Great quotes from the previous Mottram M67 campaign

Below is an extract you and various experts gave as a community to our “Concreting Mottram” campaign in 2014, which the Council’s published. Residents’ objections are in the “comments” column, and the Council’s response in the column to the right of it.

Note points of particular relevance highlighted in yellow. Also, in some cases, they flag up points you may not agree with or like to take note of (in red). We have added LCG comments in violet.
Strategic Sites –Mottram M67 extract of comments and Council response

  Comment Council Response
Sports England (page 79) This strategic site includes a number of sports facilities including a gymnastics centre / sports centre and playing fields. The development of this site to provide employment land would result in the permanent loss of these facilities. Neither the ‘weaknesses’ nor the ‘challenges’ recognise the constraints that these facilities pose to development, not do they recognise that replacement facilities would be needed. The sustainability appraisal is also silent in relation to the impact of the loss of the sports facilities. Paragraph 74 of the National Planning Policy Framework offers protection to these facilities and requires specific criteria to be met before they can be developed. Likewise, Sport England’s playing field policy would oppose development of such sites unless specific circumstances exist.
Sport England would oppose the allocation of this site unless development was demonstrated as being unavoidable and replacement facilities of at least equivalent quantity and quality were to be provided in a suitable location.
The Council acknowledges Sport England’s comments related to Mottram M67. If the proposed Safeguarded Strategic Site is retained within the Core Strategy, the sports facilities will be safeguarded during the plan period. If development of the site is pursued beyond 2029, the Council will ensure that appropriate policies are applied to the site to ensure the sports facilities are retained or appropriately re-provided within the community.
CPRE (Peak District Sheffield) (Pages 71 – 73 (b) The impacts of developing the 35 ha Mottram M67 site are unacceptable. The site straddles the congested A57 to the east of the M67 terminal roundabout and sits within an Air Quality Management Area (AQMA). To the north of the A57 the site lies in the Green Belt and to the south the site is designated Protected Green Space on the UDP Proposals Map. The Sustainability Appraisal finds that development of the site would enhance urban renaissance, help create a prosperous Borough and a healthy labour market which would provide employment for local people, and concludes that despite significant adverse impacts that the development would overall have a positive impact.
The SA also identifies that there is potential for significant negative effects: ‘New development may have an adverse impact on air quality in the Borough and especially within the AQMA primarily as a result of increased car use.’ Given the site’s ‘proximity to the M67 and lack of access by rail it is expected that development would result in an increase in traffic levels particularly given existing infrastructure capacity limitations and congestion issues in the area.’ It would encourage long distance commuting and undermine employment opportunities for local people. ‘In addition, Tameside will need to strengthen measures to reduce Carbon Dioxide (CO2) emissions and the negative impacts of transport upon air quality. This may include modal shifts and demand management of car useage and additional investment in public transport.’ Consequently the proposal scores negatively against Sustainability Appraisal objectives for citizens’ health (2), environmental quality (11), reducing the need to travel (17) and strategic transport communication and economic infrastructure (23).
(c) Use of the site would contravene Tameside saved UDP policy OL1 (Protection of the Green Belt) as no very special circumstances have been demonstrated for such inappropriate development, and OL4 (Protected Green Space) as none of the exceptions criteria would be met.
(d) Use of the site would also be contrary to the NPPF, including its core planning principles (para 17) which recognise the intrinsic character and beauty (paras 79-92), its promotion of sustainable transport (paras 29, 30), and its conservation and enhancement of the natural environment (ch 11). Local authorities should be planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure (NPPF para 114). Development on this particular location would also undermine all five of the core objectives of the Greater Manchester LTP34.
c. UDP policies OL1 and OL4 will be replaced by policies within the Core Strategy. The Council recognises that in order to develop the site a Green Belt Review will need to be undertaken and any loss of amenity space will need to be re-provided within the community.
d. The Council will ensure the Core Strategy aligns with all the guidance and policies within the NPPF. Whilst the proposal may conflict with a number of NPPF policies, it will also align with numerous policies related to economic growth and employment. As with all developments there will be a need to appropriately balance the conflicting elements of policy.

S.Tyler Longdendale Community Group.
L. Tyler & D. Tyler, Mottram.
P. Copestake Mottram.
B. Copestake Mottram.
J & S Murphy
Mottram.
A. & S. Mayer
Mottram.
A. Dandy Mottram.
L. & J. Miles
Broadbottom.
M. Byrne Broadbottom.
L. & G.ChandlerBroadbottom.
C. Fidler
Hyde.
Mr D. & Mrs K Hollows
Mottram.
D. & A. Kendrick Mottram.
S. & N. Wood Mottram.
A. & J. Smith
Mottram.
A. &S. BennDukinfield.
J, J.& L.RuddMottram.
J.& T. LawsonHyde.
J.&G. TowellAshton.
Mrs. H. and Dr. A. Jones
Mottram.
C.Barber &A.Elliott
(

Pages 164 – 167)

Our community group consulted several residents close to the site about the Preferred Plan Not one of these people had heard anything about the Plan.
The Plan thus fails the test of soundness regarding its duty of community consultation in accordance to Government Policy: Planning Act 2008: Duty to consult local community; and more so the Localism Act 2011. This Act states points such as:
61W Requirement to carry out pre-application consultation (1)Where—
(a)a person proposes to make an application for planning permission for the development of any land in England, and
(b)the proposed development is of a description specified in a development order, the person must carry out consultation on the proposed application in accordance with subsections (2) and (3).
(2)The person must publicise the proposed application in such manner as the person reasonably considers is likely to bring the proposed application to the attention of a majority of the persons who live at, or otherwise occupy, premises in the vicinity of the land.
Neither is the Plan consultation in keeping with the spirit of the law: “Planning did not give members of the public enough influence over decisions that make a big difference to their lives. Too often, power was exercised by people who were not directly affected by the decisions they were taking. This meant, understandably, that people often resented what they saw as decisions and plans being foisted on them. The result was a confrontational and adversarial system where many applications end up being fought over”. The Localism Act contains provisions to make the planning system clearer, more democratic, and more effective. To further strengthen the role of local communities in planning, the Act introduces a new requirement for developers to consult local communities before submitting planning applications for certain developments. This gives local people a chance to comment when there is still genuine scope to make changes to proposals [LCG further comment: subsequent to the publication of these responses, instead of listening to the community and incorporating their ideas, there have been no changes to the proposals – they have just gone ahead and sent the Plans to be incorporated into the GMSF Plans, unchanged!] Local planning authorities play a crucial role in local life, setting a vision, in consultation with local people, about what their area should look like in the future. If the Local authority want to avoid the resentment, confrontation and accusations both of deliberate conspiracy against the community and deliberately concealing new development, a more rigorous consultation with the community is strongly indicated.
In order to be of constructive support, the Longdendale Community Group are currently conducting a survey to ascertain how individual members of the community would like to be consulted. We wish to stress that it is not acceptable for this lack of consultation to be merely an unmet need. The situation can indeed be remedied, as the results of the community’s own communication efforts indicate. Preliminary results of our survey (which is still in progress) indicate a preference for notification of Plans (and especially ones of such momentous consequences for the community) via an inclusion with the Council Bill. This would cost the local authority minimal expense. When we suggested this to the Strategic Planning Team, their response was that timescales precluded this, according to their need to move the plans forward in their schedule. Our response to this is: they are a majority of the persons who live at, or otherwise occupy, premises in the vicinity of the land. Neither is the Plan consultation in keeping with the spirit of the law: “Planning did not give members of the public enough influence over decisions that make a big difference to their lives. Too often, power was exercised by people who were not directly affected by the decisions they were taking. This meant, understandably, that people often resented what they saw as decisions and plans being foisted on them. The result was a confrontational and adversarial system where many applications end up being fought over”. The Localism Act contains provisions to make the planning system clearer, more democratic, and more effective. To further strengthen the role of local communities in planning, the Act introduces a new requirement for developers to consult local communities before submitting planning applications for certain developments. This gives local people a chance to comment when there is still genuine scope to make changes to proposals… [LCG further comment: subsequent to the publication of these responses, instead of listening to the community and incorporating their ideas, there have been no changes to the proposals – they have just gone ahead and sent the Plans to be incorporated into the GMSF Plans, unchanged!] Local planning authorities play a crucial role in local life, setting a vision, in consultation with local people, about what their area should look like in the future. If the Local authority want to avoid the resentment, confrontation and accusations both of deliberate conspiracy against the community and deliberately concealing new development, a more rigorous consultation with the community is strongly indicated.
In order to be of constructive support, the Longdendale Community Group are currently conducting a survey to ascertain how individual members of the community would like to be consulted. We wish to stress that it is not acceptable for this lack of consultation to be merely an unmet need. The situation can indeed be remedied, as the results of the community’s own communication efforts indicate. Preliminary results of our survey (which is still in progress) indicate a preference for notification of Plans (and especially ones of such momentous consequences for the community) via an inclusion with the Council Bill. This would cost the local authority minimal expense. When we suggested this to the Strategic Planning Team, their response was that timescales precluded this, according to their need to move the plans forward in their schedule. Our response to this is: they are a planning department, and the consultation could have been planned in this way.
However, this means alone would be inadequate. There is the need to explain to people the implications of such important plans. A greater co-operation with community groups independent of local authority influence and control, and greater details in the newspapers would facilitate this.

The Council acknowledges these comments. However, reference taken from the Localism Act 2011, relates to the submission and pre-submission of a planning application. It does not relate to the Core Strategy. Whilst a Strategic Site may be adopted within a Core Strategy, any subsequent development proposals will be subject to a planning application, which is when the element of the Act quoted, will apply.
The production of the Core Strategy (and all Development Plan Documents) is guided

by the Town and Country Planning (Local Planning) (England) Regulations 2012. Part 6 of these Regulations detail the process that must be followed when creating a local plan. Part 9 relates to the availability of documents during periods of consultation:
Availability of documents: general 35.—(1) A document is to be taken to be made available by a local planning authority when—
(a) made available for inspection, at their principal office and at such other places within their area as the local planning authority consider appropriate, during normal office hours,and
(b) published on the local planning authority’s
website,
(2) In relation to any document made available under these Regulations, except a local plan or supplementary planning document which has been adopted or approved, the local planning authority may cease to make the document available once the period specified in paragraph (3) has expired.
(3) The period mentioned in paragraph (2)—
(a) where the document relates to a supplementary planning document or to the local planning authority’s statement of community involvement, is 3 months after the day on which the supplementary planning document or statement of community involvement is adopted;
(b) where the document relates to a local plan, is the 6 week period referred to in section113(4) of the Act that applies as regards the local plan concerned.
(4) Where a local planning authority adopt, or the Secretary of State approves, a revision to a local plan or a supplementary planning document, as soon as reasonably practicable after the revision is adopted or approved, the local planning authority must incorporate the revision into the local plan or the supplementary planning document made availablein accordance with this regulation.
The Council believes it has met and exceeded the requirements of Regulation 35, with the limited budget available: newspaper adverts in the Advertiser in 2 editions over a 3 week period; release to both the Advertiser and Reporter; Assembly Meetings in December to highlight the consultation was to start in January;
Publishing an article in the winter Citizen; consultation events at libraries, markets and Hyde shopping centre; documentation on the Council’s website; letter to over 500
individuals and organisations on the Local Plan consultation database; of the document to all libraries and customer service centres; and advertising the consultation at all doctors surgeries and schools within the Borough.
Coupled with this direct means of informing and consulting, the Council welcomes the work undertaken by community associations such as the Longdendale Community Group, informing their local community of the consultation and the importance of the Local Plan.
The Council acknowledges that information within the council tax bill could be an effective way of reaching each household. Unfortunately these bills are only issued once a year and did not coincide with the consultation event. However, if timescales align in the future, the Council will utilise this resource.
 

Core Strategy Policy 10: Waste Management & Environmental Quality (Page 222 onwards)

  Comment Council response
The Coal authority Policy CSP10, Waste Management and Environmental Quality
Comment/Objection –This policy seeks to address issues of pollution and contamination in terms of addressing the issues and achieving effective remediation. However it fails to make any mention of the issue of land instability which has may similar characteristics and needs consideration and mitigation as required by the NPPF paragraphs 109, 120 and 121. In order tobe sound the policy will need to: “Require adequate consideration of methods to reduce impacts upon and reach acceptable resolutions to issues surrounding ground instability, light, noise, water, odour and ground pollution, air quality and vibration; and Require that developments are mindful of and employ appropriate mitigation techniques to developments that occur on or near to existing areas of ground instability, contaminates, pollution and land fill sites.”
At present the Plan does not indicate that it intends to address the issue of ground instability at all which is a locally distinctive issue for Tameside. We raised similar concerns at the Issues stage which have not been addressed.
The Council welcomes the comments submitted by the Coal Authority and will ensure the policies highlighted (CSP08 & 10) contain / reflect the comments made in relation to the NPPF
N. Sandford
The Woodland Trust
Need to ensure that waste management facilities of whatever type do not damage irreplaceable semi natural habitats such as ancient woodland The Council acknowledges this comment and will ensure policies protect natural habitats such as ancient woodlands.

Development Management Policy 14: Flood risk

  Comment Council response
N. Sandford
The Woodland Trust
There is now strong evidence that planting of trees in appropriate locations can improve water quality by upto 80% and also help alleviate the impact of certain types of flooding. It would be useful to see reference to this in the policy. The Council acknowledges this comment and will feed
it into the policy review.
United Utilities Surface water being discharged into the sewers can have a significant impact on the capacity of our existing infrastructure. This in turn may result in a lack of available capacity to accommodate the levels of new development the Council aspires to deliver as a means to encourage economic growth; meaning new development may be delayed until infrastructure upgrades can be undertaken. It is therefore critical that Policy DMP14 is sufficiently worded to ensure stricter guidelines are applied for dealing with surface water discharge.
We recommend that a requirement of the Policy is that developers must demonstrate, as part of any planning application, how surface water run-off will be addressed without having any detrimental impact
The Council supports this comment and will ensure the revised Flood Risk policy reflects the recommendation.
In addition the Council will continue to engage proactively with United Utilities under the Duty-to-Cooperate to ensure that the comments are taken into account in further policy formulation.


FURTHER COMMENTS

From Comments Council response
Gillian Slate Audenshaw Audenshaw
My first concern is has this document been compiled as a prospectus brochure thus a mean of showing / advertising to developers what Tameside deem as available up for sale land & thus not being advertised / highlighted as vacant land
The function of the Core Startegy is to help guide and steer future development across the Borough for the next 15 years. The rationale for creating such a document is to help the Council and its communities guide where development (housing, employment, retail, leisure, etc) will go and how the demands of a growing population can be met / achieved across the Borough. Without adopted policies and guidance, the ability of the Council and its communities to ‘have a say’ in such development will be considerably less.
Collective response from a cycling workshop
For all local authorities, it is important that there is an established mechanism for the ongoing development of a cycling / sustainable transport network in Tameside. The Local Plan and Core Strategy is a plan for the long-term development of the Borough and if a realistic cycling/sustainable transport network is not included in this now, we will have lost another 20 years. Basically if cycling is not planned in, it will effectively be planned out. Most other local authorities have, or are working on, an aspirational cycling network for their area. This includes the existing cycling routes, and the required additional cycling routes needed to develop a  coherent and viable local cycling network.
The Council recognises that in order to increase participation in cycling, the Borough’s infrastructure and facilities require enhancement.
S. Fisher  Food & Allotments FAR GREATER EMPHASISMUST BE GIVEN TO ALLOTMENTS AND TO LOCAL ORGANIC FOOD PRODUCTION AND DISTRIBUTION WITHIN TAMESIDE THEREBY MAKING TAMESIDE ADAPTABLE, RESILIENT, AND SELF-SUSTAINABLE. "TMBC should develop policies which provide a presumption in favour of retail developments which make a primary contribution to sustaining local food producers, and providing accessible retail facilities to local communities, including specific guidance in  Supplementary Planning Guidance." Tameside's LOCAL PLAN fails completely to emphasise the need/necessity for Local Food production for local people; to become self-sufficient in the provision of cheap fresh fruit vegetables for local people. Such an important strategy for a self-sufficient Tameside is completely lacking in this consultation document. Allotments, both Council run and private, should form the backbone of such a local food strategy and they are scarcely mentioned despite the legal requirement for their provision. The Council acknowledges that the Core Strategy should promote locally grown food, and specifically allotments. Allotments provide health benefits through the foods grown and the physical activity of managing them; as well contributing to the Borough’s green infrastructure as a natural habitat.  Policy DMP 04: Local Services will help provide local communities will locally accessible services and retail. Whilst the Council supports the promotion of locally produced food and the employment opportunities they provide, the Council sees limited need to provide a  presumption of favour of retail developments that sell / support such business. Food retail is considered a town centre use, [LCG comment – then why have they allowed the Tesco Extra to develop in an out-of-town – centre location?!] as such would generally be supported where capacity exist

Tameside Council response to representations received on theMottram M67 Strategic Site within theCore Strategy and Development Management Policies Preferred Options Consultation

This schedule provides an overview of the 395 (excluding duplicates) representations received during the Preferred Options consultation (7th January to 18th February 2013) together with a brief response from Tameside Council. To view full copies of all consultation responses please contact the Strategic Planning Team at planpolicy@tameside.gov.uk or tel: 0161 342 3346.  It should be noted that the 395 representations do not directly translate into number of residents, as a number of representations were from more than one person. [LCG comment – their way of admitting that there were over 500 objections!]

There are 200 pages of objection summaries! In many cases, the Council just give a standard, identical response, to many objectors’ comments. Here is just a very small sample for the moment

Objector(s) Their comment Council response
D and J Ollerenshaw
We wish to strongly object to the plans to use land north of the A57 as a light industrial estate.  1. We also wish to put in writing that we are disgusted with the poor communication about this matter. There was a time when the council would write to notify residents of future planning applications. We now have to rely on our Longdendale Community Group and are very thankful for them
[extract]  The proposal for a Safeguarded Strategic Site at Mottram M67 is not a planning application
Mr & Mrs Mayer  Mottram We live in Mottram because we like to live close to the countryside. In the last 14 years we have seen changes to Mottram, villagers are losing their say as the Council and big companies do not listen to residents.  To bring in more traffic and develop an industrial area is just crazy. Keep industries on industrial sites. Why build on green belt and take away our play areas, countryside and clean air The Council acknowledges the concerns related to the development of land currently within the Green Belt. If the proposal is taken forward, an appropriate Green Belt Review will need to be undertaken and development would not be supported until the Mottram bypass has been constructed. Any loss of protected green space will be appropriately reprovided within the surrounding community
Mrs E Lloyd Hattersley Please do not let anyone build on this lovely green field. It is the only remaining one on this estate. Besides the school, there is the children’s playground sand pits, swings and slide, also gymnastic centre.  Building a factory would lower the whole tone of the area. The Council acknowledges the concerns related to the development of land currently within the Green Belt. If the proposal is taken forward, an appropriate Green Belt Review will need to be undertaken and development would not be supported until the Mottram bypass has been constructed. Any loss of protected green space will be appropriately reprovided within the surrounding community 
R & J Martin  Mottram We are deeply concerned at the proposal to open up green belt land in Mottram and the effects it will have on the landscape, wildlife habitat and the residents. Such a plan would create yet more traffic chaos and possibly devalue people’s homes. How can you call Mottram a conservation village when you are spoiling the surrounding area in such a wa Any loss of protected green space will be appropriately re-provided within the surrounding community. The development would be unlikely to affect the Conservation Area or its setting.
Mrs J Molyneaux  Hyde I do not want the plan for Mottram M67 to go forward.  Over the past 25 years we have seen an explosion of traffic on the M67 and A57. I would definitely object to any more development in this area. We objected to Tesco, but got ridden over roughshod. Does this Council not listen to peoples opinion, only their own?   The Council fully acknowledges that the Mottram and the surrounding area suffer from high levels of congestion and would not support development of the site without the bypass being in place.
D Lowe Hattersley  
[Extract] When will local councils and big corporate companies be held responsible for creating ill health, anti-social behaviour, poor social mobility and the destruction of wildlife? This will happen if the M67 plans go ahead.  This is natures and ours greenbelt, which provides children with open green space to pursue outdoor activities, explore and use their imaginations. We also know how very important trees are for use and a number of species. We should be protecting and looking after what little we have left, not destroying it.  I am very disappointed in this Labour run Council
The Council acknowledges the concerns related to the development of land currently within the Green Belt. If the proposal is taken forward, an appropriate Green Belt Review will need to be undertaken which will include assessments of landscape and biodiversity impact, together with a detailed justification for the sites release.  Any loss of protected green space will be appropriately re-provided within the surrounding community. Any development proposals will also need to assess the wildlife habitats currently present on the site and provide appropriate mitigation measures and habitats as required 
Mr. & Mrs. Leeming Mottram In making my objection to the proposed plan 'Mottram M67', I would like to highlight the  following reasons for doing so:  1. The obvious and seemingly very much overlooked situation of traffic congestion in the proposed area.  2. The actual need in Tameside for further industrial sites, having read in the local Advertiser of the amount of space being created at the Walls site in Godley, this is only a mile from the proposed site in Mottram, apart from a number of unused sites already available in Tameside.  3. Perhaps the proposers of this plan know of an expected' industrial boom' in this part of the country and see Tameside as the new 'Trafford Park' ?  4. I noted the wording of the proposed plan in include 'distribution', which leaves me to believe that this will be the land adjacent to Tesco, for their 'distribution centre' !  The Council fully acknowledges that the Mottram and the surrounding area suffer from high levels of congestion and would not support development of the site without the bypass being in place.  2. The Council acknowledges that there are currently employment sites and buildings with vacancies. If the proposed Mottram M67 site is taken forward, it will be a Safeguarded Site for future development (beyond 2029).  3. It is not the Council’s intention to support development on this site during the new plan period (up to 2029).  4. In the Council’s opinion, the site would not be of a sufficient size to meet the distribution needs of Tesco
W & Y Kneen
Broadbottom
We object to the proposal for Mottram M67 sites.
1. The proposal will make the bottleneck at the end of the M67 worse.
2. The result will increase air and noise pollution, which is already beyond reasonable levels. 
3. The loss of green belt and playing fields to the community, especially the young who make direct use of these areas.
The Council acknowledges the concerns related to the development of land currently within the Green Belt. If the proposal is taken forward, an appropriate Green Belt Review will need to be undertaken and development would not be supported until the Mottram bypass has been constructed. Any loss of protected green space will be appropriately reprovided within the surrounding community
W Jones Hattersley [Extract] These plans don't seem to follow their own Strategic Master Plan Report of 2000 which clearly states no plan around the M67 should be considered without the bypass being in place. The traffic around the M67 exit is diabolical day in day out which is not only polluting the local area but does not reflect well on any potential companies wanting to invest in the area.  This plan for the industrial units looks like the easy option has been taken as green belt and  recreational fields will be mutilated to accommodate ease of build. Within the Hattersley area there are a number of brown field areas Godley where the old Walls factory has been left in ruins where there are a few industrial units and I believe an empty British Gas building, …..you are trying to take away leisure areas from kids using bmx bikes to people just going for walks with their kids in a safe area, dog walkers, kids playing football on the fields the list can go on and on. In your plan in 2000 it also state that building should be constructed from better materials to enhance the perception of the local area and then you allow Tesco to build a prefab block which is an eye sore … [Extract] The Council fully acknowledges that Mottram and the surrounding area suffer from high levels of congestion and would not support development of the site without the bypass being in placeThe Council acknowledges that there are currently employment sites and buildings with vacancies.
N Burton  Hyde I do not want the plan for Mottram M67 to go forward.  Lazy planning – use brownfield not green belt The Borough contains a number of brownfield sites that the Council will seek redevelopment of prior to the release of Green Belt or green field sites. However, due to a number of factors, including owners desires for alternative uses on employment sites and businesses requiring locations next to key transport infrastructure, the Council believes that during the next plan period (beyond 2029) new employment sites will need to be allocated
  1. TRAFFIC CONGESTION  Mottram is already a very heavily congested village effectively bisected by the A628. Congestion is not confined to the A628 and M67 and “rat running” is a major problem. The addition of more traffic of any weight from the proposed area would only exacerbate the situation. 
2. GREEN BELT  The Green Belt around Mottram is essential to maintain the distinct nature of the villages of  Longdendale and is needed to prevent the area becoming a suburban sprawl. The proposed site has historically been in agricultural use and remains so now. … industry would be out of place in this…. 
3. SAFETY … industry can involve the use of chemicals, flammable solvents, gas cylinders and other hazardous materials. These may legally be used and stored within metres of residential homes and the possibility of fire and explosions must clearly be of major concern. The site is also criss-crossed with drainage channels and air shafts to vent water courses and there is the possibility of pollution to Manchester’s water supply. In addition, there are several public footpaths and rights of way that cross the site.
 
 
[Extract] The Council recognises that Mottram and the surrounding area suffer from high levels of congestion and would not support development of the site without the bypass being in place.  The Council acknowledges the concerns related to the development of land currently within the Green Belt. If the proposal is taken forward, an appropriate Green Belt Review will need to be undertaken which will include assessments of landscape and biodiversity impact, …Any loss of protected green space will be appropriately re-provided within the surrounding community. Any development proposals will also need to assess the wildlife habitats currently present on the site and provide appropriate mitigation measures and habitats as required. 
…… Environmental and Safety issues will also need to be addressed. 
Any development that results in the loss of Protected Green Space / recreation facilities will be required to re-provide the facilities within the local community prior to development taking place.  

 
Miss E Oates  Mottram [Extract] Many years ago a number of small industrial units were built on Hattersley, near the railway line, the same idea as what is being proposed now, these little industrial units caused the local residents discomfort and mayhem, bringing noise, destruction , and more so causing a complete eyesore for the residents that had a view previous. Apart from a call centre none of the units ever provided any decent employment to anyone local, The construction was never seen as a success.  [Extract]  The Council believes it has a duty to try and encourage investment across the Borough, to try and benefit specific communities and the Borough as a whole. How can people progress and aspire if there are no opportunities to work towards
E & C Warburton  Mottram  [Extract] …a council representative explained that notices were put up in schools and doctors surgeries etc. We do not have any children and are not registered with any doctors around here. My advice would be to act as the Longdendale Group have done and post a single letter through each door of the houses which are directly affected.  [Extract] The Council believes it has met and exceeded the requirements of Regulation 35, with the limited budget available:
E Connor  Mottram [Extract] The traffic at the end of the M67/ Mottram roundabout is already the worst bottleneck in Gtr. Manchester.  With the high density housing in that location extra traffic could also make the Roe Cross/ main road from Mottram to Stalybridge a bottleneck.  The 1981 fire/explosion at Chemstar nr Stalybridge, demonstrates what devastation and long term polluting/health problems can be caused by siting industry so close to high density housing.  The Tesco development has already reduced the green space between Mottram and Hattersley.  This has greatly reduced a vital wildlife corridor  [Extract]  The Council recognises that Mottram and the surrounding area suffer from high levels of congestion and would not support development of the site without the bypass being in place. 
……policies will ensure the impact new development has on adjacent housing will be minimised ….by the types of uses accepted on the site, the design of the buildings, use of landscape and restrictions of the hours of operation. 
Any development proposals will also need to assess the wildlife habitats currently present on the site and provide appropriate mitigation measures and habitats as required  
 
F & L Chitty [Extract] Amenity considerations:  Mottram and Hattersley are located in an area of high visual amenity and incorporate the Mottram Conservation area. The new development would be visible from parts of the Conservation area as well as from adjoining residential areas. [Response ditto red highlight in above column
H & L Gordon
Mottram
[Extract] Why does the Mottram and Longdendale area of Tameside need this industrial development when much of the current industrial development in the rest of Tameside is underused and there is other brown field areas that could be better developed.   [Extract]  There are a number of brownfield and vacant employment sites across Tameside and neighbouring boroughs that the Council will prioritise for development during the plan period (up to 2029). However, beyond 2029 the Council feels that new employment sites may be needed
  [Extract] There has been development with McDonalds, Tesco and Mottram Wood all of which promised many jobs for the local population but in reality this has not happened [Extract] …. How can people progress and aspire if there are no opportunities to work towards?
J Padget  Mottram [Extract] Decisions to blight the countryside are often made by bodies with little interest in the effects of the changes made especially by persons who do not live in the vicinity.!!!  [LCG comment – No response was made by the Council to this point!]
J Rudd
Mottram
[Extract] I object to an area of the green belt changing into industrial use when there is no identified need for this to happen. This contravenes Tameside's saved UCP policy OL1  [Extract] … beyond 2029 the Council feels that new employment sites may be needed. With the bypass in place, the Council believes the Mottram M67 site could contribute to this future supply. 
J Fewster Broadbottom If your procedures for notifying the public have been followed, then they are inadequate.  [Extract] The Council believes it has met and exceeded the requirements of Regulation 35, with the limited budget available
Longdendale Community Group  Mottram  (45 names & addresses given
1. Consultation with the community  Over 400 people throughout Mottram, Hattersley and Broadbottom were asked by members of a local community group (consisting of local residents) about the Preferred Plan for Mottram M67. Not one of these 400+ local people had heard anything about the Plan.  The Council Planners state that they had consulted the community in the following ways 
1. Via Newspapers. However, The Tameside Citizen is not delivered to various residents. Neither is the Tameside Advertiser delivered here. Only a very small percentage of residents receive the Glossop Chronicle/Reporter. According to residents, even within these newspapers, communication from the Planning Department re the above Plan did not include the maps illustrated in the 121-Page document on the TMBC/Plan web page. Therefore the significance, relevance and implications to the local community were not apparent
2. Notice on doctors’ surgeries. No one we met saw any such notice. 
3. Council web page. However, none of the 400+ persons we spoke with spends time perusing Council websites to study plans.  The Plan for Mottram M67 thus fails the test of soundness regarding its duty of community consultation in accordance to Government Policy: Planning Act 2008: Duty to consult local community; and more so the Localism Act 2011. This Act states points such as:  61W Requirement to carry out pre-application consultation (1)Where— 
(a) a person proposes to make an application for planning permission for the development of any land in England, and 
(b) the proposed development is of a description specified in a development order,  the person must carry out consultation on the proposed application in accordance with subsections (2) and (3). 
(2)The person must publicise the proposed application in such manner as the person  reasonably considers is likely to bring the proposed application to the attention of a majority of the persons who live at, or otherwise occupy, premises in the vicinity of the land. 
Neither is the Plan consultation in keeping with the spirit of the Act:  “Planning did not give members of the public enough influence over decisions that make a big difference to their lives. Too often, power was exercised by people who were not directly affected by the decisions they were taking. This meant, understandably, that people often resented what they saw as decisions and plans being foisted on them. The result was a confrontational and adversarial system where many applications end up being fought over.  The Localism Act contains provisions to make the planning system clearer, more democratic, and more effective. To further strengthen the role of local communities in planning, the Act introduces a new requirement for developers to consult local communities before submitting planning applications for certain developments. This gives local people a chance to comment when there is still genuine scope to make changes to proposals… Local planning authorities play a crucial role in local life, setting a vision, in consultation with local people, about what their area should look like in the future.” 
If the Local authority want to avoid the resentment, confrontation and accusations both of deliberate conspiracy against the community and deliberately concealing new development, a more rigorous consultation with the community is strongly indicated. 
2. Consultation with High Peak is not apparent. Therefore TMBC local authority fails in its duty to co-operate with the neighbouring local authority in the High Peak, according to the Localism Act regarding a strategic matter:  “sustainable development or use of land that has or would have a significant impact on at least two planning areas, including (in particular) sustainable development or use of land for or in connection with infrastructure that is strategic and has or would have a significant impact on at least two planning areas”. 
3. The site straddles the congested A57 to the east of the M67 terminal roundabout and sits within an Air Quality Management Area

(AQMA). To the north of the A57 the site lies in the Green Belt and to the south the site is designated Protected Green Space on the UDP Proposals Map under saved UDP policy OL4 (TMBC Local Development Scheme, May 2011, Appendix 1). Thus no additional traffic can be tolerated.  A concerned resident commented that “Councillors and planners have been reassuring residents that the proposed industrial estates will not happen unless a bypass is built”. Our response: the development impacts could be used to fuel the need for a bypass. This is not an acceptable motive for promotion of the Plan. Moreover, this reason is not stated in the Plan. 
4. Use of the site would contravene Tameside saved UDP policy OL1 (Protection of the Green Belt) as no very special circumstances have been demonstrated for such inappropriate  development, and OL4 (Protected Green  Space), as none of the exceptions criteria would be met
5. The Mottram M67 Plan is at variance with The National Planning Policy Framework (NPPF) core planning principles (para 17) which recognise the intrinsic character and beauty of the countryside, protect the Green Belt (paras 79-92), promotion of sustainable transport (paras 29, 30), and advocating conservation and enhancement of the natural environment (ch 11)
6. The Longdendale Integrated Transport Scheme (LITS) is presented by the planners as the panacea solution to the environmental problems, but the claims are speculative and unsupported by any robust arguments. Planning developments in Longdendale and High Peak have not been integrated, have not addressed the need to enhance the transport infrastructure, and there is a high proportion of local traffic.
7. Further environmental concerns.  TMBC has to comply with National Planning Policy Framework para 117
plan for biodiversity at a landscape-scale across local authority boundaries;  
 
Identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation ….promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan

Consultation
The production of the Core Strategy (and all Development Plan Documents) is guided by the Town and Country Planning (Local Planning) (England) Regulations 2012. Part 6 of these Regulations detail the process that must be followed when creating a local plan. Part 9 relates to the availability of documents during periods of consultation:  Availability of documents: general  35.—(1)

A document is to be taken to be made available by a local planning authority when— 
(a) made available for inspection, at their principal office and at such other places within their area as the local planning authority consider appropriate, during normal office hours,and 
(b) published on the local planning authority’s website, 
(2) In relation to any document made available under these Regulations, except a local plan or supplementary planning document which has been adopted or approved, the local planning authority may cease to make the document available once the period specified in paragraph(3) has expired. 
(3) The period mentioned in paragraph
(2)— 
(a) where the document relates to a supplementary planning document or to the local planning authority’s
statement of community involvement, is 3 months after the day on which the supplementary planning document or statement of community involvement is adopted;  (b) where the document relates to a local plan, is the 6 week period referred to in section113(4) of the Act that applies as regards the local plan concerned. 
(4) Where a local planning authority adopt, or the Secretary of State approves, a revision to a local plan or a supplementary planning document, as soon as reasonably practicable after the revision is adopted or approved, the local planning authority must incorporate the revision into the local plan or the supplementary planning document made available in accordance with this regulation. 
The Council believes it has met and exceeded the requirements of Regulation 35, with the limited budget available:  
Publishing 3 newspaper adverts
the Advertiser in 2 editions over a 3 week period;  
Issuing a press release to both the Advertiser and Reporter.
Attending all District Assembly Meetings in December to highlight the consultation was to start in January;  
Citizen;  
Holding 13 public  consultation events at libraries, markets and Hyde shopping centre; 
Publishing all documentation on the Council’s website;
Sent an email or letter to 500 individuals and organisations on the Local Plan consultation database;
Issuing paper copies of the document to all libraries and customer service centres; and  
Sending posters advertising the consultation at all doctors surgeries and schools within the Borough.  
 
Coupled with this direct means of informing and consulting, the Council welcomes the work undertaken by community associations such as the Longdendale Community Group, informing their local community of the consultation and the importance of the Local Plan.  The Council acknowledges that information within the council tax bill could be an effective way of reaching each household. Unfortunately these bills are only issued once a year and did not coincide with the consultation event. However, if timescales align in the future, the Council will utilise this resource.  Duty to cooperate  The Council has undertaken numerous meetings and discussions with all its neighbouring authorities in Greater Manchester and Derbyshire, to ensure compliance with the ‘duty to cooperate’. Evidence of this will be submitted with the Submission Core Strategy to the appointed examiner.  Traffic congestion  The Council recognises that Mottram and the surrounding area suffer from high levels of congestion and would not support development of the site without the bypass being in place.  Green Belt  The Council acknowledges the concerns related to the development of land currently within the Green Belt. If the proposal is taken forward, an appropriate Green Belt Review will need to be undertaken which will include assessments of landscape and biodiversity impact, together with a detailed justification for the sites release. A key element of such a review will be to ensure the Green Belt across Tameside continues to fulfil its function as outlined within the NPPF.  Alignment with the NPPF 
The Core Strategy will be independently accessed by an examiner appointed by the Secretary of State. If this examiner does not feel that the ‘plan’ meets national guidance, then it cannot be adopted by the Council.
It is the Council’s intention to align with all elements of the NPPF and associated regulations, to ensure it has a ‘sound’ Core Strategy that It can adopt. 

R. Chapman Mottram [Extract] Mottram has a small scale industrial lot and there are often units for rent on here. If an industrial estate was to be built without a customer in mind, it might be a white elephant [Extract] There are a number of brownfield and vacant employment sites across the Borough ….. However, beyond 2029 ….new employment sites may be needed. … the site could contribute to this supply. 
T McMylor  Mottram  [Extract]…why in the current economic climate when businesses all over the country are being forced to close, does the council feel it necessary to create a large industrial estate albeit in the future.  Ditto
T Craig  Mottram  One of 24 joint objectors [Extract] Views across the site lying to the north of Hyde Rd are part of the setting of Mottram Conservation Area. Industrial development on the site would be visible in several views into and from the Conservation Area, and would adversely affect its setting and character. 
In identifying the M67 site for future industrial development, TMBC have not taken into account the duty to co-operate with neighbouring authorities ….Such co-operation would have shown that existing industrial sites  located nearby in the Borough of High Peak are under-used.  As a result of this local over-provision, the proposed re-classification of the Mottram M67 site for industrial development could not reasonably be regarded as sustainable….the M67 site proposal would fail the sustainability element of the soundness test on examination.  Industrial development on the M67 site would inevitably create increased traffic flow in an area that is already very heavily congested.  The resultant increase in emissions from further traffic congestion would argue against the suitability of proposing the site for industrial development.  These foreseeable effects have not been taken into account in identifying the M67 site for industrial use.  Objections based on foreseeable storage and use of hazardous materials.  “Light and general” industrial developments can require storage and use of potentially hazardous materials such as flammable solvents and gas cylinders. There have been several well-documented incidents where fires involving such materials have caused damage to adjacent properties even where they have been kept in compliance with official guidance. 
[Extract]  policies will ensure the impact new development has on adjacent housing, landscape and Mottram Conservation Area are minimised as much as possible by the types of uses accepted on the site, the design of the buildings, use of landscape and restrictions offer hours of operation.  
 
The Council has undertaken numerous meetings and discussions with all its neighbouring authorities in Greater Manchester and Derbyshire, to ensure compliance with the ‘duty to cooperate’. Evidence of this will be submitted with the Submission Core Strategy to the appointed examiner.  … the Health and Safety Executive would not permit the development of use that would pose a substantial threat to neighbouring residential uses.  Nor would the Council support such a development. [LCG comment –  if such developments are within the existing legal guidelines, the Council would be powerless to stop them. Such was the case with Chemstar, a chemical factory in Carrbrook that broke no rules!].
W Newling  Mottram [Extract] Mottram does not need any industrial units and neither does anywhere else in Tameside, as there are plenty of empty ones around the Borough which need occupying. Our present economy is closing more businesses than starting them. [Extract] There are a number of brownfield and vacant employment sites across the Borough ….. However, beyond 2029 ….new employment sites may be needed. … the site could contribute to this supply.
B Bagshaw Mottram [Extract]  A new industrial estate will lead to more Green Belt being lost forever. Walking areas, playing fields and wildlife gone for concrete and buildings [Extract]  Any development that results in the loss of Protected Green Space / recreation facilities will be required to re-provide the facilities within the local community prior to development taking place. [LCG comment – These are empty promises. Green space lost to the Tesco site has not been reprovided so far, to our knowledge]