policy. Within the Green Belt stronger controls are necessary however in
order to preserve their openness.

Alton Towers is a major attraction and its growth has brought economic benefits to the
area. However, this needs to be balanced with conserving the landscape and heritage
of the site and its buildings, protecting the amenity of residents living close to the park
and addressing the impact on the surrounding road network. Policy SS8 identifies the
need for a link road from Alton Towers to Denstone to relieve the traffic in this area.
Detailed development considerations to address these issues will be provided by a
separate Supplementary Planning Document.

Policy TR2 – Sport, Recreation and Open Space

The Council will promote 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, in accordance with the adopted minimum
standards set out in the SPD.

Where there is a proven deficiency, qualifying new residential development will be
expected to make provision, or a contribution towards provision of open space
which is necessary and reasonably related in form and scale in accordance with
the adopted minimum standards set out in the SPD.

In addition:
 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 or that it does not
    result in a deficiency. Sites over 0.2 ha will be identified in the Site Allocations
    DPD.

   New sport, recreation and open space facilities should:
     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; and
     not harm interests of acknowledged importance.

   Applications to improve the use and availability of existing outdoor sports and
    recreation provision such as the introduction of ancillary facilities such as




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    changing rooms, artificial surfaces or floodlighting will be permitted provided
    that they :
            are directly related to the needs of the facility;
            can be satisfactorily and economically serviced; and
            meet the above criteria for new sport, recreation and open space
                facilities.

Any of the above development should be consistent with the Councils Sports and
Physical Activity Strategy.

Reasons and Justification

Open space in the Staffordshire Moorlands is important to both residents and visitors
and this policy promotes and safeguards the many types of open space. The outcome
of the PPG17 audit will inform decisions on the quantity, quality and accessibility of
recreational open space provision and a review of the SPD.

The Council will use the local space standards in the SPD as 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.

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. The Council also supports the improvement of existing facilities
in order to increase their use and availability such as changing facilities and floodlighting.
Again these need to be carefully assessed so that the scale is directly related to the
needs of the facility, they do not have a detrimental impact on the residential amenity of
the area and do not impact on the „openness‟ of the Green Belt.




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RURAL POLICIES

Objective

To maintain and promote sustainable rural areas and communities settlements with
access to services for all.

Responses to Consultation on Issues and Options

- 5% of respondents said that rural buildings should not be allowed to be converted to
  residential.
- 8% said residential should be permitted in all/any circumstance and 2% said normally/
  in most circumstances. 6% said it needs to be controlled/special circumstances/
  exceptional circumstances/ all other options considered/ as a last resort. 10% felt that
  residential conversion would be appropriate in certain circumstances such as to meet
  local need/should be main residence/ controls on price so local people are not priced
  out/ permanent residence. 6% said to bring back into use a rural building which is run
  down/derelict/empty or in need of repair. 6% said to meet local need or provide
  affordable housing. 6% said where it would safeguard a building of particular merit
  and/or a listed building.
- 9% of respondents felt that residential use was only appropriate when commercial
  use is no longer viable or the building is no longer suitable for commercial use. 6%
  said that residential use should be permitted where there is no longer a need for the
  current use/ agricultural use. 5% said it depends on location/associated traffic issues/
  existing community issues and 9% said subject to design issues/quality conversion/in
  keeping with locality/keeps the character of the building and 4% to support farming.
  2% said there was a need to considered natural environment and 2% said that the
  conversion should not be for use as second homes. 2% said the decision should be
  made on a case by case basis. The above are the most common responses to the
  question there were a number of other responses received.
- There was a very mixed response to whether the priority should be for re-use for
  commercial use there were more definite no‟s than yes‟ to this question (40% said no,
  23% yes) a further 10% were supportive of commercial re-use as long as the use is
  appropriate to the rural area. 4% said commercial re-use is a possible use but did not
  see it as being a priority. A further 4% said that it should be decided on a case by
  case basis. The above are the most common responses to the question there were a
  number of other responses received.

Regional Spatial Strategy Context

-   Preferred Option RSS Review requires LDF‟s to support sustainable diversification
    and development of rural economy through the growth of existing businesses and
    the creation of new development of rural economy through the growth of existing
    businesses and the creation of new enterprises. There is a need to conserve and
    enhance environmental assets and respect local character and distinctiveness, and
    create viable and sustainable local communities. Priority should be given to
    economic activity with strong links to the rural area e.g. food and drink processing,
    tourism and leisure, environmental economy and businesses that are ancillary to
    farming and forestry and to sustainable new activity which will strengthen and
    diversify the Region‟s rural economy. Encouragement to be given to the


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    development of business using ICT, including increased opportunities for home
    working.
-   Need to recognise the importance of agricultural sector – include positive policies to
    promote agriculture and farm diversification. Innovative business schemes including
    sustainable tourism, environmentally sustainable farming, forestry and land
    management, new and innovative crops. Any development should be appropriate in
    scale and nature to the environment and character of the locality.
-   With regard to meeting rural affordable housing needs RSS states, “in rural areas
    and small rural settlements …consider the option of allocating sites as 100%
    affordable housing” and “promote the use of rural exception sites”
-   Identify areas where the development of sustainable tourism can be encouraged in
    suitable locations where there is access to public transport and where it can
    contribute to regeneration. Whilst doing this authorities should consider the
    cumulative of such development on tourism and environmental assets (including
    biodiversity), character, infrastructure and local economy of each area, and on the
    needs of local residents based on this it may in some instances be necessary to limit
    development to particular types and scales of tourism. (Policies PA14 and PA15)
-   From the existing RSS Policy RR1: Rural Renaissance, which is not part of the
    Phase 2 Revision, the need for rural areas to regenerate is recognised and that this
    will take place through, „improvement of choice in housing; the diversification of the
    rural economy; better transport links both within rural areas and between urban and
    rural areas; improving health, education, skills training, social, shopping, community
    facilities and other services, the sustainable use of environmental assets, and the
    prudent use of natural resources.‟ There is an acknowledgement that policy priorities
    will vary due to factors such as „quality of the environment, local character and
    distinctiveness, need for new employment, need for additional housing, including
    affordable housing, to meet local needs and stem population decline, and access
    services and facilities.‟

Officer Response

There is a particular need in the District to support the rural economy, enable farm
diversification and support rural communities. Re-use of rural buildings is a particularly
important issue in the District and therefore clear policy guidance is essential. The
responses received raise a number of challenges that need to be addressed in terms of
ensuring that such buildings are appropriately re-used and particular local circumstances
are addressed such as safeguarding buildings of particular merit and meeting local
housing needs. National guidance, PPS 7, identifies the re-use of rural buildings for
economic development purposes usually being preferable but acknowledges that
conversion to residential use may be more appropriate in some locations and for certain
types of buildings.

Policy R1 – Rural Diversification

All development in the rural areas outside the settlement 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.




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Appropriate development should not harm the rural character and environmental
quality of the area by virtue of the scale, nature and level of activity involved and
the type and amount of traffic generated or by other effects such as noise and
pollution.

Wherever possible development should be within suitably located buildings which
are appropriate for conversion. Where new or replacement buildings are involved,
development should have minimal impact on the countryside and be in close
proximity of an existing settlement.

Within the Green Belt, inappropriate development which is otherwise acceptable
within the terms of this policy will still be need to be justified by very special
circumstances.

In addition, the Council will seek to maintain and support the rural areas by the
following measures:

     Resisting development that would result in the loss of an essential service
      and/or facility unless the criteria in policy C1 have been met.

     Supporting new community facilities which meet a demonstrated local need,
      which cannot be met in the identified larger or smaller settlements and which
      accord with policy C1.

     Supporting development which contributes to the wider rural economy
      particularly development of land and food related businesses (e.g. forestry
      and timber, local food businesses, energy crops), sustainable tourism
      facilities and recreation related to the enjoyment of the countryside.

     Giving priority to the re-use of rural buildings for commercial enterprise where
      the location is sustainable and the proposed use does not harm the buildings
      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, it is in close proximity of an existing settlement and would not
      undermine other tourism enterprises. All proposals for the re-use of rural
      buildings will be expected to be in accordance with the SPD.

     Supporting proposals for farm diversification providing they are
      complimentary to and do not prejudice the agricultural operations on the
      holding.

     Supporting opportunities for live/ work or enable home working that minimise
      the need to travel and makes efficient use of land.

     Supporting the limited expansion or redevelopment of an existing business for
      employment uses provided that it would not cause unacceptable harm to the
      countryside or prejudice other rural needs.

     Supporting horse riding and other equestrian activities providing they are
      closely related to an existing dwelling or farm and will not have a detrimental



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    impact on the character and quality of the landscape either in isolation or
    cumulatively. All such development will be expected to be of a scale and
    nature appropriate to the area.

Reasons and Justification

The need for rural areas to be able to meet their economic and community needs is
recognized as an important issue in both the West Midlands Regional Spatial Strategy
(RSS) and national planning guidance. The RSS recognises strengthening the rural
economy and enabling sustainable diversification as a key priority for the region. There
is a particular need in the District to support the rural economy, enable farm
diversification and support rural communities whilst at the same time protecting the
countryside from inappropriate development. The Staffordshire Moorlands draft
Community Strategy recognizes that “We should make best use of the opportunities for
economic development within our district without prejudice to our major employers or our
environment and quality of life” with one of its five themes being “enhance conditions for
business growth and sustainability.”

In line with national guidance Planning Policy Statement 7, the West Midlands RSS and
the draft Staffordshire Moorlands Community Strategy Policy R1 sets out the criteria for
economic, community and recreation development that the Council will be supportive of
in rural locations and the need for such development not to have a detrimental impact on
rural character or environmental quality.

Equestrian related activities are recognized as an important economic and recreational
activity in the Staffordshire Moorlands however it is also acknowledged that if
development associated with such activities is not adequately controlled through
planning policy it can have a detrimental impact on the landscape. Policy R1 therefore
expects that such development should be closely related to an existing dwelling or farm
and that the impact of such a development needs to be considered not just on its own
but also the cumulative impact on the landscape if there are already stables and other
associated equestrian facilities in close proximity to the proposed site.

Policy R2 – Rural Housing

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 boundary of the town and the villages:

  Housing development where it is for affordable housing or to meet an
   identified local need which cannot be met elsewhere in accordance with policy
   H2.

  A new dwelling that is essential to accommodate an agricultural or forestry
   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 elsewhere.

  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



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     the existing size and mass of the dwelling) or result in the loss of a building
     which is intrinsic to the character of the area.

  Extensions to existing dwellings provided they are appropriate in scale and
   design, and do not have a detrimental impact on the existing character of the
   rural area.

  The conversion of non-residential rural buildings for residential use where:
   o the building is suitable for conversion; and
   o it can be demonstrated that agricultural or commercial use is not viable. In
      such cases there will be a requirement for a marketing exercise to be
      carried out by a suitably qualified professional in accordance with the
      SPD; and it is either
   o for affordable housing or to meet an identified local need which cannot be
      met elsewhere; or
   o conversion to residential use would enable a building of particular merit to
      be safeguarded.

     In addition, all proposals for the re-use of rural buildings will be expected to
     be in accordance with the SPD.

Reasons and Justification

Policy R2 places particular importance on identifying and safeguarding local character. A
building can, over time, become something which is associated with a locality and which
makes a valuable contribution to a unique sense of place. Policy R2 recognises the
importance of development control decisions in protecting such buildings and the
importance of decisions being made on a case by case basis with regard to the
appropriateness of residential extensions and replacement dwellings in order that
buildings which are intrinsic to the unique character of a rural area are safeguarded.

Policy R2 recognises that the re-use of rural buildings for commercial purposes is
preferable to that of residential uses in line with Planning Policy Statement 7 and sets
out the criteria for the re-use of these buildings. It takes account of local circumstances
and the need to safeguard rural buildings that are judged to be of particular merit in
terms of architectural, historical importance or their contribution to local character in
accordance with Planning Policy Statement 7. It provides policy recognition that in
certain circumstance agricultural or commercial use may no longer be financially viable
for a rural building and places a requirement for this to be demonstrated through a
marketing exercise in accordance with the Supplementary Planning Document. If this is
successfully demonstrated then conversion for residential use will only be acceptable
where it meets the local need criteria set out in the policy or where conversion to
residential would enable a building of particular merit to be safeguarded. This is to
ensure that, due to the large number of rural buildings, residential conversion is not
permitted where it would undermine the overall development approach for the District in
terms of creating an oversupply of housing in a particular locality.




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NATURAL ENVIRONMENT POLICIES

Objective

To protect and improve the character and distinctiveness of the countryside and the
diversity of wildlife and habitats

Responses to Consultation on Issues and Options

-   To protect and improve the countryside and the diversity of wildlife habitats is a
    particularly important issue in the District with it emerging as one of the strongest
    priorities respondents to the questionnaire along with 3 (develop the economy), 4
    (provide housing that is affordable, desirable and meets needs, 5 (ensuring vitality
    and viability of the towns), 8 (promote local distinctiveness) and 9 (protect and
    improve countryside).
-   87% felt that there are areas of the Staffordshire Moorlands countryside that require
    extra protection, 9% said no. Other responses included: current legislation meets
    requirements; the best protection is to let people live in the areas to improve, care,
    manage and maintain such areas; do not know but it must be remembered that
    people should come first.
-   A variety of areas were suggested to question 34 those which were suggested the
    most frequently were the Churnet Valley, Hales Hall, Green Belt, Caldon Canal,
    Biddulph West (Congleton Edge to bypass) Whitmoor, Newpool Meadows, The
    Roaches (although within the jurisdiction of the Peak District national Park for
    planning matters) and areas on the edge of Leek (Mount Road, Highfield Road,
    Macclesfield Road).

Regional Spatial Strategy Context

-   RSS Phase 3 will include rural areas and significant environmental issues and is
    timetabled to be submitted to the Secretary of State in early 2009. The existing RSS
    states that „Local authorities and other agencies, in their plans, policies and
    proposals should conserve, enhance and, where necessary, restore the quality,
    diversity and distinctiveness of landscape character throughout the Region‟s urban
    and rural areas‟ (Policy QE6).
-   Policy QE7 states that Local Authorities in their plans and programmes should
    encourage the maintenance and enhancement of the Regions biodiversity. Priority
    should be given to the protection and enhancement of species and habitats of
    international, national sub regional (identified in the West Midlands Regional
    Biodiversity Audit), Local Biodiversity Plans (LBAPs) and other BAPs, those which
    receive statutory protection and the biodiversity enhancement areas shown within
    the RSS QE Areas of Enhancement Diagram. Policies need to be included which
    enable BAP UK and local targets to be met.
-   Also, it identifies the need for a common approach to be taken to biodiversity and
    nature conservation issues which cross local authority boundaries and regional
    boundaries. RSS identifies most of the Moorlands as an Area for Concentrated
    Biodiversity Enhancement. It states that in such areas ecological integrity should be
    reinforced by: a) supporting existing biodiversity and landscape enhancement
    projects; b) buffering habitat units from adverse impacts; c) restoring and recreating
    locally characteristic habitats; d) expanding and linking isolated habitat units; and e)



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    promoting social and economic benefits by investing in linked facilities for
    sustainable access, enjoyment and education, and in businesses that contribute to
    and capitalise on a high quality natural environment.

Officer Comment

The Staffordshire Moorlands landscape is one of the Districts greatest assets and this is
clearly reflected in the questionnaire responses. There has been a move away in
national guidance from having blanket designations to having more locally based
assessments of landscape character.

Protecting, conserving and enhancing the Districts assets whilst at the same time
meeting the growth levels in the RSS is a major challenge that faces the District,
however, it is one that can be effectively balanced/ managed through appropriate policy.

The District has a wealth of biological and geological resources that it is essential that
the core policies identify and address in terms of protection and enhancement of such
resources in line with the RSS. The RSS identifies a large portion of the Staffordshire
Moorlands as being an Area for Concentrated Biodiversity Enhancement and this needs
to be recognised within the core policies.

Policy NE1 – Biodiversity and Geological Resources

The biodiversity and geological resources of the District will be protected and
enhanced by positive management and strict control of development as follows:

    protecting the integrity of European sites in and near the District in
     accordance with their conservation objectives.

    protecting and enhancing designated sites of national and local biodiversity
     and geological importance. Meeting the objectives and targets in the UK and
     Staffordshire Biodiversity Action Plan.

    protecting ancient woodland and veteran trees.

    supporting opportunities to improve site management and increase public
     access to wildlife sites.

    ensuring development where appropriate produces a net gain in biodiversity,
     and ensuring that any unavoidable impacts are appropriately mitigated for.

    ensuring that development retains, protects and enhances features of
     biological or geological interest, and provides for the appropriate
     management of these features.

    Supporting RSS objectives for the Area for Concentrated Biodiversity
     Enhancement (BEA)




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Reasons and Justification

The District has a wealth of biological and geological resources as defined in Planning
Policy Statement 9. It is essential that the core policies identify and address this in terms
of protection and enhancement of such resources in line with the RSS and national
government guidance.

Much of the District is covered by national and local nature conservation designations.
National guidance in the form of Planning Policy Statement 9 requires that Council‟s take
an integrated approach to planning for biodiversity and geodiversity when preparing local
development documents. These documents should reflect and be consistent with,
national, regional and local biodiversity priorities and objectives (including those agreed
by local biodiversity partnerships) with a hierarchy of sites having been identified in
national government guidance. These sites are protected under separate legislation with
ODPM Circular 06/2005 outlining how statutory obligations impact within the planning
system and policy N1 will seek to reinforce their protection through the planning process.

The RSS identifies a large portion of the Staffordshire Moorlands as being an Area for
Concentrated Biodiversity Enhancement (BEA) and this needs to be recognised and
supported. Development needs to have regard to the guidance contained in the RSS.
The Staffordshire Moorlands Biodiversity Enhancement Area (BEA) has important
concentrations of: acid grassland, lowland calcareous grassland, neutral grassland,
lowland meadows, broadleaved/mixed/yew woodland, upland heathland, blanket bog,
and upland mixed ashwoods.

The Staffordshire Biodiversity Action Plan (BAP) identifies action plans for 28 priority
species and 15 habitats across the County and sets out targets for improvement. The
Council has a duty to further the interests of biodiversity in its area this includes ensuring
that a more proactive approach is taken to biodiversity within development. Most forms
of development will be expected to produce a net gain in biodiversity. The types of
developments which may not be expected to do so are those where it would not be
practicable such as town centre retail developments.

Policy NE2 – Natural Landscape

The distinctive qualities of Staffordshire Moorland‟s natural landscape will be
protected and enhanced by:

    ensuring that development respects and enhances the landscape character of
     the area as identified through the Landscape Character Assessment.

    resisting development which would be likely to impact detrimentally on the
     landscape qualities, views and features of such areas.

    supporting opportunities to positively manage the landscape and use
     sustainable building techniques and materials which are sympathetic to the
     landscape.




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    ensuring that necessary large infrastructure schemes (such as
     telecommunications and renewable energy schemes) are carefully assimilated
     into the landscape

    giving particular consideration to development adjoining or near the Peak
     District National Park to ensure that it does not impact detrimentally on it‟s
     natural beauty and special character.

Reasons and Justification

The Staffordshire Moorland‟s natural environment is one of the District‟s greatest assets
and the need for it to be protected is recognised within the Staffordshire Moorlands Draft
Community Strategy 2007-2020. National guidance set out in Planning Policy Statement
(PPS) 7 identifies the need for Council‟s to produce policies that maintain and enhance
the value of the countryside. There has been a move away in national Government
guidance from „blanket‟ local landscape designations in favour of locally based
Landscape Character Assessments. The Council will prepare a Landscape Character
Assessment in order to identify character features in the District which should be used to
inform planning decisions. Staffordshire County Council has carried out a Landscape
Character Assessment „Planning for Landscape Change: Supplementary Planning
Guidance to the Staffordshire and Stoke-on-Trent Structure Plan 1996-2011‟ for the
entire county and this should be consulted in the period before the Council has prepared
its own Landscape Character Assessment.

Policy N2 provides protection for landscape features, qualities and views that can make
a valuable contribution to the landscape quality. This will be achieved through resisting
development that would have a detrimental impact on landscape features, qualities and
views. Hedgerows and dry stone walls are examples of the types of landscape features
this policy seeks to protect.




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TRANSPORT POLICIES

Objective

To reduce the need to travel or make it safer and easier to travel by more sustainable
forms of transport

Responses to Consultation on Issues and Options

-   Over 84% of respondents considered that major development should incorporate
    measures to encourage more sustainable patterns of transport such as walking,
    cycling and public transport
-   Common comments include that new development should integrate cycle lanes/bus
    routes; that bus services should be improved, new rail facilities across the District
    etc.

Regional Spatial Strategy Context

-   The RSS Review contains a number of policies geared at promoting sustainable
    transport. Policy T1 states that access within the Region will be improved in a way
    that “reduces the need to travel, expands travel choice, tackles congestion, improves
    safety and protects the environment.” This will be achieved by measures to improve
    accessibility in non-MUA urban and rural locations so that more sustainable means
    of travel are encouraged and also measures to improve strategic road and rail
    networks in the interests of the national economy. In particular Policy T5 promotes
    an integrated hierarchy of public transport outside MUAs with priority given to
    improvements of services/interchanges in urban areas and links to catchments. In
    rural areas new services should link rural hinterlands to key local service centres.
-   Policy T2 states that LPAs should work with other agencies to reduce the need to
    travel, especially by car, and reduce journey lengths; for example through linking
    travel generating developments to more accessible locations and transport nodes.
    Policy T2 also states that authorities should reduce the need to travel, especially by
    car, and reduce journey lengths, including by “encouraging the use of
    telecommunications for the purposes of business and for other service provision”.
-   Policy T3 states the ways in which walking and cycling should be promoted, and
    parking standards and traffic management is covered by T7.


Local Transport Plans (LTP)

The majority of the Staffordshire Moorlands is covered by the Staffordshire LTP 2006-
2011. The North Staffordshire LTP covers the administrative areas of Stoke-on-Trent,
urban Newcastle-under-Lyme and the Parishes of Brown Edge, Endon and Stanley,
Bagnall, Werrington, Caverswall and Forsbrook within the Staffordshire Moorlands.
The main transport priorities in the Staffordshire LTP are better accessibility, creating
safer roads, and effective and efficient highway maintenance. Other important issues
detailed in the Plan, include reducing the impact of traffic and improving air quality. In
the Staffordshire‟s LTP 2006-2011 rural isolation is recognised as an important issue.




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Staffordshire‟s 2006-2011 Bus Strategy complements the LTP and attempts to improve
social inclusion in rural areas. The County also work with an established Rural
Transport Partnership for West Derbyshire/North Staffordshire. This aims to promote
social inclusion and tackle rural isolation through improvements to transport provision
and access to services.

The aims of the North Staffordshire LTP are similar to the Staffordshire LTP aims, with
additional aims of supporting regeneration efforts, reducing fear of crime, and enhancing
quality of life in the conurbation. These aims translate to objectives which informed the
production of the “North Staffordshire Integrated Transport Study” (NSITS) – a long term
framework for transport planning in the conurbation.

The North Staffordshire Community Rail Partnership (NSCRP), with members from the
North Staffordshire Rail Users Group and local authorities, has been established to
promote the Crewe-Stoke-Uttoxeter-Derby rail service with the aim of increasing
patronage levels.

Officer Comment

Reducing the need to travel, and reducing the reliance on the car, is a well established
planning principle stemming from international obligations at combating climate change
(reducing vehicular emissions); and of addressing social equity (ensuring physical
accessibility to all sections of society). This has fed down into both national and regional
policy.

It is considered that there is potential in affecting modal shift away from the car in two
respects: - by targeting public transport improvements along the main „work corridors‟
connecting the Moorlands with conurbation; and – by promoting public transport
schemes within rural areas / between rural areas and towns. It would appear that the
LTP funding streams work in a reactive manner to existing population distributions,
whereas the Council must decide where future population is distributed. It is important
that strategic planning decisions are not purely based on the location of existing public
transport infrastructure. For this reason the below policies are proactive in seeking
improvements to the existing network.

Policy T1 – Development and Sustainable Transport

The Council will promote and support development which reduce reliance on the
private car for travel journeys, reduce the need to travel generally and help deliver
more sustainable settlement patterns. This will be achieved by:

   Ensuring that all new development is located where the highway network can
    satisfactorily accommodate traffic generated by the development or can be
    improved as part of the development;

   Ensuring that major development is located in areas that are accessible by
    sustainable travel modes or can be made accessible as part of the proposal;

   Adhering to maximum parking standards as laid out in national and regional
    guidance; proposals not achieving their respective maximum standard will be



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    approved provided in the Council‟s opinion this would not give rise to
    (individually or cumulatively), highway danger

   Ensuring that buildings, streets and public spaces are designed to be safe and
    accessible to all users

   Where appropriate all new development shall facilitate walking and cycling
    within neighbourhoods and town centres, and link with or extend identified
    walking or cycling routes and Active Travel Routes

Development which generates significant demand for travel or is likely to have
significant transport implications will, where appropriate:

•   contribute to improved public transport provision

•   provide proactive facilities and measures to support sustainable transport
    modes including on-site features to encourage sustainable travel methods e.g.
    active travel routes, cycle path links, cycle storage facilities, bus stops etc

•   actively promote green travel plans

Reasons and Justification

This policy reflects national transport planning policy and the emerging RSS regional
transport policy which seek to deliver a system that supports sustainable transport
through the integration with land use planning at all levels, so that transport and planning
work together to support more sustainable travel choices and reduce the need to travel.
 Reducing the need to travel, and reliance on the car, is linked to social equality, through
making developments equally ‘accessible’ to all sections of society.

The approach embodied in this policy will seek to manage travel demand in an effective
and sustainable way, while improving the range of choice and responding to the needs
of residents, workers and visitors.

The Council will continue to work closely with the Highway Authority to ensure the
coordination of proposals within the LDF and the Local Transport Plan. The location of
development and the way that development is carried out are important factors in
helping achieve the priorities of the Local Transport Plan. Choices about where new
housing and employment uses are located for example, and patterns of travel that result,
will be important factors in helping to reduce reliance on the private car. Encouraging
alternative forms of travel and securing access to the most sustainable modes of travel
such as public transport, walking or cycling, represent approaches which aim to help
achieve a new balance between non motorised transport, public transport and private
car use.

This approach also reflects the Council‟s Corporate Plan priority to promote improved
health and protect the environment. The Council will aim to ensure as far as possible,
development minimises traffic problems and maximises the potential benefits of
accessibility and new infrastructure to the wider community.




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The Council will require new developments to meet specified parking standards, details
of which will be established through the RSS review.

It is important that major new developments help to mitigate any adverse impacts they
may otherwise have on transport and travel. Where appropriate, S106 planning
obligations will be used to ensure that such developments provide for related transport
improvements and fund other appropriate mitigation measures.

Policy T2 - Other Sustainable Transport Measures

In line with priorities set out in the RSS Regional Transport Strategy and the
Staffordshire Local Transport Plan, and through working with partner
organisations, the Council will encourage and support measures which promote
better accessibility, create safer roads, reduce the impact of traffic, or facilitate
highway improvements. In particular, the Council will:

   support, subject to feasibility assessment, new road schemes within the
    District where:
    o there would be evidence to suggest positive impact and need for the
       scheme; and
    o it would be in accord with the general objectives and policies of the
       RSS/LTP

   support strategic infrastructure improvements and links to major urban areas
    for example to road, rail, bus facilities in the District; and support the
    development of new rail or bus termini within the District

   continue to safeguard all existing disused railway lines within the District and
    support the reuse of these for public or commercial/tourism use. To this end
    the Council will refuse any development which would impede/truncate these
    routes. However applications for recreational routes, cycleways, bridleways
    etc will generally be acceptable.

   work with its partners to promote the improvement/expansion of existing bus
    services and the provision of innovative sustainable transport services in the
    District, particularly those serving rural areas;

   support and promote the development of a network of safe walking and
    cycling routes (including the National Cycle Network), connecting to transport
    interchanges, linking communities and recreational areas.

Reasons and Justification

A major issue for the District has been the inadequacy of the alternative modes of travel
and in particular the public transport system, both in terms of frequency, and the number
of routes.

There are strong „cross-border‟ workforce links with the Stoke conurbation (about 15.4%
of daily work-journeys into the Moorlands are from the conurbation and about 26.8% of
the Moorlands resident workforce work in the conurbation). The District also has high



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car use and low public transport use. There is only one railway line at Blythe Bridge, on
the (Crewe-)Stoke-Derby line. The overall rate for all walk-to work journeys is only
0.56% (into/within/out of the Moorlands). However the equivalent figure for those who
work in the Moorlands (which includes those who already live in the Moorlands) is
significantly higher, at 13.08%. This probably indicates that many of those Moorlands
residents who also work in the Moorlands, perhaps work in the same settlement; as all
district settlements are relatively small - facilitating „walk to work‟ over a short distance.

The above analysis would suggest there is potential in affecting modal shift away from
the car in a number of ways - by targeting public transport improvements along the main
„work corridors‟ connecting the Moorlands with the conurbation; by promoting public
transport schemes within rural areas / between rural areas and towns; and by facilitating
walking and cycling within settlments. This will also help to support healthy, inclusive
and sustainable communities as well as reducing the impacts of travel.

IWhereas the LTP funding streams work in a reactive manner to existing population
distributions, the LDF must decide broadly where future population is distributed. It is
important that strategic planning decisions are not purely based on the location of
existing public transport infrastructure, or predicted locations of funding. For this reason
Policy T2 is proactive in seeking improvements to the existing road/bus/rail networks
generally. Additionally, the Council will exploit opportunities for new road schemes
which are not identified in the LTP, provided these are feasible, and subject to available
finance.

Policy T3 – Telecommunications and ICT

The Council will support and encourage the use of telecommunications and ICT
where this will improve connectivity of the population and reduce the need to
travel. Any associated development must be sited, designed and landscaped so
as to minimize its visual impact.

Reasons and Justification

PPG13 and PPG4 support greater use of electronic communications, and also promote
home-working (where this would not impact on neighbour amenity). Homeworking can
reduce the need to travel for work trips, or can reduce the frequency of journeys.
Anecdotal evidence also suggest it can „free-up‟ the time a journey is made, thus
lessening the impact of rush hours.

The introduction of ICT into not only homes but public facilities such as libraries,
provides information and opportunities into even the smallest of communities. This links
with Community Strategy ambitions including “to ensure that everyone who wishes has
access to services [and] learning opportunities…in a way that is effective and
sustainable”; and “that everyone is able to learn, train and develop throughout their
lives”. Much work carried out by telecoms/internet companies involving the laying of
wires etc is „permitted development‟ already. However there may be cases where
associated development that requires permission must be carefully considered for their
appropriateness, especially in rural locations. For example telecoms masts must be
assessed against not only rural policies but also PPG8, and other considerations.




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APPENDIX A




Diagrammatic Representation
of the Preferred Option




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                                            APPENDIX B - SUMMARY OF PROPOSED DEVELOPMENT LEVELS



Sub-area                                               Housing                                Employment                 Retail
                       2006 – 2026              Annualised   Amount to   Affordable   2006 – 2021 Requirement   2006 – 2016
                       Requirement              development be Allocated Housing                                Requirement
                                                Rate                     Target
                                                                                                                2,975m2 convenience,
                                                                                                                9,204 m2 comparison,
Leek                   1800                     90           1051         450         5.4 hectares
                                                                                                                7,186 m2 bulky goods
                                                                                                                comparison.
                                                                                                                AAP Proposals
Biddulph               1200                     60           929          400         3.6 hectares

                                                                                                                2,564m2 convenience,
                                                                                                                2,945 m2 comparison,
Cheadle                1500                     75           1336         550         3.6 hectares
                                                                                                                2,882 m2 bulky goods
                                                                                                                comparison.

Rural                  1500                     75           813          300         5.4 hectares


DISTRICT
                       6000                     300          4129         1700        18 hectares
TOTAL




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APPENDIX C – REPONSES FROM SPECIFIC CONSULTATION BODIES AND
GROUPS/FORUMS

Advantage West Midlands

Need to take into account the emerging revised West Midlands Economic Strategy. The
main relevant component, „place‟ identifies developing sustainable communities,
regenerating our most deprived communities, maximising our cultural offer and natural
assets, improving transport and accessibility and ensuring a sustainable portfolio of land
and property as key components of a thriving economy. Examples of sub-regional
implications for Staffordshire are:

      Promoting and investing in the physical assets of Staffordshire to develop vibrant
       and sustainable town centres, market towns and surrounding rural villages.
      Promoting the importance of raising both design standards and sustainable
       construction techniques in the built environment and creating a positive image for
       the sub-region.

The key roles market towns play in regenerating rural areas is recognised in the West
Midlands Economic Strategy (WMES). The document also recognises the need to
diversify and regenerate the rural economy and improve infrastructure and accessibility.
There is a requirement for the provision of a balanced portfolio of employment land to
meet the needs of the regional economy and to develop where possible on brown field
land.

Option 1 most fully accords with the WMES – sustainable locations, accessible.
Regeneration opportunities especially on brown field land under option 4 should also be
considered, where they represent a sustainable solution. In terms of village viability it is
recognised that some development appropriate in scale and nature may be required in
village locations.

In terms of employment sites, an appropriate supply of employment land in the right
location is required whilst increasing re-use of brown field land. In rural areas like the
Moorlands in order to be sustainable, it is likely that new employment sites will be
smaller in size and mainly located in the market towns on brown field sites where
possible. Existing employment sites should be retained where they remain suitable and
are accessible.

Support re-use of rural buildings for alternative commercial uses but those in more
remote locations or with limited access may be more suitable for housing.

In order to meet targets set out in the Energy White Paper, policies need to encourage
proposals for the use of renewable energy resources. This should be a high priority.
Minimising energy demands from new developments is also required. A sustainability
checklist for the West Midlands is available.

The WMES aims to improve transport throughout the region, including a greater use of
public transport, cycling and walking. Major developments should produce detailed
travel plans showing how more sustainable patterns of transport would be incorporated
into their schemes.



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English Heritage

In developing the policy framework for the Core Strategy it is vital that the historic
environment is broadly defined. Conservation and archaeological staff should be
involved throughout the preparation of the LDF. It is of concern that the District's historic
environment resource is not covered directly in any of the supporting evidence base
reports. This needs to be addressed.

The general thrust of the identified headline issues are welcomed, however, we strongly
recommend that appropriate reference is made to the District‟s natural, built and historic
assets rather than the approach of referring to natural and built assets etc. Without this
specific consideration of the historic environment, there is a risk that its contribution to
the character and quality of the District‟s rural and urban areas is underplayed. The
historic environment makes an important contribution towards the sense of place, the
quality of life of communities and to the economic well-being of the area. Consequently,
its protection and appropriate enhancement should be an issue which should be
included - at least in broad terms - within this overarching Development Plan Document.
Promoting locally distinctive design should also be specifically referred to.

In terms of spatial objectives, for most LDFs, we would expect to see the inclusion of a
specific objective for the historic environment particularly where the
protection/enhancement of the historic environment and/or the need to reinforce local
distinctiveness has been identified as an issue that the Plan needs to address. We
acknowledge that there may not always be a specific objective relating solely to the
historic environment provided that, as a whole, the plan will set out a robust framework
for the historic environment. As currently drafted, however, we recommend that at
minimum spatial objective 8 should refer explicitly to historic assets (not heritage).
Spatial objective 9 could also focus on safeguarding the character of the landscape,
including its historic character.

With regard to the detail of the different development options presented, we strongly
recommend that the Council‟s and County Council‟s conservation and archaeological
officers are involved in determining and developing the preferred approach. In general
terms we advocate that decisions are informed by a robust consideration of the potential
implications, and indeed opportunities, for the historic environment of the area‟s towns
and wider countryside. This should include, for example, the potential impact of
expansion on the historic character of a town or village. We acknowledge that
development can facilitate regeneration, and this should seek to retain and promote the
sustainable use of the historic environment.

In determining brownfield land opportunities the reuse / conversion of existing buildings
should also be taken into account, where appropriate. With respect to housing densities,
we fully agree that a key consideration should be the character of an area and ensuring
that new development respects its local context. This can apply to the historic, central
areas of towns and villages as well as suburban, residential areas where the density of
development can be a major determinant of the area‟s prevailing character and
attractiveness.

Care will be needed to ensure that the distinctiveness of the District‟s market towns is
not undermined by the introduction of larger-scale retail development - whether through



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the competitive effects on smaller, independent retailers or through townscape and
design issues.

In terms of the conversion of rural buildings, establishment of a robust evidence base on
an area‟s stock of historic farmsteads is required to inform the preparation of policy
approaches and detailed guidance. The County Council is undertaking a county wide
survey of traditional farmsteads, due to be completed in early 2008 and will serve to
provide a better understanding of the resource and options for its future sustainable
management and use.

We recommend that detailed design guidance extends to new development in sensitive
historic areas, such as conservation areas and other historic places, and specific
considerations relating to listed buildings and other buildings of local historic or
architectural interest.

Whilst English Heritage recognises the priority to tackle climate change, renewable
energy technologies, ranging from commercial wind farms and biomass operations to
small-scale micro renewables, can have direct and indirect implications for the historic
environment. These should be taken into account when formulating policies and
determining site specific developments. Consideration should also be given to the
contribution that the reuse of the existing building stock, and its improved energy
efficiency, can make to tackling emissions and reducing waste streams.

English Heritage supports the use of a character based approach to safeguarding and
enhancing landscape character and quality rather than introducing further levels of area
based designations. Staffordshire Moorlands is well served in this respect by having a
completed county wide landscape character assessment and complementary historic
landscape characterisation. We strongly recommend that both these data sets are used
to inform the policy framework for the District‟s wider countryside, adopting an integrated
approach in recognition of the natural and cultural basis of the character of the
landscape.

Environment Agency

The SFRA should be used in guiding any proposed development away from flood risk
areas.

Development proposals should be in accordance with PPS25. The statement in the
question about flood risk describing low-medium risk is misleading. The sequential test
should be applied to development proposals and it should be stated that development
should not take place in Flood Zone 3 unless it is water compatible. There should be no
flood risk associated with development when considering today‟s design standards. The
Environment Agency is generally opposed to the construction of new flood defenses
required for new development only.

Greater emphasis should be placed on biodiversity. It should be mentioned in the issues
section and the spatial vision as the Council have to embrace local delivery of the UK
Biodiversity Action Plan. It should be noted that biodiversity is not restricted to the
countryside and is found throughout urban areas as well.

Any future development must have regard to water conservation and efficiency.


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Government Office for the West Midlands

The comments set out are primarily based on the summary leaflet provided.

   The Issues and Options Paper is very good and „fit for purpose‟. The document
    appears successful at containing sufficient information to enable people to
    meaningfully engage at this stage whilst remaining succinct and user-friendly.
   In particular support the clear identification of local issues that the Core Strategy will
    seek to address, from which follows the vision, spatial objectives and alternative
    strategies.
   A good range of options appears to have been selected. This and the invitation for
    people to suggest alternative options to those set out is supported. Each option is
    clearly expressed with a good accompanying use of illustrations.

Highways Agency

The Highways Agency (HA) is pleased to note identification of accessibility, climate
change and transport as key issues to be taken into account when formulating the Core
Strategy. It also welcomes a reduction in the need to travel and the support for more
sustainable forms of transport within the Strategic Objectives.

The HA is concerned that the identified issues and the Strategic Objectives are not fully
reflected within the Spatial Vision; in particular in respect of the function of travel within
'sustainable and balanced urban communities', and the need for these to be based on
means by which the need for travel can be reduced, and sustainable forms of transport.

The HA supports national planning guidance where consideration of brownfield sites
should be priority over release of Green Belt (PPS3) but also favours sustainable
development that reduces the need to travel, particularly by car (PPG13).

The HA favours higher densities where this is part of a spatial solution that reduces the
need to travel, particularly by car, and allows for inclusion of mitigation and travel plan
measures (to reduce car use and increase the use of public transport).

The HA supports the view that all development should incorporate appropriate measures
to encourage more sustainable patterns of transport. Measures to achieve this may
include promoting Travel Plans, public transport and strict car parking standards. The
HA welcomes any opportunity to discuss measures that encourage sustainable patterns
of travel with Staffordshire Moorlands District Council.

Mono Consultants Limited

Would like to see a telecommunications policy included in the Core Strategy, taking into
account PPG8. Suggests wording for such a policy.

Natural England

Climate change is now recognised as being of the highest priority by the government.
Climate Change is also the subject of one of Natural England‟s campaigns, being seen
as posing the most serious threat to the natural environment. Natural England support


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the inclusion of climate change as an issue but would wish to see reference to water
resources under this issue as there are potential impacts on biodiversity. The function of
green infrastructure in providing environmental services such as flood areas should be
recognised and opportunities for species and habitats to adapt to climate change.
Natural England would encourage reference to the landscape quality and character in
the countryside issue.

Natural England welcomes the reference to natural assets in the vision. The vision
should recognise green infrastructure (the networks of protected sites, green spaces and
linkages) as a fundamental and integrated element of land use strategies. The use of the
natural assets and the opportunities they provide for recreation and tourism should be
sustainable and not detrimental to the quality of the assets. The following amendments
would address the above points: „The diversity and quality of the District‟s natural assets
will have improved and been enhanced to create a strong green infrastructure and
sustainable use will be made of the opportunities they provide for recreation and
tourism‟.

Natural England would like to see the Core Strategy set high standards of design in all
new development, ensuring that development is good enough to approve, accessible to
all, locally distinctive and makes a positive contribution to the character of the area,
utilising the opportunities presented by the location. Natural England consider that the
following amendments be made to the strategic objectives: 2. To create a District where
high standards of design in all development help to mitigate the adverse effects of
climate change and makes efficient use of resources. 8. To promote local distinctiveness
by means of high standards of design and conservation, protection and enhancement of
heritage, environmental and cultural assets throughout the District. 9. To protect and
improve the countryside, the diversity of wildlife and habitats and geodiversity. Networks
of natural habitats should be informed by a Green Infrastructure (GI) Strategy or nature
conservation study with networks identified, which should be produced at a local or sub
regional level. The GI Strategy should inform the spatial strategy and general direction of
proposed development, and in particular urban extensions. The Core Strategy should
contain Green Infrastructure policy criteria providing a framework for protecting,
enhancing and creating green spaces and green corridors.

Natural England works for people and nature, to enhance biodiversity, landscapes and
wildlife in rural, urban, coastal and marine areas; promoting access, recreation and
public well-being, and contributing to the way natural resources are managed so that
they can be enjoyed now and by future generations.

Natural England would encourage options that contribute to the delivery of sustainable
development, as set out in PPS 1 „Delivering Sustainable Development‟. The preferred
option should contribute to global sustainability by addressing the potential impacts of
climate in the location and design of development and by encouraging patterns of
development which reduce the need to travel by private car, or reduce the impact of
moving freight. Natural England would seek to ensure that wherever possible, the
preferred option delivers new development, which builds in biodiversity and landscape
enhancement and ensures a good „fit‟ into its setting and the wider landscape based on
landscape character assessment. The use of brownfield land can make a contribution to
sustainable development by reducing the amount of other land that is required e.g.
undeveloped land. However where brownfield land has significant biodiversity or
geological interests of recognised local importance e.g. BAP habitats, then Natural


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England would seek to ensure that the interest is retained or incorporated into any
development on the land (PPS9 Biodiversity and Geological Conservation refers to
Previously Developed Land (para 13)).

Natural England would encourage a local density policy, which has regard for high
standards of design in all new development, ensuring that development is good enough
to approve, accessible to all, locally distinctive and makes a positive contribution to the
character of the area, utilising the opportunities presented by the location.

Natural England would indicate that any new retail development in the District likely to
have a significant adverse effect on green infrastructure, the designated sites including
County Wildlife Sites, SINCs and Regionally Important Geological Sites and the
landscape character of the area would only be permitted in exceptional circumstances.

Natural England would wish to see a policy/criteria permitting the conversion and re-use
of rural buildings, regardless of use, which takes account of impacts on landscape and
wildlife.

Natural England welcomes the Council‟s intention to provide more detailed guidance on
design issues through a SPD. High standards of design should be used in new and
refurbished buildings, which are locally distinctive, encourage sustainable construction
and design including sustainable drainage systems, the use of local construction
materials and techniques, the sustainable use of water, and the provision, protection and
enhancement of green infrastructure including public open spaces. Encouraging energy
efficient design is also important.

Natural England would like to see all new and refurbished development incorporate
sustainable design principles.

Climate change is likely to exacerbate the risk of flooding and flood plains within the
existing green infrastructure, provide an environmental service and can provide valuable
wildlife habitats. Natural England would expect any flood mitigation measures taken to
have no wider implications and be sustainable.

Natural England encourages more sustainable built development, in particular energy
efficient building whilst maintaining local distinctiveness. The Core Strategy should
include a policy that promotes renewable energy generation within the capacity of the
environment and compatible with landscape character. Consideration should be given to
the identification of broad areas of search where different types of renewable energy
projects can be located and the introduction of a „Merton type‟ rule. Any form of
renewable energy should be compatible with the landscape character and appropriate
for the location. There should be no damaging impact on internationally and nationally
designated nature conservation sites and protected species.

Natural England would like to see the Core Strategy set high standards in all new
developments, which encourage energy efficient design and local renewable energy
generation. Natural England encourages new development to dovetail with public
transport accessibility. The design of all development should use green infrastructure to
provide routes for walking and cycling.




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Natural England would wish to see the potential of public open spaces improved and
enhanced to create a strong green infrastructure throughout the District. There should be
net benefits and no net loss in the overall amount of public open space in the towns and
villages from development. Any development should consider the provision standards for
open space in particular natural green space (Accessible natural green space standards
ANGSt).

There are a number of internationally designated sites in the Staffordshire Moorlands
District and under Reg. 48 Habitat Regulations (appropriate assessment) there should
be consideration of development impacts on these sites. There should be an iterative
process parallel with the Core Strategy Consultation that addresses the issues.

Peak District National Park Authority

The LDF should point out clearly the relationship between that area that it covers and
the adjacent Peak District National Park. Also reflect the requirements in RSS8 for
adjacent areas to help achieve national park purposes and absorb some of the
pressures for development that might otherwise be directed towards the National Park.
Continuation of the current policy N11 in the SMLP is considered to be appropriate:
taking the opportunity (as other Authorities have) to broaden the protection offered so
that it refers to the valued characteristics of the National Park rather than landscape
alone. This would more correctly implement the duty placed on the District by Section
62 (2) of the Environment Act 1995.

Staffordshire County Council

A whole series of very specific comments regarding additions and amendments to the
Issues and Options Consultation Report are made, including making further reference to
transport matters, minor amendments to statistics, further reference to archaeology and
the historic built environment and use of guidance to inform the formulation of policies
e.g. „Streets for all: West Midlands‟.

The Core Strategy should include an ecology policy covering the maintenance and
creation / enhancement / repair of ecological networks that are protected from
development and / or strengthened by it. Policy on the way that the distribution of
nationally or regionally significant species and habitats may alter with climate change
and the effects on biodiversity and nationally or internationally designated areas is
required.

In terms of the provision of education facilities to meet potential growth in some parts of
the District, there are varying amounts of surplus accommodation at a number of rural
schools across the District. However, some schools are currently full and are projected
to remain full for the foreseeable future without taking into account additional
development. Therefore, the precise location of new housing sites will be significant.
The County Council does not have sufficient resources to construct new buildings etc to
keep pace with demand from new development so contributions will continue to be
sought towards additional educational infrastructure from developers through planning
obligations. The County Council is updating its planning obligations policy to take into
account new legislation and requests that the need for contributions towards education
remains in the District Council‟s Supplementary Planning Document on developer
contributions. In the future, Staffordshire is hoping to be involved with the Government‟s


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„Building Schools for the Future‟ project which may have implications for the size, types
and location of secondary schools in the Moorlands, though this is not part of the first
wave of the programme. Consequently, it is difficult to say when the Moorlands may be
affected. The scale and location of future development will be taken into account when
preparing proposals for this scheme.

It is likely that significant transport mitigation measures will be required under each of the
options outlined to cope with additional demand created by new development. The
impact of development on rural areas in transportation terms should be minimised and
the most sustainable options should be prioritised.

In selecting brownfield or greenfield land consideration should be given to the value of
brownfield sites for biodiversity.

When considering the issue of whether large scale wind farms should be considered in
Staffordshire Moorlands, consideration of constraints such as priority habitats and
species should be part of the site selection process.

The Cauldon rail link should be safeguarded for quarrying traffic.

In terms of more sustainable patterns of transport being incorporated into major new
developments, appropriate transportation measures should be identified within a
Transport Assessment in relation to the impact of a development proposal. These should
focus on reducing the need to travel, sustainable transport, accessibility by sustainable
mode users such as pedestrians, cyclists and public transport users and road safety. In
terms of sustainable measures there are numerous options including: cycle routes,
footways, bus service improvements (e.g. frequency, infrastructure and information
improvements), cycle parking, soft measures identified through a Travel Plan such as
car sharing, home working, subsidised bus/rail travel etc, etc….

Consideration should be given to the RSS policy requirements for the Staffordshire
Moorlands Biodiversity Enhancement Area (BEA). PPS9 para. 5 (ii) requires that LDFs
identify areas or sites for the restoration or creation of new priority habitats and support
this through appropriate policies. It is suggested that the Core Strategy should identify
the BEA as an area where existing habitats, whether designated or not, should be
protected and where policy should aim to ensure that development does not
compromise potential habitat expansion and creation. PPS9 para 12 advises that local
authorities should protect and aim to repair and enhance ecological networks through
plan policies.

The County Council, in formulating their landscape policies for the 1996-2011 Structure
Plan, undertook a county wide landscape assessment and followed this work with a
considerable degree of nationally recognised work on landscape quality. This work is an
appropriate basis for the special protection of the countryside identified. Para.12.2, in
outlining future steps in the process, identifies the preparation of Supplementary
Planning Documents in dealing with specific development issues. This use of a
landscape character approach to countryside protection, and its impact on informing
development, both through spatial and detailed considerations should usefully form the
basis of a separate SPD. Countryside protection, through this process would then
become a major strand of housing, regeneration and employment policies.



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In planning for new houses and employment land, the District Council should consider
the guidance in paragraph 35 of PPS10. Housing and other building layouts need to
ensure that waste can be effectively collected and that sustainable waste management
facilities can be provided.

The Moorlands is a significant area for quarrying and we need to work with the District
where opportunities arise through the reclamation of mineral workings. Particular
opportunities arise in terms of making contributions to biodiversity and geodiversity aims
– these opportunities should be planned for in terms of the wider network of ecological
and geological sites.

United Utilities

United Utilities Service area only includes Biddulph, Biddulph Moor, Flash, Heaton and
Rushton in the Staffordshire Moorlands.

Support Option 1 in terms of use of existing utility infrastructure. Support the perceived
disadvantage that some settlements have little or no facilities to support additional
development. Support the use of brown field sites before green field sites as they are
more likely to have existing utility infrastructure.

Agree with mentioning „minimising flood risk‟ in the issues. Suggest adding „limiting the
demand for natural resources such as potable water‟ within the same bullet.

Support the content of strategic objective 2, particularly in terms of minimising flood risk
and saving potable water through the built environment.

In relation to flood risk assessments, also include secondary flooding sources such as
sewer flooding and reservoir inundation.

Support the working that it is essential to consider utility infrastructure in deciding the
viability of development.

West Midlands Regional Assembly

The Core Strategy needs to provide clear details as to how the enhanced housing
supply it is likely to be allocated through the RSS review will be managed. A key issue is
the potential impact of accommodating these higher levels of development upon the
regeneration focus of the adjoining North Staffordshire MUA housing market.

The emphasis on the role of market towns as a focus of rural renaissance (RSS policy
RR3) support those options which give a greater emphasis and a correspondingly
greater proportion of development to the three main settlements in the District. It is also
accepted that there will be on-going development requirements in rural areas outside the
towns. It is suggested that in considering the balance of development in the rural areas
that the District Council be guided by evidence of local need as well as considering the
scale and nature of development appropriate in particular villages and the need not to
undermine development of the 3 towns as a main focus for rural regeneration.

Leek and Biddulph are included within RSS policy UR2 as local regeneration areas
which are experiencing high concentrations of local deprivation. The issues and options


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do not contain any specific policies or programmes to address this issue. It is
anticipated that greater clarity on how these weaknesses may be addressed will emerge
as the Core Strategy evolves.

The following issues need to be identified on a key diagram to be included in the
Preferred Option report as part of the spatial portrait of the District:
    Location of the Moorlands in the West Midlands and adjoining borders with the
       North West region;
    Green Belt and Peak District National Park boundaries;
    RENEW pathfinder at Biddulph.

Due to the Moorlands being split into Peak Park and non Peak Park, the proper planning
of the District will require the management of significant cross boundary issues in the
Core Strategy.

The evidence base of the issues and options report identifies a number of potentially
critical issues for the preferred option. The implications and capacity to resolve these
issues need to be clearly addressed in the preferred options report.

The description in the policy context in the issues and options report excluded RSS
policies RR4, PA14 and PA15 and the objectives in these additional regional policies
need to be addressed within the Core Policies of the preferred option.

The second paragraph of the spatial vision should refer to the provision of affordable
housing.

The strategic objectives do not possess sufficient spatial references to identify the
preferred distribution of development in the District linked to the spatial portrait. The
following objectives also require further consideration:

Objective 3 – this objective should refer to the sustainable diversification and
development of the District‟s economy and should also provide some guidance on the
importance and future direction for the agricultural economy;
Objective 6 – this objective should ideally refer to sustainable rural communities as it is
the residents who require equitable access to services but in this context, there would be
little difference between Objectives 6 and 10. Alternatively, if the objective does wish to
promote the creation of sustainable settlements then it should refer to local character
and distinctiveness and the quality and range of shops, services and facilities;
Objective 9 – this objective should also refer to the distinctive and nationally important
landscape of the District which includes areas within the Peak National Park;
Objective 11 – the two sections of this objective are (arguably) mutually exclusive and
should be linked by the conditional OR not the mutually inclusive AND.

These considerations and the need to improve the range, quality and distribution of
services as a key component of rural renaissance also need to be made more explicit in
the formal identification of The Issues in Section 7 of the Issues and Options Report.

The Preferred Option for the District should reflect the requirements of RSS Policies
RR3 and RR4 and the guidance in para 5.15 to 5.19 on development in Market Towns,
villages and in the open countryside and should also reflect RSS Policies PA14 and
PA15.


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Although no statement of conformity is required at this stage, the issues and options
report is considered to generally conform to the objectives of the „rural renaissance‟
agenda subject to the detailed matters above.

Other Consultees (in alphabetical order)

Alton Towers Limited

There needs to be a greater emphasis on the need to improve, enhance and expand
tourism facilities within the District and we consider that a separate issue should be
identified within the Core Strategy rather than just referring to tourism in the context of
recreation and sport facilities.      We note tourism should also form a separate
section/chapter within the Core Strategy.

The vision should be amended to include more specific reference to existing tourist
facilities and not just existing natural assets. We suggest that the following wording is
added: "The District's existing tourist facilities will be enhanced and improved to
encourage people to visit/stay overnight in Staffordshire Moorlands, and to take
advantage of the wider economic benefits that result from visitors".

Top 3 priorities are:
   1. To develop the District‟s economy and meet local employment needs in the
       towns and villages.
   2. To support and enhance the tourism, cultural, recreation and leisure
       opportunities for the District‟s residents and visitors.
   3. To promote local distinctiveness by means of good design and the conservation,
       protection and enhancement of heritage, environmental and cultural assets
       throughout the District.

Option 2 is the preferred development option. We consider that proposals for the
conversion of rural buildings should be considered on a case by case basis and subject
to the suitability of the building for its proposed future use and that the use after
conversion should not be predetermined. We consider that development should be
allowed on sites with a low-medium risk of flooding if measures are taken to remove the
risk.

British Waterways

The vision does not address rural regeneration adequately. Since so much of the area is
rural, it would be useful for the vision to promote a vibrant rural economy and to promote
development in the countryside. Rural regeneration opportunities outside towns and
villages should be addressed. Large marinas for example must be located in open
countryside because urban land values preclude them and they are quite constrained in
where they can be located. They can be appropriate development in such areas and can
provide employment and contribute to the local economy.

Top 3 priorities are:
   1. To support and enhance the tourism, cultural, recreation and leisure
       opportunities for the District‟s residents and visitors.
   2. To protect and improve the countryside and the diversity of wildlife and habitats.


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    3. To make provision for the overall land use requirements for the District,
       consistent with the Regional Spatial Strategy and the role of Staffordshire
       Moorlands within North Staffordshire.

Stockton Brook is suitable for further development. In terms of focused development,
the area around the terminus of the Leek Branch of the Caldon Canal south of Leek
would be suitable. Development could include a canal basin and improved links to the
town centre.

If we are required by Government to restrict the number of houses that we build, a
system where only a set number of houses per year are granted planning permission
with the exception of affordable housing and regeneration schemes would be
appropriate. However, it is difficult to envisage how this could be managed without
causing a clamour for permission at the start of each cycle. This would mean that
permissions would be granted on a 'first come, first served' basis which may
compromise high quality schemes.

It may not be appropriate to protect employment sites and premises for employment use
where an attractive building may not be economically viable to meet this use but could
be beneficially put to another productive use. Equally, it would be sensible to release
land that is poorly located in terms of employment market requirements for other
productive uses where appropriate. Buildings used for employment would benefit from
further design guidance.

Section 106 monies should be sought or proposals built into site master plans for
towpath improvements along the Caldon Canal to promote walking and cycling and
'access for all' standards wherever possible when major new developments are
proposed.

It may be appropriate to carry out an 'open space audit' and to consider exceptionally
allowing development on public open space where there is excess provision and where
sites are under-used and have little potential for increased use.

Caldon & Uttoxeter Canals Trust

The document should cover the issue of developing local distinctiveness and the identity
of the Staffordshire Moorlands and actively promoting the District.

Top 3 priorities are:
   1. To deliver sustainable, inclusive, healthy and safe communities.
   2. To support and enhance the tourism, cultural, recreation and leisure
       opportunities for the District‟s residents and visitors.
   3. To promote local distinctiveness by means of good design and the conservation,
       protection and enhancement of heritage, environmental and cultural assets
       throughout the District.

Along the Caldon Canal, would like to see the development of visitor moorings and
associated facilities - such as water points, interpretation and signage to local facilities -
within existing canal side community areas, with such facilities being in keeping with
surroundings.



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Rural buildings should be allowed to be converted to residential use when the building is
at risk of being lost. New buildings would benefit from further design guidance to
encourage reference to vernacular and/or high quality sustainable modern design.
Development should be allowed on sites with a low-medium flood risk if measures are
taken to remove risk.
Forms of renewable energy suitable for the Staffordshire Moorlands are:
Large scale commercial hydroelectricity and small scale domestic solar panels and wind
turbines. New development should be required to generate a proportion of its energy
requirements from renewable resources wherever feasible to incorporate without
detrimental visual impact on the distinctive nature of the Staffordshire Moorlands.

The Council should aim to capitalise on the Caldon and Uttoxeter canals as linear
recreational resources for healthy living and tourism by identifying a co-ordinated range
of environmental and recreational improvements.
     identify opportunities to improve access and connections between the canal
        network and the surrounding area.
     identify strategies and schemes for encouraging community use, tourism and
        promote extended stays in the Leek and surrounding area.
     conserve and enhance the heritage, environment and biodiversity of the Caldon
        and Uttoxeter canals
     identify partnership and external funding opportunities
     identify projects to transform the local image through the enhancement and
        promotion of the canals through SMD and Churnet Valley and create the right
        conditions for attracting inward investment.
     identify opportunities to develop partnerships and promotions with other
        complimentary initiatives e.g. Staffs Way, Rudyard Visitor Centre, Churnet Valley
        Railway.

There should be improvement of the canal towing paths to be able to support walking
and 'access for all' usage (accessible to pushchair and wheelchair users) and cycling
where appropriate, to encourage use as routes into Leek, between Leek and rural
hinterland, as linear park route through the Staffordshire Moorlands, and to promote
resident and visitor circulation within settlements e.g. Endon, Denford, Longsdon,
Cheddleton, Consall, Froghall, Oakamoor, Alton, Denstone, Rocester.

The Caldon Canal should be maintained in good order and improved; SMDC should
encourage and support British Waterways in this. The line of the Uttoxeter canal should
be preserved and those structures and lengths of canal that still exist be maintained in
good order. A walking route along the length of the Uttoxeter Canal should be created
utilising as much of the original towpath as possible. Develop and promote a "Churnet
Valley Way" walking route, utilising existing canal towpaths and footpaths through the
Churnet Valley and incorporating the above proposed walking route along the length of
the Uttoxeter canal. Investigate the feasibility of restoring to navigation some or all of
the Uttoxeter canal.

The Council should aim to protect public open space from development, especially
buffer zones between developments with important amenity and visual roles - including
for example, land adjacent to the Caldon Canal in Cheddleton between the village
conservation area and more recent housing developments.




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Protect views in to and out of conservation areas including the Caldon Canal
conservation area. Improve consideration of the visual impact of any potential
development from all of its surrounding areas, how it may impact on long-distance views,
views from footpaths, canals etc.

South Leek would benefit from redevelopment to improve access to the Caldon Canal,
reinstate a mooring basin and using these as a focus to create development, tourism
and employment opportunities. Public consultations have already given "overarching
support for the creation of a canal basin in Barnfields".

Create a vision for south Leek, including:
    road, rail and canal linkages that create complimentary throughways and
       gateways into the area, that improve travelling and access for residents, workers
       and visitors
    use these linkages to unlock the potential of the tract of under-utilised
       employment land at the southern fringe of Barnfields and the cornfield site, and
       to enhance the infrastructure available to Britannia.
    improve the environment around the River Churnet and linkages to the Caldon
       canal and create a river and canal frontage for Leek that interfaces between a
       south Leek business and tourism hub and the neighbouring greenbelt
       countryside.

The trust has long had a vision for south Leek that includes restoring the link between
the town and its canal, through recreating a canal basin which is at the heart of a visitor
honeypot. A new canal wharf and a restored railway line being the hub around which
new business activities and critical local facilities can grow. In turn they will act as both a
gateway to our market town, and an anchor and focus for sustained regeneration and
many local community activities, for example: hotel with restaurant and meeting room
facilities, community theatre with facilities also able to be used by local business and
community groups undertaking canal and countryside activities (e.g. Beatrice charity,
conservation training), small business units, medium office units with desirable outlooks.

Incorporate into the Core Strategy the outputs of the part MTI funded Caldon and
Uttoxeter Canals Trust Study "to investigate the potential to restore, extend and develop
the canal in Leek" which demonstrates the value of the benefits from reconnecting the
town with its canal, along with proposing that the option for a canal basin in the vicinity of
a proposed Leek terminus for the Churnet Valley Railway has distinct, positive linkages.

        capitalise on the Caldon and Uttoxeter canals as linear recreational resources for
         healthy living and tourism by identifying a coordinated range of environmental
         and recreational improvements.
        identify opportunities to improve access and connections between the canal
         network and the surrounding area.
        identify strategies and schemes for encouraging community use, tourism and
         promote extended stays in the Leek and the surrounding area.
        conserve and enhance the heritage, environment and biodiversity of the Caldon
         and Uttoxeter canals
        identify partnership and external funding opportunities




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        identify projects to transform the local image through the enhancement and
         promotion of the canals through SMD and Churnet Valley and create the right
         conditions for attracting inward investment.
        identify opportunities to develop partnerships and promotions with other
         complimentary initiatives e.g. Staffs Way, Rudyard Visitor Centre, Churnet Valley
         Railway.

The Caldon canal should be maintained in good order and improved; SMDC should
encourage and support British Waterways in this.

The line of the Uttoxeter Canal should be preserved and those structures and lengths of
canal that still exist be maintained in good order.

A walking route along the length of the Uttoxeter canal should be created utilising as
much of the original towpath as possible.

Develop and promote a "Churnet Valley Way" walking route, utilising existing canal
towpaths and footpaths through the Churnet Valley and incorporating the above
proposed walking route along the length of the Uttoxeter canal.

Investigate the feasibility of restoring to navigation some or all of the Uttoxeter canal.

Campaign to Protect Rural England

The plan period extends to 2026, by which time it is widely accepted that a carbon
reduction of 90% must be within reach. The urgency of this target is reinforced by the
acknowledgement that world oil reserves are forecast to have become exhausted by
2050 and in the intervening period remaining resources will have become scarce, the
subject of competitive demand and a political bargaining counter by the world's great
nations. It is not unreasonable to predicate price rises that make many of society's
present activities unsustainable.

Coupled with the unstable nature of international socio/economic/religious politics,
intensified by huge emigration movements (10s of millions of refugees have been
reliably suggested) triggered by climate change, the question must be posed however as
to whether the "challenges" defined are expressed in strong enough terms, and the
solutions proposed meet the likely extent of these changes, as unprecedented as any in
history. CPRE believes it does not exaggerate the situation, but would ask that the
questions posed are debated and only countered or dismissed on rational grounds.

A serious concern is the magnetic attraction of Moorlands for housing which major
planning (and sustainability) considerations dictates should desirably be located within
the Potteries. Is 'in-migration' to be accepted, and is the Authority in a position to
shoulder to burden of the extensive infrastructure - economic, educational, social and
environmental - which larger housing numbers entails? Can the individual communities
of the District achieve the degree of self-sufficiency likely to be required where travel and
commuting to outside facilities no longer remains an option for most, especially the less
well-off?

CPRE regards the vision as having been exceptionally well-formulated and attracts our
support. The only reservations that we have are those set out above, and the almost


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complete omission of reference to the outstanding environmental quality of the
Moorlands countryside. We also suggest that agricultural economies will be radically
transformed in the near and distant future be e.g. demands for bio-fuel and food self-
sufficiency, and for 'tourism' in its widest sense.

We would question whether spatial objective 2 "development will help to mitigate the
adverse effects of climate change.." is correctly stated. "Development" will inevitably
exacerbate such adverse effects by its inbuilt energy needs, operational energy
consumption and access and servicing requirements. CPRE suggest a word change to
"to create a District where development takes shape which minimise its adverse effects
on climate change and makes efficient use of scarce resources, including land".

Spatial objective 3 raises the inevitable question as to how creating employment in
towns and villages manages to confine such employment to local residents and avoid in-
commuting. We trust that answers will emerge from detailed Plan policies. One particular
concern in relation to SMDC is the employment 'pull' to the North Staffs conurbation and
to major employment sites such as JCB. Particular transport solutions may need to be
sought.

CPRE would not wish to select 3 top priorities. Planning is a matter of BALANCE and we
support ALL the objectives. HOW they are to be achieved in the correct balance will be
the subject of debate.

Option 1 seems to CPRE to be that most sustainable, affording the greatest access by
people to social, educational, shopping and economic facilities and also best platform for
development of public transport. CPRE also regards the possibilities for brownfield
regeneration as greatest, and support limited village development confined to affordable
housing. CPRE opposes large village-based development as providing only a limited
range of infrastructure and supporting facilities, and necessitating extensive travel for
residents. CPRE believes that Option 3 is the least desirable as minimising access to
social, employment, educational and shopping facilities whilst maximising travel and
commuting. Enlargement of smaller villages would lead to loss of rural character, one of
the District's greatest amenities. Option 4 is attractive, but seems to differ only from
Option 1 in targeting Froghall (presumably!) as a development site on the basis of re-use
of the industrial site. Except for the advantages of re-use of that brownfield land,
locationally it is undesirable for its remoteness from support facilities and requirement for
transport connection. CPRE cannot suggest other development opportunities that would
be immune from the same criticisms.

CPRE agrees with the assessment on page 14 as an excellent summary of desirable
rural objectives. We would like to see emphasised that in our preferred Option 1, and in
other options where expansion of towns and villages may be adopted, substantial
measures to secure assimilation of new development within the landscape would be
undertaken. (The North Staffs countryside suffered noticeably in the inter-war period
from ribbon development on high ground disproportionately damaging the wider
countryside).

In selecting land for development, brownfield land should be taken first, and use of
greenfield land should be overwhelmingly justified, poorest land (in quality and
environment) chosen, and remedial landscape measure required. CPRE has a basic
policy that where open landscape is taken for building use, the design quality of that


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development should be correspondingly raised to compensate for the loss of openness
and amenity of the country scene.

Densities should in many instances be raised, with some strong reservations:
a) with the need for provision of a mixed range of housing types, the opportunities for
creating admirable housing compositions should be grasped.
b) similarly with judicious variations of dwelling types there should be no need for
appearance of 'cramming' or overlooking, or loss of gardens to family homes
c) higher densities, e.g. by the creation of taller buildings, should only be chosen where it
would not harm the existing character of its surroundings.
d) all site characteristics, especially trees and hedges, should be retained and form part
of a site-sensitive design solution
f) the key to acceptable higher densities is that of site coverage rather than dwellings per
hectare.

Affordable housing is a necessity in both towns and villages, the lack of which is having
grave social consequences likely to be compounded in the future. Special need would
be required to be shown for such housing in the smallest settlements. Definition of
"affordable" is an obstacle. There should be, in CPRE's view, a range of housing made
available within the resources of a range of householders. The housing industry fails
almost entirely to provide this at present. SOCIAL housing is only a partial solution - but
necessary one. Depending on definitions, the proportion of affordable housing should
be determined by a local housing survey. It may be logical that at some point such a
survey should indicate the proportion of housing that should be built within each price
bracket. The current policy of leaving such judgement to market forces has been seen
to be inadequate. CPRE is hesitant in supporting affordable housing only sites in view of
the implications of social and ethnic 'ghettos'. Perhaps small attractively designed are a
better solution than completely mixed individual houses, and more acceptable to all
residents.

Would question how the allocation of industrial land can match local needs with no
control over where employees originate? Small-sized industries are obviously more fitted
to local needs and more flexible and responsive to change. Larger industrial units are
only justifiable under present and future circumstances where a large workforce is locally
available. Before consenting to change from employment to other uses, a survey of
employment potential should be made and a justification put forward by developers of
market demand similar to that required for rural conversions to other than business use,
or farm workers' dwelling restrictions. Allocating additional employment sites to meet
business demands requires that other considerations are brought into play. Regenerated
sites are positive gains, greenfield sites "attractive to business" involve loss of
environment and amenity. CPRE believes that a number of smaller sites, or sites for
smaller businesses, afford greater flexibility of use than larger sites, and greater
protection against business failure which could destroy prosperity of whole communities.
Smaller workshop-type buildings are likely to fit into the small town/village scale of
SMDC. Your authority might also take the view that in the global economy there is
greater vulnerability to business downturns with larger concerns than with small-scale
service or specialist high-tech business.

CPRE would wish to see the results of commissioned studies before offering its views
about amount and location of new retail development in Leek and Cheadle, but would
caution some cynicism at the optimism of many such specialist studies. Special efforts


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should be directed towards infilling and consolidating town centres before spreading
outwards. It certainly seems that edge of town sites dependent largely upon car-borne
trade is to be cautioned against, but there are some bulky goods traders that require
ready car access and loading.

CPRE holds the view that despite national policy, residential conversions are often more
appropriate than business uses for rural conversions. We say this because residential
conversions are more feasible in scale and ability to retain vernacular features, are more
sympathetic in use of site surrounds, involve less traffic (especially goods vehicles),
inflict less damage on narrow roads and lanes and do not attract commuting traffic TO
the buildings. Farm buildings and farmyard complexes are an integral component of the
rural farming landscape in their architecture and massing, and deserve special
consideration to maintain them in useful state. In the more remote areas of the
Staffordshire Moorlands there may well be a case for conversions to business use to
create/maintain local prosperity, but the LPA should satisfy itself that distance
commuting is unlikely.

It is considered that the general quality of design in new and refurbished buildings in the
Staffordshire Moorlands needs improving. Rather than selecting building types, CPRE
would strongly affirm the need for the acceptance of the principles of buildings reflecting
the materials, proportions and siting of traditional buildings of the locality. Only then can
the local environment be reinforced rather than reduced. The greatest need for
guidance is in housing layouts. The ability to group together attractively a number of
separate buildings outweighs the importance of individual architecture but as an art falls
between the architectural and planning professions. Nonetheless it is the undoubted
responsibility of the planning authority as the mouth piece of the community to require
well-considered design standards - and to make such standards clear, well-defined and
justified.

Development may well be allowed if measures are taken to remove flood risk. These
precautions would need to be absolute with no remaining possibility of flooding. If this
cannot be guaranteed development should only be permitted where no flood risk
existed.

Provision and use of renewable energy, or more importantly CONSERVATION of
energy, should be of highest priority, alongside health and safety. CPRE affirms this in
view of forecasts of global warming and depletion of world fuel reserves. In terms of
forms of renewable energy suitable for the Staffordshire Moorlands, large scale
commercial biomass has a future as part of the farming landscape and economy suitably
planned around bio-generators. Large scale commercial hydro-electricity would also be
suitable but is very limited in its availability. "Small scale "micro-generation" is estimated
to ultimately be able to contribute 40% of energy needs. Solar panels/voltaics are likely
to have greater potential [than small scale wind turbines]. Some care will need to be
given to the prospect of large reflective roof areas in vulnerable environmental areas.
The subject of economic housing design incorporating heat conservation, production and
re-use has yet to be adequately explored. Individual wind turbines, as developed so far,
are limited in their productivity. Technical advances will make this feasible and cheap
within 5 years for all development except the most minor. Thoughtful policies will be
needed for listed buildings or conservation areas.




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Major developments can have the capacity for "micro-generation" in forms such as wind
turbines and District heating - especially business and industrial proposals. Residential
micro-generation is at the development stage and conservation offers better economic
returns. A policy of requiring progressively higher levels of on-site energy generation
would accelerate the development of such processes.

Sustainability as an "over-arching" policy requires convenient access for all families to a
full range of community facilities - education, employment and physical infrastructure. It
is therefore a necessity, determining housing location policies.

Walking and cycling are the most obvious forms of sustainable transport and the most
beneficial and should receive maximum encouragement for those sections of the
community and over the distances involved. It hardly needs stating that planning
intervention should go far beyond "encouragement", "facilitating" is perhaps the most
appropriate LPA policy.

Beyond this point it may be that personal electric vehicles will need to be further
developed, with public electricity supply derived from nuclear-powered generators, fossil
fuel power stations with carbon sequestration and other renewable national power
resources.

Public transport in the Staffordshire Moorlands area would largely be via buses which
might be expected to receive priority fuel allocations. Vehicle design, routing frequency
etc will also need to be more thoughtfully aligned to passenger requirements with some
goods/parcels facilities. Goods transport raises many questions, of concern to LPAs
especially in relation to rail routes and economic organisation. The LPA might wish to
reconsider the admittedly attenuated rail network in this light and its future role, if any.

Within reason all public open space in towns and villages should be protected from
development, especially if public social activity is likely to be promoted within
increasingly self-contained communities. It is true that once built open such areas are
permanently lost to open-air activity. The LPA should look at the surrounds to POS
where a higher housing density may sometimes be appropriate making the open space
available to a larger number of people.

CPRE would suggest that the Churnet Valley is inadequately acknowledged as of
outstanding landscape beauty and would merit specific protection.

Home Builders‟ Federation Limited

The Council should acknowledge that one of the challenges it faces in preparing a
development plan is creating one flexible enough to potentially accommodate higher
housing figures depending on the outcome of the West Midlands Regional Spatial
Strategy review. This flexibility should also be integrated into the Core Strategy to
accommodate any changing circumstances arising out of any potential mini-review of the
RSS, in light of recent government proposals. This is a fundamental challenge for the
Council, especially in light of soundness tests 4 and 9 in PPS12. Objective 1 should
reflect this.

Bullet point 4 sets out that the Council must ensure a balanced housing market meeting
the needs of all current and future residents, in particular ensuring housing is affordable


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and of a high quality. While the Council has identified that it must meet the needs of
current and future residents it must also meet demand according. PSS3 defines and
sets out the requirements for planning both housing need and demand. The Council
should recognise the difference in planning for both need and demand and prepared
proposals accordingly.

The Council must acknowledge that climate change is a challenge facing the UK as a
whole and that there is soon to be published national policy in relation to planning for
climate change which will inform proposals within the Council's emerging core strategy.
This is particularly pertinent to promoting renewable energy. The HBF would draw the
Council's attention to the industry's commitment to a stepped approach to building zero
carbon homes by 2016. This will be achieved through the building regulations legislation
and the HBF object to any accelerated approach to achieving zero carbon homes before
2016. This is due to the industry being committed to working to what is already an
ambitious target linked to the code for sustainable homes and accelerated levels will be
of detriment to housing supply.

The HBF would draw the Council's attention to para 9 PPS3 in relation to it emerging
vision. The Government's policy goal is to ensure that everyone has the opportunity of
living in a decent home, which they can afford, in a community where they want to live.
The HBF believe that the essence of this para should be included within the vision for
SMD in a locally distinctive manner for both urban and rural areas. This should help the
Council achieve the challenges set out in challenges 1,3,4,5,6, and 11.

Objective 2 should acknowledge that development cannot mitigate contributors of
climate change that are not associated with the development. As stated above, the
housing industry is committed to building zero carbon homes by 2016 which will
contribute to the Council's objective for climate change but the Council cannot expect
new housing development to contribute to mitigation of existing contributors of climate
change as is beyond its remit. In this context, the Council should seek to encourage
changes to the existing housing stock as new homes are already up to 6 times more
efficient in terms of energy use than a home built in 1990.

Objective 4 should also include reference to meeting the demands of the residents. The
term 'need' should not be included alone and assumed to include demand. PPS3 clearly
defines need and demand separately and states that local planning authorities should
plan for both. This should also be informed by a strategic housing market assessment
prepared in partnership with the house building industry.

The HBF considers that subject to the comments above, numbers 1 (to make provision
for the overall land use requirements for the District, consistent with the Regional Spatial
Strategy and the role of Staffordshire Moorlands within North Staffordshire) and 4 (to
provide new housing that is affordable, desirable and meets the needs of residents of
the Moorlands) must be the priorities for the District in order that it can deliver
sustainable growth.

The HBF cannot respond on site locationally specific issues and therefore cannot
comment on the spatial options presented. However HBF do make the following general
comments. In devising the spatial options for the future development of the District, the
Council must ensure that it has considered the full range of options in order to submit a
sound core strategy for examination. In the context of the examination and tests of


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soundness, the Council must also ensure that its options are spatial in nature and not
land use based. While the HBF has no specific comment in relation to the options
presented; it does have concerns in relation to the manner in which the options do not
have strong enough relationships to the overall objectives set out in the previous section.
The HBF believe that the Council should consider options for the spatial distribution of
development based upon the objectives that it has established in the previous sections
rather than relying on options that have more land use connotations.

The HBF would like to see option development have more consideration of the spatial
implications associated with the need and demand for housing within the District. This
should be informed by a strategic housing market assessment and a strategic HLAA in
accordance with PPS3.

Given the emerging Government guidance set out in PPS3, the HBF considers it ill-
advised to proceed with principle of any form of sequential approach in relation to
development principles when that approach no longer forms part of Government policy.
The sequential approach has been deliberately omitted from PPS3 as a way of speeding
up the delivery of and release of land for housing in appropriate locations.

PPS3 still prioritises the use of previously developed land and states that housing should
be delivered in suitable locations which offer a range of community facilities and with
good access to jobs, key services and infrastructure. The emphasis of PPS3 is that the
location of new housing should contribute to the achievement of sustainable
development. This should take into account of, in particular the vision for the local area,
evidence of current and future levels of need and demand for housing as well as the
viability, availability and suitability of sites for development among other issues set out in
para 38 of PPS3.

The Council should ensure that its distribution and choice of sites is based upon clear
and transparent evidence prepared in association with the housing industry. In this
context the Council should use a strategic HLAA to underpin key core strategy
decisions.

The question with density is of far wider significance than to simply accommodate more
housing on a particular site. PPS3 sets out that using land efficiently is a key
consideration in planning for housing and that local planning authorities should develop
housing density policies, having regard to a whole series of issues.

Importantly para 46 PPS3 refers to the spatial vision and strategy for the area including
the level of need and importantly demand along with the availability of suitable land in
the area. In determining density requirements the Council should therefore seek to
identify what it is attempting to do through its vision, objectives and spatial options
before considering densities in such an isolated manner. The eventual spatial strategy
for the District will provide a framework for considering appropriate densities.

The HBF would draw to the Council's attention the first bullet point of para 29 of PPS3
which states that in setting an overall plan wide target the council should also reflect an
assessment of the likely economic viability of land for housing within the area, taking into
account risks to delivery and drawing on informed assessments of the likely levels of
finance available for affordable housing. The need for Local Planning authorities to
undertake informed assessments of the economic viability is reiterated in the 4th bullet


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point of the same para, in association with determining thresholds and proportions of
affordable housing, including the associated impacts upon housing delivery and the
creation of mixed communities.

The HBF consider that the question about controlling the supply of housing is
inappropriate in the context of PPS3 and recent ministerial statements. The Housing
green paper itself sets out clearly the Government's intentions for new house building to
deliver 2 million homes by 2016 and 3 million by 2020 with annual targets 240,000 new
homes every year from 2016 onwards. The Council should adopt positive proposals
within its LDF to meet the requirements of the RSS for the West Midlands in a manner
that is flexible enough to respond to changing circumstances. It should also set out
within its LDF how it can meet the requirements of PPS3 in the context of housing
supply.

Employment land requirements should be informed by an up to date Employment Land
Review. The Council should not favour any particular type of renewable energy over
another within planning policy. The HBF would draw the Council's attention to the
industry's commitment to a stepped approach to building zero carbon homes by 2016.
This will be achieved through the Building Regulations and the HBF do not consider that
it is appropriate to specify in planning policy the type and requirements for renewable
energy. Zero carbon homes by 2016 will be achieved through incorporating a range of
energy efficient measures into new homes and renewable energy technology from both
on-site and off-site sources. The Council should therefore not give favour to a particular
type of renewable energy source over another. If the Council is to proceed on this
approach, the HBF do not consider it can justify such an approach based upon sound
evidence and will object to the inclusion of such policy, especially if it were to accelerate
the standards of the Code for Sustainable Homes.

J C Bamford Excavators Limited

The vision should include helping the District's leading employers to thrive. Top 3
priorities are:
    1. To develop the District‟s economy and meet local employment needs in the
         towns and villages.
    2. To ensure the long term vitality and viability of the three market towns.
    3. To deliver sustainable, inclusive, healthy and safe communities.

The importance of JCB as a major local employer should be recognised and provision
should be made for the company to expand the manufacturing operations at its existing
factories at Cheadle. The Council can ensure that sufficient employment land is
available for local needs by protecting existing employment sites and premises and
allocating additional sites in suitable locations to meet the demands of modern
businesses. The Council should identify a range of employment sites to meet future
development needs. This should include provision for major local employers such as
JCB to be able to expand their existing operations to enable them to prosper during the
planning period. The Council should prioritise the use of renewable energy in
accordance with national policy.

National Trust




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Tackling climate change is identified as a challenge but in reality it means addressing
two distinct but related challenges: adapting to the effects of climate change that is
happening and will continue to happen; and mitigating further contributions to climate
change so that the scale of change will be ameliorated in the future.

In Objective 2 adding „is adapted to and‟ after „development‟ would lead to a more
rounded approach to tackling climate change. Objective 3 seeks to develop the District‟s
economy but does not mention tackling the issues of low wages, low skills, reliance on a
small number of large employers, commuting and the continuing loss of younger people
from the area. In Objective 9 adding at the end „in accordance with the local biodiversity
action plan‟ would establish the framework for prioritising wildlife and habitat
improvement. In Objective 11 deleting „to jobs and key services‟ would widen the scope
of travelling by more sustainable forms of transport. Leisure makes up an increasing
proportion of travel within the UK.

Top 3 priorities are:
   1. To create a District where development helps to mitigate the adverse effects of
       climate change and makes efficient use of resources.
   2. To promote local distinctiveness by means of good design and the conservation,
       protection and enhancement of heritage, environmental and cultural assets
       throughout the District.
   3. To protect and improve the countryside and the diversity of wildlife and habitats.

In the absence of an overall increase in housing growth in the district in the current RSS
review, this option depends on a substantial negative allocation to rural areas. No
indication is given of how this might be achieved. Even with an increase in housing totals
for the district, rural housing completions over the plan period would have to be slightly
less than existing commitments. Again, no explanation is offered but the consequence
would appear to be that no new planning permissions would be granted for any form of
housing in the rural parts of the district. This does not appear consistent with the aim of
meeting rural housing needs.

The Trust is concerned that significant development on the edge of Biddulph would have
adverse consequences for the local landscape including the settings of property in its
care at Mow Cop and Biddulph Grange. Without an increase in the RSS apportionment
to Staffordshire Moorlands, the four options propose growth figures for Biddulph ranging
from 803 dwellings to 1191 dwellings. If the RSS apportionment is increased, the figures
vary from 1304 dwellings to 1891 dwellings. These totals are additional to the dwellings
already committed in the town. As the Council stated of Biddulph in the local plan, „The
town is constrained by a number of important factors principally the topography, the
landscape and the Green Belt which is drawn tightly around the town. These factors
reduce the opportunities to expand the town peripherally.‟ The Trust is concerned that
the scale of growth envisaged for Biddulph in all the options would conflict with some or
all of these constraints. Although only limited information on capacity
assessment/housing land availability is presented in the evidence base, the figures
suggest that greenfield development would be required at a scale that would depend on
realignment of the Green Belt boundary and would have adverse effects on the local
landscape. Green Belt realignment is a strategic spatial concern but is not discussed in
the issues report. Such realignment would need careful testing: not just against the
strategic spatial objectives of the Regional Spatial Strategy and those emerging through
the ongoing RSS review but also in terms of its effects on the local environment. The


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Trust supports the Council‟s intention to conduct further work on housing land availability
and suggests that this needs to be completed before the Core Strategy advances much
further. The Trust would welcome the opportunity to comment on this work.

The environmental consequences of development should be considered in deciding
whether all development should be concentrated on brown field land. Some brownfield
land may, as the question suggests, be in inappropriate locations. There might also be
significant landscape, biodiversity or cultural heritage interests that suggest that a
specific brownfield (or green field) site should not be developed.

A reasonable increase in the density of housing development can help ensure that
development is able to support local services within walking distance as well as reducing
the land-take required. With good design, a high quality environment can be achieved at
higher densities.

Underlying the question about the approach to allocating new employment sites is the
wider issue of how the core strategy can contribute to developing the economy of the
area to reduce its exposure to a limited number of major employers, increase wages and
aspirations, reduce commuting and relate positively with the North Staffordshire
Regeneration Zone. Allocating 1 or 2 larger new sites in a district of 222 square miles
would do little if anything to address most of these issues. It would also be poorly related
to the projected demand for small units and fostering the growth of indigenous
businesses. B1 uses, projected to make up much of future demand, can co-exist with
housing and other sensitive land uses so opportunities for mixed use allocations or for
widening the mix of uses in an area should be considered. Second hand buildings can
offer cost advantages to businesses. The core strategy could act to help employment re-
use to take place and safeguard buildings in and for employment use.

Flooding is a natural process but its severity and impact can be altered by human
actions. The report discusses flooding only in terms of whether development should or
should not be allowed in areas of flood risk. Further issues have been identified in the
scope of the Strategic Flood Risk Assessment which the Council is jointly
commissioning. The Trust considers that the core strategy should at least address the
mitigation of down-stream effects of development i.e. ensuring that development,
including any associated flood defence, does not increase the risk of flooding elsewhere.
Rainfall patterns will alter through climate change, which is predicted to lead to more
frequent severe rainfall incidents with a greater risk of flooding. At a catchment scale
land management can be a significant factor in determining the pattern of river flow
following a rainfall event. With the wider spatial remit of the LDF, the core strategy
should set out a spatial strategy for flood management that encourages thinking and
action at a catchment rather than a site scale.

The National Trust believes that there is an urgent imperative to reduce greenhouse gas
emissions and to meet, if not better, the UK government‟s target of cutting carbon
dioxide emissions by 60% by 2050. Renewable energy is, however, only one part of an
overall package to mitigate future climate change and the Trust suggests that the Core
Strategy should have a wider scope with regard to energy and carbon dioxide than that
currently suggested, encompassing energy efficiency, reducing demand and sustaining
and improving carbon lockup. As a whole, this should be a high priority.




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The Council‟s evidence base suggests that the district may not be suitable for large-
scale commercial wind or hydro-electric generation. If the resources are not available
there is little point in promoting such development. Even where the resources exist,
careful consideration of the impacts is needed before such development is promoted or
ruled out. The Trust believes that the location and design of all energy generation and
distribution schemes should take account of the full range of environmental
considerations, including the protection of valued landscapes, biodiversity, the historic
environment, and peoples‟ well-being. The Peak District National Park is one of the
nation‟s most valued landscapes. While the National Park is outside the plan area,
commercial wind farms could have an impact on and landscape character and views
from the park. PPS22 requires such effects to be treated as material considerations. It is
not clear why the selection of different forms of renewable energy at the domestic scale
is considered a strategic spatial issue, particularly when the potential for substantial
impacts to be made cost-effectively through improving energy efficiency of the existing
housing stock is not addressed and there is no mention of small-scale non-residential
renewable energy. Emerging technology may radically alter the performance of different
options for the householder during the period to 2026. In addition climate change may
fundamentally alter the patterns of energy usage, for example with more energy being
used for summer cooling, less for space heating in winter and water heating becoming
more significant as a proportion of household energy demand. Combined heat and
power and tri-generation (combined cooling, heat and power) can significantly improve
the efficient use of fuels, whether fossil or renewable. These may be relevant to larger
scale developments and to industrial-scale demands for heating and/or cooling, whether
existing or arising from new development envisaged in the Core Strategy.

Requirements for new developments to generate a proportion of their energy
requirements from renewable resources can provide a real incentive to improving
renewable energy production and cutting carbon emissions. However, the use of the
term „generate‟ rather than „meet‟ in the question suggests that electrical generation is
the focus of this approach. The Trust has experience of installing and using a variety of
renewable technologies in its property including air source and ground source heat
pumps, woodchip boilers, solar technologies and passive stack ventilation. Many of
these are focused around heating and cooling without the efficiency losses inherent in
transfer to and from electrical power. Even a modest scale of built development may
provide the best opportunity for cost-effective introduction of such technology but there
may be instances where it is either not possible or not desirable - for example in some
sensitive historic environments.

There is a huge quantity of advice and guidance on the incorporation of measures to
encourage more sustainable patterns of transport in major new developments from, for
example, DCLG, CABE, Sustrans and the Princes Foundation. Key points include
careful consideration of the location, density, design and mix of uses within a
development. Travel Plans provide a mechanism for ensuring a holistic approach to the
consideration of travel within major developments. They can be used for residential
development, in August 2007 the Department for Transport published guidance on
making residential travel plans work.

The Council is, like every public authority, under an obligation to have regard to National
Park purposes when exercising its functions so as to affect land within the National Park
(Environment Act, section 62). Development outside the national Park can have an
effect on land within the National Park, particularly where there are significant views. The


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setting of the national park and any key views from it should therefore be identified for
extra protection. The Trust has protective ownership for the nation of two areas of the
Churnet Valley - Hawksmoor and Toothill. The Trust is keen to see that the valley
remains a living agricultural landscape combining high environmental quality with
meeting the economic and social needs of the area. Expansion of Alton Towers theme
park is a potential threat to the landscape of the valley and needs to be carefully
controlled. Although not perhaps what the Council has in mind when it considers
protecting the countryside, there are also the threats arising from a creeping loss of
working farms to hobby-farming as well as the replacement and enlargement of houses
in the countryside. Even if individually minor, these changes collectively dilute local
distinctiveness, reduce employment opportunities, undermine the affordability of the
housing stock and weaken social cohesion. The Churnet Valley is particularly sensitive
to diffuse development because of its preponderance of small hamlets, isolated houses
and small farms. The Trust would urge the Council to encourage and enable appropriate
re-use of buildings together with farm diversification. These can contribute to providing
affordable housing and local employment opportunities in the area while maintaining and
protecting the living landscape.

Sport England

Main Points
 Prior to submission, Core Strategies must have in place comprehensive and up to
   date PPG17 assessments – an open space strategy, playing pitch strategy and
   indoor sports strategy.
 Sport England recommends that an SPD for open space, sport and recreation is
   produced to identify local open space standards and set out planning contributions
   required for new development. Guidance, examples and best practice is provided on
   the Sport England website.
 Government has set a national target to increase participation in sport of 1% p.a.
   Staffordshire Moorlands current participation rate is 20.4% compared to a national
   average of 21%. Opportunities for physical activity that are fit for purpose are
   required. An additional source of guidance is „Active Design‟ produced by Sport
   England.
 Additional demand for new open space, sport and recreational facilities as a result of
   new housing development (determined from PPG17 assessments) will need to be
   addressed. Sport England‟s sports facility calculator can help to calculate demand
   for key indoor facilities.
 The Council should also take into account the Regional Sports Facility Framework on
   the Sport England website.
 In terms of evidence base, it would appear that the Council‟s Sports Strategy is
   about to become out of date. The Playing Pitch Strategy will need to be reviewed as
   it is some 4-5 years since the assessment work was done. There does not appear to
   be an open space strategy to underpin the local standards and comply with PPG17
   companion guide methodology.

Issues Missed
Ensuring open space, sport and recreation facilities are provided in the right quantity to
the right quality and accessibly to increase participation in sport and recreation by 1%
p.a.




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Spatial Objectives
Spatial objective 7 is not specific. Need to use results of PPG 17 assessments i.e. open
space strategy, playing pitch strategy and an indoor sports strategy.

Top 3 Priorities
   1. To support and enhance the tourism, cultural, recreational and leisure
       opportunities for the District‟s residents and visitors.
   2. To deliver sustainable, inclusive, healthy and safe communities.
   3. To reduce the need to travel and make it easier to travel to jobs and key services
       by more sustainable forms of transport.

Types of Land for Housing
Brown field land should be used in preference to green field land to prevent pressure on
open space, unless it is surplus according to PPG17 assessments.

Design
Design is not just about buildings but the places and layouts of their environments.
Refer to the Active Design document on the Sport England website.

Community Facilities
Sports and recreation facilities should be supported by the Council.

Transport
Major developments should incorporate measures to encourage more sustainable
patterns of transport. Pedestrian / cycle routes, cycle parking / storage, employment
based changing / shower facilities, good signage.

Public Open Space
This should only be built on if surplus according to PPG17 assessment.

Sustrans
Sustainable issues should be at the heart of planning. The Council should aim to
support infrastructure improvements to help pedestrians and cyclists such as crossings,
cycle lanes/tracks, greenways, traffic calmed roads as well as travel planning. Physical
improvements should be made as an integral part of new development design not as an
after-thought. All should be to the highest standards to ensure walking and cycling are
attractive options.

UK Coal Mining Limited

Agree with the issues identified. With the rise in housing numbers, ensuring land is
made available for housing and employment sites as well as improving the retail offer
will be fundamental. Although we encourage attracting higher skilled jobs, it should be
recognised that suitable employment sites for a range of employment types is required
to support a balanced economy and to support the skills and needs of the local
workforce. With an increase in additional homes and the subsequent increase in
population, addressing transport to ensure maximum accessibility to development sites
will be of significant importance.

We agree that the needs of the community will be better met through sustainable
development. To encourage sustainable development, brownfield sites should take


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priority for development. However, it should be acknowledged in the strategy that
sometimes a green field site can represent a more sustainable option than a brown field
site. Underused and poorer areas are key areas for regeneration to provide the required
opportunities for growth and investment. Poorer areas also exist outside of urban areas
and therefore some development in suitable rural locations will be necessary.

The draft spatial objectives are broad and wide ranging. The fourth objective should
take into account the increase in housing projections and should include the recognition
that new housing should meet the needs of residents both now and in the future.
Objective 6 should recognise that in order to maintain and promote sustainable rural
settlements in will necessary to allow some development in the countryside.

Top 3 priorities are:
   1. To develop the District‟s economy and meet local employment needs in the
       towns and villages.
   2. To reduce the need to travel and make it easier to travel to jobs and key services
       by more sustainable forms of transport.
   3. To make provision for the overall land use requirements for the District,
       consistent with the Regional Spatial Strategy and the role of Staffordshire
       Moorlands within North Staffordshire.

Sufficient employment land should be made available and, where possible, this should
be met through the provision of additional employment sites that can be developed to
meet the requirements of modern businesses. Existing employment sites should only be
protected where they meet an identified need or are suited to modern business
requirements. Allocations should be based on providing sites that meet the employment
needs of the district‟s workforce and enable diversified economic growth.

West Midlands RSL Planning Consortium

Principle concerns are to optimise the provision of social / affordable housing and to
ensure the evolution and preparation of consistent policies throughout the region.

The Council‟s Housing Needs Survey needs to be updated by a Housing Market
Assessment in accordance with national guidance. The need for a balanced housing
market (including a full range of special needs housing and house types) based on
evidence of need in the District is vitally important and should be seen as a priority.
Access to affordable housing should be seen as a priority in the District as identified by
credible up to date evidence and provided in all towns and villages where required. A
local definition of affordable housing is needed, taking into account local house prices
and incomes. Identification of sites for 100% affordable housing should take place
where applicable. A reasonable amount of flexibility regarding the sequential approach,
design, development control standards and section 106 agreements is required to
achieve affordable housing. The provision of affordable housing is recognised per se as
both a positive material planning consideration and a planning benefit.

Top 3 priorities in terms of spatial objectives are:
   1. Provision of land use requirements
   2. Provision of affordable housing
   3. Delivery of sustainable, inclusive, healthy and safe communities



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Consider that Option 2 is the most sustainable option allowing for the growth of the main
towns and villages and affordable housing only to be accommodated in the smaller
villages.

Consider that rural exceptions sites should be considered and possibly allocated to
ensure that affordable housing is provided in areas where there is demonstrated need.

Policies to maximise re-use of empty properties for affordable housing should be
included.

Woodland Trust

We would like to see objective 2, highlighting the threat from climate change, embrace
adaptation strategies as well as those simply for mitigation. This is particularly relevant
to the natural environment. Open green space such as woodland can make a significant
contribution towards mitigating the effects of climate change: woodland's role as a
carbon sink for CO2 emissions is well known and it can also help absorb air pollution
and improve water quality. In addition woodland can assist in control of flood run-off from
unseasonably heavy rainfalls, provide shade in hot temperatures for urban environments
and offer biodiversity refuges for species under pressure from the rise in temperatures.
The University of Manchester has calculated that a mere 10% increase in the amount of
greenspace in built-up areas would reduce urban surface temperatures by as much as
4%.

Wood fuel production and product substitution (e.g. timber frame house construction) are
other ways that woodland can help reduce energy consumption and carbon emissions.
However this is only half the story. Mitigation efforts, while crucial in tempering the worst
effects of accelerating climate change are now accepted as being insufficient to prevent
climate change taking place. This means that adaptation strategies must be given a
much more prominent role in planning policy, and especially in relation to biodiversity
and the natural environment. The reality is that climate change is already with us and it
is neither defeatist nor a distraction from the urgency of mitigation to fulfil our
responsibility to enable both people and biodiversity to adapt. We should be taking a
twin-track approach to this - making significant cuts in greenhouse gases and at the
same time taking adaptive action for climate change we are already locked into.
Adaptation is about developing resilient natural systems that can absorb and respond to
change. Developing strategies to help the natural environment cope with these changes
is not an alternative to mitigating the effect of increased CO2 emissions; indeed they
should add to the urgency for action by recognising that change is already with us.

In their current state, key habitats such as ancient woodland are simply not sustainable
given their fragmented character and the immobile nature of many of their characteristic
species, which are 'locked in' by the surrounding environmentally hostile landscape. It is
now widely accepted that the species compositions of semi-natural habitats will change
considerably. Climate change is the biggest threat faced by biodiversity and action to
enable it to adapt will therefore by key to future delivery of section 40 of the Natural
Environment and Rural Communities Act 2004. This requires that 'every public authority
must, in exercising its functions, have regard, so far as is consistent with the proper
exercise of its functions, to the purpose of conserving biodiversity. DEFRA's guidance for
Local Authorities on implementing the Biodiversity Duty (May 2007) specifically states
that "conservation of biodiversity is vital in our response to climate change and in the


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delivery of key ecosystem services such as food, flood management, pollination and
provision of clean air and water". In addition, the report published by DEFRA on behalf of
the UK Biodiversity Partnership, Conserving Biodiversity in a Changing Climate:
guidance on building capacity to adapt (2007), sets out six guiding principles of which
No. 4 is headed 'Establish ecological networks through habitat protection, restoration
and creation'. This goes on to recommend that 'some species will need to move some
distance from their current locality if they are to survive climate change; creating new
habitat, restoring degraded habitat or reducing the intensity of management of some
areas between existing habitat, will encourage this'. The draft consultation supplement to
PPS1, 'Planning and Climate Change' states that "Regional Planning bodies, and all
planning authorities should prepare and deliver spatial strategies that...-sustain
biodiversity, and in doing so recognise that the distribution of habitats and species will be
affected by climate change". We therefore believe that local planning authorities should
take action both to identify areas for new green space to help mitigate the effects of
climate change, and also to identify new habitat creation to help semi-natural habitats
adapt in response to global warming. Action should focus on reducing negative edge
effects from surrounding intensive land-use and buffering and extending existing
valuable habitats such as ancient woodland.

The Trust supports the potential of the West Midlands forestry sector to contribute to the
biomass industry. We support more use of wood as a fuel providing that harvesting is
carried out sensitively and respects the biodiversity, scale and cultural importance of the
site, especially ancient woods. The Trust believes that Woodland owners can benefit
from the developing markets for wood fuel and that income streams generated would
help owners deliver environmental and social benefits from their woods to society.
Developing a market for low-grade timber through wood fuel projects could also make
other woodland management operations with a high biodiversity benefit more
economically viable, for example the restoration of planted ancient woodland sites
(PAWS) currently under non-native conifers, amounting to some 19000ha in the WM
Region. Use of timber from existing woodland can play an important role in sustaining
rural communities, providing employment opportunities in timber harvesting and
transport and supply chains. The DTI estimates that a medium scale 20MW wood-fired
power plant (supplying energy for around 20000 homes) would provide full-time
employment for 48 permanent staff and significant short-term employment opportunities.
The Trust favours development of smaller plants serving around 5000 homes which
would still provide significant economic benefits to local communities. This would help to
support the forestry sector and would offer valuable diversification opportunities for
farmers. Support for renewable sources of energy such as woodfuel in the West Mids
can be found in both the West Mids Regional Energy Strategy (Table of actions, S.2,
Nov 2004) and the West Mids Regional Forestry Framework (S.3 on wood energy,
October 2004). The recently published Woodfuel Strategy for England (Forestry
Commission 2007) further supports woodfuel as a renewable energy source and has
adopted a target of bringing 2million additional tonnes of woodfuel to the market annually
by 2020 across England.

We believe that public open space, particularly green space, should be protected and
enhanced. However we would like to see the Core Strategy go further than this and
adopt a proactive role in the creation of POS through the concept of green infrastructure.
Woodland in particular can play a vital role in the development of areas of green space
and their integration into green infrastructure planning. Trees and woodlands - from a
country park to an urban forest - are a very important element of green infrastructure for


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several reasons". Within this wider 'holistic' definition of green infrastructure, woodland
can play a wide range of roles as well as providing visual landscape linkages, such as
benefiting health, recreation, flood amelioration, carbon sequestration and local
biodiversity. Accessible urban greenspace is another important way of improving
people's quality of life, and proximity and access to woodland is a key issue linking the
environment and health.

We would like to see absolute protection afforded to ancient woodland and ancient trees.
Ancient woodland is irreplaceable, and is our richest habitat for wildlife being home to
more species of conservation concern than any other habitat (supporting some 232
species as outlined in the UK Biodiversity Action Plan 1994). Emerging national and
regional policy now indicates that ancient woodland should be protected absolutely. It
therefore follows that Staffordshire Moorlands has a statutory obligation to protect
ancient woodland. In addition, Objective EB 2 of the West Midlands Regional Forestry
Framework (Forestry Commission, October 2004) states as its aim to protect and
enhance ancient or semi-natural woodland, including through the creation of new native
woodland in targeted locations, which will create habitat networks and increase semi-
natural woodland cover. There is a need in Staffordshire Moorlands to ensure that this
ancient tree heritage continues in a sustainable way so that future generations will be
able to enjoy the benefits of ancient trees after the current specimens are gone. There
are records of ancient trees in Staffordshire Moorlands (eg ancient oak recorded near
the Churnet Valley and this plus the above average concentration of ancient woodland in
the area - suggests that there could be other concentrations and individual ancient trees
that we may not know about in the District. It is important that there is no further
avoidable loss of ancient trees through development pressure, mismanagement or poor
practice. The Ancient Tree Forum (ATF) and the Woodland Trust would like to see all
such trees recognised as historical, cultural and wildlife monuments scheduled under
TPOs and highlighted in plans so they are properly valued in planning decision-making.
There is also a need for policies ensuring good management of ancient trees, the
development of a succession of future ancient trees through new street tree planting and
new wood pasture creation, and to raise awareness and understanding of the value and
importance of ancient trees. In addition the ATF would like to see a commitment to
auditing fully the ancient tree resource of Staffordshire Moorlands in case there are as
yet unrecorded ancient trees which should be given protection and sympathetic
management. Therefore we would like to see ancient woodland and ancient trees given
extra protection.

Parish Councils (in alphabetical order)

Bagnall Parish Council

The document would be strengthened by a reference to community safety and reduction
of petty vandalism and crime. The vision needs a stronger emphasis on safe
communities with opportunities for young people and emphasis on protecting the rural
beauty of areas surrounding the market towns.

The Parish Council‟s top 3 priorities are:
    To ensure the long term viability of the 3 market towns,
    To promote local distinctiveness by means of good design and conservation,
      protection and enhancement of heritage, environmental and cultural assets
      throughout the District.


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        To protect and improve the countryside and the diversity of wildlife and habitats.

The Parish Council would like to see town based development and opposes rural
dispersal into the green belt. It is considered that there should be a strong focus on
developing brown field land (including the conversion of historic buildings) over green
field land at increased densities to preserve the beauty of the Staffordshire Moorlands.
The Parish Council would like to see the Parish of Bagnall preserved. Consider that
there should be a total focus upon regeneration of brown field sites and industrial
heritage sites.

The Parish Council consider that half of new housing in the Staffordshire Moorlands
should be affordable and that housing development should be limited to certain parts of
the District if a restriction on house building in the Staffordshire Moorlands is required.

In terms of employment sites, the Parish Council would like to see existing employment
sites and premises being protected for such uses and if new allocations are required
them being located on a number of smaller sites. The Parish Council consider that a
limited amount of retail development should occur in Leek and Cheadle on town centre
sites only and that the restoration of shops should be continued as it is making a
massive difference.

Rural buildings should be allowed to be converted to residential where they are
redundant with strict control of materials etc. and that priority should be given to a
commercial use only where the previous use is uneconomic. The general quality of
design needs improvement in terms of poor materials like use of brick in areas where
stone is the primary construction material. Also, controlling the removal of character
from unlisted buildings and additions like UPVC windows. Those buildings within
villages in particular would benefit from further design guidance.

In terms of consideration of development and flood risk, this is difficult to respond to and
a national appraisal of strategy is needed as well as investment in infrastructure to make
it fit for purpose. The use of renewable energy in the Staffordshire Moorlands should be
a high priority. Types of renewable energy suitable for the Staffordshire Moorlands are
large scale commercial biomass and hydroelectricity along with small scale domestic
solar panels. The Parish Council would query the practicality of new development being
required to generate a proportion of its energy requirements from renewable resources.

The Council should aim to support community facilities especially transport schemes for
the elderly and youth centres. Major development should incorporate measures to
encourage more sustainable patterns of transport like a Moorlands tram metro system
using old lines. Public open space should be protected from development under all
circumstances. The regeneration of Biddulph High Street in line with work in Leek would
be beneficial. The Parish Council wishes to see the protection of historic areas like
Bagnall in the final plan.

Cheddleton Parish Council

   Option 3 is the preferred option.
   Housing to meet local needs.




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   There needs to be a change of policy to build the maximum number of affordable
    housing for local needs. Such housing should be built in conjunction with the larger
    executive homes. People should be able to purchase a home in their own village.
   Where there is a community need, developers should be obliged to make a
    contribution to a community project.

Endon with Stanley Parish Council

The Parish Council accepts that there is a need to allow a limited amount of residential
development for local needs. Consider that when all available land within the settlement
boundary has been developed, anyone with a genuine and proven desire to live within a
particular Parish should have the opportunity to do so upon presentation of proof of
entitlement. This could be factors like education, training, occupation, hereditary
attachment to the parish and practical involvement in parish life and a commitment to the
community. There is a need to facilitate the continued residence of young people who
meet these criteria and wish to remain within their parish. In Endon, the loss of such
people has resulted in a shortage of people to take part in community activities and
events. This could be imposed through a section 106 agreement on property to cover
current and future occupiers. Considers that this type of arrangement has worked well
with agricultural dwellings and could help to maintain a satisfactory balance of age
groups and abilities in Endon and elsewhere.

A more sensitive approach to those who demonstrate entrepreneurial skills would be of
great benefit to the District, for example, JCB in Cheadle.

The Parish Council‟s top 3 priorities are:
    To provide new housing that is affordable, desirable and meets the needs of
      residents of the Moorlands.
    To maintain and promote sustainable rural settlements with access to services
      for all.
    To deliver, sustainable, inclusive, healthy and safe communities.

It is important that we retain viable local services and provisions with a minimum or no
loss of services within the community. Support the distributed development option.
Consider that brown field land as a rule should usually be used in preference to green
field land. However, on occasions, green field land should be considered for
development, depending on public transport and facilities. It is essential to ensure that
the unique characteristics of the various communities are enhanced and not
compromised. The issue of increased densities is site dependent so it is difficult to be
more specific. Consider that affordable housing is needed in towns and villages but
governed by local needs criteria. A majority of new housing in the Moorlands should be
affordable. In Endon, smaller pockets of development can be accommodated rather
than producing ghetto style housing. If the Council is required by Government to restrict
the number of houses built, a system where only a set number of houses per year are
granted planning permission with the exception of affordable housing and regeneration
schemes applying a flexible approach would be suitable.

A flexible approach to redundant employment sites that no longer meet the needs of the
community should be taken with new allocations being provided through allocating a
number of smaller sites. A limited amount of new retail development on town centre



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sites only should occur in Leek, whilst also making better use of existing properties with
more choice for shoppers. It is essential to provide a better balance between banks,
building societies and estate agents, for example and retail outlets. There is limited
parking available so suggest park and ride.

In terms of circumstances under which rural buildings should be allowed to be converted
to residential use, there has got to be a balanced, mixed economy that in the long term
is sustainable. The infrastructure needs to be taken into consideration. The
circumstances allowed should equate to a direct contribution to the area (e.g. affordable
housing). Employment / tourism uses should take preference over commercial benefit.
The Parish Council considers that the general quality of design of new and refurbished
buildings requires improvement. The design should go along with 3 aspects that should
not be viewed in isolation, namely, materials, landscaping and location. There is room
for improvement in most areas including - new builds, refurbishments, change of use
from industrial to residential. Consider that the planning department should demand a
higher presentation of plans submitted for approval.

In terms of the issue of development in flood risk areas, common sense should be
employed. Why increase the risk of a serious flooding situation? Proper maintenance of
water courses is essential. The use of renewable energy in the Staffordshire Moorlands
should be a high priority to include large scale commercial wind farms, biomass, hydro-
electricity and small scale domestic solar panels and wind turbines. Every effort should
be made to remove the artificial and unnecessary barriers to the development of
hydroelectricity. Ground source heat pumps are another renewable energy source to be
considered. All new developments should be required to generate a proportion of their
energy requirements from renewable resources. Higher standards of insulation should
be a requirement.

The Council should aim to support all community facilities in towns and villages. Major
developments should incorporate measures to encourage more sustainable patterns of
development.      The blanket protection of all rail routes, facilities and assorted
infrastructures should be incorporated. The Council should aim to protect public open
space from development. Run down areas which would benefit from redevelopment are
the Thomas Boltons site at Froghall.
The Parish Council believes that all countryside areas should be protected.

Forsbrook Parish Council

The Parish Council‟s top 3 priorities are:
    Strong infrastructure to support any residential or commercial development.
    Low cost housing in suitable areas on brownfield sites.
    Protection of green belt and special landscape areas.

Developments should be focussed where infrastructure is strong i.e. schools, medical
services, transport and an adequate road network. Rural settlements suitable for further
development are areas where there are large brownfield sites. The District Council
should be aware of large residential and commercial developments which border the
Moorlands area. The Parish Council would like to see an emphasis on retaining green
field and special landscape sites.




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The Parish Councils preferred option is focussed development and it is considered that
brown field land should always be used in preference to green field land. Densities
should not be increased at the expense of depriving residents of open space and
adequate parking facilities. Affordable housing is needed in some areas and should be
provided as demand dictates, which should be assessed by the type of property on the
open market. In terms of mixing affordable housing with other types of housing or
allocating separate land for affordable housing only, this is difficult to answer because
some types of affordable property could devalue higher priced property. If the Council
has to restrict the number of houses built in the District, limiting development to certain
parts of the District would be appropriate.

In terms of employment land, the Council should protect existing employment sites and
premises for employment use. This approach may not be appropriate if existing
employment sites are not a viable proposition and with regard to vacant premises there
are no interested parties. When considering the allocation of new employment sites,
these should be a mixture of small and large sites. A limited amount of new retail
development should take place in Leek and Cheadle on edge of town centre sites if
there are no available empty premises to accommodate the business in the town centre,
and not at the expense of affecting existing businesses.

Rural buildings should not be considered for conversion to residential use. The general
quality of design in new and refurbished buildings in the Staffordshire Moorlands needs
improving. New builds in village locations should reflect the existing street scene. The
Council should aim to only allow development to take place in settlements with little or
no risk of flooding. Development should not be allowed on sites with a low-medium risk
of flooding if mitigation measures are taken to remove the risk because in the future this
will impact on residents being able to get insurance.

The use of renewable energy in the Staffordshire Moorlands should be a medium
priority. Forms of renewable energy suitable for the Staffordshire Moorlands are large
scale commercial biomass and small scale domestic solar panels. In new residential
property, developers should be considering installation of solar panels at the time of
construction together with other measures which will help the environment.

The Council should aim to support community facilities like Youth Community Centres
and Community Halls. Major developments should incorporate measures to encourage
more sustainable patterns of transport but people will still choose private vehicles for the
majority of journeys. Public open space should be protected from development without
exception. The three major towns probably have more run down areas than villages but
equal emphasis should be placed on improving areas in some villages. Special
landscape areas and areas of natural beauty in the Staffordshire Moorlands require
extra protection.

Heaton Parish Council

The Parish Council considers that the draft vision is good, provided it can be brought to
fruition. The Parish Council‟s top 3 priorities are:
      To develop the District's economy and meet local employment needs in the
         towns and villages.
      To deliver sustainable, inclusive, healthy and safe communities.



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        To reduce the need to travel and make it easier to travel to jobs and key services
         by more sustainable forms of transport.

The Parish Council considers that the majority of development should be focused in
Leek, Cheadle and Biddulph, with other development in larger villages in the Leek and
Cheadle area. Other improvements the Parish Council would like to see are sewerage
works where there are none. The Parish Council‟s preferred option is focussed
development. It is considered that brown field land should always be used in preference
to green field land and that densities should not be increased to accommodate more
housing on sites. Affordable housing is needed in towns and villages where there are a
lot of young people. A majority of new housing in the Staffordshire Moorlands should be
affordable on sites allocated for this purpose only. If the Council is required to limit the
number of houses built, development should be limited to certain parts of the District.

In terms of ensuring there is sufficient employment land available for local needs,
existing employment sites and premises should be protected under all circumstances
and new ones allocated to meet the demands of modern business. New employment
allocations should be on a number of smaller sites. A limited amount of new retail
development should occur in Leek in town centre and on edge of centre sites. Under no
circumstances should rural buildings be allowed to be converted to residential, priority
should be given to a commercial use.

The general quality of design in new and refurbished buildings would benefit from
improvement and in particular design guidance would be useful for all new buildings. It
is considered that development should be allowed on sites with a low-medium risk of
flooding if measures are taken to remove the risk. The use of renewable energy in the
Staffordshire Moorlands should be a low priority. Appropriate forms of renewable energy
for the Staffordshire Moorlands are large scale commercial wind farms and small scale
domestic solar panels. If possible, major new development should be required to
generate a proportion of its energy requirements from renewable resources.

The Council should aim to support community facilities in towns and villages. Major
developments should incorporate measures like safe footpaths/ cycle ways and regular
public transport to encourage more sustainable patterns of transport. Public open space
should be protected from development in all cases.

Ipstones Parish Council

Additional issues are:
    A need for balanced housing for senior citizens; executive and some in between.
    Do not want housing estates in rural areas - should be more infill for local need
    To ensure new roads are wide enough for parking and to give access to the
       emergency services
    To eliminate the need for landfill sites by increased re-cycling and use of
       incinerators.

There are a number of additions needed to the vision. Developments should be viable
and sustainable with work for all people in a good, clean environment. Rural areas
should not become a commuter belt. Towns and village need to retain their identity.
Quality shops should be encouraged in all town centres. Business plans for towns.



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There should be fair rates for all businesses. Villages need to stay vibrant to encourage
local businesses.

The following points are raised in relation to the spatial objectives.
    new jobs needed for the increase in population
    new houses to be energy efficient i.e. solar panels
    a policy introduced to encourage energy efficient developments
    alternative forms of transport i.e. railways and canals to reduce the number of
        HGVs on the roads.

The Parish Council‟s top 3 priorities are:
    Good health facilities based locally,
    nearly full employment with apprenticeships available - to ensure there are
      enough skilled people,
    a good mix of housing for both young and old, affordable and bigger houses that
      are built sympathetically in order to protect the countryside.

The Parish Council considers that it is not fair to restrict development to larger villages
only as all villages should have equal opportunity depending on local need. There
should be no housing estates in villages. Development should be limited to infill and that
for local need so that villages do not loose their identity. Villages do need to remain
vibrant to encourage younger people and small businesses.

Distributed development is the most favoured option - but members thought that only 4
options was not enough choice. It was thought that the percentage split was too high for
the rural areas which could have been 25%, giving an extra 5% to Cheadle.

Under the focussed development option, the Boltons site at Froghall should be
considered. The Parish Council is totally against housing on this site but would prefer to
see a small well designed good quality shopping/craft village, leisure park and heritage
centre. This would enhance the area immensely and bring employment and increased
tourism to the area. Froghall is already a tourist area with the Churnet Valley Railway
and canal so would benefit from this.

Brown field land should not always be used in preference to green field land as some
brownfield sites should be turned into leisure sites and park land for the benefit of the
local community/area. Densities should not be increased. Affordable housing is only
required in limited numbers where there is local need and should include bungalows for
senior citizens. Developments should be mixed with affordable housing, housing for
senior citizens, executive housing and a range of housing in between. Development
should be limited to certain parts of the District if restrictions on the number of houses
built in the Staffordshire Moorlands are required.

Existing employment sites and premises should be protected to ensure there is enough
employment land available to meet local needs. New employment sites should consist
of a number of smaller sites. A limited amount of retail development should occur in
Leek and Cheadle on town centre sites only.

Rural buildings should be allowed to be converted to residential use when the building
cannot be used for its original use and when the building and surroundings will be



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enhanced by the conversion. Equal consideration should be given to a commercial use
for such buildings and determined on the merits/location/accessibility etc.

The design of new and refurbished buildings in the Moorlands needs to be more
environmentally friendly i.e. solar panels etc. New buildings would benefit from further
design guidance - in particular new factories need to be designed so that they are
sympathetic to the area. Developments should not be built on flood plains.

The use of renewable energy in the Staffordshire Moorlands should be a medium
priority. Forms of renewable energy suitable for the Moorlands are large scale
commercial biomass and hydroelectricity and small scale domestic solar panels and
wind turbines. All new developments should be required to generate a proportion of
their energy requirements from renewable resources.

The Council should aim to support community facilities like village halls, post offices,
doctors surgeries and bus services in all areas. Major development should incorporate
measures to encourage more sustainable patterns of transport such as regular, cheap
public transport, safe well lit footpaths, cycle tracks on major roads, clear walkways,
better canal system, better railways.

The Council should aim to protect public open space from development without
exception. The Churnet Valley between and including Oakamoor – Froghall-Consall-
Cheddleton is an area of the countryside that requires extra protection.

Kingsley Parish Council

In terms of missing issues, no mention is made of the connection between population
and schools. Although administered by Staffordshire County Council schools are
integral to LDF. It is considered that the draft vision is ambitious but practicable and
should include an element about each community retaining its identity. It is considered
that schools are integral to each spatial objective. The Parish Council‟s top 3 priorities
are:

        To develop the District‟s economy and meet local employment needs in the
         towns and villages.
        To provide new housing that is affordable, desirable and meets the needs of the
         residents of the Moorlands.
        To maintain and promote sustainable rural settlements with access to services
         for all.

The majority of development should not be focussed in one or more of the towns as this
would have a detrimental effect on employment and housing. Kingsley is a larger village
which could accommodate additional development. Other settlements which could
accommodate additional development are Kingsley Holt, Froghall and Whiston. It is
considered that the focussed development option would have a detrimental effect. The
distributed development option is most suitable for Kingsley Parish but the town and
larger village based option may have some merit in Kingsley.

Brown field land should not always be used in preference to green field land and
densities should not be increased on sites to accommodate more housing. Affordable
housing is needed in Whiston. A small proportion of new housing in the Staffordshire


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Moorlands should be affordable but as part of mixed schemes not on dedicated sites.
Development should be limited to certain parts of the District if restrictions on the
number of houses built in the Staffordshire Moorlands are required.

Existing employment sites and premises should be protected to ensure there is enough
employment land available to meet local needs. New employment sites should consist
of a number of smaller sites. A limited amount of retail development should occur in
Leek and Cheadle on town centre sites only.

Rural buildings should be allowed to be converted to residential use in all circumstances
in order to maintain such buildings. Priority should not be given to commercial uses.
The quality of design in new and refurbished buildings in the Staffordshire Moorlands is
in need of improvement. Agricultural buildings would benefit from further design
guidance. Developments should be allowed on sites with a low – medium risk of
flooding if measures are taken to remove the risk.

The use of renewable energy in the Staffordshire Moorlands should be a high priority.
Forms of renewable energy suitable for the Moorlands are large scale commercial
hydroelectricity and small scale domestic solar panels and wind turbines. All new
developments should be required to generate a proportion of their energy requirements
from renewable resources where practicable.

The Council should aim to support community facilities in all areas. Major development
should incorporate measures to encourage more sustainable patterns of transport where
possible. The Council should aim to protect public open space from development without
exception. The Churnet Valley in general and especially Froghall would benefit from
redevelopment, would suggest a mixed scheme of housing, tourism and employment.
The Churnet Valley in general and Whiston in particular require extra protection.

Oakamoor Parish Council

The Parish Council would like the issue of extending services and facilities to rural areas
without the need for individual travel to main towns, e.g. Postal, banking, grocery, police,
medical to be covered. The vision should reflect more commitment to law and order
especially alcohol and drug abuse and commitment to 'out of hours' medical facilities in
the region. One of the spatial objectives should cover delivery of an acceptable level of
policing back to our towns and villages and reducing the current levels of drug and
alcohol abuse. The Parish Council‟s top 3 priorities are:
     To protect and improve the countryside and the diversity of wildlife and habitats.
     To develop the District‟s economy and meet local employment needs in the
        towns and villages.
     To provide new housing that is affordable, desirable and meets the needs of
        residents of the Moorlands and improved policing.

The Parish Council‟s preferred option is distributed development. Brown field land
should always be used in preference to green field land but not for infill developments in
large gardens. Densities should not be increased on sites to accommodate more
housing. Affordable housing is needed in rural areas. Half of new housing in the
Staffordshire Moorlands should be affordable but as part of mixed schemes not on
dedicated sites. Development should be limited to certain parts of the District if
restrictions on the number of houses built in the Staffordshire Moorlands are required.


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Existing employment sites and premises should be protected and new allocations should
be made to meet the demands of modern businesses to ensure there is enough
employment land available to meet local needs. New employment sites should consist
of a number of smaller sites. A limited amount of retail development should occur in
Leek and Cheadle on town centre sites only.

Rural buildings should be allowed to be converted to residential use to preserve old
buildings in a good state of repair enhancing the environment. Priority should always be
given to commercial uses. The quality of design in new and refurbished buildings in the
Staffordshire Moorlands is in need of improvement in terms of diversity to make it less
bland by using traditional and local materials. Commercial properties, especially retail
shops would benefit from further design guidance. The Council should only allow
developments to take place in settlements with little or no risk of flooding.

The use of renewable energy in the Staffordshire Moorlands should be a high priority.
Forms of renewable energy suitable for the Moorlands are large scale commercial
biomass, hydroelectricity and small scale domestic solar panels. All new developments
should be required to generate a proportion of their energy requirements from renewable
resources.

The Council should aim to support community facilities, especially basic postal, banking
and medical in rural areas. Major development should incorporate measures to
encourage more sustainable patterns of transport by having serious restrictions on car
parking facilities. The Council should aim to protect public open space from development
without exception. Areas adjacent to commercial and quarrying activity in the
Staffordshire Moorlands countryside require extra protection.

Werrington Parish Council

The Parish Council would like the issues of Leisure facilities, better public transport to be
covered. The Parish Council‟s top 3 priorities are:
    Affordable housing
    More free transport for under 16s.
    Community facilities

It is considered that the majority of development should be focussed in the three towns,
consequently, the Parish Council‟s preferred option is town based development. Brown
field land should always be used in preference to green field land. Densities should not
be increased on sites to accommodate more housing. Affordable housing is needed
throughout the whole of the Moorlands. Half of new housing in the Staffordshire
Moorlands should be affordable but as part of mixed schemes not on dedicated sites. A
system where only a set number of houses per year are granted planning permission
with the exception of affordable housing and regeneration schemes should be operated
if restrictions on the number of houses built in the Staffordshire Moorlands are required.

Additional employment sites should be allocated in suitable locations to meet the
demands of modern business to ensure there is enough employment land available to
meet local needs. New employment sites should consist of a number of smaller sites. A
limited amount of retail development should occur in Leek and Cheadle on town centre
sites only.



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Rural buildings should only be allowed to be converted to residential use in exceptional
circumstances with priority being given to commercial uses as appropriate. The quality
of design in new and refurbished buildings in the Staffordshire Moorlands is in need of
improvement. Older buildings would benefit from further design guidance. The Council
should only allow developments to take place in settlements with little or no risk of
flooding.

The use of renewable energy in the Staffordshire Moorlands should be a high priority.
Forms of renewable energy suitable for the Moorlands are large scale commercial
biomass, hydroelectricity and small scale domestic solar panels. All new developments
should be required to generate a proportion of their energy requirements from renewable
resources.

The Council should aim to support community facilities, especially those in Werrington.
Major development should incorporate measures to encourage more sustainable
patterns of transport. These measures should be more public transport and affordable
housing. The Council should aim to protect public open space from development
without exception. Wetley Moor, Werrington is an area of the Staffordshire Moorlands
countryside which requires extra protection.

Local Groups (in alphabetical order)

Biddulph Neighbourhood Forum (27th November 2007)

Summary of Questions/Comments:

      Question raised on house building – comment that housing provision for Biddulph
       already sufficient to meet needs to 2011, why is there a need for more housing in
       Biddulph?
      Question raised as to whether development would be on brownfield sites.
      Several questions raised on affordable housing – what is meant by affordable
       housing, what is current policy? How do you calculate affordability? I person asked
       whether Council was proposing to build affordable housing.
      Councillor Harris made the point that Newpool Meadows was a greenfield site
       when priority was to use brownfield sites – also he considered that there was not
       an issue of affordability in Biddulph as there were houses below £100k and also
       opportunities to get cheaper housing in Stoke.
      Question raised regarding increasing number of elderly in the District and whether
       Council would be seeking to renovate properties to make them more suitable for
       older people. Person from Help the Aged provided an information note on housing
       and the elderly – specific mention was made of Lifetime Homes standard.
      Question raised regarding employment land as to how much of the Victoria
       Business Park has been taken up and why we are looking for more employment
       land when there is sufficient already. Also whether we know what is needed in the
       future.
      Questions also raised regarding renewable energy – could we provide wind farms
       on top of Biddulph Moor? Concern raised regarding cost of installing local
       renewable energy schemes e.g. solar panels. Also general comments made about
       need to address climate change issues.




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Blythe Bridge Neighbourhood Forum (20th November 2007)

Summary of Questions / Comments:

      Will green belt be built on?
      Consider that local buildings of historic importance e.g. pubs need more protection
       from demolition for new development like housing.
      Will the recreation ground in Blythe Bridge be built on? Would not like to see this
       happen.
      How much brown field land is available in Blythe Bridge? If there are not sufficient
       amounts would green field land be required?
      How did development on land that is now Millbrook occur when it was a green field
       site?
      Recent new development in Blythe Bridge has caused traffic congestion – thinks
       adequate infrastructure should be put in place for new development.
      Are the planning laws on domestic extensions due to be relaxed so it will become a
       „free for all‟?
      Are the comments made by Parish Councils on planning applications taken into
       account in the decision making process?
      New development in Cheadle affects traffic levels in Blythe Bridge.
      Clarification of the definition of green field land.

Cheadle Neighbourhood Forum (28th November 2007)

Summary of Questions/Comments:

      Question about the rationale of Special Landscape Area (SLA) policy – what is it
       based on? Some strong views about recent cases for new dwellings or extensions,
       which were refused on grounds of being in SLA, in unattractive countryside. Will
       the policy be deleted/replaced?
      Specific question about Mobberley quarry – some people thought recent
       applications to refuse new houses on ex-quarry land perverse.
      Question about why core strategy timeline is to 2026? An earlier finish might catch
       the public‟s attention more. Some related discussion about the RSS, its timeline,
       and the planning policy hierarchy.
      A comment that existing Cheadle road infrastructure is poor and cannot
       accommodate further growth: there should be no new-build until there are new or
       improved roads.

Cheddleton Daytime Neighbourhood Forum (19th November 2007)

Summary of Questions/Comments:

      Question from Cheddleton Parish Council member – considered that local input
       into LDF important, commented that PC had already made comments, does the
       Council give more weight to PC or public comments?
      Several questions raised on house building – how does the Council manage and
       control supply? Considered that there was a need to ensure continual supply.
      Question raised on affordable housing – what are the types of affordable housing,
       is the Council committed to delivering low-cost housing as well as social rented?


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        Asked what the Council‟s definition of affordable housing was. Considered there
        was a need for more affordable housing, including low-cost housing.
       Transport links to Cheddleton were considered to be poor. Need for faster rapid
        transport links to Potteries.
       Provision of jobs in the area considered important – concerned that Council does
        not appear to be doing much to help existing businesses and attract new business.
        Examples cited at Wardles were employment opportunity was lost and at ex-
        Britons Paper Mill were flooding issues were preventing their expansion.

Cheddleton Evening Neighbourhood Forum (19th November 2007)

Summary of Questions/Comments:

       Comment that Cheddleton is large village (largest in England?) and future
        residential growth needs to be matched with infrastructure – shops and facilities,
        public transport. At present there is shortage of some types of community facilities.
       Linked comment that public transport through Cheddleton (and District generally) is
        poor. Questions about how public transport system is funded/allocated, and
        whether this is in any way coordinated with LDF process.
       Affordable housing questions/issues:-
    -     View that there was extreme shortage in Cheddleton in particular, especially
          smaller, starter-size housing.
    -     Concern that minimum threshold (15 units) was too high, or in any case criticism
          that developers would „duck under‟ it, and given this.
    -     questions about how many units were required for:-Joshua Wardles/St Edwards/
          Cheddleton Park Avenue
    -     Comment that on qualifying developments, the 33% minimum standard is just a
          minimum, ergo it will never be 100%
    -     Comment from one prior applicant that earlier Council position was that there
          was no need for affordable housing outside 3 towns – at odds with local opinion
    -     Linked question as to whether there was any more recent Council evidence/data
          saying there is now need; and..
    -     ..can this information be used in any way to compel developers to provide more
          than they have to?
    -     Questions about Council application of greenfield ban on residential development
          (particularly given recent refusal of one Greenfield resi application in the village)
    -     Further questions about greenbelt policy. One person felt that it was applied
          inconsistently across different parts of the country.

Endon Neighbourhood Forum (26th November 2007)

Summary of Questions/Comments:

       Clarification as to how the Core Strategy process would affect Endon in particular?
       When prompted locals felt there was a need for affordable housing in Endon.
        However some felt that existing Greenfield sites were also important, so the
        identification of sites for such housing would be controversial. One comment that
        Endon is already heavily built up (with a good range of facilities); another person
        asked about whether new residential developments must contribute to public open
        space.



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      The related point as to if Endon was a „growth village‟, then this would necessitate
       the development of some Greenfield sites in the village, or outside the village
       boundary (in the greenbelt).
      A related discussion about the importance of existing greenbelt.             It was
       unanimously felt that the local greenbelt was of high value. This is because it acts
       as a buffer from Stoke, giving Endon a separate identity. In particular the area in
       between Endon and Stockton Brook was considered important – a number of
       historical greenbelt cases in that area were discussed.
      A question about flood risk, and policy on residential development in flood risk
       areas.
      Concern that there is no spare capacity in existing Endon schools - questions
       about educational contributions policy for new residential developments in Endon.
       Related question about impacts on POS (see above). Another comment that
       parents have freedom to send children to any school – so developments outside
       Endon could affect Endon schools, and vice versa.
      One comment that there is not enough existing housing stock designed for the
       elderly (e.g. bungalows, or lifetime homes)
      Comment that new residential developments may lead to pressure on roads,
       leading to need for road improvements. Related discussion on what the Local
       Transport Plan (LTP) proposes. One comment that LTP largely focuses on bus
       services rather than new roads and a related comment that the LTP and LDF
       processes are not otherwise coordinated in the same areas.

Leek Neighbourhood Forum (22nd November 2007)

Summary of Questions/Comments:

      John Russell – Leek and District Civic Society. More development could be
       accommodated but wanted to warn about overcrowding. Gave the example of
       Baddeley Green development which they think is awful. Need to recognise that
       people aren‟t doing without their own transport (cars) – need to think about what
       we, the citizens of Leek, want/ require not just meeting Government requirements.
       Along with social housing we need to also consider the higher end of the market to
       retain those people in the area. Issues of design needing to be appropriate for the
       area/ respecting the character of the area. There is a need to try and insist that
       renewable energy is incorporated in new housing development – solar panels etc.
       Protecting of shops reflecting the market town history, meeting parking
       requirements within the town. Keen on green, whether that is green planting,
       green energy. Enhancing any green space we have.
      Queried whether we are going too far into the future, looking to 2026. It was
       explained that we are required to do it by government.
      Mills into apartments, would query whether Leek is an apartment culture? Chair put
       this statement/question to the group, no particular response received.
      Raised concerns over the fact that there is no mention of roads within the
       document – Haywood Street being blocked. Need the issue of roads to be
       addressed before other things. Raised the issue of Cornhill - railway which may
       come into Leek and canal development - transport/ roads will be needed to reach
       the railway/canal. These issues need to be addressed before anything else.
       Explained it‟s a consultation document.




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      Issue of Cornhill raised and specifically that there are small pockets of land which
       are in different ownerships and piece of land which people don‟t even know who is
       the owner of. There are issues relating to the tunnel and current anti-social
       behaviour problems.
      Queried whether there was an agenda already there as ways to implement/
       measures had already been established in the consultation document. The
       difficulties in producing the document – in terms of needing to give people
       something to go on/ something there for them to give views on rather than a blank
       piece of paper were explained.
      Question about the timescale for producing the document.
      It was stated that any population predictions should be looked at carefully and that
       growth should not take place if these predictions indicate that there won‟t be a
       population increase. Also need to consider the implications for town improvement.
      A question was raised about whether there will be proportions for sheltered
       housing/ older persons housing within the housing figures? Discussion about extra
       care housing.
      Suggestion of the re-use of mills for social housing.
      Would like feedback on how the public have influenced the plan.

Werrington Neighbourhood Forum (14th November 2007)

Summary of Questions/Comments:

      Concerned about houses in multiple occupation (and anti-social activities) why do
       these not require planning permission? Example – Marsh Close.
      Concern raised about housing development in back gardens and residential
       amenity of neighbours.
      Question raised on removal of local occupancy condition – this was considered to
       be a good mechanism to retain new housing for locals. Would like to see this kept.
      Question raised about level of housing provision up to 2026 if the population is not
       expected to rise significantly.
      Affordable housing – desperate need for affordable housing. Especially need
       housing for older people (especially bungalows) to free up larger family homes for
       younger families.
      Question raised about whether the infrastructure can cope with additional housing,
       access and drains etc.
      Loss of facilities/opportunities – wanted the site of the former infant school for a
       community centre but was approved for housing.
      Need for play facilities – especially youth shelter. Qualitative improvements
       needed to existing sites.

Rural Partnership Meeting – 20th November 2007

The board asked for a number of issues / concerns to be taken into account:

    a) Small businesses need the opportunity to convert buildings in order to grow.
    b) In order to keep young people in the area it is necessary to allow conversion of
       existing buildings for domestic purposes. Concerns were expressed that
       constraints were greater in the Peak Park.
    c) Planning applications should be encouraged and successful ones published.


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    d) More employment opportunities are needed in the rural area in order to retain the
       young people.
    e) Measures should be put in place to stop the „drawing off‟ of young people away
       from rural areas and into the towns, with the permanent loss of essential rural
       skills.
    f) More support is needed for tourism (significant fall in business experienced in
       2006-07).
    g) Concern expressed that in the consultation document the significant area of
       Staffordshire Moorlands that falls in the Peak Park is not included in the
       consultation. Board request that when the Peak Park Planning Authority reach
       the same stage in their LDF process (approximately 12 months time) that the
       rural executive board is a key consultation body.
    h) Transport policies and plans should be carefully co-ordinated between SMDC,
       Peak District National Park, Staffordshire County Council and Derbyshire County
       Council.
    i) Closer co-operation is needed between SMDC and Peak District National Park
       like joint meetings to make decisions about common issues.
    j) Need for affordable housing to buy and rent.
    k) Coherent strategy needed for renewable energy.

Urban Vision North Staffordshire

Issues & Options booklet is well structured, clearly written and user friendly. Option 3 –
distributed development, is the least acceptable as this would be the least sustainable
option and reduce local distinctiveness. A carefully defined version of option 2 would be
most appropriate to concentrate the majority of new development in the towns and
ensuring the viability of the rural areas by allowing infill development only in villages and
not peripheral expansion, to ensure minimal adverse impact on landscape.

New housing tends to follow generic designs with little regard for local distinctiveness.
This issue needs to be given greater emphasis in the Core Strategy as it is fundamental
to the future success of the District.

Character studies should be carried out in all areas where development is likely to take
place in order to define the special qualities of those areas. From this understanding,
appropriate policies can be formulated to protect and enhance areas where development
is likely to take place. Master plans should be produced showing how the agreed levels
of new development will be integrated into each town to preserve and enhance its
character.

The character of Leek in particular is in large derived from mill buildings. If vacant mills
are to survive then conversion of them should be favoured. The Core Strategy should
place more emphasis on the re-use of these mills and other historic buildings and
brownfield land and constrain the easier opportunities presented by greenfield sites.

There is a need to define more precisely what is meant by good design. Creative new
design which respects its context should also be encouraged to provide new buildings of
true quality which will become tomorrow‟s heritage. Imitations of past architectural styles
should be discouraged.




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Hard to Reach Groups

Endon School Pupils (31st October 2007)

        Support for development which would support schools, facilities and services in
         villages. Building where there are already facilities.
        Preferred option is town and larger village based development.
        It is a good idea to develop brown field land in preference to green field land
         because otherwise would lose green field.
        Building houses/apartments closer together can put people off. Higher densities
         in towns can give a mix of housing (can provide housing/ apartments which are
         affordable) but not in villages. Issue of gardens etc for families.
        Haven't had experience of people with house price issues/ affordability issues.
        In terms of ensuring there is sufficient employment land available for local needs,
         consider that a mixture of protecting existing employment sites and allocating
         new ones in suitable locations to meet the demands of modern business would
         be appropriate - with all the houses employment will be needed. With
         employment customers will be needed.
        A large amount of new retail development should occur in Leek on town centre
         sites. Older shops are closing down, impact of this. Need more shops to draw
         people in. Leeks a good place to build. If you attract too large a retail you will ruin
         the feel of Leek. Need to building in town centre so people do not have to walk
         out of town centre. Need to develop in the town centre to support cafes etc.
         Cheadle also needs some retail development.
        In terms of circumstances under which rural buildings should be allowed to be
         converted to residential use, this is often going to be a large house, not going to
         attract younger people - expensive. Could be converted into multiple cottages for
         tourism supporting local shops etc.
        In terms of allowing development on sites with a low-medium flood risk, if
         measures are taken to remove the risk, people may not want to live there if there
         is a risk and flood measures may look unsightly.
        The use of renewable energy in the Staffordshire Moorlands should be a high
         priority. Forms of renewable energy suitable for the Staffordshire Moorlands are
         large scale commercial biomass and small scale domestic solar panels.
         Biomass requires land, the land planted with trees could also be used for
         walking. Domestic solar panels should be designed to blend in and can look
         attractive on new houses. They should be put on top of schools and hospitals.
         On individual houses/older houses it can look unsightly. All new development
         should be required to generate a proportion of its energy requirements from
         renewable resources.
        The Council should aim to support community facilities in towns and villages e.g.
         youth clubs, village halls, parks/ recreation facilities. Would like to see more
         facilities especially youth clubs. Village halls could be used - needs to be run well
         (could pay to go). Somewhere to go inside especially in winter would be good.
         Need a park where you can play basketball, football etc. Endon park closes at
         6pm, not really able to use it. There are good facilities in Leek. Endon needs a
         proper park currently it's just for young children.
        Major new development should incorporate measures to encourage more
         sustainable patterns of transport. There is the issue of buses being quite
         expensive and if bus stations were improved more people may use them.


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        It would be a good idea to redevelop Froghall because otherwise greenfield land
         would be lost. People may not want to live there due to needing to be close to
         schools and other facilities - issue of having to drive. Suggestion that Froghall
         site could be used for recreation/ leisure tourism (hotel) due to its location.

Help the Aged

In terms of issues and the draft vision, despite reference to a 'rising elderly population'
there is little or no recognition of the need for improved transport provision, housing
options and access to essential services for that section of the population. Without a
focus on these issues, elderly people will be increasingly isolated and overloaded,
socially excluded and denied access to the benefits of sustainable communities. Before
considering the needs of older residents, SMDC should engage and consult with them.

In terms of draft spatial objective 6 "To maintain and promote sustainable rural
settlements with access to services for all." This should be amended with specific
reference being made to an increasing, older population. This caveat is also applicable
to objective 10 "To deliver sustainable, inclusive, healthy and safe communities." We
need to recognise the impact of changing communities on older people.

Help the Aged‟s top 3 priorities are:
    Sustainable communities. Cross - cut by recognition of the basic principles of
       Equality and Diversity.
    Social inclusion. Cross - cut by recognition of the basic principles of Equality and
       Diversity.
    Integrated, accessible transport. Cross - cut by recognition of the basic principles
       of Equality and Diversity.

In terms of distribution of development, would prefer focused development option in
areas requiring regeneration. If the town-based option was chosen, then Biddulph,
particularly Biddulph East, would warrant priority development. The provision of a wider
choice of housing options for older people, particularly in areas of deprivation, or those
being considered for regeneration e.g. East Biddulph, Haregate, Cheadle is needed.
Regeneration of rural areas requires integrated transport systems. Older people require
access to services.

Whichever decision is taken, it should be done so after meaningful and substantive
consultation with all local residents including those 'hard to reach' or who cannot attend
public meetings. Housing options should be increased to improve flexible provision, this
might necessitate a consideration of densities where appropriate. Affordable housing is
also needed for older people. A majority of new housing in the Staffordshire Moorlands
should be affordable. Affordable older peoples housing is required across the
Moorlands.

In terms of design improvements, all public buildings and social housing should be
"accessible" - housing should be designed after consultation with would be residents.
The Council should aim to support community facilities in towns and villages, particularly
those offering facilities, or with a potential to offer facilities, to older residents. Examples
of such facilities are day centres - e.g. Bank House in Leek, Hartington Day Centre.




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    Also village and church halls which provide luncheon clubs, indoor bowls, etc. SMDC
    should support Post Offices and prioritise their services.

    Sustainable, accessible and integrated public transport should be promoted. Older
    people rely on public transport to access health and social services facilities, post
    offices, shops and market days. Community transport should be encouraged, as should
    subsidised travel and a system of flexible concessionary fares.

    Older Persons Forum (30th November 2007)

    Comments made

    Housing

   Housing for older people was the major issue which all members of the group think
    needs addressing.
   Would like to see more extra care housing in the Moorlands where older people can stay
    in their own homes but feel secure and can have wardens on hand and a communal
    area where services like hairdressing can be brought to them. Loneliness is a concern
    and it was considered that extra care housing could help combat this. There is no extra
    care housing in Cheadle.
   This development could be on a small scale and is required in the towns and all villages
    to keep rural communities alive and enable people to stay living in their familiar rural
    communities without having to move to the towns.
   Smaller affordable homes are also required, especially in villages so that older people
    living in larger homes they can no longer manage are able to downsize and stay in that
    village. Some group members felt that affordable housing should only be available to
    locals and not people coming from outside the area.
   Concern was expressed about children not being able to afford housing in villages where
    they were born / brought up e.g. Alton.
   Physical access to housing was also a concern e.g. steps and gradients. It was
    considered that older people should be consulted on things like heights of light switches,
    width of doors and other adaptability issues.
   Second homes can be a problem in some rural areas.
   Favour distributed development option.
   There are unused buildings that could be used for housing, though developments like
    Tean Mill are too expensive. Queried the definition of affordable housing.

    Transport / Community Facilities

   Loss of community facilities e.g. post offices, pubs and shops presents a problem for
    older people as they then have to travel further to meet their basic needs. Also the loss
    of community life has a higher impact on older people.
   Mobile facilities covering the rural areas with business incentives offering a variety of
    goods at supermarket prices would be a help.
   In terms of public transport, older people can struggle to walk to bus stops and can be
    faced with very infrequent services in rural areas. They are reliant on cars and if they
    cannot drive on volunteers operating community transport.
   There is a wide network of community transport in the Moorlands funded by the County
    Council, District Council and Primary Care Trust. This takes people to hospital


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    appointments, to visit friends, the hairdressers etc. where volunteers wait and transport
    the person back to their home afterwards.
   Would like to see more medical facilities provided locally at the Moorlands hospitals so
    travelling to the Potteries isn‟t a necessity. Acknowledged that this situation has
    improved in recent years.
   Loss of schools especially in villages drives young families away.
   In Cheadle, the infrastructure has not grown with the population. There are problems
    with traffic flow and doctors and schools being full.

    Green Spaces

   Land which has previously been used for open cast mining could be turned into a
    recreational facility.
   Green space is visually important to older people e.g. views from their houses.
   The untidy condition of some green spaces is an issue.
   Green spaces should be accessible to people of all ages i.e. flat.

    Retailing

   Need for more retail development in Leek and Cheadle Town Centres.
   Need affordable clothing stores in Leek and a mixture of other shops including good
    independent ones and not so many charity shops. Can‟t buy a pint of milk along Leek or
    Cheadle high streets.
   Lack of parking in Leek town centre is a big problem.
   Many older people come to Leek from the surrounding villages on public transport and
    prefer to shop in the Moorlands towns than going into Hanley.
   In terms of accessibility, the cobbles and inclines in Leek Town Centre can be a problem
    for wheelchair users.
   Opening times in Cheadle can be a problem with many shops closing too early in the
    afternoon.
   Blythe Bridge has a lack of retail facilities for the size of the village.

    Design

   Would like to see new buildings blending in with their surroundings in terms of using
    local materials and being of an appropriate scale.
   The 3 storey new properties being built are unpopular.
   High density development can be a problem when it involves loss of green spaces and
    gardens, changing the character of areas. Public open space then becomes even more
    important.

    Renewable Energy

   Wind farms can be controversial and there were mixed views on them with some
    support. But concerns about noise and danger to wildlife.
   Better information for the general public is required in order to inform them about energy
    savings and costs involved to reduce resistance.

    Employment



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   The future of the Thomas Boltons‟ site is an issue as it is in a sensitive part of the
    countryside.
   Units for small businesses like those at Ipstones should be retained for employment.
   Could the area at Mobberley be an employment area as it would benefit from being
    tidied up, although the Special Landscape Area designation is restrictive.
   There are opportunities for employment development in rural areas e.g. rural crafts etc in
    converted buildings like the cheese factory at Hartington.
   Small scale sympathetic employment development in rural areas could take place on
    green field sites if adequate consultation takes place with the local community at an
    early stage – could link with village agents to ensure successful consultation.

    Staffordshire Moorlands Disability Action Group (4th October 2007)

    Summary of Questions/Comments:

          It was requested that SMDC make current/future Core Strategy/Local Development
           Documents available through talking newspaper/audiotapes or Braille
           automatically, rather just on request.
          Tony Green said he would personally arrange publicity with disabled groups he
           had contact with to advise that planning officers can arrange home visits to talk
           through LDF consultations, if required.
          A number of criticisms about lack of disabled access into public buildings and
           shops i.e. steps up to doors, door „lips‟. The Council‟s Access Officer advised
           about Building Regulations i.e. many works to improve access to public buildings
           are not yet mandatory. A related criticism that listed buildings are less likely to have
           public access improvements because they‟re listed.
          Discussion held about accessibility into new housing:
              o comment that most new housing is not designed to be accessible for
                 wheelchair users e.g. because of door steps/lips.
              o comment that higher density developments e.g. flats often sacrifice
                 accessibility to wheelchairs because of steps/stairs.
              o question about whether the County/RSS housing allocations must have an
                 element designed for the disabled/elderly - e.g. bungalows. There was an
                 expectation that such matters would be integral to Core Strategy policies.
              o In response to a number of these comments the Access Officer advised
                 members as to the fact that accessibility features are often only controlled by
                 Building Regulations (and sometimes not). So if Development Control does
                 not require plans to incorporate such features, and they are not a Building
                 Control requirement, there is a problem.
              o A discussion took place about new „lifetime homes‟ standards [which require
                 housing to be constructed in a way that it can be later adapted for wheelchair
                 users, as required]


          Some members felt that some of the summary leaflet questions were not clear,
           because they didn‟t know what some terms meant e.g. „greenfield‟. Somebody
           suggested that there should be a glossary of terms in future consultations.




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Youth Service

The top 3 priorities of the Youth Service are:
        To reduce the need to travel and make it easier to travel to jobs and key
           services by more sustainable forms of transport.
        To promote local distinctiveness by means of good design and the
           conservation, protection and enhancement of heritage, environmental and
           cultural assets throughout the District.
        To support and enhance the tourism, cultural, recreation and leisure
           opportunities for the District‟s residents and visitors.

In terms of other improvements, it is considered that Leek is poorly looked after and
badly presented. The preferred development option is town and larger village based
development. It is considered that brown field land should be used before green field
land - old buildings and factories should be developed to create character
accommodation. A majority of new housing in the Staffordshire Moorlands should be
affordable using existing premises. If the Council is required by Government to restrict
the supply of housing in the District, both a quota system and limiting development to
certain parts of the District would be appropriate.

The Council can ensure that there is sufficient employment land available by protecting
existing employment sites and premises for employment use. The allocation of new
employment sites should be provided through a number of smaller sites. No new retail
development should occur in Leek as there are empty shops as it is which need filling,
otherwise Leek will become a ghost town. If any new retail development takes place in
Leek it should be on town centre sites only. No new retail development should occur in
Cheadle.

Rural buildings should be allowed to be converted to residential use if they are in
keeping with the surroundings. Development should only be allowed to take place on
sites with a low-medium risk of flooding if full proof measures are in place to remove the
risk. The use of renewable energy in the Staffordshire Moorlands should be a high
priority. Forms of renewable energy suitable for the Staffordshire Moorlands are large
scale commercial wind farms and hydroelectricity and small scale domestic solar panels
and wind turbines. All new development should be required to generate a proportion of
its energy requirements from renewable resources.

The Council should aim to support community facilities in towns and villages. Major
developments should incorporate measures to encourage more sustainable patterns of
transport such as congestion charges and incentives for car-sharing like free parking.
The Council should aim to protect public open space in the towns and villages from
development without exception. Run down areas of the Staffordshire Moorlands like the
old mills on Ashbourne Road should be converted to housing.




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APPENDIX D - LIST OF ALL RESPONDENTS TO ISSUES & OPTIONS
CONSULTATION (alphabetical order – 233 no)

               Respondent                   LDF Reference Number
ACB Hydraulics Ltd                   03080
Adams                                SMLP_1542
Advantage West Midlands              SMLP_181
Alcock                               02234
Allen                                SMLP_581
Allen                                SMLP_1441
Allt                                 02228
Alton Towers Ltd                     SMLP_405
Athis                                SMLP_1785
Bagnall Parish Council               SMLP_2
Bailey                               SMLP_1880
Baldock                              SMLP_2078
Barlow                               02215
Bate                                 SMLP_1202
Beardmore                            SMLP_414
Beatty                               SMLP_523
Beech                                SMLP_2039
Bellway Homes Limited                LDF_2957
Beniston                             SMLP_994
Birks                                02221
Birks                                LDF_2924
Blood                                02237
Bloor                                LDF_2782
Bloor Homes                          LDF_2956
Booth                                03099
Booth                                LDF_2524
Botham                               SMLP_397
Bowyer                               SMLP_1258
Bradbury                             SMLP_920
Bradshaw                             LDF_2206
Brain                                SMLP_815
Briggs                               03093
British Waterways                    SMLP_1898
Brown                                LDF_2582
Brown                                LDF_2591
Brown                                LDF_2798
Brown                                SMLP_1500
Brown                                SMLP_1261
Burton                               SMLP_1313
Caldon & Uttoxeter Canals Trust      SMLP_77
Calverley                            LDF_2207
Campaign for the Protection of Rural SMLP_1717
England
Carding                              SMLP_552
Carter                               SMLP_945


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               Respondent                           LDF Reference Number
Cartledge                                    SMLP_909
Casewell                                     SMLP_1773
Cheddleton Parish Council                    SMLP_10
Chell                                        SMLP_1631
Christopher Taylor Design                    SMLP_131
Clowes                                       SMLP_542
Clowes                                       03088
Cook                                         SMLP_145
Cooper                                       03092
Corden                                       SMLP_616
Cotton College                               LDF_2617
Cowper                                       03094
Culleton                                     SMLP_821
Dalgleish                                    SMLP_900
Davies                                       SMLP_1922
Davies                                       SMLP_1753
Davies                                       SMLP_1279
Dawson                                       SMLP_1935
Deane                                        SMLP_1879
Deaville                                     SMLP_1033
Dickinson                                    SMLP_1072
Duffy                                        SMLP_563
Dupreez                                      LDF_2522
Dyer                                         LDF_2626
Eardley                                      SMLP_2107
Easter                                       LDF_2913
Edwards                                      02238
Endon High School                            03100
Endon with Stanley Parish Council            SMLP_15
English Heritage                             SMLP_106
Environment Agency                           SMLP_203
Eyre                                         03084
Eyre                                         03081
Fallows                                      LDF_3074
Fallows                                      SMLP_1183
Farquharson                                  LDF_2965
Faulkner                                     SMLP_964
Fielding                                     SMLP_1905
Fisher                                       SMLP_297
Flint                                        SMLP_881
Forsbrook Parish Council                     SMLP_17
Gallimore                                    LDF_2670
Garden History Society                       SMLP_236
Gibson                                       SMLP_554
Goodall                                      SMLP_400
Government Office for the West Midlands      SMLP_240
Gower                                        SMLP_86
Grocott                                      SMLP_517


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               Respondent                           LDF Reference Number
Hall                                         SMLP_1536
Hambleton                                    SMLP_1585
Hambleton                                    SMLP_1330
Harris                                       02219
Hart                                         SMLP_2070
Haworth                                      02240
Heaton Parish Council                        SMLP_19
Help the Aged                                SMLP_1987
Higgins                                      02213
Highways Agency                              SMLP_122
Hine                                         03082
Hodgetts                                     03098
Hodgson                                      SMLP_442
Holburn                                      02211
Hollingsworth                                LDF_2208
Home Builders‟ Federation Limited            SMLP_126
Hudson                                       03087
Hughes                                       SMLP_1164
Hurst                                        02220
Ipstones Parish Council                      SMLP_20
J C Bamford Excavators Limited               SMLP_445
Jackson-Hulme                                SMLP_1053
John Munroe Hospital                         02233
Johnson                                      SMLP_154
Jones                                        03097
Kingsley Parish Council                      SMLP_21
Knypersley Community Association             02230
Krahenbuhl                                   02229
Land Banking (UK) Plc                        LDF_2627
Lea                                          LDF_2551
Leese                                        LDF_3000
Leonard                                      SMLP_906
Lewis                                        SMLP_960
Longshaw                                     LDF_2904
Louis Taylor Chartered Surveyors             SMLP_136
Lowe                                         SMLP_938
Magee                                        SMLP_1476
Manby Steward Bowdler                        SMLP_137
Manley                                       LDF_2643
Mann                                         02239
McDermott                                    LDF_3018
McLaughlin                                   02214
McNicol                                      SMLP_1740
McNicol                                      03085
Meredith                                     03090
Millward                                     02241
Mole                                         SMLP_1912
Mono Consultants Limited                     SMLP_2194


                                                                             140
LDF Core Strategy Preferred Option – Draft                           December 2007



               Respondent                           LDF Reference Number
Morrall                                      LDF_2724
Morton                                       LDF_2734
Moss                                         LDF_2609
Murfin                                       03079
National Trust                               SMLP_1995
Natural England                              SMLP_107
NcGratit                                     02236
Needham                                      SMLP_1501
Norgrove-Moore                               02223
North Staffordshire Obesity Support Group    SMLP_2019
Oakamoor Parish Council                      SMLP_25
Ogilvie                                      SMLP_182
Payton                                       LDF_2501
Peak District National Park Authority        SMLP_172
Peal                                         SMLP_1119
Percival                                     SMLP_564
Percival                                     SMLP_574
Phillipson                                   LDF_2730
Pill                                         SMLP_712
Podmore                                      SMLP_430
Pointon                                      SMLP_2094
Poole                                        SMLP_1415
Potts                                        LDF_2713
Proudlove                                    02242
RG Foster Textile Machinery Ltd              SMLP_1885
Richardson                                   SMLP_908
Richardson                                   SMLP_330
Ridgeway                                     SMLP_783
Riding                                       LDF_2821
Rogers                                       SMLP_516
Rowe                                         LDF_3071
Rushton                                      02209
Salt                                         02224
Seabridge                                    03095
Sedgwick Associates                          LDF_2610
Shaw                                         LDF_2830
Shenton                                      SMLP_2113
Sherratt                                     02235
Shufflebotham                                03089
Simpson                                      SMLP_1000
Simpson                                      SMLP_575
Smith                                        SMLP_1926
Spooner                                      03078
Sport England                                SMLP_194
St Modwen Developments Ltd                   03096
Staffordshire County Council                 SMLP_248
Staffordshire Parish Council Association     SMLP_196
Stanler                                      03086


                                                                             141
LDF Core Strategy Preferred Option – Draft                           December 2007



                 Respondent                         LDF Reference Number
Stead                                        02223
Steele                                       SMLP_1057
Stirling Investments LLP                     02226
Stoddards Garage & JP Properties             02231
Stretch                                      SMLP_561
Sustrans                                     SMLP_228
Sutton                                       LDF_1800
Sutton                                       SMLP_438
Sutton                                       SMLP_1644
Swetnam                                      SMLP_898
Tams                                         SMLP_524
Tesco Stores Ltd                             SMLP_214
The Theatres Trust                           LDF_2607
Tunnicliff                                   02210
Turner                                       SMLP_825
UK Coal Mining Ltd                           SMLP_344
United Utilities Plc                         SMLP_701
Urban Vision                                 SMLP_1900
Wagstaff                                     SMLP_2056
Wainwright                                   LDF_2951
Walby                                        02227
Walker                                       SMLP_1904
Walmsley                                     SMLP_1338
Walters                                      LDF_2875
Waters                                       SMLP_1562
Weaver                                       LDF_2525
Werrington Parish Council                    SMLP_30
West                                         LDF_2676
West Midlands Regional Assembly              SMLP_1932
West Midlands RSL Planning Consortium        LDF_2596
Whilock                                      SMLP_1020
White                                        LDF_3029
Whiting                                      02222
Whittaker                                    SMLP_338
Williams                                     SMLP_1177
Wilshaw                                      SMLP_421
Windsor                                      SMLP_1769
Winterton                                    SMLP_1707
WM Morrisons Supermarkets PLC                SMLP_392
WM Plant & Sons                              02232
Woodland Trust                               SMLP_212
Worrall                                      SMLP_2046
Worth                                        SMLP_1383
Wyatt                                        SMLP_1394
Youth Service                                SMLP_1449




                                                                             142

				
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