· Web viewWhere schools have gone above their roll this will have a detrimental on our young people A place where people are proud to live, with a decent home, a fulfilling job,

I am an individual making my own response I work for an organisation and am submitting on its behalf I am an agent responding on behalf of an individual, group or

organisation

Name: Christopher Jepson-Brown

Address1: 11, North Parade

Address2: New Hey, Milnrow, Lancs Postcode: OL16 3RD

Email address: [email protected]

Telephone number/s: (01706) 841332

I hereby confirm I am over the age of 13 - Yes Publishing my response after this consultation closes.

Yes publish my response in full Yes - publish my response but anonymise it No

Dear Sir/Madam,

I write with reference to the following sites: GM Allocation 3: Kingsway South GM Allocation 26: Land North of Smithy Bridge GM Allocation 27: Newhey Quarry GM Allocation 28: Roch Valley

I object to the proposals in their current format with the reasons specified in this letter.

Chapter 3 – Our Vision

We do not agree that the plan in its current form has allowed for this vision in Rochdale and particularly in the following areas

GM Allocation 3: Kingsway South GM Allocation 26: Land North of Smithy Bridge GM Allocation 27: Newhey Quarry GM Allocation 28: Roch Valley

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

The pride people felt in living here in the Pennine Villages has diminished because the character of our locality is slowly being diminished.

The work that our young people can do locally is limited. Our communities put a lot of value in education whether academic or vocational. We have an outstanding college in Rochdale but not schools – investment in primary schools is paramount to ensure our young have the best start. Where schools have gone above their roll this will have a detrimental on our young people

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

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

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

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

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

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

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

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

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

Chapter 11- Proposed Additional Sites (Allocations)

Q79. I strongly disagree with the GM Allocation 3: Kingsway South

The Overview document section ‘Proposed Additional Site (Allocations)’ states that “…most new development over the plan period will take place on currently identified sites within the urban area”. This statement is directly at odds with the use of GMA3 Kingsway in particular as it lies outside of Rochdale Council’s defined urban area. This renders this statement wholly incorrect. I therefore challenge it directly.

The Overview document section ‘Net loss of Green belt’ states that “the overwhelming majority of responses [to the first draft GMSF] related to Green belt loss”. I challenge that the revised GMSF takes these comments/views into proper consideration, given the obvious (‘overwhelming majority of responses’) strength of feeling on the loss of Greenbelt. I further challenge, therefore, that the GMCA in its revised GMSF has properly considered these comments/views.

I believe that the proposed allocations of Greenbelt land will add to urban sprawl. These allocations directly conflict with both the spirit and intention of the Greenbelt as described in national legislation and should therefore be removed from the GMSF. I therefore challenge their inclusion.

I do not believe that there is a proven case to allocate Greenbelt sites across Greater Manchester using the exceptional circumstance argument as described in legislation.

I believe that the revised GMSF should exclude all existing Greenbelt land from its allocation sites and thus proposed development plans.

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

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

Why should we lose our greenbelt? Our history and the character of our Pennine Villages for more housing, industrial units which have a knock on effect of more traffic? What about our health? We urgently need the plan to be re-evaluated and the 2016 figures to be used instead.

Once our greenbelt is declassified we cannot return from this. Once it is gone, it has gone.

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

I do not think that my local council or the GMCA have done enough to make me aware of the proposals contained in the revised GMSF.

I believe that my local Council, Rochdale, has not conformed to its legal duty under the ‘Statement of Community Involvement’.

I also believe that the GMCA has relied too heavily on the ten local Councils to disseminate information to Greater Manchester residents and thus by implication has fallen short of its implicit duty of community involvement.

I believe that a brownfield first approach should be adopted whereby the GMCA seek assurance from Government that this is a legitimate route to pursue and also seek urgent legislative change to that end, and before the GMSF is submitted to independent inspection.

I do not believe that a ‘brownfield preference’ approach, as described in the GMSF Overview document, will provide the necessary protection for the current Greenbelt.

I challenge the notion that new areas of Greenbelt proposed in the revised GMSF will have any protection given that proposals will remove the said same protection from current Greenbelt.

Whilst Rochdale Borough currently is over 60% Greenbelt, much of this is moorland used for grazing animals. This is generally inaccessible to the majority of residents and visitors. Rochdale Council makes much of this Greenbelt figure and use to suggest it can be readily reduced without detriment to the environment. The revised GMSF supports this approach by using Greenbelt reduction figures which do not take any account of accessibility and usage. I challenge this approach as flawed because it doesn’t show that the Greenbelt areas of greater general usage for leisure are those selected as allocation sites closer to urban areas.

I do not think that there is a need to expand Kingsway Industrial Estate to provide a further 310,000 sqm of employment space. I believe that if this is undertaken the jobs created in the Rochdale/Oldham allocation sites are likely to be low paid warehouse-type work. Furthermore, I do not believe that Rochdale Council have demonstrated the business case that hi-tech industries will be attracted to these sites.

I believe that Kingsway Business Park only equates to 59% of the land used. There are 2 unoccupied sites already built with over 300,000 sq ft and 12 sites not even built on. Why then should vital greenbelt be taken away? It has taken over 10 years to get to 59% occupancy.

With the Mayors vision of Brownfield sites first why is Rochdale not proposing the potential 2438 housing plots as part of the GMSF proposal, with a further 800+ homes unoccupied within Rochdale?

I believe there is adequate provision of employment space as set out in Rochdale Council’s Draft Allocations Plan (Sept 2018) to allow for growth in the medium to long term across Rochdale and up until 2028.

I believe that the GMSF gives little or no regard to the local farming industry. I believe they provide a vital part of the local, regional and national economy in terms of their contribution to food production.

I believe that the local transport network and infrastructure cannot cope with houses on the Greenbelt. This has a detrimental effect on health and wellbeing of

I believe that any proposed housing should be built on brownfield sites and at much higher density.

Where I live we currently experience high levels on congestion on the main roads/routes and motorway network. I do not agree that additional infrastructure [additional roads] if built, as proposed on the maps will solve this problem

Any building in this area will directly have an impact on my health and wellbeing

• An additional 950 homes here and in GM 88 means an additional 2090 cars- This is excessive

Air Quality GMCA by their own admission state that by next year 152 roads across the region will have breached or will be close to breaching the legal limit for nitrogen dioxide If they don’t tackle air pollution.  Their

data shows that one of these highly polluted roads is Elizabethan Way, Milnrow. The large volumes of slow moving and stationary traffic at peak times are the cause of these seriously high levels.  GMSF proposed developments for Kingsway, Newhey Quarry along with those at Smithy Bridge and Littleborough will only add to the congestion and increase nitrogen dioxide to alarming high levels which will seriously impact on the health of Milnrow and Newhey residents.  Nitrogen dioxide is a major cause of asthma, bronchitis, heart problems and cancer.   An increase in pollution related health conditions will put further pressure on our already oversubscribed NHS services.

I believe that the GMSF plan will make air quality worse and that this will have a knock on effect to health services and health of the current population. I do not believe that this will be alleviated in the short to medium term.

Green spaces and the Greenbelt in our towns are a vital lifeline to a huge variety of plants, animals, insects and birds. I believe building on our green spaces and Greenbelt will have a negative impact on the environment.

Specifically, I believe that Kingsway South will have a catastrophic impact on Red and Amber Listed Birds of Conservation concern that are to be currently found on the site. Criteria for Red Listed are:

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

Examples of such birds found on the site include: skylark, lapwing and linnet.

I believe Kingsway South would have a negative impact on key habitats and other wildlife found on the site, notably ‘the Meadow North of Moss Gate, an SBI with a rich and typically scarce floral assemblage. Here is a locally uncommon habitat of neutral grassland (not common in this area of predominantly acid geology), which again holds several rare and declining species, notably adder’s tongue, pignut, devils bit scabious, knapweed and betony. Not only are these species declining and scarce (primarily through loss of habitat!), but they are also important plants for invertebrates and key pollinating insects such as bees, butterflies, hoverflies, moths, etc. Even if this SBI was retained, development/alteration of the surrounding pasture would result in habitat fragmentation and isolation, cutting it off from green corridors and severely limiting the movement of species.

I rely on the green spaces and Greenbelt close to my home for my well-being and leisure time. Building additional houses and employment space on Greenbelt and green space will, I believe, have a negative impact on my and other people’s mental health and physical health. The NCA 54 Manchester Pennine Fringe document points to there being ‘a high demand for recreational opportunities, especially walking, horse riding and cycling’. Increasing housing and industry on an important green space not only intensifies that demand but limits the opportunities for countryside access. Not only will ordinary public rights of way be affected, but three recreational waymarked footpaths that cross the site – the Oldham and Rochdale Ways and Crompton Circuit. The importance of countryside and wildlife for good mental health and well-being is well

documented. Increasingly, activities such as walking and bird-watching are being prescribed by doctors for anxiety and depression as a sustainable alternative to drugs.

In the NCA 54 Manchester Pennine Fringe document is stressed the importance of ‘sense of place/inspiration’ and talks at length about how this is constrained by urban and industrial development. I believe replacing this area of countryside with housing and industry can only homogenise and take away our area’s special character and qualities. The following lifted from the aforementioned document illustrates the point beautifully and can never be underestimated:

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

Infrastructure such as hospitals, doctors, dentists, and educational facilities, are already over capacity/subscribed and the utilities such as sewerage/water system are already in need of urgent renovation and upgrading. I do not believe that the GMSF proposals will improve such services to the level required, particularly in the Milnrow and New Hey .

I believe these plans will be catastrophic for the school’s systems in Milnrow and New Hey. School places are already over scribed and resources are low. How can the villages cope with an additional 1805 children in GM3 and GM27

I believe that all avenues to bringing all brownfield sites across Greater Manchester to a ‘deliverable’ state must be exploited before any Greenbelt land is considered for development. I therefore call for all allocation sites containing Greenbelt land to be withdrawn from the GMSF until this is achieved.

I believe that remediation of difficult/toxic brownfield sites across Greater Manchester, no matter how large or small, should be undertaken before considering Greenbelt or green space for development.

I believe that money for brownfield site remediation must be found in the short to medium term, from either Central, Regional or local Council sources so that these sites are not left for future generations to deal with.

I recognise the need to plan properly and aspire for improvements to my local area, but I believe that the deregulation of existing Greenbelt is the wrong approach and will have a detrimental effect on my health and wellbeing, and a catastrophic effect on the heritage and sense of place for the local community.

Q106. I strongly disagree with the GM Allocation 26: Land North of Smithy Bridge?

Any building in this area will directly have an impact on my health and wellbeing

An additional 510 homes here and in GM 28 means an additional 1122 cars

All those who currently live in this are who need to travel via the M62 do so via Wildhouse Lane and through Milnrow Village

We currently experience high levels on congestion on the main roads/routes and motorway network. I do not agree that additional

infrastructure [additional roads] if built, as proposed on the maps will solve this problem

Air Quality GMCA by their own admission state that by next year 152 roads across the region will have breached or will be close to breaching the legal limit for nitrogen dioxide If they don’t tackle air pollution.  Their data shows that one of these highly polluted roads is Elizabethan Way, Milnrow. The large volumes of slow moving and stationary traffic at peak times are the cause of these seriously high levels.  GMSF proposed developments for Kingsway, Newhey Quarry along with those at Smithy Bridge and Littleborough will only add to the congestion and increase nitrogen dioxide to alarming high levels which will seriously impact on the health of Milnrow and Newhey residents.  Nitrogen dioxide is a major cause of asthma, bronchitis, heart problems and cancer.   An increase in pollution related health conditions will put further pressure on our already oversubscribed NHS services.

I believe that the GMSF plan will make air quality worse and that this will have a knock on effect to health services and health of the current population. I do not believe that this will be alleviated in the short to medium term.

Q107. I strongly disagree with the GM Allocation 27: Newhey Quarry

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

I believe that GMA27 proposal has the same challenges today and the impact on the local residents, community and wildlife are unchanged. The quarry is recognised as a significant geological site by the ‘UK Fossils Network’ and is quoted to be full of Calamities, bivalves and brachiopods, ripple marks, worm burrows and fish marks. The Milnrow Sandstone for which it was originally quarried for is estimated to be 306-316 million years old.

I believe that it is imperative that further investigation is undertaken in this area as the quarry also has a family of Peregrine Falcons, which are afforded the highest degree of legal protection (as quoted by RMBC) Interestingly RMBC have a live webcam set up on their own Town Hall clock tower to share the progress of a family of similar Peregrines which have called it home since 2008. Surely the peregrines that annually breed in the quarry are every bit as important as the ones that breed on Rochdale Town Hall (and elsewhere in GM, where they are celebrated, eg Manchester city centre, when the RSPB often set up well attended viewing events for the public)?

I believe that reducing the biodiversity balance can have negative environmental impacts when decimating grasslands and moss which can be a contributing factor to flooding due to the rain water causing erosion to the soil states and causing flooding beyond the site at the lower levels. I strongly believe that this area of significant biodiversity needs to be investigated further.

I believe that the infrastructure is incompatible for a project of this magnitude. Newhey Quarry is accessed by 18th century roads via Huddersfield Road, Jubilee bend and the recently upgraded Smart motorway M62/M60. The motorways recent alterations have not noticeably eased any traffic problems and daily, the 18th century roads are used as a default alternative route and are already overflowing with traffic queues

I believe we already experience high levels on congestion on the main roads/routes and motorway network. I do not agree that additional infrastructure [additional roads] if built, as proposed on the maps will solve this problem

Any building in this area will directly have an impact on my health and wellbeing

• An additional 950 homes here and in GM 3 means an additional 2090 cars- This is excessive

Air Quality GMCA by their own admission state that by next year 152 roads across the region will have breached or will be close to breaching the legal limit for nitrogen dioxide If they don’t tackle air pollution.  Their data shows that one of these highly polluted roads is Elizabethan Way, Milnrow. The large volumes of slow moving and stationary traffic at peak times are the cause of these seriously high levels.  GMSF proposed developments for Kingsway, Newhey Quarry along with those at Smithy Bridge and Littleborough will only add to the congestion and increase nitrogen dioxide to alarming high levels which will seriously impact on the health of Milnrow and Newhey residents.  Nitrogen dioxide is a major cause of asthma, bronchitis, heart problems and cancer.   An increase in pollution related health conditions will put further pressure on our already oversubscribed NHS services.

I believe that the GMSF plan will make air quality worse and that this will have a knock on effect to health services and health of the current population. I do not believe that this will be alleviated in the short to medium term.

Green spaces and the Greenbelt in our towns are a vital lifeline to a huge variety of plants, animals, insects and birds. I believe building on our green spaces and Greenbelt will have a negative impact on the environment.

I rely on the green spaces and Greenbelt close to my home for my well-being and leisure time. Building additional houses and employment space on Greenbelt and green space will, I believe, have a negative impact on my mental health and physical health.

Infrastructure such as hospitals, doctors, dentists, and educational facilities, are already over capacity/subscribed and the utilities such as sewerage/water system are already in need of urgent renovation and upgrading. I do not believe that the GMSF proposals will improve such services to the level required, particularly in the Milnrow and New Hey .

I believe these plans will be catastrophic for the school’s systems in Milnrow and New Hey. School places are already over scribed and resources are low. How can the villages cope with an additional 1805 children in GM3 and GM27

Alternative uses for the quarry

In keeping with the GMCS’ vision of: ‘A place where all children are given the best start in life and young people grow up inspired to exceed expectations’, the quarry site should become a nature reserve and/or a geological SSSI (either way, a valuable educational resource, with science and conservation at its heart), in keeping with the both National Character Areas, 36 Southern Pennines and 54 Manchester Pennine Fringe. The annual breeding peregrine falcons are a magnificent focal point here, just as the regular pair are on Rochdale Town Hall. There are also ponds here which provide breeding for amphibians and the site also has a rich and varied flora, with associated invertebrates, especially key pollinating insects like bees, butterflies and hover-flies. As well as biodiversity, geodiversity is a significant feature of this site (see details mentioned prior).

Q108. I strongly disagree with the GM Allocation 28: Roch Valley

Any building in this area will directly have an impact on my health and wellbeing

An additional 510 homes here and in GM 28 means an additional 1122 cars

All those who currently live in this are who need to travel via the M62 do so via Wildhouse Lane and through Milnrow Village

We currently experience high levels on congestion on the main roads/routes and motorway network. I do not agree that additional infrastructure [additional roads] if built, as proposed on the maps will solve this problem

Air Quality GMCA by their own admission state that by next year 152 roads across the region will have breached or will be close to breaching the legal limit for nitrogen dioxide If they don’t tackle air pollution.  Their data shows that one of these highly polluted roads is Elizabethan Way, Milnrow. The large volumes of slow moving and stationary traffic at peak times are the cause of these seriously high levels.  GMSF proposed developments for Kingsway, Newhey Quarry along with those at Smithy Bridge and Littleborough will only add to the congestion and increase nitrogen dioxide to alarming high levels which will seriously impact on the health of Milnrow and Newhey residents.  Nitrogen dioxide is a major cause of asthma, bronchitis, heart problems and cancer.   An increase in pollution related health conditions will put further pressure on our already oversubscribed NHS services.

I believe that the GMSF plan will make air quality worse and that this will have a knock on effect to health services and health of the current population. I do not believe that this will be alleviated in the short to medium term.

Q110. Do you have any further comments on the overall proposals for Rochdale, Including the strategic transport interventions? I am genuinely puzzled as to why Kingsway South has been earmarked for development on such a damaging scale, especially when the current Kingsway Site is only at 59% occupation after a decade. I’m also interested as to why it hasn’t been suggested to extend the current Kingsway site. Are there Greenbelt

restrictions adjacent here too? If so, why is this Greenbelt deemed to be more sacrosanct than the Kingsway South ones? I am talking about the area highlighted on the map below: