1.04a Statement of Consultation Part 1 of 3

Transcription

1.04a Statement of Consultation Part 1 of 3
1.04a
Local Plan Part 2:
Site Allocations and Development Management Policies
Statement of Consultation
Regulation 22 (1) (c)
Part 1 of 3
June 2014
CONTENTS
Section
Page numbers
Introduction
3
Background
4
Overview of key stages of consultation on the plan and policy development
5
Regulation 18 consultations: Preparation of a Local Plan
6
•
Information gathering and preparation of Issues and Options
6
•
Internal workshop – May 2011
8
•
Community Engagement at Ward Solution Meetings –
July-September 2011
•
Issues and Options consultation - July – September 2012
•
Consultation on potential housing development sites –
8
10
February-May 2013
12
•
Site allocations
16
•
Draft Development Management Policies
19
Appendices
1. List of Local Plan consultees
2. Internal workshop. Tasks, group feedback and key findings – May 2011
3. Engagement at Ward Solution meetings July-September 2011: Notes from meetings
4. Summary of representations to questions included in issues and options paper and
actions taken – July 2012
5. Summary of representations relating to general issues of concern in issues and
options paper and consultation on potential housing development sites – July
2012/February-May 2013
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6. Summary of representations relating to site specific issues of concern: issues and
options paper and consultation on potential housing development sites – July
2012/February-May 2013
7. Maps to illustrate the target areas for distribution of resident invitations to
consultation events – February-May 2013
8. List of consultees to update on site specific land availability – May-June 2013
9. List of consultees on draft Development Management policies
10. Summary schedule of representations relating to Development Management Policies
– July- August 2013
11. Summary schedule of representations relating to Development Management Policies
– August 2013
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INTRODUCTION
1. This statement has been prepared to meet the requirements of Regulation 22 (1) (c) of The
Town and Country Planning (Local Planning) (England) Regulations 2012 in relation to the
Council’s Local Plan Part 2: Site Allocations and Development Management Policies. The
purpose of the statement is to provide a summary of the Council’s consultation process,
feedback and outcomes for the production of the Local Plan. In accordance with the
legislative requirements the statement sets out the following information:•
•
•
•
Who has been consulted;
How they were consulted;
A summary of the main issues raised in response to the consultation;
How the issues raised have been actioned/taken into account in the Publication
Edition of the Local Plan.
2. This statement (Part 1 of 3) was made available as a supporting document to the consultation
on the Publication Edition of the plan which took place over 6 weeks from Monday, 27
January 2014 to Monday, 10 March 2014.
3. During the Publication consultation period the Council discovered that a small number of
representations made during the previous consultations (February – May 2013) had not been
fully recorded. An addendum to this statement (Part 2 of 3) has been prepared to include
these and provide copies of the consultation material.
4. Following the consultation at Publication stage a corresponding statement will be prepared
setting out the consultation process, how many representations were received together with a
summary of the main issues raised in the feedback. This will form Part 3 of the Statement of
Consultation.
5. All 3 parts of the Statement of Consultation, together with all representations received at
from the Publication consultation, will form part of the Submission documentation (Regulation
22 documents) to the Secretary of State for consideration at the independent examination of
the plan which will be managed by a Planning Inspector.
6. The Publication Plan was prepared in accordance with the Council’s Statement of Community
Involvement (adopted August 2006) and the supporting plan document ‘Statement of
Community Involvement Note – January 2014’.
7. The 2006 Statement of Community Involvement (SCI) confirms the Council’s commitment to
community engagement and sets out how it will engage with all sections of the community
including residents, statutory consultees and other stakeholder groups in the planning
process including the production of the Local Plan. The 2014 statement confirms the
changes to legislation and regulations which have been put in place since the SCI was
adopted and sets out the implications of these changes to the preparation of the Local Plan
Part 2, in particular the requirements for consultation. This is referenced in the background
document ‘Statement of Community Involvement Note – January 2014.’
8. The Publication Edition of the Local Plan was approved for consultation by Council Forum in
November 2013.
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BACKGROUND
9. The Publication Edition of the plan combines local planning policies on strategic site
allocations and Development Management policies. The document firstly sets out a series of
core policies to address the key issues that every development needs to address such as
location, impact and appearance; the following chapters are structured in the order of the
thematic spatial interventions included in the Core Strategy: •
•
•
•
•
•
Spatial Intervention 1:(Employment) Land supply for business development in
higher value sectors
Spatial Intervention 2: (Housing) Quantity, quality and mix of housing
Spatial Intervention 3: (Public facilities) Range and quality of public facilities
Spatial Intervention 4: (Environment) Protecting and enhancing the environment
Spatial Intervention 5: Quality of Place
Spatial Intervention 6: Access to jobs and services
10. The policies in the plan will apply to every development proposal that requires planning
permission.
11. The site allocations sections of the plan contain detailed, site specific policies and
development considerations for individual sites and will operate alongside the Development
Management policies which set out general policies to guide development.
12. Once adopted, the Site Allocations and Development Management Policies document
together with the Core Strategy (adopted January 2011) and the Joint Lancashire and
Minerals and waste Development Framework Core Strategy DPD (February 2009) and Joint
Lancashire Minerals and Waste Local Plan (Site Allocation and Development Management
Policies Part One and Part Two(adopted September 2013)) will form the development plan for
the borough.
13. The Local Plan Part 2 has been in preparation since mid- 2010. During its preparation, as
noted in ‘Statement of Community Involvement Statement – January 2014’ amended
regulations came into force on 06 April 2012; amendments included the introduction of a duty
to cooperate, reflecting the provisions of the Localism Act 2011 and a revision of the
reference numbers relating to each part of the plan preparation process.
14. With reference to Regulation 38 regarding ‘Saving’ of work previously carried out in
accordance with previous regulations the consultation completed prior to April 2012
(compliant with Regulations 25 of the 2004 Act) is considered to be compliant with
Regulations 18 of the 2012 Regulations. On this basis the consultations noted in this
statement will be referred to with reference to the current 2012 regulations.
15. As noted above this statement is one of a number of documents that will be submitted to the
Secretary of State alongside the Regulation 22 Submission Plan. Other relevant Submission
and supporting documents will include: •
The sustainability appraisal (SA) report. The SA process has been carried out
alongside the development of the Publication Edition of the plan and has informed its
content including consideration of the consultation feedback;
•
The duty to cooperate statement setting out how the Council has engaged with
certain bodies identified in the Act including neighbouring authorities and national
governmental organisations such as the Environment Agency/Network Rail and the
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Highways Agency on strategic and/or cross-boundary matters in the preparation of
the plan; and
•
Technical work on plan deliverability/viability and supporting evidence including an
updated version of the Strategic Housing Land Availability Assessment (SHLAA),
Plan Viability assessment, a Green Belt Study, Employment land Review, a Local
Highways Impact Study and a Level 2 Strategic Flood Risk Assessment.
OVERVIEW OF KEY STAGES OF CONSULTATION ON THE PLAN AND POLICY DEVELOPMENT
16. Consultation has been an integral part of the preparation of the Local Plan and has been
carried out to date, in a number of stages in the plan making process, as noted below in Table
1.
17. The Council tends to treat the statutory requirements as minimal obligations. It is committed
to engaging with all who may be affected by and /or have expressed a wish to be involved
with the preparation of plans that include their homes/neighbourhoods and the borough
generally. The Council acknowledges that consultation is a 2- way process and made a
commitment to all involved with this plan making process that it will feedback to residents to
set out its response and the actions taken in relation to community/stakeholder feedback.
More detail is provided in the following section.
18. It should be noted that consultation on the site allocations and Development Management
policies elements of the plan has on some occasions been carried out separately as recorded
below in Table 1. This is in part a reflection of the particular interests of the consultees
involved in each of the strands of the plan i.e. we found that generally residents were much
more interested in the site allocations, specifically the potential housing allocations. The
Council’s response has been to provide additional opportunities for consultation/engagement
with local communities on the issues of concern to residents.
Table 1: STAGES OF CONSULTATION
STAGE
Site
DM
Allocations Policies
REGULATION 18 Preparation of a local plan
CONSULTATION
Engagement
Dates
(Previously Regulation 25 of the Planning and Compulsory Purchase Act 2004)
Information gathering
and preparation of Issues
and Options
•
Call for Sites (CFS)
•
Internal workshop with Members and key
officers.
Series of area based workshops/Ward Solution
Meetings.
•
•
•
•
Feedback to community and community
organisations
•
•
Publication of issues and options paper
‘Delivering the Targeted Growth Strategy –
January-March
2011
May 2011
JulySeptember
2011
May 2012
Consultation on Issues
and Options paper
July 2012
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Table 1: STAGES OF CONSULTATION
STAGE
Site
Allocations
DM
Policies
•
•
CONSULTATION
Engagement
Site Allocations and Development
Management Policies Issues and Options –
July 2012’.
Drop-in sessions and exhibitions including bus
tour around villages
Dates
JulySeptember
2012
Consultation on potential
housing development
sites
•
Series of area based consultation events.
Feedback was provided in July 2013 to all who
attended /provided written feedback
February-May
2013
Update on site specific
information
•
Mailing to 92 consultees to request any
updates on availability of the put forward in the
call for sites in 2011
May-June
2013
Consultation /workshop on draft Development
Management policies
Consultation /workshop on draft Development
Management policies
July – August
2013
August –
September
2013
Statutory 6-week consultation.
27 January –
10 March
2014.
Draft Development
Management policies
•
•
REGULATION 19 Publication of a local plan
Consultation on
Publication Local Plan
(pre-Submission
consultation)
•
•
Please note:
This forms Part 3 of the Statement of
Consultation
19. Each key stage of consultation is discussed in more detail in the following section.
REGULATION 18 CONSULTATIONS: PREPARATION OF A LOCAL PLAN
20. The Publication Plan includes site allocations and a set of Development Management policies
that will be used in determining planning applications. As noted above and in Table 1
consultation on each of these strands of the plan did on occasion take place separately. The
following will track this as presented in Table 1 i.e. on the occasions when the 2 strands were
combined in a consultation activity the summaries of representations are combined and when
not the summaries are site allocation or Development Management policies specific.
21. Going forward to the Publication stage the statutory 6-week consultation will be undertaken
on the combined, single document.
•
INFORMATION GATHERING AND PREPARATION OF ISSUES AND OPTIONS
22. Information on sites for development had been gathered from various sources over a number
of years and continued during the plan preparation process.
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23. A call for sites exercise, to support the updating of the Council’s Strategic Housing Land
Availability Assessment (SHLAA) and in turn the preparation of the Local Plan, was carried
out for a 7-week period between 25 January and 11 March 2011. A Call for Sites form and
covering letter was posted to approximately 640 consultees on the Local Plan consultation
list. Recipients were asked to put forward sites for development, redevelopment or protection.
The majority of the responses related to sites already recorded in the SHLAA. 13 additional
sites were identified for development or redevelopment as listed below.
1. Harrison Street
2. Land between Whalley Banks, Duckworth/Galligreaves Streets and Dale/Thomas
Streets, Blackburn
3. Land at 7-13A Richmond Hill, Tontine Street, Blackburn
4. Land at junction Hollins Grove Street/Blackburn Road, Darwen
5. Land off Vale Street, near to junction with Tockholes Road, Darwen
6. Land at Higher Avondale Road/Owlet Hall Road/Woodbank Avenue, Darwen
7. Canterbury Street, Darwen
8. Land at Taylor Street, Blackburn
9. Land adjacent to Lower Eccleshill Road
10. Cheetham Farm, Green Arms Road, Chapeltown
11. Standhill Farm, r/o 53-95 Glenshiels Avenue, Hoddlesden, Darwen
12. Land on west side Bolton Road, Edgworth
13. Sandy Bank Road, Edgworth
24. At this same time a planning agent had initiated preliminary discussions with the Council
relating to land at Yew Tree Drive in the proximity of an area identified in the Core Strategy as
‘attractive areas suitable for executive housing’.
25. The 14 sites were added to the list of potential development sites.
Consultees
26. Appendix 1 sets out the consultees included on the Local Plan consultation list. This includes
statutory bodies/ neighbouring authorities/landowners/developers/residents and community
groups/planning agents and other professional bodies i.e. all persons/groups/agencies
identified as statutory consultees together with everyone who provided written feedback on
the plan and/or has asked to be included/kept informed on the preparations and future
consultations relating to the Local Plan.
27. Please note that this list has been used for a number of consultations over the plan making
timeframe to date (October 2013). The list provided in Appendix 1 is our current version
including any deletions/additions made over the plan making process since January 2011.
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•
INTERNAL WORKSHOP – May 2011
28. In May 2011 an internal workshop was held with Councillors and key Council officers
including representatives from Housing, Planning, Education, Corporate Policy and
Environmental Services. The purpose of the workshop was to raise awareness of the plan
making process and the input that would be needed from other council departments; to
identify and consider the strategic options that would support delivery of the Core Strategy;
and to provide information on suitable sites.
Consultees
29. 54 officers /Councillors were invited to the workshop; 32 attended.
Consultation process
30. The format of the workshop involved 4 groups each discussing and providing feedback on the
following questions:-
What strategic options need to be considered/consulted on?
-
Which strategic option do you prefer?
-
Which sites will be prioritised under this option?
31. The workshop tasks, feedback from the groups and key findings are provided in Appendix 2.
Please note that CIL was also discussed at this workshop. However the Council is not
preparing a CIL Charging Schedule at the moment.
•
COMMUNITY ENGAGEMENT AT WARD SOLUTION MEETINGS (July-September 2011)
32. The Council was keen that residents and community groups should have an opportunity to
make an input/influence the issues to be considered and addressed in the plan early in the
plan making process. Through July to September 2011 a series of consultation
events/workshops were held in local neighbourhoods at Ward Solution Meetings (WSM).
33. WSM are now an integral part of the Council’s neighbourhood engagement structure, are
chaired by an elected member and take place on a bi- monthly cycle in most of the 23 wards.
However in July 2011 they had been newly introduced to communities and in some areas
there was an element of hesitation amongst residents regarding their expectations and their
input to these meetings. Acknowledging this, every effort was made by planning officers and
the neighbourhood community based officers to present an accessible format for
engagement; further detail of the consultation process is noted below.
Consultees
25 This consultation was primarily targeted at residents and local groups. The
consultation/workshops were publicised on the homepage of the Council’s website, in the
Lancashire Evening Telegraph and through posters displayed in wards by the Community
Officers. The ward solution meetings, venues and agendas were also publicised by the
Neighbourhood Teams.
Consultation process
26 The consultation was included as an agenda item at each Ward Solution Meeting. It was
structured as a workshop and was designed to be interactive, with residents being asked to
identify sites in their local area on a map that they would like to see developed/redeveloped or
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protected from development. Residents were also encouraged at the WSM to discuss any
other planning issues of concern and or interest and their thoughts on how facilities and
services in their area could be improved .At this time the Council was considering setting up a
CIL Charging Schedule and intended to use this feedback to inform how communities would
like to see the monies spent their local area. The Council is not introducing a CIL charge on
development at the moment.
27 Planning officers attended 16 of the 23 Ward Solution Meetings. The remainder were
facilitated by Community Officers (CO). A briefing session and toolkit was prepared for the
Neighbourhood Managers and Community Officers which included notes on the background
to the Local Plan, purpose and format of the consultation together with a box of materials
such as maps, coloured stickers, posters and leaflets/hand-outs for each area (East
Blackburn, West Blackburn and Darwen and Rural).
28 The consultation programme including a list of the venues is provided below.
Table 2: CONSULTATION AT WARD SOLUTION MEETINGS – JULY-SEPTEMBER 2011
Date
Ward
Location
Time
Corporation Park
Revidge Hub
6.30pm
JULY 2011
th
Wednesday 20
Monday 25
th
Wensley Fold
Bank Top Centre
6.30pm
Monday 25
th
Shear Brow
Revidge Fold Church
6pm
Turton/Tockholes
Barlow Institute
Roe Lee
Trinity United Church
7.15pm
Queens Park
Guide Village Social Club
7pm
Wednesday 3
Little Harwood
Little Harwood Community Centre
6pm
Wednesday 3rd
Beardwood/Lammack
Lammack Church
6.30pm
Thursday 4
Earcroft
Earcroft Children’s Centre
Tuesday 9th
Sunnyhurst/Sudell
New Methodist Church
Marsh House
Borough Pub
Whitehall
Bolton Road Methodist Church
Roman Road Community Centre
th
Tuesday 26
AUGUST 2011
Monday 1
st
nd
Tuesday 2
rd
th
th
Wednesday 10
SEPTEMBER 2011
st
Thursday 1
Monday 5
th
Highercroft
Monday 5
th
Bastwell
th
Tuesday 6
th
Wednesday 7
6pm
5.30pm
Audley
Chester Street Mosque
6pm
Livesey/Pleasington
Feniscowles School
6.30pm
Page 9 of 21
Table 2: CONSULTATION AT WARD SOLUTION MEETINGS – JULY-SEPTEMBER 2011
Date
Ward
Location
th
East Rural
Carus Centre, Hoddleston
th
Shadsworth/Whitebirk
St Oswald Church
6pm
th
Mill Hill Ward
Mill Hill Community Centre
6.30pm
Wednesday 14
th
Fernhurst Ward
Fernhurst Hotel
6.30pm
Thursday 15th
Ewood Ward
Ivy St Community Centre
6.30pm
Monday 19th
Meadowhead
Greenfield Community Centre
6.30pm
Wednesday 7
Wednesday 7
Wednesday 14
Time
Feedback
29. Whilst every effort was made to encourage residents to become involved attendance and the
extent to which residents engaged with the planning issues at this stage was mixed and did
vary across the wards.
30. Appendix 3 provides the notes from the meeting which summarises the comments and issues
of concern. These were used to inform the development of the next stage – the preparation of
the issues and options consultation paper.
•
ISSUES AND OPTIONS CONSULTATION (July-September 2012)
31. In July 2012 the Council issued an issues and options consultation paper ‘Delivering the
Targeted Growth Strategy – Site Allocations and Development Management Policies Issues
and Options: July 2012’. The key influences on the content/strategic direction of this
document included:
Consultation feedback to date;

The Core Strategy and its strategic framework for transformation, economic
and housing growth across the borough;

Considerations of deliverability taking into account the impact of the
recession, the end of external funding, the borough’s development market
and the need to establish private sector investment confidence;

The Government’s agenda for localism, economic and housing growth and a
more light touch planning system as outlined in its National Planning Policy
Framework (NPPF);

The shift towards a development management approach i.e. a more
proactive and positive approach to development, and;

The intention to provide additional detail and guidance on a number of topics
via a supporting set of Supplementary Planning Documents.
32. The issues and options document set out a series of planning issues for the borough and
different ways – the options - in which these could be addressed to deliver attractive and
sustainable development.
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33. The format of the consultation document was structured around the six spatial interventions
identified in the Core Strategy, as noted above. For each of the six headings the document
set out: •
•
•
•
Issues in relation to allocating and designating sites;
Consultation questions and in some cases options in relation to site allocations and
designations. For housing allocations the options took the form of ‘bundles’ of sites
representing different scenarios including ‘delivery-led’/’urban-led ‘and ‘regeneration led’;
Issues in relation to Development Management policies, and;
Consultation questions and in some cases options in relation to Development Management
policies.
Consultees
34. Appendix 1 sets out a list of the people invited to submit representations.
Consultation process
35. The consultation process was carried using a combination of the following methods:•
•
•
•
•
•
•
The document and all supporting material were made available on the Council’s
website.
Contact details were provided for anyone needing further information and comments
could be returned on line via an electronic representation form;
Notices were placed in the local press (Lancashire Telegraph and the Bolton News)
to inform people of the arrangements for the drop-in sessions and exhibitions;
Feature article was included in the Council’s free newspaper ‘The Shuttle’ distributed
throughout June to all households across the borough informing the community of the
purpose of the consultation and the planned events. The included a questionnaire –
the same questionnaire as available at the exhibitions and drop in-sessions – for
people to complete and return;
Letters were sent to all included on the Local Plan consultation list, approximately 640
consultees;
Posters were displayed in key public locations across Blackburn and Darwen
including the town halls/libraries/market/The Mall shopping centre/colleges and
supermarkets;
Copy documents were available in both town halls and main libraries; and
A number of drop-in sessions and exhibitions including village exhibition bus tours
were held across the borough. The drop-in sessions and public exhibitions, including
the bus tours contained a number of display boards setting out the Core Strategy’s
vision, the need for more detailed plans and policies to realise this vision over the
Core Strategy time period to 2026 and the issues this raised that needed to be
addressed in the Part 2 plan. The consultation document was available to view at the
exhibition, copies of the exhibition material were available to take away and
questionnaires - the same as printed in the Shuttle and accessible on-line – were
handed out to all consultees. Two or three members of staff attended each of the
events to answer any questions and in many cases to outline the content of the
consultation document and the next steps in the preparation of the plan.
36 The list of the consultation venues is provided in Table 3 below.
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Table 3: ISSUES AND OPTIONS CONSULTATION EVENTS JULY 2012 - PROGRAMME
OF EVENTS
Date
Event location
Time
Drop in sessions:
th
Monday 16 July
th
Tuesday 17 July
Blackburn Library meeting rooms 1 & 2
Darwen Library Theatre café/bar
2-7pm
2-7pm
Public exhibitions:
th
Monday 9 July
th
Friday 13 July
Blackburn Market
Darwen Market Atrium
10am-4pm
10am-4pm
Village exhibition bus tours:
th
Tuesday 24 July
Barlow Institute, Edgworth
Chetham Arms pub car park, Chapeltown
Ranken Arms pub car park, Hoddlesden
th
Wednesday 25 July
Butlers Arms pub car park, Pleasington
Roddlesworth Visitor Centre/Vaughn’s café
Tockholes
Black Dog Inn car park, Belmont
10am-1pm
1.30-2.30pm
3-5pm
10am-12 noon
12.30-2.30pm
3-5pm
37. At this stage 188 written responses were received. The main issues raised are noted together
with the continuing consultation through February-May 2013 in the next section of this
statement (Consultation on potential housing development sites – February-May 2013).
38. A summary of the feedback and the outcome has been documented and is provided in the
schedules included in Appendices 4, 5 and 6.
39. Appendix 4 sets out the feedback received and actions taken –in terms of how the comments
have been taken in account the content of the Publication Edition plan - with regard to each of
the questions included in the issues and options consultation document.
40. The general and site specific comments made on completed questionnaires are included in
Appendices 5 and 6:-
•
-
Appendix 5: Summary of representations relating to general issues of
concern in issues and options paper and consultation on potential
housing development sites – July 2012/February-May 2013
-
Appendix 6: Summary of representations relating to site specific
issues of concern in issues and options paper and consultation on
potential housing development sites – July 2012/February-May 2013.
CONSULTATION ON POTENTIAL HOUSING DEVELOPMENT SITES (February-May 2013)
41. Following the issues and options consultation held in July 2012 a significant number of
residents and elected members commented that they had not been aware of the events and
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were frustrated that they had not been able to input into the preparations of the plan. The
majority of concerns related to the future, potential housing development across the borough.
The Council acknowledged that attendance had been low and agreed that consultation
needed to be extended to provide additional opportunities for community engagement at this
stage in the production of the plan.
42. Whilst there was a time gap between the completion of the consultation events carried out in
July 2012 and the commencement of a series of 14 events in February 2013 the consultation
has altogether been regarded as a single exercise in terms of the outcome, its influence on
the content of the Publication Edition of the plan including both site allocations and policy
development.
Consultees
43. The targeted consultees were principally residents in the areas surrounding the potential site
allocations. Other stakeholder groups including statutory bodies had been involved and had
had the opportunity to respond to the previous consultation process on the issues and options
paper. It was not considered necessary to contact them again. All comments at this issues
and options stage have been recorded together in the schedules at Appendices 4, 5 and 6, as
noted above.
44. Over 11,000 invitations with details of all consultation events were sent out in the post to
households surrounding the potential development sites. The maps at Appendix 7 indicate the
target areas for distribution of this mailing; 1. Blackburn
2. Darwen and Hoddlesden
3. Tockholes,
4. Belmont Village and Edgworth/Chapeltown
45. The boundaries for the mailing were agreed in discussion with the Neighbourhood Teams and
local elected members.
Consultation process
46. The consultation process was carried out using a combination of the following methods: •
•
•
•
•
•
A series of briefings were held with neighbourhood officers and elected ward members to
inform the consultation process including the identification of suitable venues/drafting and
distribution of leaflets and attendance at the events;
Letters were sent to all statutory consultees, agencies, developers, interested parties and
members of the public on our mailing list of people who had asked to be kept informed of
progress including future opportunities for consultation on the plan;
A copy of the exhibition material and a comments form – the same as available at the events were made available on the Council’s website. People were offered a number of choices
regarding the return of their feedback including on-line/via post or at the events;
11,259 leaflets/invitations to the events were posted out to residents in the areas surrounding
the proposed residential development sites. The ‘target area’ for the posting was agreed in
discussion with the local neighbourhood teams and the elected ward members. In some
areas residents and/or members printed additional copies of the invitations and distributed
these by hand. Refer to Appendix 7 for the distribution areas;
Posters were displayed in key public locations within the neighbourhoods close to the
proposed development sites/events and at the events to make people aware of future events;
A press briefing was organised with the Lancashire Telegraph’s local government reporter;
Page 13 of 21
•
•
An article was included in the Council’s free newspaper ‘The Shuttle’ distributed to all
households across the borough informing the community of the planned consultation events;
A series of 14 drop-in sessions /exhibitions were held across the borough, including the
villages. The exhibition consisted of a number of display boards setting out the housing
related issues that need to be addressed in the plan to achieve the Core Strategy ‘s vision
and housing targets/an explanation of the considerations and challenges to delivery in the
current market and maps showing the potential development sites across Blackburn and
Darwen. Copies of the exhibition material and comments forms – the same as available on
line – were handed out to all consultees. A minimum of three members of staff attended each
of the events to answer any questions and in many cases to outline the content of the
consultation document, the next steps in the preparation of the plan including how
consultation feedback would be taken into account and how the Council intended to feedback
to residents.
47. The consultation programme including a list of the venues is provided in Table 3 below. The
material available at each event was the same and residents were encouraged to attend any
event if the drop-in session in their area was not convenient.
Table 3: CONSULTATION ON POTENTIAL HOUSING DEVELOPMENT SITES FEBRUARY-MAY
2013 – PROGRAMME OF EVENTS
Events
Sites
Event time/location
1
Belmont Village
5.30-7.30 Tuesday, 26 February
Black Dog Inn, Belmont Village
2
Edgworth/Chapeltown
5.30-7.30 Wednesday, 27 February
Barlow Institute, Edgworth
3
Golf Club (2 sites)
4
Paterson Street/Alaska/William
Street/Highfield
Road/Infirmary/Griffin
Queen’s Park/Haslingden Road (2
sites)/Blackamoor Road
5.30-7.30 Tuesday, 05 March
Golf Club, Beardwood Brow, Blackburn
5.30-7.30 Thursday, 07 March
Ivy Street Community Centre, Ivy Street, Blackburn
5
6
6.00-8.00 Wednesday, 13 March
Blackburn Central High School with Crosshill,
Haslingden Road
Roe Lee Mills and land behind up
to Knowles Arms/Royshaw
Gib Lane/Sappi/Voith/Albion
Mill/Moorgate/Bridge/Pioneer Mills/
Eclipse Mill
6.00-8.00 Monday, 18 March
Pleckgate High School, Pleckgate Road
3.30–7.30 Friday, 22 March
Greenfields Community Centre, Green Lane,
Blackburn
8
Parsonage Road/Brownhill
Drive/Bank Hey Lane
5.30–7.30 Tuesday, 09 April
St Gabriel’s Church, Brownhill Drive, Blackburn
9
Rugby Club/Ramsgreave
Drive/Yew Tree Drive
10
Hoddlesden
5.30 - 7.30 Thursday, 18 April
Blackburn Rugby Club, Ramsgreave Drive, BB1
8NB
5.30-7.30 Tuesday, 23 April
Carus Centre, 3 Queen Street, Hoddlesden
11
Bailey’s Field/Pole Lane/Cranberry
7
6.00-8.00 Monday, 29 April
Page 14 of 21
Lane/Jack’s Key/ Sough Road
Moorlands School/Robin/Shorey
Bank/Premier and Progress Mills
West Darwen
12
13
Darwen Vale High School, Blackburn Road,
Darwen
4.00 – 7.30 Wednesday, 08 May
Derwent Hall
6.00–8.00 Thursday, 16 May
Darwen Vale High School, Blackburn Road,
Darwen
14
Tockholes
5.30–7.30 Tuesday, 21 May
Tockholes Village Hall, Tockholes,
48. Over 1100 people attended the events.
49. The Council has received 239 written responses.
50. Together with the responses received in July/September 2012 the Council has received 427
written responses to the consultation on the issues and options.
51. The main issues that arose in July 2012 and February-May 2013 included:
•
•
•
•
•
•
Concerns regarding the impact of development particularly on greenfield sites;
Constraints to development on particular sites; examples included. incidence of localised
flooding, access difficulties, oversubscribed local facilities such as schools/doctors;
Questioning of the demand/need for the proposed scale of new housing when
employment opportunities are declining and so many houses remain unsold for long
periods;
View that brownfield sites should be prioritised over greenfield and before urban
extensions are considered;
Need for complementary investment to support growth agenda; examples included in
local facilities, the town centres, jobs and business development and renovation/reuse of
empty properties, and
Desire to protect the surrounding countryside/access to the countryside for the benefit of
established residents.
52. A summary of the main representations received and an indication of how these comments
have been taken into account in the Publication Edition of the plan is set out in in Appendix 5
and 6: -
Appendix 5: Summary of representations relating to general issues of
concern in issues and options paper and consultation on potential
housing development sites – July 2012/February-May 2013.
-
Appendix 6: Summary of representations relating to site specific
issues of concern in issues and options paper and consultation on
potential housing development sites – July 2012/February-May 2013
53. The specific housing sites included in Appendix 6 are as follows: -
Page 15 of 21
1. Belmont Village and surrounding area
2. Edgworth and surrounding area
3. Blackburn Golf Club, Blackburn
4. Griffin/Paterson Street/Alaska-William Streets/Highfield Road and Infirmary, Blackburn
5. Haslingden Road (including Fishmoor and Blackamoor Roads), Blackburn
6. Roe Lee, Blackburn
7. Gib Lane (including west of Gib Lane and east of Heys Lane)/Sappi (including Stockclough
Lane)/Voith/Albion/Moorgate/Bridge/Pioneer and Eclipse Mill, Blackburn
8. Parsonage Road, Blackburn
9. Brownhill Drive Blackburn
10. Blackburn RUFC and land north of Ramsgreave Drive (including Yew Tree Drive and
Preston New Road), Blackburn
11. Bailey’s Field/Ellison Fold , Darwen
12. Pole Lane, Darwen
13. Former Moorland School, Darwen
14. Kirkham’s Farm/Cranberry Lane/Jacks Key, Darwen
54. Appendices 5 and 6 both include a column headed ‘Council response’. As part of the desire to
keep the community involved in what many residents considered a lengthy plan making
process the Council made a commitment to residents that it would provide feedback following
completion of the consultation events and prior to the consultation on the Publication Edition
of the plan. In July 2013 we mailed out a leaflet ‘A New Local Plan for Blackburn with Darwen’
that summarised by topic the general issues included in the written feedback together with a
Council response to all residents who attended/provided written responses/completed
comments forms. A document providing the Council’s response to site specific issues was
made available on the Council’s website.
•
SITE ALLOCATIONS
Update on site specific information (May-June 2013)
55. During May-June 2013, to complete the updating of the SHLAA and to support the ongoing
site specific assessments for allocations, a further information gathering/consultation exercise
was carried out with the people/organisations who had responded to the call for sites in 2011.
Its purpose was to gain updated and/or any new information on site availability in particular to
establish that land is either available now, or is likely to be available at a specific point in time.
56. The majority of responses related to identified sites. However a few further site suggestions
were received which have now been included in the SHLAA update; these are noted below.
Page 16 of 21
1. Land to west side of Bolton Road, Turton
2. Land at Fickle Hall Farm
3. Land at corner of Bedford Street and Parkinson Street
4. Land off Whinny Lane, Blackburn
5. Land off Pleasington Lane, Pleasington, Blackburn
57. 4 of these sites (1, 3, 4 and 5) have subsequently been accessed as non-starters in terms of
their availability for housing development as they are either below the site size threshold used
in the SHLAA or are contrary to policy – the land off Whinney Lane is located in the Green
Belt.
Consultees
58. Appendix 8 sets out the list of consultees including individuals and agencies invited to provide
feedback. These were principally people who had previously contacted the Council regarding
sites for inclusion in the Local Plan site allocations.
Consultation process
59. Letters and a pro-forma were sent to all consultees included on the list in Appendix 8 to
complete and return.
HOUSING Site allocations
60. An overview of the methodology that has been used to identify and select the housing sites
contained in the Publication Edition plan is provided in a supporting site selection topic paper
‘Approach to the Selection of Housing Allocations.’
61. In summary as set out in the site selection topic paper all site suggestions made throughout
the various stages of consultation and plan preparation process have been considered in
updating the Council’s Strategic Housing Land Availability Assessment (SHLAA). This has
provided an up-to-date assessment of each sites suitability, availability and achievability – the
key indicators of a sites’ deliverability.
62. The up-to date assessment has also enabled a detailed housing trajectory to be developed
based on the potential land supply and to demonstrate that the targets within the Core
Strategy remain achievable. The identification of specific sites within the housing trajectory
was restricted to sites with a development potential of 50 dwellings or more, so that the
process focussed on strategic issues. A windfall allowance has been applied below this
level. Whilst applying a minimum size threshold of 50 dwellings for identification within the
housing trajectory, it was also necessary to consider which of these sites should be allocated
within the plan.
63. The NPPF does not require the allocation of all of the specific sites which will form part of the
housing supply. However, para 47 does state that there is a need to ensure that Local Plans
identify key sites which are critical to the delivery of the housing strategy over the plan period.
Furthermore, para 157 states that Local Plans should allocate sites to promote development
and flexible use of land, bringing forward new land where necessary, and provide detail on
Page 17 of 21
form, scale, access and quantum of development where appropriate. On this basis the
following criteria were used to appraise potential allocations:
•
Key sites which are critical to the delivery of the housing strategy over the plan period:
o
Key GROWTH sites - all housing developments outside of the urban area boundary
(or village boundaries);
o
•
Key REGENERATION sites - within the urban boundary and rural regeneration sites
Sites where it is necessary to provide specific details on form, scale, access and quantum of
development
o
Sites where it is necessary to deliver / coordinate specific infrastructure (i.e. require
policy guidance on form of development to ensure infrastructure provided);
o
Those which will provide for a specific identified need, particularly that for older
people (i.e. promotion of a specific development type).
64. The findings of the updated SHLAA and consultation responses were then reviewed to make
a professional judgment about which sites satisfied the criteria.
65. For those sites identified for allocation, policy wording has been developed to ensure that the
main development considerations are identified based on issues which emerged during the
consultation and plan preparation process. In parallel, detailed site allocation proformas were
prepared to provide for the reasoned justification for allocations (these are attached to the site
selection topic paper).
EMPLOYMENT Site allocations
66. The employment land allocations have been informed by the process and outcome of
updating the Council’s Employment Land Review. (ELR)
67. Conclusions from the 2009 Employment Land Review were used to understand the supply
and demand for employment land and underpin policies in the Core Strategy. A commitment
was made in the Core Strategy to consider the future allocation of employment sites through
subsequent Development Plan Documents i.e. Local Plan Part 2.
68. An updated ELR was completed in September 2013. This analyses employment land
demand, supply and need to 2026 and was informed, in part, by the 2012 Development
Markey Study carried out for the Council by GH Regeneration and Jones Lang LaSalle, which
itself informed the employment sites and policy options which were put forward in the 2012
issues and options paper.
69. Consultation with stakeholders is a key part of the ELR process. This has included
discussions with commercial developers and Council representatives, with the comments
helping to inform the construction of a qualitative picture of employment land viability in the
borough. In addition, the 2012 Development Market Study provided an assessment of
development market conditions across the borough, including whether a selection of
proposed housing and employment sites were realistic and deliverable in light of market
conditions. Sites were attributed scores according to an assessment matrix which consisted
of a checklist of key factors that influence development viability, and led to the selection of a
range of sites which were put forward in the 2012 issues and options paper. This assessment
method was extended to all employment sites in the borough, to enable sites to be compared
and contrasted according to score and therefore development viability.
Page 18 of 21
70. At the conclusion of the ELR process, a draft copy of the document was sent out to
neighbouring authorities, the county council and the Lancashire Enterprise Partnership. In
addition, the sites considered for employment allocations were assessed as part of the
Sustainability Appraisal.
71. Three of the potential sites which were identified for employment at issues and options stage
were not taken forward in the Publication Edition:•
Blackamoor Road was not deliverable for employment development due to the requirement
for a new link road.
•
Lower Darwen Paper Mill and Sappi have been identified as 'Development Opportunities' to
offer flexibility for mixed uses (residential and/or employment) to come forward.
72. A key issue for the selection of employment sites was to ensure that sites of the correct
typology were available. A range of typologies were defined in the Core Strategy (CS2:
Typology of Employment Land); every employment site was categorised in the ELR according
to these typologies. This categorisation, alongside the viability scores, enabled the selection
of a portfolio of available development land (as explained in the Publication Edition) which
could accommodate different types of businesses at every stage of their growth, and should
also allow the market to create modern business environments. With this in mind, sites were
selected to provide a supply of good quality, ready to develop land for employment, which
are supported by a flexible and positive policy framework.
•
DRAFT DEVELOPMENT MANAGEMENT POLICIES – July-September 2013
73. As noted above in Table 1: ‘Stages of Consultation’ consultations on the Development
Management (DM) policies did on occasion take place discretely in July and September 2013.
74. The DM Policies have been created in accordance with the plan-making objectives set out in
the NPPF, and aim to deliver each theme of the Core Strategy. The Publication Edition plan
includes a set of 12 core policies followed by more specific policies grouped into
chapters following the thematic format of the Core Strategy.
75. The structure and content reflects the Council’s objective to have a relatively simple, high
level, flexible policy framework with significantly fewer policies than can be found in the
current Local Plan (Blackburn with Darwen Borough Local Plan (adopted April 2002)), and to
provide a set of policies that will actively support development in coming forward. The
intention is to provide more detailed guidance on a range of topics via a supporting suite of
Supplementary Planning Documents including for example Housing Delivery, Green
Infrastructure, Developer contributions, Issues relating to development and people (Policy 8)
and Town character studies.
76. A draft version of the DM Policies was produced for consultation in July 2013 following
consideration of feedback received in relation to the issues and options and potential housing
development sites consultations in 2012 and 2013.
Consultees/consultation process
77. Letters were sent to 34 people including statutory agencies, planning agents and
neighbouring authorities inviting them to attend a consultation workshop in July 2013 to
discuss the draft document. 16 stakeholders attended the workshop; each of the draft
policies was discussed. Stakeholders were also encouraged to provide their views in writing
after the event.
Page 19 of 21
78. Appendix 9 sets out a list of the people invited to the workshop.
79. 14 stakeholders provided comments during and after the July 2013 workshop. A summary of
the representations and the Council response is set out in Appendix 10.
80. This feedback informed the preparation of a revised draft of the DM Policies which was
produced for consultation in August 2013. The revised draft was again circulated to the
consultees listed in Appendix 9 with a request for further comment.
81. A further 10 written responses were received. These were considered alongside issues raised
by the interim Sustainability Appraisal report relating to DM policies and together have
informed the development of the Publication Edition plan.
82. Appendix 11 sets out a summary of the representations received in August 2013 and the
Council response which has informed the Publication Edition set of Development
Management policies.
83. The particular themes that stakeholders raised included:•
Widespread support for the simplified structure and concise number of policies.
•
Several stakeholders were keen to ensure that policies should not add unnecessarily to
the financial burdens on development.
•
Stakeholders felt that policies should be positively worded - seeking positive improvement
rather than merely managing harm.
•
Stakeholders had a clear view that the DM Policies should be consistent with the NPPF.
Page 20 of 21
APPENDIX 1: List of Local Plan Consultees
Local Plan Part 2: Site Allocations and Development Management Policies
Regulation 18 Consultations: Preparation of a Local Plan
Organisation
53 Degrees North
A & A Building Solutions Ltd.
A & K Solutions Ltd.
A.L.H. Design Services
A.N. Designs Ltd.
A+Studio
AAMIR Design Ltd.
Abbey Inet Ltd.
AC Joinery and Building
Accrington Road Community
Association
Acland Bracewell Surveyors Limited
ACME Studios Housing Association
Ltd.
Action on Hearing Loss
Adam Building Design Services
Adams Holmes Associates
Adams Holmes Associates
ADB
ADM Design
ADS
AEDAS Building Consultancy
Age Concern Blackburn and
Darwen
Age UK
Ainscough Strategic Land
Ainscough Strategic Land
Ainsworth Lord Estates
Alan Kinder Associates
Alexandra West Sales and Lettings
Alison Roland Town Planners Ltd
AMEC E&I Ltd on behalf of National
Grid
Anchor Trust Housing Association
Ancient Monuments Society
Anglezarke Parish Meeting
Architectural Consultancy
Arcus Consulting LLP
Arley Homes
Arlington Securities
Arriva Northwest
Artech Design
Position
First name
Surname
Usman
Hafejee
Andrew
Swain
Asif
L.M.
Neki
Tugwood
Andrew
Crotty
Keiran
Paul W.
Kareem
Smith
Jonathan
Harvey
Mohammed
Carol
Liz
Emily
Andrew
Rafiq
Leanne
Adam
Horlock
Reese
Gardiner
Morgan
Mogra
Elkin
Pauline
Walsh
John
Rachael
Brooks
Ainscough
Alison
Roland
Robert
Deanwood
Peter
A.L.
Smellie
Tomlinson
Bobby
Gareth
Chakravarthy
Jarvis
Managing Director
Chairman
Director
Clerk
Land Executive
Page 1 of 16 APPENDIX 1: List of Local Plan consultees
ATC Construction Design
Athertons Chartered Surveyors
Atkins Global (on behalf of NOMS)
Audley and Queen's Park
Community Association
B & E Boys Ltd.
B.T.C.V.
Badenoch & Clark
BAE Systems
Associate Property
Director
Lancashire County
Field Officer
Regeneration
Division
Property & Planning
Property l & lS
Bailey Dyson
Bank Top Community Association
Banks Developments
Barlow Institute
Barlow Rowland
Barratt Homes
Barratt Manchester Ltd.
Barry Watson Davies
Barton Willmore
Barton Willmore Partnership
Barton Willmore Partnership
BBC Radio Lancashire
BE Ltd.
Beardwood Design Ltd.
Bellway Homes
Bellway Homes Ltd
Belmont Village Association
Belthorn Village Committee
BHRV Health Care NHS Trust
Blackburn & District Blind Society
Blackburn & District Enterprise
Trust
Blackburn & District Trades Council
Blackburn Chamber of Trade
Blackburn Citizen
Blackburn Civic Society
Blackburn College
Blackburn Conservative Association
Blackburn Groundwork Trust
Blackburn Labour Party
Blackburn Natural History Society
Blackburn Record Exchange
Blackburn Rovers Community Trust
Blackburn Rovers F.C.
Blackburn with Darwen Borough
Council
Blackburn with Darwen Council for
Voluntary Service
Community
Development Officer
Information &
Records Team
Partner
John
John
Schofield
Atherton
Barry
Dean
Eddie
Mr
Reed
Mapple
Richard
Dyson
Charlotte
Burgess
A.
Brown
Claudia
Dan
Nathan
Hawkins
Mitchell
Smith
Station Manager
Chris
Peter
Planning & Development Division
Chair
Director of Estates
Secretary
Principal
Wilson
Holgate
David
Jason
Bateson
Slack
Mike
Latham
K.
Ian
Rita
Whittaker
Gallagher
Wakeley
Richard B.
Prest
Tony
P.
Gillian
Nick
Culverhouse
Vaughan
Kinloch
Hall
Paul
Rea
Executive Director
Community Office
Ewood Caravan Site
Liaison Officer
Page 2 of 16 APPENDIX 1: List of Local Plan consultees
Blackburn with Darwen Friends of
the Earth
Blackburn with Darwen Learning
Disability Partnership Board
Bloor Homes North West
BM&E
BM&E
BNP Paribas Real Estate
Bolton Council
Bolton College
Bolton News
Martinda
le
A.
Strategic Lane Director
Planner - Development &
Residential Consulting
Development Manager
(Planning Strategy)
Brian A. Cass
Bridgewater Meeting Room Trust
Bridgfords
Briery Homes
Brindle and Hoghton Parish
Councils
British Geological Survey
British Telecom
Bruton Knowles
Building Plan Services
Bury Metropolitan Borough Council
Business Link East Lancs
Buttress Fuller Alsop Williams
Architects
BwD Youth M.P.
C3S Projects Ltd
CA Planning
CA Planning
Cable and Wireless
CALA Homes (Yorkshire) Limited
Calder Design Associates
Campaign for the Protection of
Rural England
Campaign for the Protection of
Rural England (Lancs)
Campaign Land Ltd
Campbell Driver Partnership
CAMRA
Capita Symonds
Barlow
Sharif
Haji
Paul
Forshaw
Simon
Robin
Godley
Mackereth Astles
Elizabet
h
Graham
Sally
Taylor
Jones
Smith
Mark
Head
Samant
ha
Borley
Karen
Wright
Tony
Harkness
Tony
John
Jemmett
Manley
Neal
Amjad
Tim
Charlton
Rashid
Healy
Guy
Evans
Peter
Lord
Tony
Duckworth
Carl
Morris
Emily
Roberts
News Editor
Bootstrap
Bootstrap
Bovis Homes
Bovis Lend Lease Ltd.
Bradshaw Gass and Hope LLP
Bray Singleton Partnership
BREEAM Centre
Stephen
Naveed
Shirin
BREEAM Technical
Consultant: Government
Focus
District P.R. Officer
Campaigns Manager
Assistant Planner
Page 3 of 16 APPENDIX 1: List of Local Plan consultees
Capita Symonds
Capita Symonds
Carnegie Design Solutions Ltd.
Cartwright & Gross
Cass Associates
Cassidy and Ashton
Castleland Ltd.
CB Richard Ellis
CC Gladding Archictects
Central Lancs
Centre for Ecology and Hydrology
Centre Traders Association
Chadwick Dryer
Child Action North West
Chorley Borough Council
Chris Thomas Ltd.
Church Commissioners for England
Citizens Advice Bureau
Civil Aviation Authority
Clearview Home Improvements
Cliff Walsingham & Co.
Coal Authority
Colliers CRE
Colliers CRE
Colliers International
Community Network (Older
People's Forum)
Compass Architectural Consultants
Connexions Careers Advice
Conservative Association (Ross. &
Darwen)
Cornell Group
Corporate Architecture Ltd.
Council for British Archaeology
Council For The Protection Of Rural
England
Council For Voluntary Service
Country Land and Business
Association
Countryside Properties Plc
Cowan Co. Ltd
Crown Estates
Crown Paints Ltd
Cunnane Town Planning
CXL Lancashire Ltd
D.P.D.S.
D.P.P.
Daisyfield Residents Association
Daniel Thwaites
Head of Architecture
Surveyor
Richard
Nick
Halstead
Garsrud
Simon
Graham
Dan
Michael
Miles
Trewhella
Thorpe
Lewis
Chris
Steven
Gladding
Brown
Doug
Chadwick
John
Tempest
Joanna
Loxton
Linda
Hardicker
Rachael
Marc
Adam
Wendy
Bust
Hourican
Pyrke
Sockett
Mike
Lukman
Madigan
Vika
Kelly
Stevie
Peter
Dewhurst
Hart
Carrington
Jackie
Garth
Copley
Hodgkinson
Douglas
Chalmers
Stephen
Eccles
Graham
Haworth
Diane
Bowyer
S.
Bailey
Secretary
Children & Families
Representative
Head Of Planning
Services
Bureau Manager
Chief Planner/Principal
Planner
Senior Planner
Development Officer
Secretary
Chairman
Planning Officer
Researcher
Managing Director
Page 4 of 16 APPENDIX 1: List of Local Plan consultees
Darnton EGS
Darwen Chamber of Trade
Darwen Coach Services
Darwen Community Association
Darwen Local History Society
Darwen Shop and Business
Association
Richard
Denise
D.
Community Development Officer
Dot
Eileen
Darwen Town Council
Darwen Valley Community Centre
David C. Smith Architects Ltd.
David Haworth Architectural Design
Service
David Wilson Homes North West
De Pol Associates Ltd.
DEFRA
Department for Culture Media and
Sport
Department for Transport
Department for Transport Rail
Group
Department of Health
Derbyshire Gypsy Liaison Group on
behalf of the National Federation of
Gypsy Liaison Groups
Design Council CABE
Diocesan Board of Finance
Diocese of Blackburn
Diocese of Salford Board of
Administration
Divisional Police Headquarters
Clerk to
Doctors Connect
Drivers Jonas Deloitte
DTZ
DTZ Debenham Thorpe
DTZ DebenhamTie Leung
DTZ Development Consultancy
Duckworth's Estate Agents
Duerden Design
East Lancs Chamber of Commerce
East Lancs Chamber of Trade
East Lancs Deaf Society
Eccleshill Parish Council
E-den Sales and Lettings
Edward Symmons
ELCID
Electricity North West Limited
Electricity North West Limited
Elliot Maunders Homes
Emerson Group Planning Dept.
Smith
Gee
Russell
Waring
Guy
Rebecc
a
Hay
Alexis
De Pol
Mary
M.
Smith
Wedgeworth
Hamish
Robertshaw
John
Brooks
Chief Executive
c/o Hobkirk Sewing
Machines
Mike
Peter
Damms
Hobkirk
Chair
Sue
Crosdale
Project Manager
Infrastructure & Service
Development Manager
Aileen
Evans
Ian
Phil
Povey
Snape
Helen
Hartley
Planning Manager
Secretary of State
Secretary
Secretary
Community Safety
Department
Page 5 of 16 APPENDIX 1: List of Local Plan consultees
English Golf Union
English Heritage in the North West
Entwistle Design Services
Entwistle Green
Environment Agency
Enza
Equality and Human Rights
Commission
Eric Wright Construction
Ethnic Minorities Development
Association (EMDA)
Ethnic Minority Health & Social
Care Forum
Evans Vettori
Ewood Community Association
Farleys Solicitors
FFT Planning
Fields in Trust
Firstplan
Fisch Design Ltd.
Flanagan Design Associates
Forestry Commission England
Foxx Limited
Francis Bradshaw Partnership
Francis Roberts Architects
Freight Transport Association
Friends Families and Travellers
Fusion On Line Ltd.
G L Consultancy
G.L. Hearne
G.L. Hearne
G.L. Hearne
Geo Lancashire (Lancashire RIGS
Group)
George Wimpey
Georgian Group
Gerald Eve
Gerald Eve
Gerald Eve LLP
GF Sectional Buildings
GHA
Gladman Developments
Gleeson Homes North West
Good and Tillotson Ltd.
Graham and Brown
Graham Anthony Associates
Graham Bolton Planning
Partnership
Graham Schofield Associates
Great Places Housing Group
Regional Planner
Area Director
Emily
Melanie
Hrycan
Entwistle
Philip
Paul
Carter
Westhead
Mark
Michael
Servanti
Madigan
Abdul
Robert
Brian
Piracha
Evans
Todd
Steve
Staines
Ross
Kimberl
ey
Anthony
Keith
Kilgour
Simon
Preugschat
Beverley
Graeme
David
Laura
Graham
Keith
Butler
Luxton
Brown
Kettle
Lamb
Williams
Michael
Louise
James
Robinson
Armstrong
Wickham
Gary
John
Hoerty
Chorlton
Andrew
Graham
Graham
Salisbury
Stephen
Stringer
Bloor
Flanagan
Jones
Reform Project and
Traveller Law
Partner, Head of Building
Consultancy
Page 6 of 16 APPENDIX 1: List of Local Plan consultees
Green Lane Community Centre
Green Party
Greenhalgh and Williams
Greys Inn Estates Group
R.
Paul
Glenn
Catherin
e
Griffin Park CP School
GSS Designs
GVA Grimley
GVA Grimley
Gypsy Council
Halsall Lloyd Partnership
Hammond Suddard
Hampshire Helmn
HCA
Health and Safety Executive
Health and Safety Executive
Heritage Trust NW
Higham & Co.
Highways Agency
Hilary's
Hindle & Jepson Chartered
Accountants
Hindley Design Services
HJ Banks
Hobkirk Sewing Machines
Home Builders Federation
Hourigan Connolly
HOW Planning
HOW Planning
HOW Planning LLP
Howard Cross Building Design
Consultant
Humphreys Teal Partnership
Hutchinson 3G UK Limited
Hyndburn Borough Council
Ibbotson Construction
ID Planning
Idox Software Ltd.
IMD Associates
Independent Telephone Services
Indigo Planning
Ingham Yorke Chartered Surveyors
(For Lord Aliving
Inpartnership
Insignia Projects Ltd.
Integer Ltd
Irlam Mowbray Belinda
Ivy Street Community Association
IWA Architects
Director
Principal Planner
Field
Flood
Algar
Clayton-Young
Sewell
Glynn
McGoug
h
Rob
Peters
John
Miller
Erica
Peter
Phoenix
Hobkirk
Marc
Emma
Jon
Richard
Hourigan
Singleton
Suckley
Barton
Howard
Nigel
Cross
Teal
Simon
Prideaux
Richard
Irving
Bernade
tte
Daniel
Woods
Clive
Chris
West
Bracewell
B.
Booth
Fowler
Regional Director
Page 7 of 16 APPENDIX 1: List of Local Plan consultees
J & S Travel
J.
Jonatha
n
J.
J. Hadfield Engineering/Surveying
J. Hancock & Associates
J.J. Taylor
J.Wareing & Son (Wrea Green) Ltd
Jacqueline Michael & Co.
James Whitehead
Janet Dixon Town Planners Ltd
JASP Planning Consultancy Ltd.
Jones Day
Jones Lang LaSalle
Joseph Jackson & Sons
JTS Partnership
JWPC
Kashmiri Association
Keepmoat Homes North West
Khalid Khan Associates
King Sturge LLP
Kirkwells - town planning and
sustainable development
consultants
Knight Frank
Lambert Smith Hampton
Lancashire Constabulary
Lancashire Council Of Mosques
Lancashire County Archaeology
Service
Lancashire County Council
Lancashire County Council
Lancashire County Council Strategy and Policy Group
Lancashire Economic Partnership
(LEP)
Lancashire Enterprise Partnership
(LEP)
Lancashire Fire Brigade
Lancashire Local Nature
Partnership
Lancashire Police Authority
Lancashire Telegraph
Landmark Information Group Ltd.
Langtry Langton Architects
LARA HQ
Lawn Tennis Association
Lawson Margerison Partnerships
Lea Hough & Co.
Lea Hough & Co.
Lea Hough & Co.
Director
Chief Superintendent
Environment Directorate
Environment Directorate
Environment Directorate
Environment Directorate
Economic Development
Manager
Head of LEP Coordination and
Development
Dearden
Hadfield
Hancock
Janet
Simon
Angela
Adam
Grenvill
e
Stephen
Stuart
Dixon
Pemberton
Turner
White
Khalid
Frazer
Michael
Khan
Sandwith
Wellock
Emma
Claire
Bob
Ibrahim
Latimer
Norris
Eastwood
Masters
Peter
Phil
Richard
Iles
Megson
Sharples
Peter
Thomas
Kathryn
Molloy
Ann
Selby
Stephen
Peter
Irving
Gallagher
Mark
Fishery
Richard
David
Daniel
Prest
Bailey
Hamer
Hartley
Lower
Booth
Chief Executive
News Editor
Motor Recreation
Development Officer
Facility Development
Manager
Page 8 of 16 APPENDIX 1: List of Local Plan consultees
Legal Services Commission
Les Gooding Design Ltd
Les Stone Architectural
Consultancy
Liberal Democrats
Lidl UK
Little Harwood Community Centre
Livesey Parish Council
Lloyd Evans Pritchard Ltd.
Local Dialogue
Lovell Johns
Lovell Partnerships North West
Region
Lucite International UK Ltd.
M & M Coaches
M.J. Gleeson Group Plc
Makin Architecture
Manchester Property and
Development
Mansell
McDermott Homes
MCK Associates
MDA
Mellor Parish Council
Mid Pennine Arts
Mill Hill Community Association
Miller Homes
MJM Design Services
ML Planning Services Ltd.
MLL Telecom Ltd
Mobile Operators Association c/o
Mono Consultants
Modulus Associates
Morris Homes
Mortimers Estate Agents
Mosaic Town Planning
Mosaic Town Planning
Mse Designs
N.W. England Forest District
Nathaniel Lichfield & Partners
Nathaniel Lichfield & Partners (on
behalf of) Marks and Spencer
National Air Traffic Services (NATS)
National Farmers Union NW Region
National Federation of Builders
National Grid (Gas)
Nationwide Estate Agents
Natural England
Neil Pike Architecture Ltd.
Partnership Support
Officer
Stella
Rew-Dixon
Les
Gooding
Matt
Jones
Rory
Chloe
S.
Richard
Needham
Mather
Hanley
Hunt
Kevin
I.
Leith
Iqbal
Chris
Stroud
Andrew
Matthew
Managing Director
Dale
C.
Creative Director
Nick
Community Development Officer
Strategic Land Manager
David
Darbyshire
King
Stokes
McDonald
Hunt
Ruffley
Melanie
Lawrenson
Barry
McMahon
Leon
Michael
Armstrong
Ellerton
Jenny
Hill
ATC Systems
Safeguarding Engineer
Environment and Land
Use Advisor
Sacha
Rossi
Helen
Little
Planning Manager
Land & New Homes
Division
Consultation Service
Lorna
Millington
Neil
Pike
Page 9 of 16 APPENDIX 1: List of Local Plan consultees
Network Rail
Newhey Loft Conversions
NHS Blackburn with Darwen
NHS Blackburn with Darwen
NHS Blackburn with Darwen
NHS Blackburn with Darwen
Town Planning Team
LNW
Diane
Clarke
Dominic
Harrison
Gifford
Michael
Shirley
Kerr
Ellerton
Goodhew
Mark
Katya
Saunders
Samokhvalova
Joanne
Vost
Paul
A.
Stock
Shuttleworth
Renewables Developer
Andrew
Bower
Development Officer
Community Network
Development Officer
Mike
Madigan
School Business Manager
Sharon
O'Brien
P.
Phil
Entwistle
Robinson
Malcolm
Nigel
David
Jonatha
n
John
Joey
Gareth
Sally
Walker
Peel
Thompson
Andrew
Walker
Alison
Ingham
Director Of Public Health
Consultant in Public
Health
Capital & Estates
Public Health
Development Manager
Nick Evans Architects
NJL Consulting
NJL Consulting
Norden Primetime Community
Centre
North Turton Parish Council
NorthCountry Homes Group Ltd.
Northern Box and Packaging Co.
Ltd.
Northern Counties Housing
Association
Northern Rail
NPower
O2 UK Limited
Office of Government Commerce
Older People's Forum
Older People's Forum
One 2 One Personal
Communications Ltd
Orange PCS Ltd
Orbit Group
Our Lady of Perpetual Succour R.C
Primary School
P.C.E. Designs
Partek Design Services Ltd.
Paul Butler Associates
Paul Smith Design Services
Peacock and Smith
Peel Design Partnership
Peel Investments North Ltd.
Pegasus
Persimmon Homes Lancashire
Petty Chartered Surveyors
Pilkington Construction
PJ Livesey Group Ltd.
Places for People
Plan-Draw
Planning and Development Network
Planning Bureau Ltd.
Planning Inspectorate
Planning Potential
School Operations
Manager
Vose
Jackson
Lauder
Pilkington
Gunning
Page 10 of 16 APPENDIX 1: List of Local Plan consultees
Pleasington Parish Council
Pleckgate Residents Association
Plot of Gold Ltd.
Preston & Western Lancashire
Racial Equality Council
Primrose Holdings
Private Hire Authority
Proctors
PSSC The Canal and River Trust
Quadra Solutions Ltd
R.S.P.B.
R.T.E. Fabrications
RA Design & Project Management
Raheny Management Services
Rail Property Ltd.
Ramblers Association
Ramsgreave Parish Council
Rapley's
Rapleys LLP
Ratcliffe Architectural Services
Ratcliffe Groves Partnership
Rayson Wilshaw Estate Agents
Redrow Homes (Lancashire)
Redwater Group
Regenerate
Renewable UK
RFT Project Management Ltd.
Ribble Valley Borough Council
Rivington Parish Council
Road Haulage Association
Robinson Architects
Robinson Design Group
Roger Tym and Associates
Roman Road Community Centre
Rossendale & Darwen Labour Party
Rossendale Borough Council
Rossendale Transport Ltd.
Royal Estates
Royal Mail Group Ltd.
Royal Mail Letters
RPS Planning & Development
RT Design
Rural Futures (North West) Ltd.
Rural Scheme
Rural Solutions on behalf of
Blackburn Rugby Club
Salford Community Housing
E.L.
Brian
Robert
Smith
Rees
Taylor
Gary
Moham
med N
Thompson
Khan
Area Planner, North West
and North Wales
Alison
Truman
Northern England Office
Tim
Young
P.
Mulrooney
Neil
Mervyn
Jones
Ratcliffe
Gail
Kate
Steve
Roe
Adderley
Hobson
Olive
Fisher
Catherin
e
Robinson
A.
Nuttall
Joseph
Keller
D.
Proctor
Rowles
R.
Hindle
Secretary
Town Planning
Department
Land and Property Officer
Chief Planning Officer
Clerk
Secretary
Borough Engineering And
Planning Officer
Interim Managing Director
and Operations Director
District Head Postmaster
Page 11 of 16 APPENDIX 1: List of Local Plan consultees
Association
Salisbury Hamer Commercial
Samlesbury and Cuerdale Parish
Council
Sanderson Weatherall LLP
Sanderson Weatherall LLP
Savills
SBS Architects
Scheme Designs
School Governors Rep.
Seddon Homes Ltd.
Sedgwick Associates
P.
Mulrooney
Emma
John
Hulley
Goodchild
Ms
Rebecca
Ebrahim
Angela
Karolia
Aspinall
Paul
Frances
ca
Sedgwick
Holloway
Jamie
Pyper
Roy
Speer
Steve
Fitch
David
C.
Neil
Alastair
Laura
White
Bowles
Andrews
Skelton
Ross
Andrew
Bowe
Planning Assistant
Jo
Mark
Mark
Joanna
Duncan
Lovelady
Phillips
Dennett
Meehan
Isherwood
Strategic Planning
Manager
Peter
Ryan
Paul
Peter
David
Sheppard
Taylor
Hagan
Anne
Elliott
Surveyor Corporate
Services
Housam
Seymour Harris Architecture
Shadsworth Neighbourhood Centre
Signet Planning
Sinclair Knight Merz
Society for the Protection of Ancient
Buildings
South Ribble Borough Council
Speer Dade Planning Consultants
Sport England NW
Spring Architects
St Wilfrid's C of E High School and
Technical College
Stagecoach Northwest
Stanton Andrews
Steven Abbott Associates
Stewart Ross Associates
STL
Stonham North Housing Association
Storey Homes
Storey Sons and Parker
Storey SSP
Story Homes
Strutt and Parker
Studio E Architects
Suburban Studios Ltd.
Suburban Studios Ltd.
Sunderland Peacock
Taylor Design
Taylor Wimpey NW
Taylor Young
Taylor Young
Taylor Young
Telecom Securicor Cellular Radio
Ltd
Terence O'Rourke Plc
The Community Centre
The Co-operative Group Ltd
Director Of Development
& Planning
Head Teacher
Retail Planning Liaison
Page 12 of 16 APPENDIX 1: List of Local Plan consultees
Manager
The Disabled Persons Transport
Advisory Committee
The Fowler Partnership
The Intelligent Design Centre
The Interfaith Forum
The Mall Corporation Ltd.
The Mall Shopping Centre
The Theatres Trust
The Vinden Partnership
Tidy Britain Group
Tockholes Parish Council
Tom Pate Design
Transdev/LUL
Transport 2000 Lancashire
Traveller Law Reform Project
Trevor Dawson & Co. Chartered
Surveyors
TriCad Solutions Ltd
TriCAD Solutions Ltd.
Turley Associates
Turley Associates
Turnbull Tweedale Planning &
Design
Twentieth Century Society
Twin Valley Homes (Together
Housing Group)
Twin Valley Homes (Together
Housing Group)
UCLAN
United Utilities
Urban Vision Partnership Limited
Valli Architectural Services
Valuation Office
Vernacombe Associates
Victorian Society
Viridis Wind Turbines Ltd
Vodafone Limited
Voluntary Health & Social Care
Forum
Wainhomes NW Ltd.
Walton & Co.
Warburton Associates
Ward Hadaway
Wardell Armstrong
Wates Construction
Watson Stirrup
Westbury Homes
Westbury Homes
Managing Director
Shopping Centres
Keith
John
Fowler
Dickinson
Mark
Bourgeois
L.
Rose
Jones
Freeman
G.
Foster
David
Wilson
Caroline
James
Mark
Adam
Will
Rory
Drummond
Derbyshire
Kumar
Davis
Glen
Finch
Wendy
Malone
Charles
Romijn
Dave
Janette
Sherratt
Findley
Sheraz
Valli
Matthew
Jackson
Pauline
Iain
Vicky
Walsh
Fowler
Richards
Neil
Riding
Jane
Jenny
Dickman
Daly
North West Region
Commercial Development
Director
Secretary
Senior Partner
Project Engineer
IsWindTech Project
Property Manager
Associate Planning
Consultant
Group Valuation Officer
Age Concern
Senior Land Manager
Office Manager
Page 13 of 16 APPENDIX 1: List of Local Plan consultees
White Lady & New Horizons
Disabled Transport
White Young Green
Whitehead & Co.
Whittaker Design
Wildlife Trust for Lancashire
Manchester and North Merseyside
William Thomas Estate Agency
Wilpshire Parish Council
Wilson Bowden Developments
Withnell Parish Council
Wood Associates
WYG
Yate And Pickup Bank Parish
Council
Young Peoples Services
Your Move
B.
Whitehead
A.
Lee
Whitehead
Hollinworth
David
Dunlop
L.
Lund
Bernard
Golding
Yvonne
Booth
J.
David
Edward
Robert
T.
Jason
Sayid
Frank
Jake
S.J.
Harry
Howard
S.
A.
Neil
Mr
J.
Eric
Mick
Steve
Alan
Patricia
Duxbury
Ainsworth
Aspin
Atkins M.E.P
Atkinson
Barton
Bawla
Belshaw
Berry MP
Bialecki
Blackwell
Bland
Boocock
Brown
Cameron
Cameron
Chambers
Chambers
Cochayne
Connell
Cross
Da Silva
Chris
John
Kevin
Philip
Mr
Henry
Raymon
d
Mr
T.K.
Moham
med
Mr
Davies M.E.P.
Duckworth
Ellis
Errington
Fairweather
Feilden
Fish
Fleck
Fox
Ghafoor
Gillatt
Page 14 of 16 APPENDIX 1: List of Local Plan consultees
S
P.
D.
David
Stuart
R
Trevor
D.
P.
Yasmin
Carolyn
Peter
Robert
John
Sajjad
Stephen
Mrs
Younus
David
Alice
Darren
Mr
Brian
David
Mr
M.
Mr
Mike
Mrs
Arlene
Marion
Kim
IS & K
David
Mrs
Joe
Keith
Mr
A.
Nigel
Paul
C.
Mr
Maxine
Kevin &
Karl
Ian
Mr
S.
Jason
Gormley
Griffin
Hartley
Haworth
Hayman
Heeks
Hobday
Holt
Hoole
Hussain
Jepps
Jepson
Jopling
Karim M.E.P.
Kay
Kennedy
Khan
Knowles
Knowles
Kovacs
Lahen
Lehan
Liversidge
Livesey
Lohan
Lund
Markham
McBride
McCarthy M.E.P.
McCumskay
McInery
McInery
McLean
Mercer
Monks
Murray
Nolan
Nuttall
Nuttall
Nuttall M.E.P.
Oley
Patel
Philbin
Pover
Price
Quinn
Ramwell
Riding
Page 15 of 16 APPENDIX 1: List of Local Plan consultees
Karen
S.
Mr
Mike
Lynda
S.
Jon
Shiraz
H.
Mr
Les
Sue
D.
Jack
Mr
Hossein
Margare
t
Alan
A.
Pauline
J.
Frank
A.
D.
Mr
Glynn
Riding
Rothwell
Royale
Ryan
Ryder
Salind
Sanderson
Shardar
Spacey
Stamp
Stone
Stott
Stratford
Straw MP
Taylor
Varzandeh
Walsh
Walsh
Wanless
Ward
Whitehead
Whittaker
Whittam
Wild
Williams
Woon
Page 16 of 16 APPENDIX 1: List of Local Plan consultees
APPENDIX 2: Internal workshop. Tasks, group feedback and key findings – May 2011
Local Plan Part 2: Site Allocations and Development Management Policies
Regulation 18 Consultations: Preparation of a Local Plan
Site Allocations and CIL Workshop
26th May 2011
Meeting Room A
12:30 – 16:00
Summary of Event
Purpose of workshop:
The purpose of the workshop was to engage with key Council officers and councillors on the
early preparation of the Site Allocations and Development Management Policies DPD and the
Community Infrastructure Levy.
The aim of the workshop was to build on information gathered at the previous workshop held
in October 2010 and to encourage stakeholders to consider how sites should be selected for
allocation, how priorities should be set (i.e. how the Core Strategy should be implemented on
the ground), and which sites should be allocated for development in light of this. The
workshop was also intended to raise awareness of the Community Infrastructure Levy (CIL)
and gather initial thoughts as to how CIL spending should be prioritised in the Borough.
Attendance:
In total 54 Officers/Councillors were invited to the workshop, and 32 attended. A broad range
of officers attended from various sections including housing, planning, education, corporate
policy and environmental services.
Format of workshop:
Attendees were assigned to four groups. An introductory presentation was delivered by Rea
Psillidou, who outlined the overall purpose of the workshop, and introduced the tasks to be
undertaken by the groups during the site allocations part of the workshop. An overview of
current thinking on the criteria that will be used to assess site suitability was also provided, to
show the factors that will be taken into account in the allocation of sites, and the reasons for
this. For the second portion of the workshop Elizabeth Brigden presented an introduction to
the Community Infrastructure Levy, and introduced the workshop task of discussing priorities
for CIL spending.
Tasks:
For the Site Allocations part of the workshop, the groups were asked to consider 3 questions:
1. What strategic options need to be considered/consulted on?
A number of options were presented as suggestions, which were based on different
emphases and interpretations of the Core Strategy’s Targeted Growth Strategy. These
included: ‘Growth’, ‘Regeneration’, ‘Delivery’ and ‘Accessibility’ and represent different options
for the types of sites that could be allocated. Attendees were asked to offer their opinion on
these as suitable options on which to consult in the ‘Issues and Options’ paper, and to
suggest any additional options.
2. Which strategic option do you prefer?
Page 1 of 5 APPENDIX 2: Internal workshop. Tasks, group feedback and key findings – May 2011.
Attendees were asked to discuss and come to an agreement in their group as to which of the
options they felt to be most appropriate for the Borough and to give reasons for this.
3. Which sites will be priorities under this option?
After deciding upon a preferred option for site allocations, groups were tasked with selecting a
set of housing sites for the next 5 years, and then the longer term, which fit with the option
they had chosen. Sites were marked on the maps and information collected at the previous
October 2010 workshop was made available and used to assess sites’ suitability for
development.
CIL Task:
Groups were presented with a set of 19 cards, each with a different infrastructure priority
written on, e.g. M65, local roads network, community facilities, green infrastructure etc.
Groups discussed the various priorities and were asked to collectively agree on the top 5
infrastructure priorities for the Borough that they felt CIL funding should be directed towards.
This judgement was to be based upon the preferred option they had chosen in the previous
task, and the infrastructure needs that would arise from the associated selection of sites.
Findings:
The key findings from the workshop are shown in the table overleaf.
Page 2 of 5 APPENDIX 2: Internal workshop. Tasks, group feedback and key findings – May 2011.
Group 1
What options to consider?
Group 2
Group 3
The options presented were generally
accepted as suitable for use in the
issues and options consultation
although it was questioned in reality
whether a single option could be
taken forward or whether a hybrid
approach would be required.
Which is your preferred option?
Group 1 prioritised a ‘deliverability’
emphasis for the first 5 years due to
the challenging market conditions in
the Borough. It was considered that a
focus on delivery may stimulate the
market and help create conditions for
inner urban regeneration after 5
years, as it is unlikely that sites in the
inner urban area will be viable within
the first 5 years. Within the ‘delivery’
option it was felt that there should be
a focus on executive housing sites.
Which sites?
For the first 5 year period the group
selected sites that are all within the
urban area boundary. The sites
selected were those considered most
deliverable in the early years and
comprised of mid market sites and a
few upper market/executive housing
Group 4
Would not be keen on progressing a
solely ‘deliverability’ option. Instead a
balance between growth and
regeneration would be the preferred
option – we want to attract more
affluent people into the Borough
whilst at the same time meet the
needs of existing residents within
inner urban areas.
The group decided that the most
appropriate option would be an
appropriate balance of growth and
regeneration. This option would
capitalise on opportunities for growth
in upper market and executive
housing, particularly suited for higher
wage workers and commuters. The
need to continue regeneration efforts
in inner urban areas at the same time
was also noted.
Growth in urban areas to facilitate
regeneration of town centres,
employment sites and economy.
Group 2 began by looking for
attractive growth sites within the
urban area. From this exercise it was
agreed that the supply of sites
identified suggests that we will not
need to allocate ‘growth’ sites outside
of the urban boundary for upper
This group split the first 5 years into
two phases. Sites selected for
development in the first two years
were all located in the Haslingden Rd
area.
Attractive sites should be released to
established developers who can then
fund improvements to infrastructure.
Growth sites should attract people to
live in the Borough.
For the 2-5 year phase a mixture of
Group 4’s preferred option was a
balance between growth and
regeneration, as it was agreed that
neither growth nor regeneration can
be pursued in isolation. One option
may undermine the other if don’t give
both options equal weight. The group
agreed that due to difficult market
conditions at present it will be difficult
to achieve growth in the short term.
Infrastructure will be a serious
consideration in facilitating growth. It
was commented that there is a need
to attract higher wage earners
through a better housing offer but that
this must also be complemented by
investment in the town centre,
particularly the night time economy, to
improve the area’s desirability.
The group selected a range of growth
and regeneration sites for the first 5
year period, all located within the
urban boundary, except for the
commencement of an urban
extension in the Gib Lane area. The
selection contains a number of
Page 3 of 5 APPENDIX 2: Internal workshop. Tasks, group feedback and key findings – May 2011.
sites. Only 4 of the selected sites lie
within the inner urban areas, which
reflect the emphasis on deliverability.
For the 6-10 year period the vast
majority of selected sites were also
within the urban boundary, with one
safeguarded site being selected (NE
edge Blackburn) and another partly
lying outside the boundary (Moorland
School).
CIL priorities?
The top 5 priorities for CIL funding
were considered to be:
1)
2)
3)
4)
Local Road Network
Primary School Provision
Rail Services/Facilities
Open Space Provision and
Improvements
5) = Broadband
=Sports Facilities
The local road network was
considered of paramount importance,
as without an effective network, sites
won’t come forward.
market/executive housing in the first 5
years of the plan. The group then
proceeded to identify sites for the first
5 years within the urban area that had
more of a regeneration emphasis and
focussed on mid market housing on
brownfield sites.
The group then identified a set of
longer term housing sites geared
towards growth. The majority of
these sites are located outside of the
urban area
The top 5 priorities for CIL funding
were considered to be:
sites were selected in inner
Blackburn, Northern outer urban
areas of Blackburn (inc safeguarded
land NE edge Blackburn) and also the
urban (not inner urban) area of
Darwen, and two sites outside the
urban boundary (Pole Lane and
Spring Meadows).
For the period beyond the first 5
years the group selected sites
focussed towards growth within
Blackburn’s urban boundary, and a
range of sites within the inner urban
area of Blackburn.
The top 5 strategic priorities for CIL
funding were considered to be:
1) Local Road Network
2) M65
3) Public Transport and
Sustainable Travel Facilities
4) Primary Schools
5) Community Facilities
1) Skills
2) Local Road Network (in
particular Haslingden Road)
3) Public Transport and
Sustainable Travel Facilities
4) Primary School Provision
5) Cultural Facilities
The highways network was
considered particularly important as
an effective network will be crucial in
unlocking development and making
new housing attractive to commuters.
Also, public realm works and face
lifting were considered to be
important as a specific
neighbourhood level priority.
regeneration sites within the inner
urban area of Blackburn, including the
Griffin area.
The group identified a number of sites
for the period beyond the first 5 years.
These sites were generally growth
sites and the selection includes some
safeguarded land sites e.g. east
Darwen, and also an urban extension
at Gib Lane.
The top 5 strategic priorities for CIL
funding were considered to be:





Local Road network
Improve capacity of M65
Primary schools
Skills and training
GP provision
Broadband was highlighted as a
problem in rural locations, however
GP provision was viewed as more of
a priority across the Borough.
A significant amount has already
been invested in public transport e.g.
Pennine Reach therefore it was
viewed as less of a priority. It was
questioned whether CIL could be
used for site remediation/site
assembly in order to prepare and
bring forward sites for development.
Page 4 of 5 APPENDIX 2: Internal workshop. Tasks, group feedback and key findings – May 2011.
KEY FINDINGS
Preferred Option
The general consensus from the workshop was that in allocating housing sites, an appropriate balance
between growth and regeneration should be achieved. It was agreed that there is a need for upper
market and executive housing in order to attract higher wage earners to live in the Borough, whilst at the
same time addressing regeneration needs in the inner urban areas. The difficult market conditions were
acknowledged as presenting a significant challenge to the delivery of both regeneration and growth
housing sites in the short term. One group therefore prioritised ‘deliverability’ as a key criterion for
selecting sites for the first 5 year period, in an attempt to stimulate the market.
Key Sites
All the groups acknowledged that upper market and executive housing will play an important role in
achieving economic growth and a more balanced housing market. Each group therefore identified a
range of suitable ‘growth’ sites for delivery within the first 5 year phase. The vast majority of these sites
were identified within the existing urban boundary, suggesting that there should not be a need to allocate
sites outside of the boundary within the first 5 years.
Key ‘Growth’ sites for first 5 year period identified by more than one group:
Site
Within present urban boundary:
Roe Lee
Blackburn Golf Course Practice
Ground
Sough Road, Darwen
Eclipse Mill
Rear Revidge Road
Haslingden Road
Sappi
Outside present urban boundary:
Parsonage Road
SHLAA ID
Yield
178,179,181
270
166
169
301
182
45
Various: 125, 289, 38, 26, 257,
154, 175
n/a
76
52
52
~ 1000
188
117
unknown
Key ‘Growth’ sites for first 5 year period identified by only one group:
Site
Within present urban boundary:
Progress Mill
St Wilfrid’s playing fields
Mill adjacent to Dewhurst St
Moorland School site
Outside present urban boundary:
Pole Lane
Gib Lane
SHLAA ID
Yield
279
204
229
171
120
164
66
244
190&277
n/a
146&148
250+
Page 5 of 5 APPENDIX 2: Internal workshop. Tasks, group feedback and key findings – May 2011.
APPENDIX 3: Engagement at Ward Solution meetings July-September 2011: notes from
meetings
Local Plan Part 2: Site Allocations and Development Management Policies
Regulation 18 Consultations: Preparation of a Local Plan
Engagement at Ward Solution Meetings
July – September 2011
Notes from Meetings
Page 1 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Key to coloured dots Housing Employment Retail Other Protect from Development Corporation Park 20th July 2011 Revidge Hub Stickers: Protect from development: Green stickers were placed on allotments, Corporation Park and playing fields. Retail Orange stickers were placed in the New Bank Street Major Neighbourhood Centre area. Development Management Issues:  Shop fronts don’t comply with local housing image.  Previous permissions given to takeaways on New Bank Road which were not welcomed by local residents.  Overlooking extensions not welcome and should be enforced. CIL Issues: Page 2 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Residents’ ranked their CIL priorities: Community Facilities Primary School Provision Surface Water Drainage Open Space Provision and Improvements Public Transport & Sustainable Travel facilities Community Safety GP Provision Local Road Network Social Care Broadband Sports Facilities Climate Change M65 Skills Cycling Provision Green Infrastructure Linkages Rail Services/ Facilities Cultural Facilities Flood Defences 4 5 x x x x 1 3 3 4 5 1 3 5 2 x x x x x 1 1 2 3 1 5 2 4 2 2 4 3 4 5 x x x x x x Page 3 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Wensley Fold 25th July 2011 Bank Top Centre Housing Housing on end of row along Buncer Lane (south end) Retail The Wrangling Shear Brow 25th July 2011 Revidge Fold Church Stickers: Other The Nash playing fields – for a community centre. Corner of Oozebooth Terrace and Northfield Road – potential site for a community centre. St Mary’s College playing fields – residents feel more parking is needed for the college. Comments:  Want a community centre in the ward. North Turton & Tockholes 26th July 2011 Barlow Institute Residents were hesitant about undertaking the exercise in the event that it could be misinterpreted as residents wanting development in their area. All the residents present were from Edgworth and all felt that the area should not be developed as the local services, facilities and road network are currently severely limited. Some residents expressed concern about the future status of Green Belt areas and the retention of current boundaries. Page 4 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Residents decided to flip chart their priorities for their area. These were identified as:  Undertaking a village appraisal in conjunction with the Parish Council as a mechanism to inform planning with a broader perspective.  Transport – it was agreed that highways and public transport are to be discussed with residents at a subsequent meeting with relevant officers.  Assurance that current Green Belt boundaries will be upheld.  Retention of Conservation Areas.  Retention of the village identity.  Retention of local businesses and services.  Retention of the Barlow Institute as a focal point for the village.  Recognition that the ward of North Turton & Tockholes is split into definitive areas, each with their own individual identity. Roe Lee st
1 August 2011 Trinity United Church Stickers: Other Designate land between Ramsgreave Drive and railway as common land. Comments:  Cycle Lane needed from Roe Lee into the town centre.  Use stone if possible for houses.  Affordable Housing, part ownership, possible later able to buy.  No offices to be built here – plenty of empty ones all over Blackburn.  Recycling Centre wanted. Queens Park (Guide) meeting 2nd August 2011 Guide Village Social Club Meeting only attended by residents from Guide area –no one from Queens Park area. Traffic was raised as a major issue on Haslingden Road. Page 5 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Residents felt there has already been enough development in Guide so don’t want any further development. Residents pointed out that there are already lots of empty units in the area. A further meeting was arranged to discuss the issues as many residents weren’t aware of this meeting. Little Harwood 3rd August 2011 Little Harwood Community Centre Stickers: Protect from development: Green Belt to north and west of urban area. Allotments on Philips Road. Sports area opposite St Stephen’s C of E Primary School. . Willow Street where it meets Beardsworth Street (already part of new housing development?) space should be protected from development Blackburn cemetery. Employment Employment area bounded by Whitebirk Drive. Wellfield Mill Blue sticker corner of Whalley Old Road and Daisy Lane (old working men’s club). Open space/playing fields off Whitebirk Drive, opposite junction with Whalley Old Road. Housing Land between Clarendon Road east and Laburnum Road (just western side?) Next to old men’s working club, Whalley Old Road/Peter Street Other Adjacent to 39 Whalley New Road. Mixed Page 6 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Corner site bounded by Laburnum Road and Providence Street. (already being developed for housing) Bastfield Mill Land off Whalley New Road (East Lancs Coachbuilder Site). Comments:  Money should be put forward to help regenerate the area. This has long been promised.  Once the infant school building (St Stephen’s Church of England school?) is empty. No new homes should be built on the land. This area is too built up already.  Repair or remove play area (post it note near Clarendon Road East).  Cob Wall an eyesore. Needs urgently to be renovated.  Back of Oval World needs cleaning. Too much fly tipping. And traffic Calming. Beardwood/Lammack 3rd August 2011 Lammack Church Due to low attendance (4 residents) the interactive session with maps, stickers etc was not run. Instead a brief discussion of issues took place. Comments:  Residents felt that there is not really any room for developments in Beardwood as it’s already very developed. Earcroft 4 August 2011 th
Earcroft Children’s Centre No comments. Sunnyhurst/Sudell 9th August 2011 New Methodist Church Page 7 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Stickers: Protect from development: Open space alongside Borough Road, and on Bold Venture park. Allotments on Hollins Grove Street. Open space behind 1‐15 Owlet Hall Road. Open space next to Darwen Vale school, on corner bounded by Moor Lane and Knowle Lane. (in Green Belt in Local Plan) Open space along Chapels and Chapels Brow. (protected open space in Local Plan). Behind houses on Westfield Avenue and Manor Road (countryside area in Local Plan). Open space to west of Robin Bank Road. (protected open space in Local Plan). Employment Lidl site on Duckworth St. Orchard Mill. Land between railway and Goose House Lane (Business and Industrial Development Area in Local Plan). Open space on corner of Nelson Street ad Frederick Street. Housing Red stickers were put on The Darwen Vale School site at Holden Fold, suggesting the site for housing in the future. Site of former flats on Wood St (part of Queen St/Hindle St redevelopment). Land bounded by Tockholes Road, Hope Street and Vale Street. Industrial/employment area on Blackburn Road (Bottom Croft Mill) Mill on Hollins Grove Street. Land near Dobson Street/Nelson Street, adjacent to River Darwen. Comments:  Moors and Sunnyhurst Woods and Bold Venture Park. All protected. Keep protected! Page 8 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Sunnyhurst/Sudell (Second set of maps) 9th August 2011 New Methodist Church Stickers: Protect from development: Fields to NE of Roman Road (NE of junction with Punch Bowl pub). Darwen Vale playing fields. Housing Land at corner of Knowle Lane and Moore Lane. (currently Green Belt) Land at corner of Chapels and Chapels Brow. (currently protected open space) Land at corner of Winterton Road St James’ Crescent. Other Sports ground to east of Darwen Vale school – what for? open space off Lloyd Street Uncompleted housing site off Dove Lane. Comments:  Existing Core Strategy to remain intact. Marsh House 10th August 2011 Borough Pub No comments. Guide Meeting (additional) 17th August 2011 Protect from development: 1‐3 Haslingden Road is a catchment area for the reservoirs, the drainage developments on Eurogarage site suggests there are already problems – more Page 9 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 development, possibly more problems. 3. Leaving a green buffer between business and housing and ensuring a wildlife corridor. 4‐8. Any more development, residential or commercial will only add to the already disastrous traffic congestion leading to the M65 bearing in mind the location of the hospital both for the increase in traffic attending and visiting and emergency vehicles going to A&E. 9‐13 Protect from any development. A large proportion of existing new commercial/industrial buildings still unoccupied therefore there is no necessity to build more. 10 Already turned down for development owing to the close vicinity of motorway. 14 New school being built on Haslingden Road will greatly add to already congested roads. Other 2. Guide/Fishmoor reservoirs are a breeding ground for wild birds and sanctuary for rare species. 1. Pedestrian crossing suggested near top of School Lane near junction with Blackburn Road and roundabout. Pedestrian crossing much needed since weight restrictions on Grain Road and opening of M65 – big increase in traffic. Comments:  No houses to be built or estates. Crime is low but will increase if estates are built.  Green buffer zone is needed to disguise buildings from road view. Development Management Issues:  Buildings should be designed discreetly and blended in with surroundings. Page 10 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 
Policies should consider the amount of traffic and litter than any development would generate. 
Would the roads hold the capacity for site vehicles that will be travelling on the road – is this referring to construction site traffic? 
Also, the height of the development should be taken into consideration (should not be too high and not more than 2 storey) CIL Issues:  Some residents felt that money collected from developers could be used for better play facilities.  Some residents said that no money was wanted, neither was any development. They felt that development was not needed.  Some residents also strongly thought that money should go to a better bus service (e.g. to Darwen). Whitehall 1 September 2011 st
Bolton Road Methodist Church “No change” wanted. Higher Croft 5 September 2011 th
Roman Road Community Centre No comments Bastwell th
5 September 2011 Attendance too low to run item. Audley th
6 September 2011 Chester Street Mosque Stickers: Page 11 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Housing Nottingham Street, Pringle Street and Ripon Street area North Road corner Land behind Ripon Street Comments: Queen’s Park is about the only green space left for recreation in the area. Shadsworth & Whitebirk 7th September 2011 St Oswald Church Stickers: Protect from development Open space bounded by Worcester Road, Surrey Road, Hereford Road and Devon Road. Land between Staffa Crescent and Haslingden Road. Open space around Shadsworth Leisure Centre Open Space behind Arran Avenue Open Space and play area on corner of Rothesay Road and Bute Road Land behind Our Lady and St John RC High School Open space/play area behind Shetland Close Housing Newfield School? Open space at corner of Audley Range and North Road Employment Behind buildings on corner of Burnley Road and Thornley Avenue Bus depot off Whitebirk Road Land on Carluke Street Page 12 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Land bounded by Sett End Road North and Partnership Way Mixed Land behind Shadsworth Children’s Centre Junction of Ayr Road and Ballantrae Road Land to south of allotment gardens Land to north of bus depot on Whitebirk Road. Comments:  Keep Shadsworth Leisure Centre open. CIL Issues: Residents chose their top 3 priorities: Infrastructure Votes Education and skills for work Child education Community facilities Communications network/broadband GP provision Community safety Public transport Sports facilities Parks and open spaces 5 5 4 3 3 3 2 2 1 Livesey/Pleasington 7th September 2011 Feniscowles Primary School Residents declined to take part in the activity. East Rural th
7 September 2011 Exercise not undertaken at meeting. Page 13 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Fernhurst th
14 September 2011 Fernhurst Hotel Planning item was not run at this meeting as it was considered it would be too contentious. Mill Hill 14 September 2011 th
Mill Hill Community Centre Stickers: Protect from development Feniscliffe Playing Field Housing Land at corner of Aqueduct Road and Spring Bank Terrace Retail Land at corner of Queen’s Terrace and New Wellington Street Mixed Land bounded by railway line, New Chapel Street, Mill Hill Street and Queen Victoria Street – housing, retail and employment. Comments:  Want housing rather than industrial.  Cut down pollution and heavy industry. CIL Priorities: Residents completed forms and selected their top 5 priorities. Community Facilities Open Space Provision and Improvements Sports Facilities Community Safety Social Care Public Transport & Sustainable Travel facilities Surface Water Drainage Skills Green Infrastructure Linkages x x x 2 1 4 3 5 2 5 1 3 4 x x x x x x x x Page 14 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Local Road Network GP Provision Primary School Provision Broadband Climate Change M65 Cycling Provision Rail Services/ Facilities Cultural Facilities Flood Defences x x x Ewood th
15 September 2011 Ivy Street Community Centre There was not enough time to cover the item at this meeting as the agenda over‐ran. Bastwell/Brookhouse 16th September Additional meeting with community group Stickers: Protect from development Allotments off sycamore Road – Protect allotments but a lot of maintenance needed to make it look more attractive – looks very scruffy. Open space off Wimberley Street Open space/play area on corner of London Road and Calder Street Mixed Industrial Site between Logwood Street and Holly Street Very unattractive building – car park needed, also children’s play area. Land on corner of Plane Street and Beech Street Structure has been up for a large hall for years – nothing done with land. Could also be a car park. Land at junction of Bangor Street and Norwich Street. Small supermarket e.g. Tesco Express, Sainsbury’s. Employment opportunities from this as well. Corner of Whalley New Road and New Mill Street.
Page 15 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 Very unattractive area. Need shops and stores, affordable houses, car park. Corner of Brookhouse Lane and Boyle Street. These buildings are very old and unattractive – need to be knocked down. Shops and affordable housing could be built on site. Land above garages on Whalley Street The grass area above the garages is a hotspot for dumping rubbish. This land could be made into quite a nice seating area or dug out and levelled to make more car parking space. This would reduce the number of mice and rats. Other Part of Brookhouse Primary School grounds The land at the bottom of the football pitch could be flattened and turned into car parking spaces. Open land between Whalley Range and Baywood Street. Could be used for car parking spaces – this will stop people parking on double yellow lines on Whalley Range. CIL Issues Residents brainstormed about how they feel CIL money could be spent on improving their neighbourhood.  Grants for community groups.  Solar power panels for houses.  More green spaces.  Resurface roads (too many potholes)  Cable – Calder Street  More lighting (to reduce drug crime) e.g. around Bangor Community Centre  Improve outside of houses – some houses did not receive grants and do not make the area look nice e.g. Maple Street.  More parking.  Trams service  More zebra crossings near schools and mosques.  Street events in Summer or key times of year e.g. Christmas  Cycle and walking routes (not along main roads)  Improved play areas  More CCTV cameras  Improved drainage.  Provision for holidays e.g. family outings Page 16 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 
Regular street cleaners. Meadowhead th
19 September 2011 Greenfield Community Centre Protect from development: Bunker’s Hill Wood Land to west of Gib Lane Feniscliffe Playing Field Land at corner of Tower Road and Hillcrest Road Housing Land between 353 Livesey Branch Road and St John Vianney Church Land off Anglesey Street Land behind Bentham Close, adjacent Moorgate Street Land on corner of Tewkesbury Street and Shorrock Lane Land on corner of Meadowhead Close and Brothers Street Land on St Francis’ Road (currently residential home?) Page 17 of 17 APPENDIX 3: Engagement at ward solution meetings July‐September 2011 APPENDIX 4: Summary of representations to questions included in issues and options paper and actions taken – July 2012
Local Plan Part 2: Site Allocations and Development Management Policies
Regulation 18 Consultations: Preparation of a Local Plan
The Issues and options paper included a series of questions relating to the development of more detailed policy intended to manage
future development. The paper was structured to reflect the spatial interventions in the Core Strategy as noted below
Introduction
The urban boundary and village envelopes
SPATIAL INTERVENTIONS
1. Land supply for business development in higher value sectors
2. Quantity, quality and mix of housing
3. Range and quality of public facilities
4. Protecting and enhancing the environment
5. Quality of place
6. Access to jobs and services
APPENDIX 4: Summary of representations to questions included in issues and options paper and actions taken – July 2012
Local Plan Part 2: Site Allocations and Development Management Policies
Regulation 18 Consultations: Preparation of a Local Plan
Spatial Intervention 4: PROTECTING AND ENHANCING THE ENVIRONMENT
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
6.1
JWPC on
behalf of
Westholme
School
Response made with particular reference to school campus on Meins
Road, Blackburn.
Noted
Would like to see a policy included in the Local plan. Acknowledge that
NPPF does not require the plan to identify ‘Major developed sites within the
Green Belt’. School is not confident that development at the school, as
covered in saved policy RA4:’Identified major development sites in the
Green Belt’, will be supported by local plan policies if the existing policy is
removed.
Westholme School needs flexibility within any future designation of the site
and/or policy to deliver any changes/alterations needed to the school’s
operational and building footprint.
6.1
Environment
Agency (EA)
In relation to development/redevelopment of major sites in the Green Belt
only those parts of the site that do not have any existing ecological value or
ecological corridors within them should be considered. There should be no
net loss of biodiversity value or habitat features and any new design should
include linking ecological networks and enhancing ecological features, such
as the removal of culverts to restore open watercourses.
As referred to in the representation the NPPF does not require
the Local Plan to identify major development sites in the Green
Belt.
The Council considers that it is not necessary to have a separate
policy relating to development at Westholme School on their
Meins Road site; Core Policy 3: ‘The Green Belt’ provides
sufficient guidance to consider any future development
proposals by the school.
Noted
EA have been involved in the process of determining site
allocations and the development and refinement of the
Development Management policies included in the plan; refer to
Appendices 10 and 11.
Page 1 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
The Council considers that provision for the protection,
enhancement and management of ecological assets is covered
in Core Strategy Policy 15: ‘Protection and enhancement of
ecological assets’, publication Plan Core policy 9: Development
and the environment (sections on green infrastructure, habitats
and species and environmental enhancements) and Policy 40:
Integrating green infrastructure with new development.
Biodiversity and ecological networks are addressed by Core
Policy 9 which aims to ensure that the relationship between new
development and the environment is managed, and that the right
balance is always struck between environmental concerns and
other factors. Policy 40: Integrating Green Infrastructure with
New Development provides additional detail.
Detailed matters will be taken into account on a site by site basis
at the Development Management stage.
6.1
6.1
Wildlife Trust
for Lancashire,
Manchester
and
Merseyside
JASP Planning
Consultancy
Ltd for River
No comment on principle of including a policy.
Noted
Identify a range of development considerations for Springside Works to the
south of Belmont Village.
Springside Mills has been allocated for housing development;
refer to Policy 16/18 Springside Works. The Wildlife Trust’s
comments were taken into account as part of the process to
select housing sites; refer to ‘Approach to the selection of
housing sites’.
With regard to other listed sites. Not aware of any designations which may
be impacted by development. Any potential issues relating to components
of the ecological network should be addressed and cross-referenced to the
plan’s environment policies.
This representation was made with particular reference to Greenbank
Terrace, Lower Darwen.
Note that the requirement to make provision for Major Developed Sites has
The policy sets out the development considerations that need to
be taken into account in scheme detailing including proximity to
Longworth Clough Site of Special Scientific Interest.
Noted
The policies relating to particular allocations set out the
development considerations that need to be taken into account
Page 2 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.2
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
Street Assets
LLP
been superseded by NPPF.
in the design/preparation of scheme proposals and at the
planning application stage.
JWPC Ltd for
Witton Estates
Response made with particular reference to land at Horden Farm adjacent
to Gib Lane, Blackburn.
Policy is not necessary unless there are specific proposals relating to
individual sites.
In context of providing a longer-term strategy for the area agree that land
not considered for inclusion within Green Belt or allocated for development
within the plan period should be safeguarded for future development.
However there needs to be flexibility within the plan to enable the
safeguarded site to be brought forward during the plan period if the need
arises. The safeguarded policy should therefore provide criteria for the land
to be developed.
Noted.
The plan has not allocated any land in this area for development
beyond the plan period; refer to Policy 4: Land for development
beyond the plan period. The Council considers that the plan’s
allocations and policies make adequate provision to meet
housing needs and balance the opportunities for development
with the need to protect the countryside.
Land surrounding Horden Farm has been allocated for housing
development; refer to Policy 16:9 – Land west of Gib Lane,
Blackburn. The policy sets out the development requirements
including the production of a masterplan covering the whole site
and taking into account the site covered by Policy 16/10 (land
west of Heys Lane) and land to the south of Broken Stone Road.
Refer to the ‘Green Belt Study (September 2013)’, ‘Green Belt
Position Paper (January 2014), Landscape Appraisal of Three
Locations in Blackburn (January 2014) which sets out the
landscape considerations in this locality.
6.2
Urban Vision
Partnership
Ltd for
Castleland Ltd
and
landowners of
adjoining sites
in Gib Lane
area,
Blackburn.
Response made with particular reference to land in the Gib Lane area,
Blackburn.
Support principle of safeguarding land at Gib Lane for development beyond
the plan period. Castleland consider the land offers considerable potential
for development in a sustainable location.
Noted
The plan has not allocated any land in this area for development
beyond the plan period; refer to Policy 4: Land for development
beyond the plan period. The Council considers that the plan’s
allocations and policies make adequate provision to meet
housing needs and balance the opportunities for development
with the need to protect the countryside.
Two sites in the Gib lane area (on the north side of Broken Stone
Page 3 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
Road) have been allocated for housing development. Refer to
Policy 16/9: Land west of Gib Lane, Blackburn and Policy 16/10
Land east of Heys Lane.
The land to the south of Broken Stone Road will remain a
Countryside area/Green Belt land. This area is not connected to
the urban area and is of a distinct landscape character which the
Council considers should be protected from development. Refer
to the ‘Green Belt Study (September 2013)’, ‘Green Belt Position
Paper (January 2014), Landscape Appraisal of Three Locations
in Blackburn (January 2014) which sets out the landscape
considerations in this locality.
6.3
JWPC Ltd for
Witton Estates
Response made with particular reference to land at Horden Farm adjacent
to Gib Lane, Blackburn.
Do not support extension of Green Belt designation northwards from M65.
Consider Broken Stone Road would provide a defensible boundary if the
designation/boundary is amended.
6.3
Not
referenced
Urban Vision
Partnership
Ltd for
Castleland Ltd
and
landowners of
adjoining sites
in Gib Lane
area,
Blackburn
Response made with particular reference to land in the Gib Lane area,
Blackburn.
Tockholes
Parish Council
Confirm commitment to preservation of the Green Belt. Parish Council (PC)
would like to see status extended northwards crossing Broken Stone Road
Noted.
Agee that there is no merit in extending the Green Belt
boundary. This is supported in the ‘Green Belt Study – 2013’ and
‘Green Belt Position Paper – January 2014’.
The Council is confident that Policy 5: Countryside Areas is
sufficient to manage/protect these areas in the vicinity of Gib
Lane/Broken Stone Road/north of M65.
Not supportive of an extension of the Green Belt boundary northwards from
the M65 to cover land not allocated or safeguarded in the plan. Consider
the objectives of the Core Strategy do not justify an extension or align with
the NPPF’s criteria of exceptional circumstances, which would support a
change to Green Belt boundaries.
Noted
Page 4 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
and over southern part of Gib Lane to the top of the ridge. Consider this
would limit housing development and retain the open skyline as seen from
Tockholes.
PC would also like to an extension in the southern area of the village in the
area currently designated as a ‘Countryside Area’.
The Green Belt boundary has not been re-drawn to include north
of M65.The Council considers there is no merit in extending the
Green Belt boundary and is confident that Policy 5: Countryside
Areas is sufficient to manage/protect these areas in the vicinity
of Gib Lane/Broken Stone Road/north of M65 from urban
development pressures.
The development of the allocated sites to the north of Broken
Stone Road, including in particular land between Broken Stone
Road and the ridge will be managed in accordance with Policies
16/9: land west of Gib Lane and 16/10: Land east of Heys Lane.
The policies set out the masterplanning work required before
planning consent is granted for development on any part of the
site. The masterplanning work will be informed by the
development considerations included in the policy which
specifically sets out landscape matters and by the conclusions of
the ‘Landscape appraisal of three locations in Blackburn’
including Broken Stone Road.
With regard to land to the south of the village the Council
similarly feels that Policy 5 is sufficient to protect the area from
development pressures. The Core Strategy only indicated
consideration of a revised boundary north of the M65. It has not
carried out a strategic review of the Green Belt and therefore it
was beyond the remit of this plan to review the Green Belt
boundary.
Additionally Policy 17: ‘Housing development in Tockholes’ has
been included in the plan to enable residential development that
supports the changing needs of its community. It sets out the
position for housing development that would not normally be
acceptable in the Green Belt.
6.4
Jones Lang
Response made particular reference to Blackburn Rugby Club site on
Noted
Page 5 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
LaSalle for
Ainscough
Strategic Land
and Blackburn
Rugby Union
Football Club
Ramsgreave Drive.
Council response/ACTION TAKEN
Do not object to not showing designated ecological sites on Proposals Map
provided an up to date record and consolidated record is
signposted/referenced within the plan.
The Policies Map identifies the key elements of Blackburn with
Darwen’s Green Infrastructure (Policy 38: Green Infrastructure
on the Adopted Policies Map). Ecological and other
designations are not be shown because periodic reviews of such
sites can lead to changes that render the Adopted Policies Map
out of date. This may create uncertainty for both developers and
decision-makers.
Lists and maps of designated sites will be held as part of a
Supplementary Planning Document on Green Infrastructure,
which can be updated more readily and frequently to reflect
changes.
6.4
Environment
Agency
County Heritage sites and Local Sites should be identified somewhere in
the plan. If not included on the Proposals Map consider preparation of a
Supplementary Planning Document, which can be updated more easily on
a more frequent basis.
Noted
The Policies Map identifies the key elements of Blackburn with
Darwen’s Green Infrastructure (Policy 38: Green Infrastructure
on the Adopted Policies Map). Ecological and other
designations are not be shown because periodic reviews of such
sites can lead to changes that render the Adopted Policies Map
out of date. This may create uncertainty for both developers and
decision-makers.
Lists and maps of designated sites will be held as part of a
Supplementary Planning Document on Green Infrastructure,
which can be updated more readily and frequently to reflect
changes.
6.4
The Wildlife
Trust for
Lancashire,
Manchester
and North
Merseyside
Do not agree to not showing County Biological Heritage Sites and Local
Sites on the Proposals Map. Consider omission would not be in conformity
with NPPF (para 117).
Consider that the inclusion of the local ecological networks on the
Proposals Map would provide more certainty to applicants of the
constraints and opportunities that need to be taken into consideration in
scheme proposals. Do not consider updating of information is a difficult
Noted
The Policies Map identifies the key elements of Blackburn with
Darwen’s Green Infrastructure (Policy 38: Green Infrastructure
on the Adopted Policies Map). Ecological and other
designations are not shown because periodic reviews of such
sites can lead to changes that render the Adopted Policies Map
out of date, creating uncertainty for both developers and
Page 6 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
task; information is readily available.
decision-makers The Adopted Policies Map is the visual
representation of the Plan and is changed only when a revised
plan is published. .
Lists and maps of designated sites will be held as part of a
Supplementary Planning Document on Green Infrastructure,
which can be updated more readily and frequently to reflect
changes.
6.4
Lancashire
County
Council
Archaeology
Unit
Agree with not showing locally-designated sites on the Proposals Map.
Noted
Consider it will be necessary to list nationally designated sites and provide
details on how information on locally designated sites can be obtained.
The Policies Map identifies the key elements of Blackburn with
Darwen’s Green Infrastructure (Policy 38: Green Infrastructure
on the Adopted Policies Map). Ecological and other
designations are not be shown because periodic reviews of such
sites can lead to changes that render the Adopted Policies Map
out of date. This may create uncertainty for both developers and
decision-makers.
Lists and maps of designated sites will be held as part of a
Supplementary Planning Document on Green Infrastructure,
which can be updated more readily and frequently to reflect
changes.
6.5
JWPC Ltd for
Witton Estates
Response made with particular reference to land at Horden Farm adjacent
to Gib Lane, Blackburn.
Note that client’s site should not be considered within a more detailed
policy to manage type and amount of development in rural areas not in
Green Belt.
Noted.
The land surrounding Horden Farm has been allocated for
residential development: refer to Policy 16/9: Land west of Gib
Lane. The site will form an extension of the urban area.. The
policy sets out the development considerations that will need to
be taken into account in preparing scheme proposals.
DEVELOPMENT MANAGEMENT ISSUES
Page 7 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.6
6.6/1
Respondent
JWPC for The
Slack and
Timms Group
of SIPPS
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
Response made with particular reference to Premier Mill, Darwen.
Noted
Support single overarching policy in principle. Consider this would provide
certainty to developers.
Policy 9 - ‘Development and the Environment’ has been included
as an over-arching core environment policy in the Publication
Edition, which applies to all proposals and allows all
environmental issues to be considered simultaneously. It
provides clear criteria relating to climate change, green
infrastructure, habitats and species, water resources and trees.
The potential environmental impacts of development are also
addressed within individual policies which provide more detailed
criteria regarding the key environmental considerations relating
to specific aspects or types of development, such as Policy 8:
‘development and people (addresses man made environmental
issues such as noise and air pollution); Policy 11 ‘Design’; Policy
36 ‘Climate Change’; Policy 37 ‘Wind Turbines’; and Policy 40
‘Integrating Green Infrastructure with New Development’.
6.6
6.6/1
JWPC Ltd for
Witton Estates
Response made with particular reference to land at Horden Farm adjacent
to Gib Lane, Blackburn.
Support single overarching policy in principle. Consider this would provide
certainty to developers.
Noted
Policy 9 - ‘Development and the Environment’ has been included
as an over-arching core environment policy in the Publication
Edition, which applies to all proposals and allows all
environmental issues to be considered simultaneously. It
provides clear criteria relating to climate change, green
infrastructure, habitats and species, water resources and trees.
The potential environmental impacts of development are also
addressed within individual policies which provide more detailed
criteria regarding the key environmental considerations relating
to specific aspects or types of development, such as Policy 8:
‘Development and people (addresses man made environmental
issues such as noise and air pollution); Policy 11 ‘Design’; Policy
36 ‘Climate Change’; Policy 37 ‘Wind Turbines’; and Policy 40
‘Integrating Green Infrastructure with New Development’.
Page 8 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.6
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
Jones Lang
LaSalle for
Ainscough
Strategic Land
and Blackburn
Rugby Union
Football Club
Response made particular reference to Blackburn Rugby Club site on
Ramsgreave Drive.
Noted
Support a simplified approach via a single, overarching environment policy.
However, measures of what will be acceptable will need to be clearly
defined. If too many issues are open to interpretation it could result in an
adversarial planning system that creates uncertainty and delays.
Policy 9 - ‘Development and the Environment’ has been included
as an over-arching core environment policy in the Publication
Edition, which applies to all proposals and allows all
environmental issues to be considered simultaneously. It
provides clear criteria relating to climate change, green
infrastructure, habitats and species, water resources and trees.
The potential environmental impacts of development are also
addressed within individual policies which provide more detailed
criteria regarding the key environmental considerations relating
to specific aspects or types of development, such as Policy 8:
‘development and people (addresses man made environmental
issues such as noise and air pollution); Policy 11 ‘Design’; Policy
36 ‘Climate Change’; Policy 37 ‘Wind Turbines’; and Policy 40
‘Integrating Green Infrastructure with New Development’.
6.6
Environment
Agency
If the Council decides to use a single environment policy it will need to
clearly define those aspects/parts of the environment it is seeking to protect
from development and/or prevent from impacting on development.
A single policy could be over-simplified and open to interpretation, but
equally it could offer flexibility.
Noted
Policy 9 - ‘Development and the Environment’ has been included
as an over-arching core environment policy in the Publication
Edition, which applies to all proposals and allows all
environmental issues to be considered simultaneously. It
provides clear criteria relating to climate change, green
infrastructure, habitats and species, water resources and trees.
The potential environmental impacts of development are also
addressed within individual policies which provide more detailed
criteria regarding the key environmental considerations relating
to specific aspects or types of development, such as Policy 8:
‘development and people (addresses man made environmental
issues such as noise and air pollution); Policy 11 ‘Design’; Policy
36 ‘Climate Change’; Policy 37 ‘Wind Turbines’; and Policy 40
‘Integrating Green Infrastructure with New Development’.
Page 9 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
6.6
The Wildlife
Trust for
Lancashire,
Manchester
and North
Merseyside
Not supportive of a single overarching environment policy.
Noted
Welcome an integrated approach in principle. However have concerns
relating to offsetting of biodiversity loss against other environmental assets.
Consider environmental assets are not equivalent and a ‘lumping’ approach
risks diverting attention from the integration of the environmental, social
and economic components of sustainable development.
The Core Policies set out the unacceptable impacts on people
and environmental assets that should all be avoided or mitigated
by development.
Concerns would be alleviated if this issue could be satisfactorily addressed
and delivered via a Supplementary Planning Document on sustainable
development.
Policy 9 - ‘Development and the Environment’ has been included
as an over-arching core environment policy in the Publication
Edition, which applies to all proposals and allows all
environmental issues to be considered simultaneously. On
balance, this approach was selected because the policy provides
clear and accessible criteria relating to climate change, green
infrastructure, habitats and species, water resources and trees.
The potential environmental impacts of development are also
addressed within individual policies which provide more detailed
criteria regarding the key environmental considerations relating
to specific aspects or types of development, such as Policy 8:
‘development and people (addresses man made environmental
issues such as noise and air pollution); Policy 11 ‘Design’; Policy
36 ‘Climate Change’; Policy 37 ‘Wind Turbines’; and Policy 40
‘Integrating Green Infrastructure with New Development’.
An SPD on Green Infrastructure is to be produced, to provide
further clarity in relation to all aspects of Green Infrastructure
including open space and ecological networks.
6.6
6.6/2
Lancashire
County
Council
Archaeology
Unit
Supportive of option 6.6/2.
Noted
Consider a single policy would not be able to deal comprehensively with all
the issues.
Policy 9 - ‘Development and the Environment’ has been included
as an over-arching and comprehensive core environment policy
in the Publication Edition, which applies to all proposals and
allows all environmental issues to be considered simultaneously.
On balance, this approach was selected because the policy
provides clear and accessible criteria relating to climate change,
green infrastructure, habitats and species, water resources and
Page 10 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
trees.
The potential environmental impacts of development are also
addressed within individual policies which provide more detailed
criteria regarding the key environmental considerations relating
to specific aspects or types of development, such as Policy 8:
‘development and people (addresses man made environmental
issues such as noise and air pollution); Policy 11 ‘Design’; Policy
36 ‘Climate Change’; Policy 37 ‘Wind Turbines’; and Policy 40
‘Integrating Green Infrastructure with New Development’.
6.6
CBRE for
United Utilities
Confirm that any policy should ensure that significant emphasis is placed
on the need to ensure new development does not increase the potential for
surface water flooding. It should include a requirement that new
development is designed to reduce the impact of flooding and to protect
existing residents within the surrounding area.
Noted
Policy 9 (Development and the Environment) within the Local
Plan Part 2 Core Policies contains a requirement for
development to demonstrate that it has taken full account of
issues relating to climate change (including flood risk), either
through the development itself, or causing an increase in the
level of risk from the effects of climate change in another
location. Development will be required to demonstrate that it will
not be at an unacceptable risk of flooding. In addition, the policy
states that any development with the potential to create
significant amounts of new surface water run-off will be expected
to consider, and wherever possible implement, options for the
management of the surface water at source.
Policy 36 (Climate Change) requires all development to be
located so as to minimise its susceptibility to predicted effects of
climate change over the lifetime of the development. The Council
will take account of issues including the development’s
susceptibility to flooding.
6.7
6.8
JWPC for The
Slack and
Timms Group
Response made with particular reference to Premier Mill, Darwen.
Noted
Do not support inclusion of noted issues within the plan as strict policies;
In order to achieve sustainable development without imposing
Page 11 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.12
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
of SIPPS
plan should encourage identified types of approach relating to
environmental measures and/or building practices. Consider these policies
may cause developers uncertainty of cost implications; details referred to
are best delivered through other regimes for e.g. building regulation and/or
construction techniques.
strict/onerous requirements on developers, an over-arching
environment policy has been included as a core policy within the
Publication Edition – Policy 9 (Development and the
Environment), which applies to all proposals and allows all
environmental issues to be considered simultaneously. Together
with Policy 8:’Developemnt and People’ these policies set out
the unacceptable impacts on people and environmental issues
that should all be avoided or mitigated by development allowing
developers to respond in the most appropriate fashion fro the
site.
6.13
6.16
7.2
7.3
At the same time Core Policy 7: ‘Sustainable and Viable
Development’ and Core Policy 11:’ Design’ takes a flexible
approach to securing sustainable, viable development that
improves the economic, social and environmental conditions of
the area. The policies indicate how the Council will be proactive
in working with developers to bring schemes forward. The
policies set out sustainability objectives, without prescribing
solutions, allowing developers to bring forward the best solution
for the site.
6.7
6.8
6.12
6.13
6.16
7.2
7.3
JWPC Ltd for
Witton Estates
Response made with particular reference to land at Horden Farm adjacent
to Gib Lane, Blackburn.
Do not support inclusion of noted issues within the plan as strict policies;
plan should encourage identified types of approach relating to
environmental measures and/or building practices. Consider these policies
may cause developers uncertainty of cost implications; details referred to
are best delivered through other regimes for e.g. building regulation and/or
construction techniques.
Noted
In order to achieve sustainable development without imposing
strict/onerous requirements on developers, an over-arching
environment policy has been included as a core policy within the
Publication Edition – Policy 9 (Development and the
Environment), which applies to all proposals and allows all
environmental issues to be considered simultaneously. Together
with Policy 8:’Developemnt and People’ these policies set out
the unacceptable impacts on people and environmental issues
that should all be avoided or mitigated by development allowing
developers to respond in the most appropriate fashion fro the
site.
Page 12 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
At the same time Core Policy 7: ‘Sustainable and Viable
Development’ and Core Policy 11:’ Design’ takes a flexible
approach to securing sustainable, viable development that
improves the economic, social and environmental conditions of
the area. The policies indicate how the Council will be proactive
in working with developers to bring schemes forward. The
policies set out sustainability objectives, without prescribing
solutions, allowing developers to bring forward the best solution
for the site.
6.7
6.8
Jones Lang
LaSalle for
Ainscough
Strategic Land
and Blackburn
Rugby Union
Football Club
Response made particular reference to Blackburn Rugby Club site on
Ramsgreave Drive.
Not supportive of policies that impose a requirement to achieve specified
exemplar standards. Consider these would be overly restrictive and may
dis-incentivise developers or landowners from bringing their sites forward.
Plan should encourage environmentally sustainable development and
make provision for individual sites to be assessed on their merits.
Policy should acknowledge that there may be circumstances where noncompliance of a proposal is outweighed by other benefits.
Noted
In order to achieve sustainable development without imposing
strict/onerous requirements on developers, an over-arching
environment policy has been included as a core policy within the
Publication Edition – Policy 9 (Development and the
Environment), which applies to all proposals and allows all
environmental issues to be considered simultaneously. Together
with Policy 8:’Developemnt and People’ these policies set out
the unacceptable impacts on people and environmental issues
that should all be avoided or mitigated by development allowing
developers to respond in the most appropriate fashion fro the
site.
At the same time Core Policy 7: ‘Sustainable and Viable
Development’ and Core Policy 11:’ Design’ takes a flexible
approach to securing sustainable, viable development that
improves the economic, social and environmental conditions of
the area. The policies indicate how the Council will be proactive
in working with developers to bring schemes forward. The
policies set out sustainability objectives, without prescribing
solutions, allowing developers to bring forward the best solution
for the site.
Page 13 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
The Plan acknowledges there may be circumstances where the
public benefit of the development clearly outweighs the harm
caused. In such situations the Council will seek to secure
mitigation measures and/or a financial contribution from the
developer
6.7
Environment
Agency
Representation Includes an addendum of ways new development can
benefit the environment and an appendix including information on the
current ecological status of watercourses on or adjacent to the proposed
allocations.
Noted
An SPD on Green Infrastructure will provide additional guidance
on how development might provide environmental
enhancements.
Note there is a duty for everyone to comply with the objectives of the Water
Framework Directive.
New development should adhere to the Lancashire Green Infrastructure
Plan
6.7
6.7
6.8
6.9
6.7
The Wildlife
Trust for
Lancashire,
Manchester
and North
Merseyside
Consider there is a risk of conflation between multi-functional ‘Green
Infrastructure’ and a purpose specific district wide ‘Ecological Network’.
Consider the Council should require every design/layout to have regard to
the existing ecology and ecological functioning of the proposed
development site and its surroundings and seek to retain and secure the
effective management of as much semi-natural habitat as is practical to
contribute to the maintenance, restoration and enhancement of the district’s
ecological network.
Lancashire
County
Council
Archaeology
Unit
Positive benefits to developers need to be emphasised.
HOW Panning
Representation made with particular reference to Sappi site, Blackburn.
(The Lancs GI Strategy has no status.)
Noted
Core Policy 9: Development and the Environment and
supporting Policy 40: Integrating Green Infrastructure with New
Development acknowledges Green Infrastructure and Ecological
Networks as discrete entities.
.
Noted
An SPD on Green Infrastructure will provide additional guidance
on how development might provide environmental
enhancements
Noted
Page 14 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.8
6.12
6.13
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
LLP for
Aeternum
Capital and
Taylor Wimpey
Acknowledge that protecting the environment is important. Suite of policies
needs to ensure that development is deliverable and not hindered by cost
implications of onerous policies that can impact on scheme viability.
Core Policy 7: Sustainable and Viable Development and Core
Policy 11: Design takes a flexible approach to securing
sustainable, viable development that improves the economic,
social and environmental conditions of the area. The policies set
out sustainability objectives, without prescribing solutions,
allowing developers to bring forward the best solution for the
site.
Supportive of a flexible approach that allows for a site-by-site assessment.
6.16-6.18
Reference should be made to requirements outlined in Building
Regulations
Core Policy 8: Development and People and Core Policy 9:
Development and the Environment set out the unacceptable
impacts on people and environmental assets that should all be
avoided or mitigated by development allowing developers to
respond in the most appropriate fashion for the site.
6.7
6.8
6.12
6.13
HOW Panning
LLP for HB
Villages and
Bolderstone
(Chesterfield)
LLP
Representation made with particular reference to Moorgate Mill, Moorgate
Street, Blackburn.
Acknowledge that protecting the environment is important. Suite of policies
needs to ensure that development is deliverable and not hindered by cost
implications of onerous policies that can impact on scheme viability.
Consider there needs to be flexibility in policies seeking to reduce the
effects of climate change to allow developers to adopt different approaches
as long as the end result assists in achieving identified objectives.
Noted
Core Policy 7: Sustainable and Viable Development and Core
Policy 11: Design takes a flexible approach to securing
sustainable, viable development that improves the economic,
social and environmental conditions of the area. The policies set
out sustainability objectives, without prescribing solutions,
allowing developers to bring forward the best solution for the
site.
Core Policy 8: Development and People and Core Policy 9:
Development and the Environment set out the unacceptable
impacts on people and environmental assets that should all be
avoided or mitigated by development allowing developers to
respond in the most appropriate fashion for the site.
6.7
6.8
6.9
6.12
JASP
Planning,
Town Planning
and
Development
Consultancy
Representation made with particular reference to Greenbank Terrace
(former Lower Darwen Paper Mill), Lower Darwen.
Not supportive of policies that require environmental measures/standards
as an absolute. Consider that any measures that add to the cost of
construction may have an impact on scheme viability in marginal markets
Noted
Core Policy 7: Sustainable and Viable Development and Core
Policy 11: Design takes a flexible approach to securing
sustainable, viable development that improves the economic,
social and environmental conditions of the area. The policies set
Page 15 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.13
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
for River
Street Assets
LLP
and consequently on delivery.
out sustainability objectives, without prescribing solutions,
allowing developers to bring forward the best solution for the
site.
Consider these environmental considerations should be encouraged. Note
that many of the measures referred to are administered by other legislation,
such as Building Regulations which negates the need fro further controls
via the Local Plan.
Core Policy 8: Development and People and Core Policy 9:
Development and the Environment set out the unacceptable
impacts on people and environmental assets that should all be
avoided or mitigated by development allowing developers to
respond in the most appropriate fashion for the site
Whilst many environmental measures are controlled by other
legislation such as Building Regulations, there is a need for
planning policy on the issue to ensure that sustainable
development is delivered and to provide clarity for developers in
accordance with the NPPF.
6.8
6.8
Environment
Agency (EA)
Supportive of a strict policy requirement for new development to include
environmental measures identified in para 6.21 (Issues and Options paper)
and listed in EA response to question 6.7.
The Wildlife
Trust for
Lancashire,
Manchester
and North
Merseyside
Acknowledge it would be impractical to adopt a ‘one size fits all’ policy
approach to the effective and efficient management of the ecological
diversity within the local ecological network.
Advise that all but the most minor developments should be required to
demonstrate that it has regard to the ecology of the site/area and its
position and function in the local ecological framework and its design/layout
Noted
Instead of imposing strict requirements for new developments to
include specific environmental measures, Policy 9 (Development
and the Environment) of the Publication Edition requires all
development to ensure that there is no unacceptable impact on
environmental assets or interests, and also encourages the
exploration of opportunities to provide enhancements. Each site
will provide different opportunities in terms of environmental
measures, and flexibility is important as the availability of
technology changes over time.
Noted
Policy 40: Integrating Green Infrastructure with New
Development requires all development that includes an element
of green space to secure appropriate maintenance of the space
in the long term.
Page 16 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
reflects this.
Provide signposts to schedules of information relating to habitats and
species of principal importance.
Instead of imposing strict requirements for new developments to
include specific environmental measures, Policy 9 (Development
and the Environment) of the Publication Edition requires all
development to ensure that there is no unacceptable impact on
environmental assets or interests, and also encourages the
exploration of opportunities to provide enhancements. Each site
will provide different opportunities in terms of environmental
measures, and flexibility is important as the availability of
technology changes over time.
An SPD on Green Infrastructure is to be produced for Blackburn
with Darwen, to provide additional information and clarity in
relation to all aspects of green Infrastructure. It will address
ecological matters and provide the necessary links to habitat and
species information.
6.8
CBRE for
United Utilities
(UU)
UU encourages early discussion with potential developers as a means to
ensure measures to enhance and protect the environment can be
incorporated.
Use of sustainable drainage systems (SuDs) should be required where
possible as a means of reducing surface water run-off rates.
Noted
Policy 9 (Development and the Environment) of the Local Plan
Part 2 Core Policies requires that any development with the
potential to create significant amounts of new surface water runoff will be expected to consider, and wherever possible
implement, options for the management of the surface water at
source.
The policy also states that development will only be permitted
where there is no unacceptable impact on environmental assets
or interests, including but not limited to climate change (including
flood risk), green infrastructure, habitats, species, water quality
and resources, trees, and the efficient use of land. It also
encourages the exploration of opportunities to provide
enhancements. Each site will provide different opportunities in
terms of environmental measures, and flexibility is important as
the availability of technology changes over time.
Page 17 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.9
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
Jones Lang
LaSalle for
Ainscough
Strategic Land
and Blackburn
Rugby Union
Football Club
Response made particular reference to Blackburn Rugby Club site on
Ramsgreave Drive.
Noted.
No single answer. Installation of environmental measures in new
development must have regard to individual site-specific circumstances
and the availability/development of technology at any one time.
Whilst many environmental measures are controlled by other
legislation such as Building Regulations, there is a need for
planning policy on the issue to ensure that sustainable
development is delivered and to provide clarity for developers in
accordance with the NPPF. The Government’s objective is that
planning should fully support the transition to a low carbon
economy in a changing climate.
In order to ensure compliance with the Local Plan, developers
will be expected to include environmental measures as an
integrated part of the project, identifying potential opportunities
and associated costs alongside marketability benefits.
Core Policy 7: Sustainable and Viable Development and Core
Policy11: Design take a flexible approach to securing
sustainable, viable development that improves the economic,
social and environmental conditions of the area. The policies set
out sustainability objectives, without prescribing solutions,
allowing developers to bring forward the best solution for the
site.
Core Policy 8: Development and People and Core Policy 9:
Development and the Environment set out the unacceptable
impacts on people and environmental assets that should all be
avoided or mitigated by development allowing developers to
respond in the most appropriate fashion for the site.
Page 18 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
6.9
Environment
Agency
The environmental measures, which appear to be the most difficult for
developers to implement, include the protection of habitats and the
enhancement of habitats.
Noted.
The aim of Core Policy 9: Development and the Environment
and supporting Policy 40: Integrating Development with Green
Infrastructure is to ensure that the relationship between new
development and the environment is managed, and that the right
balance is always struck between environmental concerns and
other factors.
Policy 9 provides clear and accessible criteria relating to climate
change, green infrastructure, habitats and species, water
resources and trees and allows each application to be
considered flexibly on its own merits.
An SPD on Green Infrastructure will provide additional guidance
on how development might provide environmental
enhancements.
6.9
The Wildlife
Trust for
Lancashire,
Manchester
and North
Merseyside
Determined by the location and type of site and the scale of the
development. Retaining or re-creating and managing ecological features
may be more difficult than starting with a blank canvas but there can be
marketability benefits for the developer. As well as to nature for its own
sake. Some rough costings for many natural environment capital and
revenue cost are available from Natural England and the Forestry
Commission.
Noted.
Whilst many environmental measures are controlled by other
legislation such as Building Regulations, there is a need for
planning policy on the issue to ensure that sustainable
development is delivered and to provide clarity for developers in
accordance with the NPPF.
In order to ensure compliance with the Local Plan, developers
will be expected to include environmental measures as an
integrated part of the project, identifying potential opportunities
and associated costs alongside marketability benefits.
An SPD on Green Infrastructure will provide additional guidance
on how development might provide environmental
enhancements
6.10
Jones Lang
LaSalle for
Ainscough
Response made particular reference to Blackburn Rugby Club site on
Ramsgreave Drive.
Noted
The Plan aims to ensure that the relationship between new
Page 19 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.10
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
Strategic Land
and Blackburn
Rugby Union
Football Club
Consider policy should acknowledge there may be circumstances where
the loss of an ecological asset is outweighed by other benefits.
development and the environment is managed, and that the right
balance is always struck between environmental concerns and
other factors
The Wildlife
Trust for
Lancashire,
Manchester
and North
Merseyside
The Plan acknowledges there may be circumstances in which
the public benefit of the development clearly outweighs the harm
caused. In such situations the Council will seek to secure
mitigation measures and/or a financial contribution from the
developer
Reserve fuller comment to the policy wording, once available.
Noted
Welcome the approach in the proposed policy. However are uncertain how
much protection the proportionate approach would provide to locally
valuable habitats and whether all sections of the ecological network would
be treated equally.
Core Policy 9: ‘Development and the Environment’ and
supporting Policy 40: ‘Integrating Development with Green
Infrastructure’ take the proposed approach of protecting
designated habitats from unacceptable destruction or damage by
development, the degree of protection being proportionate to the
level at which the habitat is protected, and preventing further
fragmentation of ecological networks.
An SPD on Green Infrastructure will provide additional guidance
on how development might provide environmental
enhancements, as required by Policy 40.
6.10
6.11
6.11
Lancashire
County
Council
Archaeology
Unit
Agree with the approach set out in para 6.24 relating to the protection of
habitats.
Noted
The Wildlife
Trust for
Reserve fuller comment to the policy wording, once available.
Noted
The proposed approach – of protecting designated habitats from
unacceptable destruction or damage by development, the
degree of protection being proportionate to the level at which the
habitat is protected, and preventing further fragmentation of
ecological networks - has been taken and is set out in Core
Policy 9: Development and the Environment and supporting
Policy 40: Integrating Development with Green Infrastructure
Page 20 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.12
6.12/3
6.12
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
Lancashire,
Manchester
and North
Merseyside
Welcome the intent of this approach, but it is unclear if all protected species
would be treated equally.
Policy 9 (Development and the Environment) of the Publication
Edition sets out the framework for consideration of protection of
species, based on their importance.
Turley
Associates for
Sainsbury’s
Jones Lang
LaSalle for
Ainscough
Strategic Land
and Blackburn
Rugby Union
Football Club
Signpost to schedules of information relating to habitats and species of
importance.
Response made with particular reference to Thwaites Brewery Site,
Blackburn
Option 6.12/3 is the preferred option.
This option provides the flexibility for development to meet current national
standards/guidance.
Response made particular reference to Blackburn Rugby Club site on
Ramsgreave Drive.
Consider policy should encourage sustainable development without
imposing unduly restrictive requirements on developers, for e.g. the
achievement of exemplar standards. These standards are not administered
by the Council and may change over the plan period.
6.12
Environment
Agency
Support inclusion of policy that requires developers to build to exemplar
Code for Sustainable Homes and BREEAM standards. Consider a
requirement to exceed current Building Regulations requirements will
ensure development exceeds the minimum standards of sustainability.
6.12
McAteer
Associates Ltd
for landowners
of land at Gib
lane,
Blackburn
Response made with particular reference to land at Gib Lane, Blackburn
(land to the rear of 393-423 Livesey Branch Road and 2-42 Gib Lane)
6.12/2
Support Option 6.12/2.
Support the reduction of the carbon footprint of development. However
consider policy should not impose requirements which would impact on
An SPD on Green Infrastructure is also to be produced for
Blackburn with Darwen, to provide additional information and
clarity in relation to all aspects of green infrastructure.
Noted
The plan sets out clear requirements for sustainable design to
ensure that environmental sustainability is maximised in every
development. This is considered to be the most appropriate
approach rather than imposing CSH and BREEAM standards
which are subject to regular modifications.
Core Policy 7: Sustainable and Viable Development and Core
Policy11: Design take a flexible approach to securing
sustainable, viable development that improves the economic,
social and environmental conditions of the area. The policies set
out sustainability objectives, without prescribing solutions,
allowing developers to bring forward the best solution for the
site. With Policy 36: Climate Change, the policies provide clarity
for developers, in accordance with the NPPF and the
Government’s objective that planning should fully support the
transition to a low carbon economy in a changing climate.
Noted.
Refer to the ‘Plan Viability Report’; this supporting document
indicates that the plan policies do not impose any burdens that
will impact on scheme viability.
Core Policy 7: Sustainable and Viable Development and Core
Page 21 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.12
6.12
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
scheme viability.
Policy11: Design take a flexible approach to securing
sustainable, viable development that improves the economic,
social and environmental conditions of the area. The policies set
out sustainability objectives, without prescribing solutions,
allowing developers to bring forward the best solution for the
site. Policy 7 sets out how the Council will work proactively with
developers on scheme delivery. With Policy 36: Climate Change,
the policies provide clarity for developers, in accordance with the
NPPF and the Government’s objective that planning should fully
support the transition to a low carbon economy in a changing
climate.
The Wildlife
Trust for
Lancashire,
Manchester
and North
Merseyside
Welcome the intent of such an approach.
Noted
Note concerns that although BREEAM includes a biodiversity section a
high score can be obtained without achieving a good score with regard to
biodiversity.
Clear requirements in terms of sustainable design have been
included in the Publication Edition, within Policy 11 (Design); to
ensure that environmental sustainability is maximised in every
development. This is considered to be the most appropriate
approach rather than imposing specific standards such as CSH
and BREEAM standards which are subject to regular
modifications.
Together
Housing
Group
Agree with Option 6.12/2.
Noted
HOW Planning
for Aeternum
Capital and
Taylor Wimpey
Response made particular reference to Sappi Site and Moorgate Mill,
Blackburn
Whilst protecting the environment is important, policies still need to ensure
that development is deliverable and viable. Policies should therefore be
flexible and assessed on a site by site basis.
CSH and BREEAM standards have not been included in the
Local Plan Part 2 as developments will have to meet these
requirements through Building Regulations.
Clear requirements in terms of sustainable design have been
included in the Publication Edition, within Policy 11 (Design); to
ensure that environmental sustainability is maximised in every
development. This is considered to be the most appropriate
Page 22 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
JASP Planning
Consultancy
Ltd on behalf
of River Street
Assets LLP
Response made particular reference to Land at Greenbank Terrace, Lower
Darwen
These measures should be encouraged but not required as an absolute.
The government has made it clear that these are matters for other
legislation, such as Building Regulations, and there is no demonstrable
need for any further controls
approach rather than imposing external standards which are
subject to regular modifications.
Policy 9 (Development and the Environment) of the Local Plan
Part 2 Core Policies requires development to demonstrate that it
has taken full account of issues relating to climate change. In
addition, Policy 36 (Climate Change) states all development
should be designed with the aim of minimising its contribution to
carbon emissions and climate change, both directly from the
development and indirectly arising from factors such as travel to
and from the development. The policy highlights that the Council
will be supportive of exemplar developments with high
environmental performance.
Policy 9 also considers the impact of development on
biodiversity and the Borough’s ecological network.
Policy 7 (Sustainable and Viable Development) of the Local Plan
Part 2 Core Policies ensures the viability of development is
considered.
With Policy 36: ‘Climate Change’ the policies provide clarity for
developers in accordance with NPPF and the Government’s
objective that planning should fully support the transition to a low
carbon economy in a changing climate.
6.13
6.13/5
Turley
Associates for
Sainsbury’s
Response made with particular reference to Thwaites Brewery Site,
Blackburn
Preference for option 6.13/5.
Consider policies relating to issues and options questions 6.12 and 6.13
should be combined; the strategic objectives of the Council could be met by
requiring all new development to meet the requirements of the Building
Regulations.
Noted
As new developments are likely to include a significant
proportion of renewable energy in order to comply with evolving
Building Regulations, specific renewable energy targets are not
included in Local Plan Part 2. Policy 36 (Climate Change) aims
to be flexible but also to ensure that development is designed
with the aim of minimising its contribution to carbon emissions.
Page 23 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.13
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
Jones Lang
LaSalle for
Ainscough
Strategic Land
and Blackburn
Rugby Union
Football Club
Response made particular reference to Blackburn Rugby Club site on
Ramsgreave Drive.
Not supportive of options 6.13/1-6.13/5. Consider these would impose
onerous requirements on developers, which may dis-incentivise
development being brought forward.
Plan should encourage environmentally sustainable development and
include flexibility to allow an assessment of proposals on an individual site
basis including consideration of the availability/development of technology
at the time.
Policy should acknowledge that there may be circumstances where noncompliance of a proposal may be out weighed by other benefits.
6.13
Together
Housing
Group
Agree with options 6.13/1, 6.13/2 and 6.13/3.
Consider Option 4 can be difficult to achieve; very much influenced by the
size of the development and the orientation of the units.
Confirm targets should be set in the plan.
6.14
6.14
Environment
Agency
Support this policy proposal. Consider policy could go further and include
measures to increase the overall sustainability of the building, such as
greywater harvesting and recycling.
JASP Planning
Consultancy
for River
Street Assets
LLP
Response made with particular reference to land at Greenbank Terrace
(former Lower Darwen Paper Mill), Lower Darwen.
Consider it unreasonable to require the retrofitting of renewable energy
measures to existing buildings when considering unrelated applications for
minor developments.
Noted
A retrofitting policy has not been included within Local Plan Part
2. It would only be reasonable for the Council to require this
where it is part of the application under assessment. If the
retrofitting of renewable energy measures is needed in order to
mitigate other impacts, developers will still have this option and
the flexibility to consider opportunities on a case-by-case basis.
Page 24 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
6.14
Together
Housing
Group
Support inclusion of policy that requires retrofitting renewable energy
measures.
6.15
Environment
Agency
Suggest an alternative option – to consider the environmental impacts of
renewable energy schemes through the general environmental
policy/policies referred to in question 6.6.
The Wildlife
Trust for
Lancashire,
Manchester
and North
Merseyside
Advise they would like to see either a criterion-based local policy wording
relating to biodiversity or a cross reference to relevant local policy on
habitats, species and the local ecological network.
6.15
Council response/ACTION TAKEN
Noted
The environmental impacts of renewable energy schemes can
be considered against Core Policy 9 (Development and the
Environment). Instead of relying on national policy and guidance
alone, an additional specific policy is proposed in relation to
Wind Turbines (Policy 37) to provide greater clarity for
developers.
Noted
Within Policy 9 of the Core Policies (Development and the
Environment), there is a section which provides protection for
habitats and species of importance. The policy also states that
development that would result in the further fragmentation of, or
compromise the function of, Blackburn with Darwen’s ecological
framework will not be permitted unless a) the harm is
significantly and demonstrably outweighed by other planning
considerations; and b) an appropriate mitigation strategy can be
secured.
Additionally, Policy 37 (Wind Turbines) includes a requirement
that any wind turbine development has no unacceptable adverse
impact on a protected habitat or other feature of ecological
importance, unless a) the benefits of the development clearly
outweigh the harm caused, b) the development is designed to
minimise the degree of harm, and c) the residual harm is
mitigated or compensated for.
Page 25 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
6.15
Lancashire
County
Council
Archaeology
Unit
Consider the impacts of large renewable energy developments are
assessed reasonably well under present processes such as Environmental
Impact Assessment (EIA); option 6.15/2.
Noted
Not
referenced
CBRE for
United Utilities
Request a policy which sets a presumption against the development of
wind turbines on land used for water catchment purposes which is also
deep peat.
Noted
6.15
Together
Housing
Group
Support option 6.15/2
Noted
Tockholes
Parish Council
The Council should insist on a separation area for the locating of wind
turbines of a minimum of one kilometre from any building or dwelling to
reduce the nuisance of flicker and noise.
6.15/1
6.15/2
Not
referenced
Express concerns that smaller developments are not always subject to
appropriate levels or qualities of assessment and analysis; further guidance
would be useful; option 6.15/1. Suggest a co-operative approach in the
development of this guidance with other authorities and the County Council
would be beneficial and would provide more certainty for developers..
The environmental impacts of renewable energy schemes
(including smaller schemes) can be considered against Core
Policy 9 (Development and the Environment). Instead of relying
on national policy and guidance alone, an additional specific
policy is proposed in relation to Wind Turbines (Policy 37); this
reiterates the environmental requirements relating to this form of
development in order to provide greater clarity for developers.
Policy 37 (Wind Turbines) includes a number of criteria which
need to be met for any wind turbine development. One of these
requires that the development has no unacceptable impact on
local hydrology or other below-ground considerations including
safeguarded mineral resources.
The environmental impacts of renewable energy schemes can
be considered against Core Policy 9 (Development and the
Environment). Instead of relying on national policy and guidance
alone, an additional specific policy is proposed in relation to
Wind Turbines (Policy 37) to provide greater clarity for
developers.
Noted
The Council does not see it as appropriate to impose minimum
separation distances; separation distances are dependent on the
circumstances of the proposal As highlighted by national policy,
distance itself does not necessarily determine whether the
impact of a proposal is unacceptable. Distance does play a part
but other factors such as topography, the local environment and
near-by land uses.
Page 26 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
Indicative separation distances between turbines and residential
properties are given in the Council’s informal guidance document
- Wind Turbine Development in Blackburn with Darwen: A Guide
for Developers
Policy 37: ‘Wind Turbines’ will ensure that factors including the
amenity of neighbouring occupiers, noise, shadow flicker,
reflected light or any other effect are considered in any wind
turbine development.
6.16
6.17
6.18
Jones Lang
LaSalle for
Ainscough
Strategic Land
and Blackburn
Rugby Union
Football Club
Response made particular reference to Blackburn Rugby Club site on
Ramsgreave Drive.
Consider the suggested options relating to an Allowable Solutions policy
would impose onerous requirements on developers; requirement to achieve
specified standards or make a payment to secure emissions reductions
would be unduly prescriptive. Cumulative impact of policy requirements on
scheme viability needs to be considered.
Plan should encourage environmentally sustainable development.
6.16
6.16/1
6.16
6.16/1
The Wildlife
Trust for
Lancashire,
Manchester
and North
Merseyside
Confirm preference for Route A; no views on whether Route A1 or A2
would be preferable.
Together
Housing
Group
Support options 6.16/1 and 6.16/2.
Noted
Policy 36 (Climate Change) includes the option to use Allowable
Solutions as a means to ensure that a development complies
with required environmental standards. Specific options in terms
of carbon saving initiatives are not defined within Local Plan Part
2 as the Allowable Solutions framework is still evolving. It is
expected that if introduced Allowable Solutions will be at national
level.
Policy 7 (Sustainable and Viable Development) of the Local Plan
Part 2 Core Policies ensures the viability of development is
considered.
Advise it is possible to offset carbon through funding restoration of peatland
as a carbon sink and store.
6.16/2
Page 27 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
6.17
McAteer
Associates Ltd
for landowners
of land at Gib
lane,
Blackburn
Response made with particular reference to land at Gib Lane, Blackburn
(land to the rear of 393-423 Livesey Branch Road and 2-42 Gib Lane)
Noted
Not supportive of prescriptive policies on energy consumption and
renewable energy schemes being included in the plan. Consider such
policy requirements would impact on scheme viability.
The Plan is not prescribing specific standards and instead allows
developers to bring forward the most appropriate solutions to
meet the Council’s objectives for sustainable and viable
development. Similarly as new developments are likely to
include a significant proportion of renewable energy in order to
comply with evolving Building Regulations specific renewable
energy targets are not included in Local Plan Part 2.
The following policies aim to be flexible but also to ensure that
development is designed with the aim of minimising its
contribution to carbon emissions: Core Policy 7: ‘Sustainable
and Viable Development’ and Core Policy 11: ‘Design’
addresses sustainability objectives. With Policy 36: ‘Climate
Change’, the policies provide clarity for developers, in
accordance with the NPPF and the Government’s objective that
planning should fully support the transition to a low carbon
economy in a changing climate.
6.17
6.18
6.17
JASP Planning
Consultancy
for River
Street Assets
LLP
Response made with particular reference to land at Greenbank Terrace
(former Lower Darwen Paper Mill), Lower Darwen.
Together
Housing
Group
Support inclusion of an Allowable Solutions policy.
Do not consider the Council should adopt an Allowable Solutions Policy
until it is clear what the framework is within which a policy should work.
Consider this should include -installation of smart appliances/, PV panels/
on site waste management,/retrofit of low/zero carbon technologies/ low
energy storage solutions/ investment in district heating systems/ retrofitting/
low carbon cooling and energy storage.
Noted
Policy 36 (Climate Change) includes the option to use Allowable
Solutions as a means to ensure that a development complies
with required environmental standards. Specific options in terms
of carbon saving initiatives are not defined within Local Plan Part
2 because the Allowable Solutions framework is still evolving. It
is expected that if introduced Allowable Solutions will be at
national level.
Page 28 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
6.19
6.19
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
Jones Lang
LaSalle for
Ainscough
Strategic Land
and Blackburn
Rugby Union
Football Club
Response made particular reference to Blackburn Rugby Club site on
Ramsgreave Drive.
Noted
Plan does not need to make policy provision. The NPPF already provides
adequate policy guidance in relation to climate change. The plan should
avoid unnecessary duplication.
Comprehensive policies have been included within Local Plan
Part 2 in relation to flood risk and resilience, surface water
drainage and water quality in policies 9 (Development and the
Environment), 36 (Climate Change) and 40 (Green
Infrastructure). The policies provide additional clarity to the
relevant NPPF guidance rather than duplication.
Environment
Agency
Policy should be worded to ensure that where the council is satisfied no
alternative sites are available, development that has to be located in areas
at risk of flooding is not at an unacceptable risk of flooding or will
exacerbate risk elsewhere. The policy should identify the specific
measures identified through the Level 2 SFRA (Strategic Flood Risk
Assessment), which must be included to make development safe.
Noted
Policy also needs to make provision to protect water quality through new
development. In addition to the use of SUDS via the provision of buffers
between development and watercourses, the use of greywater recycling
measures and the diversion of surface water away from foul or combined
sewers.
Core Policy 9 (Development and the Environment) requires
development to demonstrate that it will not be at an
unacceptable risk of flooding. Where appropriate this will include
a requirement to demonstrate that there is no sequentially
preferable location in which the development could take place,
and if necessary, that the development complies with the
Exception Test. Development with the potential to create
significant amounts of new surface water run-off will be expected
to consider, and wherever possible implement, options for the
management of surface water at source.
The policy also states that development must avoid any
Page 29 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
6.19
CBRE for
United
Utilities(UU)
UU supports the Council’s aspirations to reduce the impact of climate
change, particularly the issue of flooding. UU request that new
development generates minimal discharge; surface water should be
managed at source and not transferred.
Connecting surface water to the public sewerage system is not a
sustainable solution and should be discouraged.
Any sites’ natural discharge should be continued; if the existing surface
water does not have an existing natural solution and the land is prone to
flooding UU would question its suitability for development unless
acceptable mitigation measures can be agreed.
Consideration should be given to green infrastructure and SuDs solutions.
Request a specific policy on surface water to require development to
comply with the surface water drainage hierarchy. The policy should:-
-
set out a requirement to reduce surface water discharges to the
equivalent of a greenfield run-off rate on undeveloped sites and a
significant reduction in surface water discharges on previously
developed sites;
require maximum use of porous paving, driveways and hard
standings.
6.19
Together
Housing
Group
Adaptation measures to be promoted include flood resistance and
resilience measures and conservation of water.
6.20
Together
Housing
Group
Further adaptation measures to be considered include fabric first
approaches.
unacceptable impact on environmental assets or interest,
including climate change (including flood risk) and water quality.
Policy 36 (Climate Change) requires all development to be
designed with the aim of minimising its contribution to carbon
emissions and climate change, both directly from the
development and indirectly arising from factors such as travel to
and from the development.
In addition, it requires all development to be located and
designed so as to minimise its susceptibility to the predicted
effects of climate change over the lifetime of the development. In
making its assessment against this requirement the Council will
take account of issues including but not limited to susceptibility
to flooding; availability of shade in public areas; incorporation of
measures to reduce unwanted solar gain during periods of hot
weather; and incorporation of measures to reduce the need for
artificial heating and cooling of buildings, including during
extremes of temperature.
Policy 40 (Green Infrastructure) requires, where circumstances
permit, for all development to be designed to make a positive
contribution to the Borough’s green infrastructure.
An SPD on green infrastructure will provide additional guidance
on how development may provide environmental enhancements.
Page 30 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
6.21
Environment
Agency
Consider that developers should already be factoring climate change
impacts into their site specific Flood Risk Assessments.
Noted
The Wildlife
Trust for
Lancashire,
Manchester
and North
Merseyside
Confirm support.
CBRE for
United Utilities
UU would like to add the following to their response for consideration in the
preparation of the plan:-
6.21
-
Regarding sewage treatment infrastructure. There is a need for
this to be located remotely to reduce any detrimental impact on
residential amenity. Potential amenity issues associated with
odour should be reflected in a general development management
policy alongside policies on nose/dust etc.;
-
Request Environmental Health Authority are consulted on future
developments adjacent to waste water infrastructure assets;
-
UU have a legal right of access to their assets. UU will not permit
development over and/or near its infrastructure assets;
-
Ask to be kept informed of any waste management related
development and/or planning application adjacent to large
diameter trunk main.
-
Seek support of the Council in local plan and planning application
processes to protect/secure land for future infrastructure
requirements.
Policy 36 (Climate Change) requires all development to be
located and designed so as to minimise its susceptibility to the
predicted effects of climate change over the lifetime of the
development. In order for the Council to assess whether a
development complies with this policy, developers will need to
provide this evidence to accompany planning applications. A
proportionate approach to validation requirements will be taken.
Noted
Core Policy 8 (Development and People) requires development
to secure a satisfactory level of amenity and safety for
surrounding uses and for occupants or users of the development
itself, with reference to noise, vibration, odour, light, dust, other
pollution or nuisance, privacy/overlooking, and the relationship
between buildings.
Other issues highlighted by UU have been noted.
Page 31 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Council response/ACTION TAKEN
Page 32 of 32 Appendix 4 Spatial Intervention 4: Protecting and enhancing the environment
APPENDIX 5: Summary of representations relating to general issues of concern in issues and options (I/O) paper and consultation on potential
housing development sites - July 2012 and February-May 2013
Local Plan Part 2: Site allocations and Development Management Policies
Regulation 18 consultations: Preparation of a Local Plan
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
EMPLOYMENT/
LAND SUPPLY FOR BUSINESS DEVELOPMENT IN HIGHER VALUE
SECTORS/
ACCESS TO JOBS AND SERVICES
Lancashire
County
Council (LCC)
(Strategy &
Policy)
In addition to detailed representations to individual i/o questions. With
reference to LCC’s strategic objectives and wider corporate activities – in
particular – promoting sustainable economic growth/ improving roads and
transport/protecting and improving our environment: 
Plan should give greater emphasis to retaining an advanced
manufacturing base and the need to plan to support indigenous
business expansion and high valued manufacturing. Consider this
is needed to support delivery of LEP’s key priorities and the
Lancashire Advanced Engineering and Manufacturing programme
(in particular the Enterprise Zone (EZ), and;

Existing transport links between neighbouring key economic growth
areas should be referenced and influence the selection of preferred
allocation sites.
.
Concerns that development of executive homes in attractive/outer areas
may lead to development in less accessible locations and an increase in car
usage. Note that sites listed in ‘Delivery-led’ option seem contrary to aims of
Core Strategy/outside ‘transport corridor focus for new development’.
Suggest policies relating to ‘Access to jobs and services’ should address the
implications of the EZ designation to ensure that development that would
support businesses and/or workers serving the EZ are not disadvantaged by
the locations of new housing.
Page 1 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
ACTION TAKEN:
Noted.
Refer to Policy 13: Employment land allocations; Policy 16: Housing allocations; and Policies Map
The Plan recognises the importance of job creation particularly in key growth sectors. It makes adequate provision of development land to enable
the establishment and growth of new and existing businesses. Engagement with the LEP has ensured that the Plan conforms to LEP’s key
priorities.
The development of the East Lancs Transport Masterplan will improve connectivity within and outwith East Lancs, including connectivity to key
economic growth areas.
It is necessary to develop outer areas to ensure sufficient deliverable housing land. This is not contrary to the Core Strategy transport corridor
focus. Accessibility has influenced the selection of sites and has been considered as part of the Sustainability Appraisal. Policy 16 identifies 18
strategic housing allocations across the borough. The Policies Map indicates that Blackburn is the main focus for housing development. The
allocated suites in north and western Blackburn including Housing allocations 16/1, 16/2, 16/3, 16/9 and 16/10 are particularly complementary to
the EZ designation. Each of the site specific allocations include development consideration that will need to be taken into account as scheme
proposals are prepared.
QUANTITY, QUALITY AND MIX OF HOUSING
HOUSING DEVELOPMENT
Tockholes
Parish Council
Efforts to progress development on brownfield land should be prioritised
before considering any development beyond the existing urban boundary.
Consider it important that inner areas are attractive, offer a choice of welldesigned homes and provide an efficient transport network.
ACTION TAKEN:
Noted. Council agrees with this comment.
Refer to Policy 1: Urban boundary; Policy 2: Inner urban area: Policy 10: Accessibility and transport; Policy 11: Design; Policy 16: Housing
allocations; Policy 18: Housing mix; Policy 40: Integrating green infrastructure with new development; and the Policies Map
Policy 1 and the Policies map confirm the proposed urban boundary changes around the Gib Lane area on the north side of Broken Stone Road.
This reflects the release of land to the west Gib Lane and to the east of Heys Lane for development; refer to Policies 16/9 – land west of Gib
Lane and 16/10 - Land east of Heys Lane. The site specific policies set out the development consideration that will need to be taken into account
as scheme proposals are prepared. Initially a comprehensive masterplan is required for the whole of the area between Broken Stone Road and
the existing built up area, including site 16/10 and taking into account the Pleasington Lakes site, south of Broken Stone Road.
Page 2 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
The Plan acknowledges the need for a combined approach to investment and improvement that delivers growth and the regeneration of the inner
area. Policy 1 confirms that the urban area is the preferred location for development. Policy 2 confirms the inner urban area where regeneration
is a priority. Policy 10 sets out the considerations for development to be located in areas that provide good access to public transport. Policies
11,16 and 40 identify the issues that need to be taken into account to in scheme detailing to ensure development is attractive, well designed and
provides a choice of dwellings in particular family homes.
Tockholes
Parish Council
Majority of Tockholes’ residents wish to see the village character, its local
facilities and surrounding countryside protected and significant development
discouraged.
ACTION TAKEN:
Noted.
Refer to Policy 3: The Green Belt; Policy 5: Countryside areas; Policy 8: Development and people; Policy 11: Design; Policy 17: Housing
development in Tockholes; Policy 35: Protection of local facilities; Policy 40: Integrating green infrastructure with new development and the
Policies Map.
Policies 3 and 5 (read in conjunction with the Policies Map) confirms that the protection via Green Belt and Countryside Area status surrounding
Tockholes remains in place.
The Plan acknowledges that Tockholes is a village. However it does not have an identifiable boundary and as such is ‘washed over by Green
Belt’. The plan recognises that Tockholes does need to have the flexibility to provide for the changing needs of its community. Policy 17 sets out
the circumstances which would influence favourable consideration of residential development proposals in the Green Belt surrounding
Tockholes. This is complemented by Policies 8, 11 and 40. Policy 8 confirms the need for development to make a positive contribution to the
elements of local areas that make them attractive, for example local character and sets out a range of issues which need to be addressed to
ensure the development does not give rise to any adverse effects on people’s lives. Policy 11 sets out the Council’s design requirements. Policy
40 identifies the requirements relating to the integration of green infrastructure within all new development including connectivity with
neighbouring sites.
Policy 35 responds to the need to retain local facilities, particularly in the rural area, and sets out how the Council will manage proposals for
change and development relating to established local facilities.
.
Priority should be given to investment/development in the inner areas on •
The overall approach in the Local Plan is for the majority of
brownfield sites, the renovation of empty properties and existing stock and
the proposed 9,400 houses to be on sites within the urban
the kick starting of stalled schemes before any development takes place on
area, mainly brownfield. The total capacity of the sites
greenfield land.
identified on the edge of the urban area is around 2,5003,000; hence the remaining 6,500-7,000 will need to be in
the urban area.
•
However there are other factors that need to be taken into
account, including:
Page 3 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
The need to be able to show that enough land is
available and ready to be built on now, to meet our
housing requirement for the next 6 years, and
The need to provide land for larger homes for families,
which cannot be accommodated on many of the sites in
our inner urban areas.
It is therefore not possible to put forward a policy that
requires no green field sites to be released until all
brownfield sites had been developed. Such a policy would
result in planning permissions being granted on appeal,
which would give the Council and local communities much
less influence over the development.
-

ACTION TAKEN:
Noted.
The Plan acknowledges the need for a combined approach to investment and improvement that delivers growth and the regeneration of the inner
area. Policy 1 confirms that the urban area is the preferred location for development. Policy 2 confirms the inner urban area where regeneration
including the re-development of brownfield/previously developed land is a priority.
The Council is developing a toolkit of measures it can use to support the renovation of empty properties, promote development, and assist in
situations where development has stalled. This will be put together in a “Housing Implementation Strategy” which is expected to be published
along with the Publication edition plan. Tools the Council is considering include:
Setting up a “local delivery fund” funded by New Homes Bonus, contributions from developers of greenfield sites, and receipts from the
sale of Council-owned land for housing;
Reviewing how the Council uses its own land – selling it for housing, entering into development partnerships / joint ventures, allowing
developers to buy through staged payments, etc.;
Reviewing our own procedures to ensure that the Council is an easy partner for developers to work with, and;
Adopting a flexible approach to planning requirements while ensuring that we maintain quality standards.
At the same time it is important to be realistic about what the Council can and cannot achieve – some stalled sites have complicated
circumstances, for example bankruptcy procedures, which the Council is not able to resolve.
The argument that brownfield/inner areas are not attractive or viable for new
development was challenged. That development is ongoing within the inner
area for e.g. at the Infirmary and at Mosley Street would indicate that
developers can be encouraged to build on these sites, can contribute to the
regeneration of areas, make a profit and can include the provision of
affordable (low cost) homes.
•
•
Sites that have come forward, such as Mosley Street in
Blackburn and Queen Street in Darwen, have been
supported by external grant funding from central government
which is no longer available. There are few or no sites in the
inner urban area currently progressing on a normal
commercial basis.
In order to meet the requirement in national planning policy
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•
to demonstrate a supply of sites deliverable now, it will be
necessary to plan for greenfield sites to come forward in the
early part of the plan period.
This situation is expected to improve over time as the market
becomes stronger. In addition the Council is working hard to
identify a toolkit of measures to support the delivery of urban
sites, including use of land that the Council owns, affordable
housing contributions from developers of greenfield sites,
and proactive support and assistance for developers in
planning and bringing forward sites.
ACTION TAKEN:
Noted. Refer to Council response.
Alternative/additional development sites: what options have the Council
considered? Some options suggested include former factory and mill sites,
revitalising town centre living, and the conversion of empty office and
commercial buildings.
•
•
The Issues and Options consultation paper that was
prepared in Summer 2012 considered three overall strategic
options: A regeneration-focused option concentrating solely on
brownfield and other sites within the inner urban area;
A urban-based strategy relying entirely on sites within
the urban area but with less of a focus on the inner
areas;
A “delivery” strategy, which planned for the early release
of greenfield sites outside the built-up area.
At this stage in our preparations of the Local Plan and
assessment of potential site allocations for new housing we
will consider all site/strategic options.
ACTION TAKEN:
Refer to Policy 16: Housing allocations; Policy 18: Housing mix; and Policies Map
Policy 16 identifies 18 housing development allocations and sets out the design considerations that need to be taken into account during the
preparation of detailed scheme proposals. The package of sites will make a significant contribution and encourage investment to meet the
Council’s housing agenda for growth and the regeneration of the inner urban area. Reference to the Policies Map shows that the 18 sites are
located across the borough and will offer a choice of housing, in particular good quality family housing, within the inner area, in the wider urban
area and greenfield sites along the edge of the urban area. Development will not be limited to the sites identified; the Policies Map indicates
other ‘general areas’ where complementary and appropriate development can take place.
Policy 18 sets out the housing mix requirements for all housing schemes.
Residents queried the evidence base for the 15-year housing target (9400
•
The Council is committed to providing an equitable, attractive
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homes) considering the poor performance of the housing market, the small
number of completions in recent years and the loss/closure of businesses.
•
Residents questioned the need for the scale of housing proposed
considering there are lots of empty properties and so many houses for sale
including larger homes and house prices are falling. Residents also
questioned the benefits of and need for “luxury” homes, which seem to be
the focus of Council plans for development. Given the high levels of
unemployment and high wage earners there would seem to a greater need
for affordable housing.
•
Residents questioned the evidence/market research carried out to support
the demand for higher value new homes.
•
•
•
and high quality choice of housing for all residents.
To provide this choice the Local Plan will allocate sites for a
range of house types, mix and tenure including smaller and
affordable houses as well as larger homes for families. The
majority of new homes (around two thirds) will be within the
towns/existing urban area rather than on greenfield sites on
the edge of the towns.
The Council’s evidence of housing demand and need is
identified in its “Strategic Housing Market Assessment
“(SHMA); this looks at the overall amount and type of new
housing that will be needed in the future. With regard to
residents’ concerns regarding the high demand/need for
larger homes. The SHMA considered a range of factors that
informed this conclusion: The average wage of people working in the Borough is
around 10% higher than that of people living here.
People working in higher paid jobs in the Borough tend
not to live here. Availability of suitable housing is one
reason for this.
The large majority of the Borough’s housing stock is in
Council Tax Bands A and B, and we have fewer houses
in higher bands (D and above) than some of our
neighbouring Councils.
At the same time the Council acknowledges that there are
equally important needs for a range of house types from
other groups including people on the housing waiting list.
Altogether we do not currently have a balanced housing
market in Blackburn and Darwen and therefore people
trading up the housing ladder may often reach a point where
they have to move out of the area to access the housing they
want. This is reflected in 2011 Census information about our
population and patterns of migration.
The new homes do not necessarily have to provide directly
for people setting up house for the first time. The main issue
is people’s ability to move within the market. It is more likely
that family housing on the edge of the built up area would
allow people to trade up from smaller properties elsewhere in
the towns, releasing these smaller properties into the market
for people for example who are first time buyers.
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ACTION TAKEN:
Noted. Refer to Council response.
A disproportionate amount of new housing is proposed for Darwen: 5 sites
in Darwen compared to 7 in Blackburn. As most employment and population
is in Blackburn more housing should be developed there.
•
•
•
The consultation material shows the key sites on the edge of
the urban area. Development will also take place over the
life of the plan on a wide range of sites within the urban
areas. There are many more of these urban sites in
Blackburn than in Darwen, so we expect the overall amount
of development to be significantly greater in Blackburn. This
is in line with our Core Strategy policy.
The important issue is not the number of sites on the edge of
the urban area, but the number of houses expected to be
built in each town. The greenfield sites in Darwen are
estimated to be able to provide approximately 750-1,000 new
homes; those in Blackburn may accommodate as many as
2,000.
More information will be available at the next consultation
later in the year.
ACTION TAKEN:
Noted. See Council response.
Refer to Policy 16: Housing allocations. This policy identifies 18 key sites that have been allocated for housing development in the Publication
edition plan, gives an indication of the timescale for delivery and sets out the design considerations that will need to be taken into account in the
preparation of scheme details. Of the 18 sites allocated 6 are in Darwen.
Some residents anticipated that new development within the local area
would cause the value of existing homes to fall.
•
•
Planning legislation does not allow the Council to take house
prices into account when making planning decisions;
Even so, it is not guaranteed that development will impact on
house prices in the longer term. A stronger economy and
housing market created by new investment, a more balanced
mix of housing and our wider growth and regeneration
agenda, could be expected to increase house prices across
the area overall.
ACTION TAKEN:
Noted. See Council response.
AFFORDABLE HOUSING
Residents wanted greater clarity on affordable housing. Is it property for
market sale, private rent or would it be social housing? Some residents
•
The National Planning Policy Framework identifies three
types of affordable housing and confirms that affordable
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linked affordable housing to troublesome low income families, anti-social
behaviour and crime. Others regarded affordable housing as housing
provided at an accessible market price for first time buyers or families.
housing is provided to ‘eligible households whose needs are
not met by the market’. They are:
Social rented housing. Within Blackburn and Darwen
these homes tend to be owned, let and managed by
private registered providers (housing associations) such
as Twin Valley Homes, Places for People and Great
Places;
Affordable rented housing. These homes also tend to be
let by private registered providers to eligible households,
and;
Intermediate housing which are homes for sale and for
rent. This can include shared equity, low cost homes for
sale and intermediate rent.
ACTION TAKEN:
Noted. See Council response.
Refer to Policy 18 Housing mix. The Council recognises need for affordable housing to be included in the borough’s housing mix/housing offer.
Policy 18 sets out the requirements for the provision of affordable housing.
A definition of affordable housing is provided in the plan’s glossary.
Residents expressed a preference for affordable housing to be provided
within the inner area, in close proximity to bus and rail connections for ease
of access to jobs, and via the renovation of empty properties.
•
•
•
The Council fully agrees with this and is committed to
providing high quality homes for all residents. The Council
considers everyone deserves a good home irrespective of
location, type, size and value and will work with developers
to provide equality in the opportunity for people to have a
quality home.
Affordable housing tends to be needed by people, including
families, on lower incomes and has traditionally been built
within the inner urban areas.
It is hoped that a wider choice/mix of homes – particularly
family homes - will provide the opportunity for more
movement within the local housing market and release these
typically smaller homes within the inner urban area for first
time buyers and other homeowners.
ACTION TAKEN:
Noted.
Refer to Policy 2: The inner urban area; Policy 10: Accessibility and transport; Policy 12: Developer contributions; Policy 18: Housing mix; and
Policies Map.
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Council agrees that many of the residents in affordable housing may prefer to be located within the inner areas close to public transport networks
which offer access to local services and jobs. Altogether this is likely to be a sustainable option for those residents needing affordable housing –
both to rent and/or to buy.
The Plan acknowledges the need to promote a combined approach to investment and improvement that delivers growth and the regeneration of
the inner area. Policy 2 (read in conjunction with the Policies map) confirms the inner urban area where regeneration is a priority
All development is required to make a contribution to affordable housing. It will be essential that the affordable housing mix offers a good choice
and quality of home to all. Policy 18 acknowledges the need for a wider choice of housing to contribute to the Council’s housing growth and
regeneration agenda in particular the need for high quality family housing. It sets out the Council’s development considerations relating to house
type mix and the options for the provision of affordables – on site or elsewhere via a financial contribution. Policy 12 sets out the approach to
developer contributions, which in the first instance will be secured, via a Section 106 agreement.
With regard to the renovation of empty properties. The Council developing a toolkit of measures it can use to support the renovation of empty
properties. This will be put together in a “Housing Implementation Strategy” which is expected to be published along with the Publication edition
plan.
SERVICES AND INFRASTRUCTURE
AMEC for the
National Grid
Confirm wish to be involved in preparation/alteration and review of Council
planning policies which may affect their assets relating to the following
issues: 
Overhead transmission lines/underground cables/gas pipeline
installations;

Site specific allocations affecting sites crossed by overhead
lines/underground cables or gas transmission lines;

Land use policies/development proposed adjacent to existing high
voltage electricity sub-station sites and gas above ground
installations;

Policies relating to diversion of overhead transmission lines;

Policies relating to infrastructure/utility provision;
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
Policies relating to development in the countryside;

Landscape policies, and

Waste and mineral plans
COUNCIL RESPONSE
ACTION TAKEN:
Noted. National Grid has been involved in the Infrastructure Plan and the Council will continue its communication with the organisation.
Sport England
With reference to NPPF paragraphs 171 and 73 note that local plans need
to be based on an up-to-date playing field and built sports facilities strategy
(both carried out in accordance with a methodology approved by Sport
England).
Confirm their records indicate the Council does not have either and
therefore they challenge the soundness of the plan work completed to date.
Confirm willingness to work with the Council to put strategies in place.
ACTION TAKEN:
Noted. The Council has commissioned consultants to prepare a Playing Pitch Strategy, which assesses the supply and demand for playing
pitches within the borough. Sport England has been involved in its preparation from the outset.
Coal Authority
Provided an information leaflet which outlines the general issues that the
Coal Authority consider should be addressed in Local Plans covering
coalfield areas.
ACTION TAKEN:
Noted. Policy 8 (Development and People) requires development on previously developed, potentially contaminated or unstable land to secure a
land remediation scheme to ensure that the land is remediated to a standard which provides a safe environment for occupants and users and
does not displace contamination. Additionally, Policy 37 (Wind Turbines) sets out a list of criteria which wind turbine applications must meet,
including that the development must have no unacceptable impact on local hydrology or other below ground considerations including
safeguarded mineral resources.
Mono
Consultants
Limited for
Mobile
Operators
Association
Consider it important that a telecommunications policy remains in place in
the Local Plan. A model Development Management policy is suggested.
ACTION TAKEN:
Noted. Policy 44 in the Publication edition sets out the Council’s requirements for the siting of new telecommunications equipment.
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Network Rail
(NR)
Provide details of 3 level crossings owned by NR in the borough. Consider
the policy does not take account of the impact of development on these
level crossings. Raise concerns that increased patronage over level
crossings may require train speeds to be reduced i.e. impact on train
timetabling and frustrate train service improvements; there may also be
safety issues. Request Network Rail Level Crossings Policy is integrated in
the plan; similar policies are in place in the Wirral and are proposed in the
West Lancashire Council Plan.
COUNCIL RESPONSE
Also request that plan identifies the need for developer contributions to fund
rail infrastructure improvements where they are required as a result of the
proposed development.
ACTION TAKEN:
Noted.
Refer to Policy 10: Accessibility and Transport; and Policy 12: Developer contributions
Policy 10 sets out the approach the Council will adopt in managing the transport implications of development.
The Theatres
Trust
In some cases the developer may be required to make a contribution to improvements required to local infrastructure in response to the impacts
of development. Policy 12 identifies the options for securing this contribution. The Council may produce a Supplementary Planning Document to
expand on the operation of this policy.
Support options paper statement that Blackburn town centre will be the
location for arts and cultural services. Question the intention to identify a
cultural quarter; note their concerns that the locations of various quarters
may exclude appropriate venues/buildings or activities.
Support efforts to establish an evening economy.
With reference to NPPF and the protection/safeguarding and improvement
of established cultural facilities and services provide advice on a model
policy to be included in the plan.
ACTION TAKEN:
Noted.
Refer to Policy 35: Protection of local facilities
The Publication edition recognises that facilities such as small shops, post offices, public houses and community halls are an important part of
life in our towns and rural areas. Policy 35 aims to retain and protect these local facilities.
CBRE for
United Utilities
Confirm willingness to work in partnership with local planning authorities to
progress sustainable development and growth.
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Note that future site allocations and policies should consider the impact of
new development and ensure adequate infrastructure capacity is available.
If infrastructure deficiencies cannot be addressed, an alternative location
and/or timescale should be considered.
ACTION TAKEN:
Noted.
Refer to Policy 13: Employment land allocations and Policy 16: Housing allocations.
The Council has regular liaison meetings with United Utilities to identify any potential issues with infrastructure capacity for the planned growth in
the borough. Any particular issues identified have been integrated within the allocation policies – Policies 13 and 16 - for individual sites and will
be addressed as an integral part of scheme development. The Council will continue this dialogue with United Utilities to ensure they are made
aware of progress on developments and can plan ahead to make adequate provisions for the development.
Small scale retail in residential development should be provide for/contribute
towards sustainable development / communities
ACTION TAKEN:
Some of the allocated sites in the Plan will require a masterplan to be produced prior to any development taking place. It is envisaged that the
masterplan will include requirements to provide facilities, including shops, on site. Whether a new local shop is developed is, however, a
commercial decision.
Existing facilities should be protected as these are regarded as an essential
element within local areas and villages.
The Council fully agrees and will work with local communities and
developers to ensure this happens.
ACTION TAKEN:
The Publication edition recognises that facilities such as small shops, post offices, public houses and community halls are an important part of
life in our towns and rural areas. Policy 35 aims to protect these local facilities and includes a requirement that any proposal for the complete
change of use of buildings identified as being important to the sustainability of the community which it serves, will not be permitted except where
it can be demonstrated that the use is no longer economically viable or required by the local community, and that the use is not capable of being
supported by enabling development or a diversified use.
Concerns were expressed that the existing infrastructure including local
road networks, sewers and drains, schools and shops and the hospital are
not able to cope and that any increased demand would seriously worsen the
situation for established residents. Flooding/risk of flooding was of particular
concern to a large number of residents.
The Council is working on an Infrastructure Plan to accompany
the Local Plan. This will set out what new infrastructure is
needed to support new development. The Infrastructure Plan
and the Local Plan will set out where developments need to
provide or contribute to this new infrastructure in order to be
granted planning permission.
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ACTION TAKEN:
Information from the Infrastructure Plan in terms of infrastructure required for new development has been integrated into the individual site
allocation policies. Such information includes whether the development will need to contribute towards a new Primary school, SuDS, local
highway improvements etc.
Preference was expressed for service cuts rather than pursuing the need for
income generation via the release of greenfield sites.
•
This point was made by a single resident. Based on its other
discussions with communities about budgets and services,
the Council is not convinced all residents would support or
could afford this option
•
New houses generate additional Council Tax and New
Homes Bonus, which will be able to be spent on local
services.
ACTION TAKEN:
Noted. See Council response.
Some residents also said that the Council is not able to maintain existing
roads and run established services. How will it afford to manage more?
ACTION TAKEN:
Noted. See Council response.
PROTECTING AND ENHANCING THE ENVIRONMENT/
GREEN BELT /WILDLIFE/ ENVIRONMENT
6.7, 6.8,
6.9
Canal and
River Trust
New development can in some cases have a detrimental impact on the
quality and condition of the canal infrastructure. Advise that the plan should
include a requirement for a CIL contribution towards
improvement/enhancement of existing green infrastructure assets including
the canal.
ACTION TAKEN:
The Council is not progressing CIL at the present time.
Refer to Policy 8: Development and people; Policy 9: Development and the environment; Policy 16/5 – Rockcliffe Mill, Blackburn; and Policy 40:
Integrating green infrastructure with new development.
With regard to particular development allocations adjacent to the canal for e.g. the Rockcliffe Mill site the allocations policy includes a
requirement for the developer to optimise on the connectivity with the canal and mitigate the impact of the increased use arising from the
development. Policies 8, 9 and 40 complement this.
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COUNCIL RESPONSE
Policy 8 of the publication edition plan seeks to ensure that development makes a positive contribution to the local area and the elements of the
area that make them attractive to people. Policy 9 states that any development involving the partial or complete loss of an area of green
infrastructure identified on the Policies Map, or which otherwise has the potential to result in the fragmentation of green infrastructure or the
severance of green connections between town and country will not be permitted unless i) the development can be accommodated without the
loss of the function of the open space; ii) the impact can be mitigated or compensated for through the direct provision of new or improved green
infrastructure elsewhere, or through the provision of a financial contribution to enable this to occur; or iii) the need for or benefits arising from the
development demonstrably outweigh the harm cause, and the harm has been mitigated or compensated for so far as is reasonable.
Policy 40 identifies the components of green infrastructure including canals, describes its benefits to local communities and sets out the
requirement for development to integrate and enhance the network of green infrastructure across the borough; this includes improving
connectivity with neighbouring sites. The policy makes particular reference to the development considerations for proposed schemes alongside
the Leeds Liverpool Canal.
Natural
England
No specific comments on particular sites.
Request full consideration of natural environment in process of
selecting/assessing/allocating sites and in policy development –
biodiversity/geodiversity/landscape character and quality/green
infrastructure/access to countryside and other open spaces and protection
and enhancement of soils. Need to take account of environmental
designations in delivery of housing sites
ACTION TAKEN:
Consideration has been given to all allocated sites, and where issues have been identified for a particular site, these have been included within
the ‘development considerations’ part of the site allocation policy.
Within the Publication edition, Policies 9 (Development and the Environment), 40 (integrating green infrastructure with new development) and 41
(Landscape) ensure the natural environment is considered in any new development.
Environment
Agency
Response provided to individual i/o questions relevant to their remit;
Provided information on flood risk/proximity to a watercourse of identified
sites and list of sites where impact upon aquatic environment needs to be
considered.
ACTION TAKEN:
Information provided by the Environment Agency has been integrated within individual site allocation policies under ‘development
considerations’.
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Wildlife Trust
for Lancashire,
Manchester
and North
Merseyside
In addition to specific comments note that cooperation with neighbouring
authorities will be critical in policy development relating landscape and
nature conservation in the West Pennine Moors and Lancashire Valleys.
COUNCIL RESPONSE
ACTION TAKEN:
Noted. The Council is required to work with neighbouring authorities on strategic matters that have cross boundary implications under the
requirements of the Duty to Cooperate.
Lancashire
County
Council
Archaeological
Unit
Note that they have only assessed the proposed development sites for their
potential environmental constraints in a general way. Welcome the
opportunity to provide more detailed information when site allocations are
more certain.
ACTION TAKEN:
Noted.
Tockholes
Parish Council
Committed to preservation of Green Belt designation; would like to see this
extended: -
Over southern part of the Gib Lane area, and
-
At the southern end of the village.
ACTION TAKEN:
Refer to the Policies Map for the extent of Green Belt about Tockholes.
The Policies Map (Publication version) identifies the area south of Broken Stone Road and the land between Gib Lane and Heys Lane as
Countryside Area (Policy 5). The retention of this designation was supported by the Green Belt Review, which advised that the Countryside Area
policy was adequately robust for the planning of this area.
The area north of Broken Stone Road has been allocated for new housing development in the Publication edition (Policies16/9 and 16/10). The
corresponding policy for these allocated sites includes a requirement for the sites to be brought forward in line with a comprehensive masterplan,
which must be approved prior to any development commencing. This masterplan will require the development to integrate landscape works on
site. The allocation policy also requires the development to be designed to minimise the impact of development on the countryside, and to
enhance access to the countryside, in addition to protecting the important landscape features, such as areas of woodland.
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Tockholes
Parish Council
Noisy spots and leisure activities in the countryside should be discouraged.
Parish Council of the view that the beauty and tranquillity of the countryside
including its wildlife should be protected for enjoyment of residents and
visitors
COUNCIL RESPONSE
ACTION TAKEN:
Publication edition Policy 5 (Countryside Areas) states that planning permission within the Countryside Areas will only be granted for
development needed for the purposes of agriculture or forestry, or economic uses appropriate in nature and scale to the rural area. The policy
aims to preserve what is important in the countryside and manage change in a way that balances competing pressures.
Policy 40 in the Publication edition requires, where circumstances permit, for all development to be designed to make a positive contribution
Blackburn with Darwen’s green infrastructure. One of the requirements of this policy is retain and enhance existing ecological and landscape
features on the site. The policy also requires all new residential development to contribute towards the provision of high quality open space for its
residents, either through financial contributions towards improving the quality and/or accessibility of nearby existing spaces.
Additionally, Policy 9 does not allow any development to occur which is likely to damage or destroy habitats or harm species of international or
national importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or habitats or species
listed in the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other planning
considerations and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to damage or
destroy habitats or species of local importance unless the harm caused is outweighed by other planning considerations and an appropriate
mitigation strategy can be secured.
The Council is giving greater consideration to income generation from new
development than protecting and investing in greenfield sites.
•
Green Belt boundaries need to be preserved and protected.
Concerns were expressed that wildlife and habitats would be lost.
Surrounding countryside is regarded as one of the Council’s greatest assets
and a major influence in encouraging people to relocate to the area. Once
used it will be gone forever.
•
The Council acknowledges and understands residents’
concerns about the value of the Green Belt to the character
and attractiveness of the borough. Our Local Plan will aim to
ensure that development is designed to minimise its impact
on the openness of green areas and to preserve important
areas of character. The scale of development proposed
outside the built up area is similar to developments that have
taken place over many years in the past.
The community will be consulted on any planning application
for development on Green Belt sites (as with all major
developments).
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COUNCIL RESPONSE
ACTION TAKEN:
Policy 40 in the Publication edition requires, where circumstances permit, for all development to be designed to make a positive contribution
Blackburn with Darwen’s green infrastructure. One of the requirements of this policy is retain and enhance existing ecological and landscape
features on the site. The policy also requires all new residential development to contribute towards the provision of high quality open space for its
residents, either through financial contributions towards improving the quality and/or accessibility of nearby existing spaces.
Additionally, Policy 9 does not allow any development to occur which is likely to damage or destroy habitats or harm species of international or
national importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or habitats or species
listed in the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other planning
considerations and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to damage or
destroy habitats or species of local importance unless the harm caused is outweighed by other planning considerations and an appropriate
mitigation strategy can be secured.
Residents questioned the argument that development on greenfield sites
will make a contribution/generate monies for the re-development of
brownfield sites. What assurances are there that once the Green Belt has
been released that development on brownfield sites will take place?
•
If the Council does take a decision to collect financial
contributions from greenfield developments in lieu of
affordable housing, any money received is required to be
used in line with the requirements of the planning legislation.
This ensures that the money can only be used for the
purpose it was collected for, but also sets a requirement that
it is spent within a reasonable timescale. If this is not done
the Council is liable to refund the money to the developer.
So there is a powerful incentive for the Council to ensure that
development on these urban sites does take place.
•
It is true that the Government has made the delivery of new
housing a top priority for the whole country. The Government
has changed the planning system to help ensure that this
happens.
However, providing more good quality family housing is also
a Blackburn with Darwen priority. It is reflected in our
adopted Core Strategy, and in the Council’s Corporate Plan
which was approved in 2012.
The Council recognises that delivering this new housing will
involve some hard decisions, and is committed to keeping
residents informed and involved.
ACTION TAKEN:
Noted. See Council’s response.
Some feel the proposed house building requirements and the release of
Green Belt land is a central government driven agenda. The Council should
be supporting local people to resist this.
•
•
Page 17 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
ACTION TAKEN:
Noted See Council comments above.
QUALITY OF PLACE
7.10
Canal and
River Trust
Confirms need for detailed policy on green networks to clarify mechanisms
for delivery of Policy CS19 with reference to the Lancashire Green
Infrastructure Study; policy relating to Leeds Liverpool Canal corridor needs
to be developed jointly with LCC and neighbouring authorities.
ACTION TAKEN:
Policy 40 sets out a requirement for integrating green infrastructure within new development. This requires all development, where
circumstances permit, to be designed to make a positive contribution to Blackburn with Darwen’s green infrastructure. The policy also recognises
Blackburn with Darwen’s river s and water bodies, including the Leeds and Liverpool Canal are important components of green infrastructure.
Additionally, it states that functioning ecological networks are primary components of green infrastructure and they should not be compromised.
Development should contribute to the restoration, enhancement and connection of natural habitats through the provision of appropriate green
infrastructure.
English
Heritage (EH)
Supportive of Core Strategy framework for sustainable development in
particular the protection and enhancement of the historic environment. Note
the need for the Part 2 Plan to provide the detail/mechanism for delivery as
required by NPPF.
Signpost to a number of EH guidance documents.
ACTION TAKEN:
Refer to Policy 39: Heritage.
The policy sets out how the Council will manage change affecting the historic environment in a way that focuses on and is proportionate to the
significance of the asset.
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
Page 18 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
Complementary investment is needed in both town centres. Residents were
disparaging about the quality and range of facilities currently available. It
was felt they would not attract people to move into Blackburn and Darwen.
Investment is needed to improve the offer and encourage businesses to
take up the many empty shops. This would help to make the centres more
attractive and encourage higher wage earners to consider relocating and to
spend in the centres.
•
The Council fully agrees that progress needs to continue in a
number of areas, not simply building more houses. The Core
Strategy identifies six areas that will contribute to future
growth:
Land for employment development
The amount, type and quality of housing
Our public facilities – schools, town centres, culture
“Quality of place” – design of new development, historic
buildings etc
Protection and improvement of our environment
Better access to work – transport, skills, health
•
In recent years both town centres have seen major
investments:
The Mall / new Market development in Blackburn
Development of Blackburn College’s University Centre
and new main College building
The Darwen Academy
Darwen Leisure Centre
Darwen Health Centre
Heritage-led regeneration in Darwen including the
creation of new shop units in the front of the Town /
Market Hall
Refurbishment of Blackburn Library
•
In addition there has been major investment in education
through Building Schools for the Future
•
Further investments already planned include:
The demolition and redevelopment of Blackburn Markets
The Blackburn Cathedral Quarter
A new Blackburn Leisure Centre
The Pennine Reach public transport scheme
Further work to improve the Blackburn / Darwen /
Manchester rail route
ACTION TAKEN:
Noted. See Council’s comments.
Page 19 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
THE COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
There is a need for a comprehensive approach to housing delivery across
the borough, which includes the inner urban sites/redevelopment of existing
property. This should consider all aspects of the borough/growth agenda
including employment, transport, retail and the town centre.
•
The Council is working hard to develop a toolkit of measures
it can use to promote development and assist in situations
where development has stalled. This will be put together in a
“Housing Implementation Strategy” which is expected to be
published along with the draft Local Plan. Tools the Council
is considering include:
Setting up a “local delivery fund” funded by New Homes
Bonus, contributions from developers of greenfield sites,
and receipts from the sale of Council-owned land for
housing;
Reviewing how the Council uses its own land – selling it
for housing, entering into development partnerships /
joint ventures, allowing developers to buy through staged
payments, etc.;
Reviewing our own procedures to ensure that the
Council is an easy partner for developers to work with,
and;
Adopting a flexible approach to planning requirements
while ensuring that we maintain quality standards.
•
At the same time it is important to be realistic about what the
Council can and cannot achieve – some stalled sites have
complicated circumstances, for example bankruptcy
procedures, which the Council is not able to resolve.
How proactive can the Council be in influencing where investment takes
place?
The Council should be proactive in kick -starting stalled sites and /or
securing a way forward on those sites where the developer is ‘in
administration’.
ACTION TAKEN:
Noted. See Council’s comments above.
How are decisions made about where any monies received are spent?
If it is decided to adopt the approach of collecting financial
contributions in lieu of affordable housing, a procedure will need
to be set up to manage the money received. A similar procedure
is already in place to manage money collected for public open
space – in this case the ultimate decision about where money will
be spent rests with the Council’s Executive Member for
Regeneration.
Page 20 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
ACTION TAKEN:
Noted. See Council’s comments.
Refer to Policy 12: Developer contributions; Policy 16; Housing allocations; and Policy 18: Housing mix.
Policy 16 includes 18 sites allocated for housing development. A set of site specific policies are set out for each site including the development
considerations that will need to be taken into account as scheme proposals are prepared. In some cases the development considerations identify
the need for the developer to contribute towards particular infrastructure improvements for example to the local highway network, and/or to the
provision of additional capacity for example to facilitate additional primary school places. There is some flexibility in the form of contribution; in
some cases this can be via making land available or by a financial contribution.
Policy 18 sets out the options for the provision of affordable housing including off-site through a financial contribution.
Policy 12 sets out the process for securing financial contributions. The intention is to prepare a Supplementary Planning Document to expand on
the operation of this policy.
Has the Council considered alternative approaches to delivery for example
could small derelict inner area sites be offered to small local builders at a
reasonable cost to provide employment for local trades’ people? Another
suggestion was that a consortium of local builders is set up to bid for and
purchase inner area sites. This could provide employment opportunities for
a local workforce including apprentices together with local purchase of
building materials.
•
•
Not all of these suggestions are within the Council’s control
since it does not own the large majority of the land in
question.
The Council would however be keen to help facilitate any
proposals by private developers to bring forward urban sites,
and is increasingly looking at options such as joint ventures
with developers to bring forward development on land that it
does own.
ACTION TAKEN:
Noted. See Council’s comments above
The Council should resist developer pressures to release Green Belt
particularly when it is not what local people want.
•
The potential release of Green Belt is not a response to
developer pressure – it is responding to the requirements of
national planning policy and to the need to increase the
supply of new housing, to meet local needs, in a situation
where the Borough has not met its house building targets for
a number of years.
Page 21 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
ACTION TAKEN:
Noted. See Council response.
The Council has recently completed a review of its Green Belt along the urban boundary. This was a technical piece of work to assess whether
the existing Green Belt (as defined in the Adopted 2002 Local Plan) meets the purposes of the Green Belt as identified in the government’s
National Planning Policy Framework (NPPF). The study’s recommendations indicate that a number of parcels of land can be released from the
Green Belt. A copy of this document will be available alongside the Publication edition plan at the next stage of statutory consultation, prior to
submission of the plan and supporting documentation to the Secretary of State.
How does the Council balance profit to developers with benefits, or not, to
the local community?
The Local Plan will contain a series of policies which require
developers to contribute towards things which “benefit the
community” such as affordable housing and local infrastructure
(roads, schools etc). In setting these policy requirements the
Council has to use information about the costs of development
and the potential returns to a developer. The Council has to be
able to show that the requirements that it sets will still allow a
developer to make a commercial profit. If this was not the case
then the development would not happen anyway and any
community benefits would not be realised.
ACTION TAKEN:
Noted. Refer to the Council’s response.
Refer to Policy 7: Sustainable and viable development; Policy 12: Developer contributions; Policy 16: Housing Allocations; Policy 18: Housing
mix; Policy 40: Integrating green infrastructure with new development; and Policy 45: Major road schemes.
With the exception of Policy 7 all of the above policies make reference to the mechanism (Policy12) and/or the need for developer contributions
to scheme delivery. The form of contributions can vary and is negotiable; the options include a financial contribution, making land available
and/or direct implementation in lieu of part or all of the contribution. Policy 7 sets out the Council approach to assessing scheme viability and its
proactive approach to working with developers on scheme delivery. Policy 12 sets out the process for setting and securing a financial
contribution. The Council may produce a Supplementary Planning Document to expand on the operation of Policy 12.
THE CONSULTATION PROCESS
Page 22 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
The local community needs to be kept informed and consulted, as more
detailed proposals are prepared.
•
•
•
•
The Council believes that residents have a valuable
contribution to make, and is committed to community
consultation and ongoing local engagement on proposals that
will impact on residents and their neighbourhoods.
Consultation is a statutory requirement of this Local Plan
process and the Council will be asked to demonstrate to an
independent Inspector at the public examination of the Plan
that consultation has been carried out at key stages in the
preparation of the Plan.
Consultation on the next stage, the draft Plan is scheduled to
take place later this year/beginning 2014.
Residents will be kept informed of the opportunities for further
comment/involvement
via
local
members,
their
Neighbourhood Teams and via the Council’s website.
ACTION TAKEN:
Noted. Refer to the Council response.
The Council’s Adopted Statement of Community Involvement (SCI) sets out how the Council will engage with the community and other
stakeholder groups during the planning process. The Council’s response refers to the opportunities for continuing involvement with the plan
making process. In addition the community will be consulted and offered the opportunity to engage with the advancing of scheme proposals in
preparation for the submission of a planning application and in the planning application decision-making process.
Page 23 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
A number of residents felt that decisions on housing allocations had already
been made and that the Council would not take account of the views of the
community.
•
Residents asked for confirmation that the Council would respond to the
comments made and will be open to making changes and modifications to
the proposals.
•
•
•
We can assure residents that the Council is committed to
taking their views into consideration.
No decisions on housing allocations have been made. The
purpose of the consultation was to offer residents the
opportunity to influence and inform this process.
All of the comments received to date have been read and
noted. Over the next few months a ‘Statement of
Consultation’ will be prepared to accompany the next stage
of the Local Plan. This statement will provide details of the
consultations carried out in the preparations of the Plan, a
summary of the feedback together with information to explain
how the comments have influenced the plan including how
these have guided the site allocations included in the Plan.
The statement will be available at the next consultation early
in 2014. It is a statutory requirement as supporting
information for the Plan. It will be available at the public
examination of the Plan and will be reviewed by the
independent Inspector carrying out the examination.
ACTION TAKEN:
Noted See Council’s comments above.
The Council provided written feedback in July 2013 to all who had taken part in the issues and options consultation.
The Statement of Consultation referred to in the Council response has been completed and sets out how the consultation feedback to date has
informed the advancing development of the plan. The statement will be available as a supporting document at the next stage of consultation on
the Publication edition plan.
Page 24 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
Concerns were expressed at the lack of detail provided for proposals with
the exhibition material.
•
•
•
•
These comments were received with particular reference to
those sites identified with a ‘star’ in the exhibition material. In
these cases it was not possible to draw a boundary as the
extent of the developable part of the site has not been
identified. This will be informed by feedback from residents
on site issues and the recommendations from technical
appraisals such as viability/flood risk and infrastructure
capacity assessments;
These assessments will be completed over the next few
months as an integral part of the work to confirm housing site
allocations;
At the next consultation, at the end of this year/early 2014,
boundaries will be shown for all sites;
Some residents hoped to see detailed layouts for each site
including proposed access, housing layout and house types.
This level of detail will be worked up at a later stage by the
landowner and/or developer as part of the process of
applying for planning permission to carry out the
development. There is no set timescale for this.
ACTION TAKEN:
Noted. See Council response.
Refer to Policy 13: Employment land allocations; Policy 16: Housing site allocations; and the Policies Map.
Policies 13 and 16 include allocated sites for the respective land uses. Boundaries for each allocated site have been confirmed and are shown
on the accompanying Policies Map.
Page 25 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
A number of residents said they did not receive information/invitations to the
events and only found out by word of mouth or receive the information after
a number of events had already taken place.
•
The Council made a range of alternative arrangements to
provide information and to make residents aware of the
consultation events including: -
-
-
-
•
•
Over 11,000 individually addressed leaflets/invitations to
the consultation events were posted out to homes in the
neighbourhoods surrounding the major sites. The extent
of the mailing in each area was discussed with
Neighbourhood Teams to try and ensure this captured
those residents that relate to the proposed sites;
Posters were displayed in local areas in shops and other
frequented places such as post offices and at venues in
advance of the event;
Community officers distributed information via their
neighbourhood networks such as Ward Solution
meetings;
Information was made available, and still is, on the
Council’s website
Press briefings were held and articles written in the local
Telegraph.
The majority of invitations were sent out 2 weeks in advance
of each event to give people notice and the opportunity to
consider which event best suited them.
Everyone was welcome to attend any of the events. Whilst
we appreciate local events may have been more convenient
the exhibition material was the same at each event.
ACTION TAKEN:
Noted. See Council response.
OTHER ISSUES
Equality and
Human Rights
Commission
Confirmed they do not have the resources to respond.
ACTION TAKEN:
Noted
Page 26 of 27 APPENDIX 5
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
Residents commented on the link between the high numbers of
empty/properties for sale and the lack of jobs. The current lack of jobs and
investment in up-skilling of local people was considered a major barrier to
the Council’s agenda for housing growth. The impact was new residents
would not come and those that could would leave the borough to find
employment elsewhere.
•
•
People commented that there appears to be a lack of high-income job
vacancies or employers in the area providing ‘executive’ jobs. This will
discourage new residents.
•
The perceived high number of properties currently for sale is
a result of the weak housing market and the “credit crunch”.
In particular, first time buyers and lower income households
find it very difficult to get mortgages. This has an effect right
up the chain as people wanting to sell and trade up are
unable to do so. We have to expect that over the next 15
years the housing and mortgage markets will return to normal
and people will be able to move house as they wish to.
It is already the case that many higher-income earners in
Blackburn with Darwen (professionals, managers / directors
of companies in the Borough, skilled blue-collar workers) do
not live in the Borough. This is reflected in the fact that the
average wage of people working in the Borough is higher
than the average wage of people living here. Part of the
intention of the new Local Plan is to enable these people to
live in the Borough rather than commuting in from elsewhere.
The Council and its partners are heavily involved in
developing the skills of the local workforce, for example the
continuing development of high level technical courses at
Blackburn College, support for apprenticeships, direct
support for people running or considering establishing
businesses, and so on.
ACTION TAKEN:
Noted. See Council’s comments above
Page 27 of 27 APPENDIX 5
APPENDIX 6: SUMMARY OF REPRESENTATIONS RELATING TO SITE SPECIFIC ISSUES OF CONCERN:
ISSUES AND OPTIONS PAPER and CONSULTATION ON POTENTIAL HOUSING DEVELOPMENT SITES –July 2012 and February-May 2013.
Local Plan Part 2: Site Allocations and Development Management Policies
Regulation 18 Consultations: Preparation of a Local Plan
Page number
1. Belmont Village and surrounding area
1
2. Edgworth and surrounding area
10
3. Blackburn Golf Club, Blackburn
12
4. Griffin/Paterson Street/Alaska-William Streets/Highfield Road and Infirmary, Blackburn
18
5. Haslingden Road (including Fishmoor and Blackamoor Roads), Blackburn
23
6. Roe Lee, Blackburn
30
7. Gib Lane (including west of Gib Lane and east of Heys Lane)/Sappi (including Stockclough
35
Lane)/Voith/Albion/Moorgate/Bridge/Pioneer and Eclipse Mill, Blackburn
8. Parsonage Road, Blackburn
53
9. Brownhill Drive Blackburn
63
10. Blackburn RUFC and land north of Ramsgreave Drive (including Yew Tree Drive and Preston New Road), Blackburn
73
11. Bailey’s Field/Ellison Fold , Darwen
85
12. Pole Lane, Darwen
92
13. Former Moorland School, Darwen
101
14. Kirkham’s Farm/Cranberry Lane/Jacks Key, Darwen
110
Page 1 of 120 APPENDIX 6
1. BELMONT VILLAGE and surrounding area (including Springside Works)
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
SITE ISSUES
Speeding traffic on High Street.

Very dangerous driving over Rivington Road – cars and motorbikes.

Scrambler bikes on the moors are a problem
Council has noted resident’s comments and appreciates the impact
of these on the village;
These are not issues that can be remedied as part of the Local
Plan process. However we will forward the comments to the
Council’s Highways Team with a request that they review and take
any available actions.
ACTION TAKEN:
These issues cannot be remedied as part of the Local Plan process. Comments have been forwarded to the Council’s Highways Team.
HOUSING DEVELOPMENT
Sedgwick
Associates
Owners of former Springside Works propose that the site is
allocated for residential development including upper
market/executive housing. Priority should be given to such
previously developed sites before Green Belt land is released.
ACTION TAKEN:
Refer to Policy 16/18 – Springside Works, Belmont and Policy 18: Housing mix
This site has been allocated for residential development. The policy sets out the specific development requirements/considerations for this site that
will need to be taken into the account in scheme preparation and implementation.
Policy 18: Housing mix complements the site allocations and confirms the requirement for new development to widen the choice of housing types.
Page 2 of 120 APPENDIX 6
The Publication edition plan confirms the need for high quality family housing to improve the housing offer available in the borough.
United
Utilities
Regarding Ryecroft Lane. Resubmission of information provided in
response to Call for Sites evidence gathering in preparation of the
Council’s Strategic Housing Land Availability Assessment (SHLAA).
Confirms owner preference to see land allocated for housing.
ACTION TAKEN:
Refer to Policy 6: Village boundaries; Policy 3: The Green Belt, and; Policy 24: Rural exceptions.
The Publication edition plan confirms that the Council’s overall planning strategy for the rural areas is to focus development within the identified
village boundaries. At the same time it acknowledges that, in some cases, there may be a local need for affordable housing. In these
circumstances it may be appropriate to consider development outside the village boundary, including on sites in the Green Belt.
Policy 6 confirms that development within the rural areas, including Belmont Village, should be located within the village boundary as shown on
the Adopted Policies Map/Southern Section. This site has not been allocated and would not generally be considered favourably for residential
development as it is outside the settlement boundary.
This site is also located within the Green Belt. The Publication edition confirms the importance of Green Belts in national planning policy. Policy 3
confirms the circumstances and the uses that would be considered as appropriate development.
Policy 24 sets out the criteria that would need to be met by a proposal for an affordable housing scheme outside the village boundary.
United
Utilities
Relates to land adjacent to the Vicarage. Resubmission of
information provided in response to Call for Sites evidence
gathering in preparation of the Council’s Strategic Housing Land
Availability Assessment (SHLAA). Confirms owner preference to
see an extension to the village settlement boundary/release of land
from the Green Belt to enable residential development to be
brought forward.
ACTION TAKEN:
Refer to Policy 6: Village boundaries; Policy 3: The Green Belt, and; Policy 24: Rural exceptions.
The Publication edition plan confirms that the Council’s overall planning strategy for the rural areas is to focus development within the identified
village boundaries. At the same time it acknowledges that, in some cases, there may be a local need for affordable housing. In these
Page 3 of 120 APPENDIX 6
circumstances it may be appropriate to consider development outside the village boundary, including on sites in the Green Belt.
Policy 6 confirms that development within the rural areas, including Belmont Village, should be located within the village boundary as shown on
the Adopted Policies Map/Southern Section. This site has not been allocated and would not generally be considered favourably for residential
development as it is outside the settlement boundary.
This site is also located within the Green Belt. The Publication edition confirms the importance of Green Belts in national planning policy. Policy 3
confirms the circumstances and the uses that would be considered as appropriate development.
Policy 24 sets out the criteria that would need to be met by a proposal for an affordable housing scheme outside the village boundary.
No space for new housing after development on dyeworks and
Beechwood has been completed.


The Council agrees with this position. Very limited scope within the
village envelope for additional housing development;
Residents have not, to date, requested that the village boundary be
reviewed to enable any further development.
ACTION TAKEN:
Refer to Policy 6: Village boundaries; Policy 16/18 – Springside Works, Belmont; and Policy 24: Rural exceptions.
It is acknowledged that there is limited space within the village for future development.
The Publication edition plan confirms that the Council’s overall planning strategy for the rural areas is to focus development within the identified
village boundaries. At the same time it acknowledges that, in some cases, there may be a local need for affordable housing. In these
circumstances it may be appropriate to consider development outside the village boundary, including on sites in the Green Belt; any site within the
Green Belt would need to adjoin the village boundary.
Policy 6 confirms that development within the rural areas, including Belmont Village, should be located within the village boundary as shown on
the Adopted Policies Map/Southern Section.
Policy 16/18 relates to Springside Works, a former paper mill to the south of the village. This site has been allocated for housing and offers the
opportunity for a wider choice of house types to be made available within this rural area. The policy sets out the specific development
considerations that will need to be taken into the account in scheme preparation and implementation.
Policy 24 sets out the criteria that would need to be met by a proposal for an affordable housing scheme outside the village boundary.
How can local people influence the spending of New Homes
Bonus? Some of these monies (generated from building of 16
homes on Beechwood) would be appreciated for measures to


Spending of these monies is part of the Council’s overall budget
setting process and is not ring-fenced to a particular area;
Scope for influence is via local Ward Solution meetings and their
input to identifying projects/spend setting process within their local
Page 4 of 120 APPENDIX 6
control traffic speeds on main road through the village.
ACTION TAKEN:
How New Homes Bonus monies are spent cannot be determined by the Local Plan. The scope for influence is as noted in the ‘Council response’
above.
AFFORDABLE HOUSING
Some residents have the understanding that affordable homes can
only be provided if enabling market development is carried out in
the local area. As this would require use of greenfield/Green Belt
there is no support for further housing development.



A number of residents have asked for clarity on the definition of
affordable housing. This is provided in the attached information on
‘general themes’.
With regard to any changes in the village boundary please refer to
the Council’s response above;
There are not expected to be any changes to the Green Belt
boundary around the villages.
ACTION TAKEN:
Refer to Policy 6: Village boundaries; Policy 3:The Green Belt: Policy 18: Housing mix: and Policy 24: Rural Exceptions
The Publication edition plan confirms that the Council’s overall planning strategy for the rural areas is to focus development within the identified
village boundaries (Policy 6). Policy 18 sets out the preferred housing mix required to achieve the Council’s objectives for housing growth and a
widened choice of house types; it notes that developments of 10 units or more including all affordable housing will only be acceptable in
exceptional circumstances. The onus would be on the developer to put forward a robust case to demonstrate the exceptional circumstances.
The Green Belt boundary around Belmont Village will remain as currently drawn. The Publication edition confirms the importance of Green Belts in
national planning policy. The opportunities for development in the Green Belt are limited; Policy 3 confirms the circumstances and the uses that
would be considered as appropriate development. Similar to the above the onus would be on the developer to put forward a robust case to
demonstrate the special circumstances that would merit a favourable consideration of such a proposal.
At the same time the plan acknowledges that, in some cases, there may be a local need for affordable housing. In these circumstances it may be
appropriate to consider development outside the village boundary, including on sites in the Green Belt; any site under consideration within the
Green Belt would need to adjoin the village boundary.
Page 5 of 120 APPENDIX 6
Policy 24 sets out the criteria that would need to be met by a proposal for an affordable housing scheme outside the village boundary.
A number of residents cannot afford to buy in the village and rent
instead. There is a preference to rent in a village surrounded by
countryside rather than lose the setting to development which may
provide an opportunity to buy.


The Council appreciates the importance of the countryside setting
to local residents and has noted the preference for the boundary to
be retained as it is now;
Please see above note regarding the Green Belt study.
ACTION TAKEN:
Noted. All feedback will be passed on to any development discussions.
SERVICES AND INFRASTRUCTURE
Protect local facilities i.e. both pubs/shop PO/school/church/playground – all are an essential part of village
life


The Council acknowledges the real importance of local facilities
and services to the rural areas;
Protection of these facilities will be referred to in Development
Management policies.
ACTION TAKEN:
The Publication edition recognises that facilities such as small shops, post offices, public houses and community halls are an important part of life
in our towns and rural areas. Policy 35 aims to protect these local facilities and includes a requirement that any proposal for the complete change
of use of buildings identified as being important to the sustainability of the community which it serves, will not be permitted except where it can be
demonstrated that the use is no longer economically viable or required by the local community, and that the use is not capable of being supported
by enabling development or a diversified use.
GREEN BELT/WILDLIFE/ENVIRONMENT
Wildlife Trust
for
Lancashire,
Manchester
and North
Issues of concern regarding Springside Mills:1. Previous developments on site have fragmented key
habitats which contribute to a significant Living Landscape
in Longworth Clough/Eagley Brook Valley are on the West
Pennine Moor fringe;
Page 6 of 120 APPENDIX 6
Merseyside
2. Site is adjacent to Longworth Clough nature reserve – trust
mange for nature conservation and public amenity;
3. Most of Longworth Clough nature reserve is designated as
Longworth Clough SSSI and Oak Field SSSI and nearly all
the remainder is identifies as Local wildlife Sites, sensu
Defra (‘Biological Heritage Sites’ in Blackburn/Darwen and
‘Sites of Biological Importance’ in Bolton);
4. History of land contamination on the site and frequent water
pollution incidents in the nearby Eagley Brook which forms
part of the SSSI along this stretch.
Request that these constraints and opportunities for conservation,
restoration and recovery of wildlife and wildlife habitats are
addressed is site specific policy.
ACTION TAKEN:
An extensive remediation scheme has been approved which when implemented will prepare the site for development. Within the allocation policy,
there is a requirement for the development to be informed by a landscape masterplan identifying strategic areas of planting that are required to
integrate the development into the surrounding countryside.
Policy 40 within the Publication edition requires all development, where circumstances permit, to be designed to make a positive contribution to
green infrastructure in the borough. This will include the retention and enhancement of existing ecological and landscape features on the site and
incorporation of features in the built fabric that support and enhance key local species.
Additionally, Policy 9 states that any development likely to damage or destroy habitats or harm species of international or national importance will
not be permitted. Furthermore, any development likely to damage or destroy habitats or species of principal importance, Biological Heritage Sites,
or habitats or species listed in the Lancashire Biodiversity Action Plan will not be permitted unless the harm caused is significantly and
demonstrably outweighed by other planning considerations and an appropriate mitigation strategy can be secured. Development likely to damage
or destroy habitats or species of local importance will not be permitted unless the harm caused is outweighed by other planning considerations
and an appropriate mitigation strategy can be secured.
The policy also states that development that would result in further fragmentation of, or compromises the function of Blackburn with Darwen’s
ecological network will not be permitted unless the harm caused is significantly and demonstrably outweighed by other planning considerations
and an appropriate mitigation strategy can be secured.
Preserve wildlife, views and countryside setting of the village.
Page 7 of 120 APPENDIX 6
ACTION TAKEN:
See requirements of Policy 9 above. Additionally, the allocation policy requires the development of the site to be compatible with the rural
character of the surrounding area, with particular attention to the massing and distribution of buildings, architectural vernacular, materials and
landscaping/boundary treatments. It also requires any new development on the site to be informed by a landscape masterplan identifying the
strategic areas of planting that are required to integrate the development into the surrounding countryside. It also confines development in the first
instance to the footprint of the industrial buildings formerly on the site and their associated hard standing.
Retain and respect the Green Belt/Heritage sites and the West
Pennine Moors designation
ACTION TAKEN:
The Publication edition recognises that the Green Belt remains a fundamental element of national planning policy, and is essential in managing
growth and preventing urban sprawl. Policy 3 (The Green Belt) states that planning permission for development within the Green Belt will only be
permitted in very special circumstances.
OTHER ISSUES
WIND TURBINES
Concern for the environmental impact on peat land habitats.



Council appreciates this is a controversial topic for many residents;
Concerns will be picked up in Development Management policies;
Opportunities for public consultation will be available for any future
planning applications.
ACTION TAKEN:
Policy 37 (Wind Turbines) has been included in the Publication edition, setting out the criteria against which wind turbine planning applications will
be assessed; including a requirement for development to have no unacceptable adverse impact on a protected habitat or other feature of
ecological importance, local hydrology or other below-ground consideration.
ACTION TAKEN:
Page 8 of 120 APPENDIX 6
All comments made under the following heading have been actioned as part of the general feedback; refer to Appendix 5.
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
Page 9 of 120 APPENDIX 6
2. EDGWORTH and surrounding area
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
AFFORDABLE HOUSING
Does not support development within the Green Belt alongside
the village to enable affordable housing to be provided



Thank you for your comments;
Council acknowledges that there is very limited scope within the
village for additional housing development;
During the consultation we have not received any request for
amendments to village boundary.
ACTION TAKEN:
Refer to Policy 6: Village boundaries; Policy 3:The Green Belt: Policy 18: Housing mix: and Policy 24: Rural Exceptions
The Publication edition plan confirms that the Council’s overall planning strategy for the rural areas is to focus development within the identified
village boundaries (Policy 6); the accompanying policies Map defines the boundary for Edgworth – here has been no change to this boundary.
Policy 18 sets out the preferred housing mix required achieving the Council’s objectives for housing growth and a widened choice of house
types; it notes that developments of 10 units or more including all affordable housing will only be acceptable in exceptional circumstances. The
onus would be on the developer to put forward a robust case to demonstrate the exceptional circumstances.
The Green Belt boundary around Edgworth will remain as currently drawn. The Publication edition confirms the importance of Green Belts in
national planning policy. The opportunities for development in the Green Belt are limited; Policy 3 confirms the circumstances and the uses that
would be considered as appropriate development. Similar to the above the onus would be on the developer to put forward a robust case to
demonstrate the special circumstances that would merit a favourable consideration of such a proposal.
At the same time the plan acknowledges that, in some cases, there may be a local need for affordable housing. In these circumstances it may be
appropriate to consider development outside the village boundary, including on sites in the Green Belt; any site under consideration within the
Green Belt would need to adjoin the village boundary.
Policy 24 sets out the criteria that would need to be met by a proposal for an affordable housing scheme outside the village boundary.
Page 10 of 120 APPENDIX 6
OTHER ISSUES
WIND TURBINES
Individual wind turbines preferable to wind farms as on
Oswaldtwistle Moor.
What analysis of wind conditions has been carried out in North
Turton?



Resident comments have been noted and will be taken in account
in the consideration of any future proposals for wind turbines;
All proposals will use a criteria based approach to gauge the
impact;
There will be opportunities for community consultation as/if
proposals are developed.
ACTION TAKEN:
Policy 37 (Wind Turbines) has been included in the Publication edition, setting out the criteria against which wind turbine planning applications
will be assessed; including a requirement for development to have no unacceptable adverse impact on a protected habitat or other feature of
ecological importance, local hydrology or other below-ground consideration. Further information has been published in the Council’s wind
turbine guidance for developers (May 2013).
ACTION TAKEN:
All comments relating to the following headings have been actioned as part of the general feedback; refer to Appendix 5
SITE ISSUES
HOUSING DEVELOPMENT
SERVICES AND INFRASTRUCTURE
GREEN BELT/WILDLIFE/ENVIRONMENT
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
Page 11 of 120 APPENDIX 6
3. BLACKBURN GOLF CLUB, Blackburn
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
SITE ISSUES
Local flooding.
Properties in Beardwood Fold have previously (2002) been
flooded from a culvert that borders properties. Some
improvement work to the culvert/culvert grill has been carried
out at resident’s expense. This captures run-off from the golf
course. Concerns regarding impact of increased flow/surface
run-off. Further concern regarding possible increased water
run-off/flooding and proximity of Beardwood substation.



Information/concerns have been noted and will be taken into account in
assessing suitability of the site for development and development
requirements;
For each proposed development site the Council will prepare a schedule
setting out all development/scheme requirements including provision for
surface water drainage. The developer will need to demonstrate how
these requirements will be met before any development can progress;
Information/concerns regarding substation will be forwarded to the
Council’s drainage team.
ACTION TAKEN:
The site has not been allocated for development within the Publication edition, due to its comparatively small size. However, it remains as a
potential housing site on the Council’s Strategic Housing Land Availability Assessment and could therefore be brought forward for development
in the later stages of the plan period. If a planning application is received, residents adjoining the site will be consulted, and Policy 9 of the
Publication edition requires development to demonstrate that it will not be at an unacceptable risk of flooding, or increase the level of risk
elsewhere.
HOUSING DEVELOPMENT
Mixed development preferred.

Provision of parking spaces needs to be a priority.


Council has made a note of resident’s comments and will use these to
inform site development requirements;
Council is committed to providing an equitable high quality housing
choice across the borough;
For each proposed development site the Council will prepare a schedule
Page 12 of 120 APPENDIX 6

setting out all development/scheme requirements including housing mix,
house types, design standards and off-street parking;
These requirements will be secured via the application of Development
Management policies /guidance to any planning application.
ACTION TAKEN:
Refer to Policy 1: The Urban Boundary; Chapter 4 (para 4.5) of the Publication edition plan and accompanying Policies Map.
Map confirms the protected open space designation has been removed and site is available for appropriate development.
Chapter 4 sets out the criteria for housing allocations. This site was not considered to satisfy the criteria and therefore has not been allocated for
housing development. However it is identified as a developable site within the Council’s updated Strategic Housing Land Availability Assessment
(SHLAA).
Policy 1 confirms that the urban area is a preferred location for new development. The Publication edition plan acknowledges that development
within the urban area is welcome and makes a vital contribution to the vitality and viability of the borough and the regeneration of its towns. The
Council will work proactively with developers to explore options to ensure urban sites are deliverable
SERVICES AND INFRASTRUCTURE
Significant loss of open space
ACTION TAKEN:
Policy 9 of the Publication edition states that development involving the partial or complete loss of an area of green infrastructure will not be
permitted unless the development can be accommodated without the loss of the function of the open space; the impact can be mitigated or
compensated for through the direct provision of new or improved green infrastructure elsewhere, or through the provision of a financial
contribution to enable this to occur; or the need for or benefits arising from the development demonstrably outweigh the harm caused, and the
harm has been mitigated or compensated for so far as is reasonable. As a result, any new development on the site would have to meet these
requirements.
This policy also requires all new residential development to contribute to the provision of high quality open space for its residents, either through
provision of public open space on site, or where more appropriate, through financial contributions towards improving the quality and/or
accessibility of nearby existing spaces.
Local facilities should be protected. Developers should be
encouraged to provide a range of facilities as part of their
Page 13 of 120 APPENDIX 6
developments including shops, schools, nurseries and
community centres.
ACTION TAKEN:
The Publication edition recognises that facilities such as small shops, post offices, public houses and community halls are an important part of
life in our towns and rural areas. Policy 35 within the Publication edition aims to protect these local facilities and includes a requirements that any
proposal for the complete change of use of buildings identified as being important to the sustainability of the community which it serves, will not
be permitted except where it can be demonstrated that the use is no longer economically viable or required by the local community, and that the
use is not capable of being supported by enabling development or a diversified use.
If a development proposal comes forward on the site the Council will look to secure provision of facilities, if appropriate, on site or a contribution
towards new facilities.
In terms of nursery places, the Council’s Early Years team have confirmed there are sufficient places available to meet the needs of residents in
the borough both now and in future years. This will be kept under review.
PUBLIC TRANSPORT
Bus service through Beardwood is poor


Council fully appreciated resident’s needs for convenient connection to
surrounding areas and to local services;
Demand from increased numbers of residents on this site/together with
adjacent developments may present an opportunity for an improvement
in the local bus service;
ACTION TAKEN:
The need for existing and future bus services to be financially sustainable results in difficulty in planning for public transport as a form of
infrastructure. New bus services will require a customer base in place first due to their commercial nature. Policy 10 of the Publication edition
states that development for uses that are likely to generate large numbers of trips will only be permitted in locations which are conveniently
accessible by existing or proposed public transport services. If appropriate, the Council will also work with the developer to formulate, implement
and monitor a Travel Plan setting out the measures that the developer, either alone or in conjunction with neighbouring uses, shall adopt to
reduce reliance on the use of the private car for journeys to and from the site.
HIGHWAYS
Providing vehicular access will be problematic via either
Mollington Road or Beardwood Brow. Both roads have
difficult junctions with Revidge Road and junctions will be


Council is grateful for resident’s comments and acknowledges that this
information needs to be taken into account as part of the assessment of
the suitability of each site for development;
For each proposed development site the Council will prepare a schedule
Page 14 of 120 APPENDIX 6
difficult to bring to an acceptable standard.
Surrounding roads are not capable of taking additional traffic
– already dangerous.


setting out all development/scheme requirements including
highways/footpath new/upgraded and site access. The developer will
need to demonstrate how these requirements will be met before any
development can progress;
An assessment of capacity/impact of potential development sites on
local highway network is being carried out to inform site allocations. This
will be used as an evidence base to assist with individual site appraisals
and determining site requirements;
These requirements will be secured via the application of Development
Management policies /guidance to any planning application.
ACTION TAKEN:
The Local Highways Study will assess the current condition and capacity of the local highways network in the Borough and to assess the impacts
of new housing and employment sites in the borough over the Plan period. Any new development on this site will need to ensure any issues
identified are addressed and may need to contribute towards local highway improvements.
Policy 10 (Accessibility and Transport) of the Publication edition requires development to demonstrate that road safety and the safe, efficient and
convenient movement of all highways users is not prejudiced; appropriate provision is made for vehicular access, off-street servicing and parking
in accordance with the Council’s adopted standards. As a result, any development proposal on this site would have to demonstrate how it
complies with these requirements.
NEW INFRASTRUCTURE REQUIRED



Replacement open space


As for the comments above regarding highways. The schedule setting
out all development/scheme requirements will include a requirement for
the provision/integration of additional infrastructure such as local shops,
integration of open space/green infrastructure as needed;
The developer will need to demonstrate that the proposed scheme
meets all requirements before planning consent is granted/scheme can
progress. In some cases the developer may need also to make a
contribution to the provision/enhancement of local facilities and services;
Developer may be asked to contribute and/or integrate provision within
scheme delivery as appropriate.
In addition, as noted below: Please see above;
ACTION TAKEN:
See previous comments
Page 15 of 120 APPENDIX 6
Improved bus service

As noted above for public transport;

We are working closely with the Education Department to identify the
need for and the opportunities to deliver additional school places;
ACTION TAKEN:
See previous comments
Increased capacity in local primary schools
ACTION TAKEN:
There will be a requirement for a new single entry Primary school to support new housing planned for in the north of Blackburn. If the site was to
be developed, the Council may require a contribution towards this.
Local shops within walking distance.

Please see above.
ACTION TAKEN:
See previous comments.
ACTION TAKEN:
All comments relating to the following headings have been collated with the representations covering ‘general feedback’; refer to Appendix 5
AFFORDABLE HOUSING
GREEN BELT/WILDLIFE/ENVIRONMENT
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
OTHER ISSUES
Page 16 of 120 APPENDIX 6
Page 17 of 120 APPENDIX 6
4. GRIFFIN/PATERSON STREET/ALASKA-WILLIAM STREETS/HIGHFIELD ROAD AND INFIRMARY, Blackburn
Issues
and
options
question
Respondent
4.1
Janet Dixon
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE

All of the following representations
relate to sites within Griffin except if
noted otherwise
HOUSING DEVELOPMENT
Queen Victoria Street
Currently protected employment land covered by
saved Local Plan policy EC3 Established Business
and Industrial Areas.
Site and buildings are vacant; little prospect of site
being developed for employment in the foreseeable
the site; suggest it is allocated for an alternative use
– preference is for housing. Site is
available/sustainable location suitable for larger
family homes and owner contact with housebuilders
suggests there would be an interest in the site.
ACTION TAKEN:
Refer to Publication Edition Policies Map and Policy 1: The Urban boundary.
The map confirms that the protected employment designation for this site has been removed and the site is available for appropriate development.
Policy 1 confirms that the urban area is a preferred location for new development. The publication edition plan acknowledges that development
within the urban area, in particular development which involves the re-use of empty buildings and/or brownfield land, is welcome and makes a vital
contribution to the vitality and viability of the borough and the regeneration of its towns. The Council will work proactively with developers to
explore options to ensure urban sites are deliverable.
Page 18 of 120 APPENDIX 6
J.
Whitehead
Land at Parkinson Street/Bedford Street/Stakes
Hall Road.
Requests that protected open space designation is
removed.
ACTION TAKEN:
Refer to Publication Edition Policies Map and Policy 1: The Urban boundary.
Protected open space designation has been removed and site is available for appropriate development.
Policy 1 confirms that the urban area is a preferred location for new development. The publication edition plan acknowledges that development
within the urban area, in particular development which involves the re-use of empty buildings and/or brownfield land, is welcome and makes a vital
contribution to the vitality and viability of the borough and the regeneration of its towns. The Council will work proactively with developers to
explore options to ensure urban sites are deliverable.
Local residents need to be consulted as housing
proposals are brought forward and meetings held
within their area.


Council fully support this and is committed to ongoing engagement with residents
as scheme proposals become available;
Every opportunity will be provided for community involvement as Council moves
forward to identify developer partner/works up scheme detail.
ACTION TAKEN:
Noted. Refer to Council response; Policy 16/4 – Griffin, Blackburn.
Policy 16/4 confirms that land in Griffin has been allocated for housing.
HOUSE TYPES
Bungalows and 2/3 and 4 bed properties.

Larger houses are essential. Many larger families
are living in houses too small for their families.



Council has made a note of resident’s comments and will use these to inform site
development requirements;
Council is committed to providing an equitable high quality housing choice across
the borough;
For each proposed development site the Council will prepare a schedule setting out
all development/scheme requirements including provision for housing mix including
affordables for rent and for sale, house types and specific design standards;
These requirements will be secured via the application of Development
Page 19 of 120 APPENDIX 6

Management policies /guidance to any planning application;
Allocations policy will set out requirements for housing mix. Information provided
will be considered.
ACTION TAKEN:
Noted. Refer to Council response; Policy 16/4 – Griffin, Blackburn; and Policy 18: Housing mix
The Council is supportive of the regeneration of the inner areas of Blackburn and acknowledges that development needs to address the needs
within established communities.
Policy 16/4 confirms that land in Griffin has been allocated for housing. The policy sets out the development considerations that will need to be
taken into account in the development of scheme proposals; reference is included to the Griffin Supplementary Planning Document (adopted July
2011) which provides detailed guidance on the housing mix the Council expects to see on each of the redevelopment sites.
Policy 18 sets out the Council’s requirements for new development to provide a wider choice of homes, in particular high quality family housing to
support its objectives for housing growth.
AFFORDABLE HOUSING
Affordable housing essential in this deprived area.
Measures need to be put in place to stop purchase
by landlords. Need to make provision for decent
families who are trying to buy by providing homes at
a price they can afford.



Please see note above regarding house types/provision of affordables;
Selective Licensing is in place to promote good landlord practices;
When sites come forward for re-development the Council will look at opportunity for
setting up process of nomination rights/eligibility for housing.
ACTION TAKEN:
Noted; refer to Council response. There will be ongoing opportunities for community engagement as scheme proposals are developed. The Council
will pass on these comments to developers and will be encouraging the scheme content to include a housing mix – both house type and tenure –
that meets the needs of the established community.
Page 20 of 120 APPENDIX 6
SERVICES AND INFRASTRUCTURE
Improved bus service is needed.


Council appreciates residents’ need for a convenient connection to surrounding areas
and to local services and facilities;
Demand from increased numbers of residents on this site/together with adjacent
developments may offer the opportunity for an improvement in the local bus service.
ACTION TAKEN:
New bus services will require a customer base in place first. Policy 10 of the Publication edition requires development for uses that are likely to
generate large numbers of trips will only be permitted in locations which are conveniently accessible by existing or proposed public transport
services. The Council will also work with the developer to formulate, implement and monitor a Travel Plan setting out the measures that the
developer, either alone or in conjunction with neighbouring uses, shall adopt to reduce reliance on the use of the private car for journeys to and from
the site.
Developments need to include parks, green spaces
and shops.





Council is grateful for resident’s comments and acknowledges that this information
needs to be taken into account as part individual site assessment and in determining
scheme requirements;
Council is keen to promote sustainable development;
For each proposed development site the Council will prepare a schedule setting out
all development/scheme requirements;
Anticipated the Council will prepare a development brief for this site to inform
discussions with potential developer partners. This will include a requirement for
integrating green infrastructure within scheme proposals. including
provision/integration of open space/green infrastructure and that local facilities such
shops and/or convenient links to similar are made available as part of the scheme
proposals/layout;
These requirements will be secured via the application of Development Management
policies /guidance to any planning application.
ACTION TAKEN:
Policy 40 in the Publication edition requires, where circumstances permit, for all development to be designed to make a positive contribution
Blackburn with Darwen’s green infrastructure.one of the requirements of this policy is for all new residential development to contribute towards the
provision of high quality open space for its residents, either through financial contributions towards improving the quality and/or accessibility of
nearby existing spaces.
Page 21 of 120 APPENDIX 6
ACTION TAKEN:
All comments relating to the following headings have been actioned as part of the general feedback; refer to Appendix 5
SITE ISSUES
GREEN BELT/WILDLIFE/ENVIRONMENT
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
OTHER ISSUES
Page 22 of 120 APPENDIX 6
5. HASLINGDEN ROAD, Blackburn (including Fishmoor and Blackamoor Road)
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
SITE ISSUES
Flooding and drainage are a problem from the
McDermott homes (Whinny Heights) built 3-4 years
ago.



Information/resident concerns have been noted and will be taken into
account in assessing suitability of the site for development and determining
development requirements;
Surface drainage issues are being investigated as part of a series of
technical studies being carried out to support the appraisal of the suitability
of each proposed development site for future house building;
Any particular requests will be set out in a site-specific schedule, which will
confirm all development/scheme requirements including provision for surface
water drainage. The developer will need to demonstrate how these
requirements will be met as an integral part of scheme proposals before any
development can progress.
ACTION TAKEN:
Policy 9 (Development and the Environment) of the Publication edition requires development to demonstrate that it will not be at an
unacceptable risk of flooding. Any development with the potential to create significant amounts of new surface water run-off will be expected to
consider, and wherever possible, implement, options for the management of the surface water at source.
The SFRA identifies that he site is entirely within Flood Zone 1 and has a low risk of surface water flooding, although some localised shallow
ponding is indicated. The allocations policy for the site (16/7) includes the requirement to incorporate appropriate measures to control surface
water run-off.
HOUSING DEVELOPMENT
4.1
United
Utilities
Resubmitted information provided in January 2007 in
response to Call For Sites linked to evidence gathering
for the Council’s Strategic Housing Land Availability
Assessment; relates to 2 parcels of land on west side
Page 23 of 120 APPENDIX 6
of Haslingden Road adjacent to Fishmoor and Guide
Reservoirs. Previous planning consent for a mixed use
development. Landowner considers land suitable as a
residential allocation.
ACTION TAKEN:
Refer to Policy 16/7 Haslingden Road, Blackburn; Policy 16/8 – Blackamoor Road, Blackburn; Policy 45: Major road schemes; and Policies
map
Both of these sites are regarded as strategic growth sites and have been allocated for housing development; the policies set out the
development considerations that need to be taken into account in scheme detailing. It is expected that both sites will be substantially developed
over the next 5 years to 2018.
Policy 45 makes provision for the protection of a future road link (Fishmoor Link Road) across the Blackamoor Road site allocation to improve
connectivity between Blackamoor Road and Roman Road.
HOUSE TYPES
Detached and semi-detached to blend in with existing.




Council has made a note of resident’s comments and will use these to inform
site development requirements;
Council is committed to providing an equitable high quality housing choice
across the borough;
For each proposed development site the Council will prepare a schedule
setting out all development/scheme requirements including provision for
housing mix including affordables for rent and for sale, house types and
specific design standards;;
These requirements will be secured via the application of Development
Management policies /guidance to any planning application.
ACTION TAKEN:
Refer to Policy 8: Development and people; Policy 11: Design; and Policy 18: Housing mix
Policy 18 acknowledges the need for a wider choice of housing to contribute to the Council’s housing growth agenda in particular the need for
high quality family housing. The proposed housing mix will be particular to each site/development and will be influenced by a number of issues
such as site characteristics, local needs and the dynamics of the local housing market. Detached and semi-detached dwellings should be the
main house type in the mix on all suitable sites. Policy 8 sets out the development considerations that need to be taken into account with
regard to the effect of development on people and neighbourhoods and the need for development to make a positive contribution to the
character of the local area.
Policy 11 identifies the design and layout considerations that need to be taken into account in the preparation and construction of all
Page 24 of 120 APPENDIX 6
development schemes. Adopted Supplementary Planning Documents covering design in general and the design of residential development are
already in place.
AFFORDABLE HOUSING
Elsewhere in more appropriate areas


Council agrees that this form of housing may in some cases be better located
nearer to public transport connections/access to jobs. Altogether this is more
likely to be a sustainable option for those residents needing affordable
housing – both to rent and/or to buy;
It will be essential that the affordable housing mix offer a good choice and
quality of home to all. These requirements will be set out in the individual
schedules of site development requirements.
ACTION TAKEN:
Refer to Policy 1: The urban boundary; Policy 12: Developer contributions; and Policy 18: Housing mix
Policy 1 confirms that the urban area is the preferred location for development and for many residents this is the most convenient location near
to existing facilities and transport connections to services and jobs.
All development is required to make a contribution to affordable housing. Policy 18 acknowledges the need for a wider choice of housing to
contribute to the Council’s housing growth and regeneration agenda in particular the need for high quality family housing. It sets out the
Council’s development considerations relating to house type mix and the options for the provision of affordables – on site or elsewhere via a
financial contribution. Policy 12 sets out the approach to developer contributions, which in the first instance will be secured, via a Section 106
agreement.
SERVICES AND INFRASTRUCTURE
Use of land for development would leave residents
without any green recreational space nearby and
would have a detrimental impact on local wildlife. Open
space needs to be preserved for children to play.



Council has noted resident concerns and can understand residents’ worries
that development may have a detrimental impact on their neighbourhood.
One of the key aims of planning is to ensure that this does not happen;
As noted above a site specific schedule of development requirements will be
prepared for each site. In addition to the items already mentioned this will set
out the requirements for open space and children’s play space and if
appropriate the improvement of existing facilities;
With regard to wildlife. Site assessments and Sustainability Appraisal
Page 25 of 120 APPENDIX 6

processes will identify any mitigation measures that may be needed to
protect wildlife and their habitats. These will be included in the schedule of
development requirements;
The developer will need to demonstrate as part of any planning application
how all requirements will be met/integrated within scheme proposals before
development can proceed on site.
ACTION TAKEN:
Policy 40 in the Publication edition requires, where circumstances permit, for all development to be designed to make a positive contribution
Blackburn with Darwen’s green infrastructure. One of the requirements of this policy is retain and enhance existing ecological and landscape
features on the site. The policy also requires all new residential development to contribute towards the provision of high quality open space for
its residents, either through financial contributions towards improving the quality and/or accessibility of nearby existing spaces.
Additionally, Policy 9 does not allow any development to occur which is likely to damage or destroy habitats or harm species of international or
national importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or habitats or species
listed in the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other planning
considerations and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to damage or
destroy habitats or species of local importance unless the harm caused is outweighed by other planning considerations and an appropriate
mitigation strategy can be secured.
HIGHWAYS
Haslingden Road is already busy with traffic from
housing, school, and hospital and motorway junction
generally.

No access from Sullivan Drive as this would create a
rat-run to Roman Road.




Council is grateful for resident’s comments and acknowledges that this
information needs to be taken into account as part of the site assessment;
Capacity on the Haslingden Road corridor is subject to further work including
increasing capacity at ‘pinch points’;
For each proposed development site the Council will prepare a schedule
setting out all development/scheme requirements including highways and site
access. The developer will need to demonstrate how these requirements will
be met as an integral part of scheme proposals before any development can
progress;
A technical assessment of capacity/impact of potential development sites on
local highway network is being carried out to inform site allocations. This will
be used as an evidence base to assist with individual site appraisals and
determining site requirements;
These requirements will be secured via the application of Development
Management policies /guidance to any planning application.
ACTION TAKEN:
Page 26 of 120 APPENDIX 6
The Local Highways Study will assess the current condition and capacity of the local highways network in the Borough and to assess the
impacts of new housing and employment sites in the borough over the Plan period. The allocation policy for the site (16/7) requires that the
development of site will need to contribute towards improvements to local highways network in the locality.
Policy 10 (Accessibility and Transport) of the Publication edition requires development to demonstrate that road safety and the safe, efficient
and convenient movement of all highways users is not prejudiced; appropriate provision is made for vehicular access, off-street servicing and
parking in accordance with the Council’s adopted standards. As a result, any development proposal that came forward on this site would have
to demonstrate how it complies with these requirements. The allocations policy for the site (16/7) states that access to the site is to be obtained
off Haslingden Road.
NEW INFRASTRUCTURE REQUIRED
More local shops


As for the comments above regarding highways. The schedule setting out all
development/scheme requirements will include a requirement for the
provision/integration of additional infrastructure such as local shops,
integration of open space/green infrastructure as needed;
The developer will need to demonstrate that the proposed scheme meets all
requirements before planning consent is granted/scheme can progress. In
some cases the developer may need also to make a contribution to the
provision/enhancement of local facilities and services.
ACTION TAKEN:
The Council recognises the importance of ensuring sufficient services and facilities are available for its residents. Policy 35 within the
Publication edition aims to protect local facilities. However, although the Council can encourage new shops to be developed on site, it is
ultimately a commercial decision.
More school places for pre-school and primary school
children.

We are working with the Education Department to identify the need for and
opportunities to provide additional primary school provision.
ACTION TAKEN:
The Council’s Education Department and Early Years Team have confirmed there are sufficient Primary School and Nursery places to
accommodate development on this site. This will be kept under review.
Page 27 of 120 APPENDIX 6
GREEN BELT/WILDLIFE/ENVIRONMENT
Area is used as a habitat and feeding ground for a
range of birds for e.g. kestrels, swallows and bats.







A number of residents have expressed similar concerns;
Council acknowledges the value/contribution of open space/landscape
setting and the diversity of wildlife to the character and attractiveness of the
borough and to residents’ enjoyment of their local neighbourhood;
Site assessments and Sustainability Appraisal processes will consider the
impact of proposals on wildlife and identify any mitigation measures that may
be needed;
The requirement to make provision for the mitigation measures will be an
identified requirement set out in the site-specific schedule of requirements for
each development site;
The protection of wildlife and associated habitats will be referred to in
Development Management policies and will be a key consideration in the
review of any planning application;
At the planning application stage too there will be opportunities for community
consultation on detailed scheme proposals before any decisions are made;
A developer will need to demonstrate how all the site requirements will be
delivered before development can proceed.
ACTION TAKEN:
Policy 40 in the Publication edition requires, where circumstances permit, for all development to be designed to make a positive contribution
Blackburn with Darwen’s green infrastructure. One of the requirements of this policy is retain and enhance existing ecological and landscape
features on the site.
Additionally, Policy 9 does not allow any development to occur which is likely to damage or destroy habitats or harm species of international or
national importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or habitats or species
listed in the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other planning
considerations and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to damage or
destroy habitats or species of local importance unless the harm caused is outweighed by other planning considerations and an appropriate
mitigation strategy can be secured.
ACTION TAKEN:
All comments relating to the following headings have been collated with the representations covering ‘general feedback’; refer to Appendix 5.
Page 28 of 120 APPENDIX 6
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
OTHER ISSUES
Page 29 of 120 APPENDIX 6
6. ROE LEE, Blackburn
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
SITE ISSUES
Roe Lee Plantation. Previous plans to develop feel through due to
ownership issues and an understanding (instructions in a will) that
the land was to be used for recreation.



Council has noted the information and will bear this in mind in
discussions with developers;
Council owns the majority of the land and does not understand
there to be any restrictive covenants in place that would limit
development;
Council will investigate this in more detail before any development
could take place.
ACTION TAKEN:
Noted - Refer to Council response above.
HOUSING DEVELOPMENT
4.2
Lea Hough
and Co for
landowner/Roe
Lee Farm
Landowner of Roe Lee Farm supports ‘delivery-led’ and ‘urban-led’
options for achieving housing growth and is willing for the farm to
be included in residential allocation. Considers the site is well
located within an established residential area, accessible, would
suit family housing and could be brought forward in the short term.
Availability of the farm site would enable release of adjacent land
for development and improve amenity to existing residents.
ACTION TAKEN:
Refer to Policy 16/3 – Roe Lee, Blackburn.
Page 30 of 120 APPENDIX 6
Policy16/3 confirms that this site has been allocated for housing together with adjoining lands.
Area is in need of low cost housing




Council has made a note of resident’s comments and will use
these to inform site development requirements;
Council is committed to providing an equitable high quality
housing choice across the borough;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including housing mix, house types and design standards;
These requirements will be secured via the application of
Development Management policies /guidance to any planning
application.
ACTION TAKEN:
Noted. The Council is committed to widening its housing offer across the borough and acknowledges this will be influenced locally by a number
of factors including the housing market and local housing needs.
Refer to Policy 16/3 – Roe Lee, Blackburn.; Policy 18: Housing mix
Policy 16/3 sets out the development considerations that will need to be taken into account in the development of scheme proposals for Roe
Lee; this includes a requirement for a comprehensive masterplan to be prepared before planning consent will be considered for development
on any of the individual sites. The masterplan will provide guidance on an appropriate mix of housing to be provided across the whole site; this
will be informed by local housing needs and other Local Plan policies including Policy 18. Policy 18 confirms that the housing offer, both in local
areas and across the borough as a whole is critical to the success of the plan. It acknowledges the need for high quality family housing and
housing that is accessible/affordable to residents.
SERVICES AND INFRASTRUCTURE
Brownhill and Roe Lee shopping areas already oversubscribed with
no parking and inadequate road crossing facilities



The Council has noted resident concerns and will take these into
account if/when sites are brought forward for development in this
part of Blackburn;
In assessing site development requirements the Council will
review the capacity of local infrastructure and service needs. Any
requirements will be incorporated into the site specific schedule of
development requirements referred to above;
In some cases developers may be asked to make a contribution;
Page 31 of 120 APPENDIX 6


In the meantime residents are advised to raise these issues
locally at their Ward Solution meetings;
We will forward the concerns to the Highways Department with a
request they consider any available actions.
ACTION TAKEN:
Noted – See Council comments above.
In terms of any future development in this area, Policy 10 (Accessibility and Transport) of the Publication edition requires development to
demonstrate that road safety and the safe, efficient and convenient movement of all highways users is not prejudiced; appropriate provision is
made for vehicular access, off-street servicing and parking in accordance with the Council’s adopted standards. As a result, these issues must
be addressed for any new development in the borough.
HIGHWAYS
Access would be problematic between railway and dual
carriageway




Council is grateful for resident’s comments and acknowledges
that this information needs to be taken into account as part of the
site assessment;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including highways/footpath new/upgraded and site access. The
developer will need to demonstrate how these requirements will
be met before any development can progress;
An assessment of capacity/impact of potential development sites
on local highway network is being carried out to inform site
allocations. This will be used as an evidence base to assist with
individual site appraisals and determining site requirements;
These requirements will be secured via the application of
Development Management policies /guidance to any planning
application.
ACTION TAKEN:
The allocation policy for the site includes a requirement for a comprehensive masterplan to be prepared for the whole site, plus any additional
land which may become available. This will consider the most appropriate access to the site. The policy does state that the southern section of
the site has existing access onto Campbell Street. The northern section of the site would require an additional signalised junction off
Ramsgreave Drive.
Policy 10 in the Publication edition requires development to demonstrate that, amongst other things, appropriate provision is made for vehicular
Page 32 of 120 APPENDIX 6
access, off-street servicing and parking in accordance with the Council’s adopted standards.
NEW INFRASTRUCTURE REQUIRED
Need to expand local school capacity.


Resident’s comments have been noted and will be used to inform
site development requirements;
We are working closely with the Education Department to identify
the need for and the opportunities to deliver additional school
places.
ACTION TAKEN
The allocation includes a requirement for the development to contribute towards the establishment of a new primary school in north Blackburn.
GREEN BELT/WILDLIFE/ENVIRONMENT
Fields are well used by the community and regarded as a valuable
open space.




A number of residents have expressed similar concerns;
Council acknowledges the value/contribution of open space and
landscape setting to the character and attractiveness of the
borough and to people’s enjoyment of their local area;
Expected that developers will also regard this as an asset to be
enhanced/form an integral part of any development;
Retaining the character of local areas will be referred to in
Development Management policies and will be a key
consideration in the review of any planning application.
ACTION TAKEN:
Policy 40 sets out a requirement for integrating green infrastructure within new development. This requires all development, where
circumstances permit, to be designed to make a positive contribution to Blackburn with Darwen’s green infrastructure. It requires all new
development to contribute to the provision of high quality open space and for functioning ecological networks not to be compromised. In addition,
development should contribute to the restoration, enhancement and connection of natural habitats through the provision of appropriate green
infrastructure.
Site is marsh land. This supports a range of wildlife including
kestrels, owls and deer. There are several ponds with frogs.

Concerns regarding impact on wildlife and wildlife habitats.

Council also values the contribution of wildlife/countryside to
residents and accepts it needs to make every efforts to ensure
this is safeguarded;
Individual site assessments and Sustainability Appraisal
processes will identify any impact and the need for mitigation
Page 33 of 120 APPENDIX 6


measures;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including all mitigation measures that developer’s will have to take
on board in any scheme proposals;
Developer will need to demonstrate with any planning application
that these requirements have been addressed before planning
consent is granted/scheme can proceed.
ACTION TAKEN:
Policy 9 does not allow any development to occur which is likely to damage or destroy habitats or harm species of international or national
importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or habitats or species listed in
the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other planning considerations
and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to damage or destroy habitats or
species of local importance unless the harm caused is outweighed by other planning considerations and an appropriate mitigation strategy can
be secured.
ACTION TAKEN:
All comments relating to the following headings have been collated with the representations covering ‘general feedback’; refer to Appendix 5
AFFORDABLE HOUSING
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
OTHER ISSUES
Page 34 of 120 APPENDIX 6
7. GIB LANE (including land west of Gib Lane and land east of Heys Lane)/SAPPI (including STOCKCLOUGH
LANE)/VOITH/ALBION/MOORGATE/BRIDGE/PIONEER AND ECLIPSE MILLS - Blackburn
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS

COUNCIL RESPONSE
All of the following representations relate to Gib Lane and
surrounding land except if noted otherwise.
SITE ISSUES
Canal and
River Trust
Relates to Sappi. Leeds Liverpool Canal towpath in the vicinity of
the site is in a poor condition and will require significant
improvement to accommodate the likely increased level of usage
by cyclists and pedestrians that would result from the
development of the site.
ACTION TAKEN:
The Sappi site has been identified in the Publication edition as a Development Opportunity (Policy 28). In order to satisfy Policy 10, a major
development at the site will require a Transport Assessment to accompany the planning application, which will consider all impacts on existing
transport systems. Any potential impacts which require intervention / enhancements are to be funded by the developer.
Will development impact on route of Weaver’s Way?
Development will impact on Weaver’s way/Reeler’s Trail
/greenspace corridor through eastern part of site including
Cockridge Wood (also known locally as Bluebell Wood) and
Bunker’s Hill Wood; both woods are designated Local Heritage
Sites.





Yes, this route does cross the site;
Routes through development to the countryside will need to be a
key consideration in scheme proposals/layout;
Public Rights of Way will be protected and integrated within
scheme proposals. There may be some requirement for
realignment as part of the scheme proposals/layout and if needed,
the opportunity for improvements;
The developer will need to demonstrate how established routes will
be integrated and potentially improved, if needed, within scheme
proposals;
This requirement will be delivered via Development Management
policies as part of the planning application process.
ACTION TAKEN:
The Publication edition includes requirements to consider / mitigate impacts on public rights of way which traverse the site (Policy 16/9); to
Page 35 of 120 APPENDIX 6
protect important landscape features such as Cockridge Wood (Policy 16/9); and to enhance access to the countryside (Policy 16/10).
Former quarry on Gib Lane was used as a rubbish tip.
Understand the land on Bunkers Hill is solid rock underneath:
makes significant contribution to run off/flooding

The developer will carry out a full site investigation to assess
ground conditions and to identify any constraints/need for mitigation
and/or particular construction requirements.
ACTION TAKEN:
Policy 8 of the Publication edition requires developers of potentially contaminated land to secure a remediation scheme to ensure that a safe
environment is provided for occupants and does not displace contamination. Policy 9 requires development with the potential to create
significant amounts of new surface water to manage the surface water at source.
HOUSING DEVELOPMENT
2.1/4.2/4.4
JWPC
Limited for
Witton
Estates
Relates to Horden Farm and surrounding land adjacent to Livesey
Branch Road and Broken Stone Road (currently covered by
Saved Local Plan Countryside Policy RA6).
Confirms support for review of the urban boundary to include this
site and allocation of land for residential development for larger
upper market/’executive’ homes. Considers site is within a
stronger market area.
Promotes the ‘delivery-led’ and ‘urban-led’ delivery options as the
most realistic and achievable for getting development early in the
plan period – within the first 5 years.
Regarding site selection criteria – consider delivering on overall
housing objectives should take precedence over location criteria
i.e. deliverability of ‘executive’ homes should be main influence for
site allocations.
Support a mixture of locations to stimulate development.
ACTION TAKEN:
Page 36 of 120 APPENDIX 6
Refer to Policy 16/9 - Land west of Gib Lane, Blackburn.
The policy allocates this site for housing development and sets out the development considerations that will need to be taken into account in the
preparation of scheme proposals. Horden Farm is retained and will need to be sensitively incorporated in the area masterplan and scheme
detailing. Housing delivery will be phased over a number of years, possibly beyond the plan period; early phases – over the next 5 years to 2018
– are expected to provide up to 120 units.
4.1/4.2
Kirkwells
2 sites at Stockclough Lane, Feniscowles (currently covered by
saved Local Plan policies covering Industry and Business area
EC3 and Protected Open Space TRL1); the majority of the site is
on the edge of the urban boundary and is within the West Pennine
Moors.
Seeks the allocation of an existing employment area for housing
development. Considered to be a sustainable medium/long term
development opportunity for housing and suitable for ‘executive’
homes.
Site currently offers low level of employment and limited scope for
redevelopment for employment/ little prospect for
growth/investment.
Existing use regarded as a ‘poor neighbour’ to surrounding
residential development.
Land outside the urban boundary (protected open space) well
positioned to enhance housing scheme and local green
infrastructure.
ACTION TAKEN:
Refer to Policy 28: Development opportunity; Policy 3: The Green Belt; Policy 5: Countryside areas; and Policies Map
Policy 28 confirms the 2 sites referred to have been identifies as a development opportunity and are included within the wider site including
Sappi land at Moulden Brow/Livesey Branch Road. Altogether the site offers the opportunity for a high quality development and is suitable for a
range of uses. The policy notes that potential uses include a mix of commercial space and upper market residential with the distribution of uses
responding to the configuration of the site, accesses and adjacent land uses. An area of protected open space between the 2 development
parcels has been released for appropriate development.
Page 37 of 120 APPENDIX 6
Green Belt (Policy 3) and land in the countryside covered by Policy 5 form the eastern boundary of these sites.
The extent of these areas is shown on the Policies Map.
2.1/4.2/4.4
McAteer
Associates
Ltd for
landowners
of land at Gib
Lane.
Relates to land to the rear of housing fronting Livesey Branch
Road and Gib Lane (land to rear of 393-423 Livesey Branch Road
and 2-42 Gib Lane. Land is currently covered by Saved Local
Plan Countryside Policy RA6 and is adjacent to a Greenspace
Corridor linking with the Leeds Liverpool Canal).
Confirms owner support for extension of urban boundary and
willingness for their land to be allocated for residential
development. Considers the site is appropriate for a mix of
housing including ‘executive’ homes.
Supports delivery of housing growth via a mix of the options
outlined in 4.2.
ACTION TAKEN:
Refer to Policy 16/9 - Land west of Gib Lane, Blackburn.
The policy allocates this site for housing development and sets out the development considerations that will need to be taken into account in the
preparation of scheme proposals.
2.1/4.1/4.2
HOW
Planning LLP
for Aeternum
Capital and
Taylor
Wimpey
Sappi (Star Paper Mill and surrounding land). Site includes land
within Chorley Council area and is covered by a number of saved
Local Plan policies relating to:- Established industry and business (EC3)
- Protected open space (TRL1)
- Development in the rural areas/Green Belt (RA1) and
- County heritage site.
Regarded as a development opportunity for mixed use including
housing and employment. Housing element is seen as the
enabling development for the regeneration of the site/renovation
of the mill for employment activities.
Request for a revision of the urban boundary to include complete
Page 38 of 120 APPENDIX 6
site.
Acknowledge, in principle, that Sappi site would be suitable for
residential development; preference for house type/mix to be
market determined.
Support inclusion of Sappi site in proposed list of ‘delivery-led’
and ‘urban-led’ site options; also consider the site is a
regeneration opportunity and should be included on the
‘regeneration-led’ option. Express caution that regarding sole
development for upper market/’executive’ housing and consider
mix should be market responsive.
Need to ensure deliverable sites are not prevented from coming
forward by onerous phasing policies.
Consider site is deliverable in accordance with NPPF criteria –
available now/sustainably located/reasonable prospect of being
delivered within next 5 years.
Support for development on Sappi
ACTION TAKEN:
Refer to Policy 28: Development opportunities; Policy 38: Greenspace infrastructure; and the Policies Map
Policy 28 confirms this site has been identifies as a development opportunity. The site offers the opportunity for a high quality development and
is suitable for a range of uses. The policy notes that potential uses include a mix of commercial space and upper market residential with the
distribution of uses responding to the configuration of the site, accesses and adjacent land uses. An area of protected open space covered by
Policy 38 is retained within the development site.
Green Belt (Policy 3) and land in the countryside covered by Policy 5 form the eastern boundary of these sites.
The extent of these areas is shown on the Policies Map.
2.2/4.2
HOW
Planning LLP
for HB
Villages and
Bolderstone
Moorgate Mill.
Ask for inner urban boundary to be amended to include this site
as part of ‘regeneration-led’ delivery option and that site is
acknowledged as available/ready to come forward for residential
Page 39 of 120 APPENDIX 6
(Chesterfield)
LLP
development.
ACTION TAKEN:
Planning permission granted October 2012 (planning application reference 10/12/0686) for 20 apartments in 2 blocks and outline for up to 17
houses. Discharge of conditions granted May 2013 (10/12/1189). Work has commenced on site on the housebuilding.
2.1/4.1/4.2
Urban Vision
for
Castleland
Ltd and
landowners
of adjoining
lands in Gib
Lane area.
Relates to land to south of broken Stone Road and 2 parcels of
land in the vicinity of Livesey Branch Road and west of Gib Lane
(currently covered by Saved Local Plan Countryside Policy RA6
and is adjacent to a Greenspace Corridor linking with the Leeds
Liverpool Canal).
Promotes a change to the urban boundary to include this land to
enable housing development to be brought forward.
Presents a case that this land is an attractive and achievable
development opportunity that can secure Council objectives for
housing growth and an improved house mix to include upper
market and ‘executive’ homes on non-Green Belt/potential urban
extension sites as identified in the Core Strategy.
Agrees that elements of each housing delivery option will be
needed over the plan period; this will provide the flexibility to
respond to changes in the market.
ACTION TAKEN:
Refer to policy 16/9: Land west of Gib Lane, Blackburn
Taylor
Land at Buncer Lane would be suitable for housing.
ACTION TAKEN:
Refer to Policy 38: Green Infrastructure.
This site remains protected open space. The Council’s objective is to develop a more connected network of open space.
Page 40 of 120 APPENDIX 6
Suggest alternative sites in open spaces off Roman
Road/brownfield land on Sappi site/Eclipse Mill.

Develop on brownfield sites within inner urban area including
former factory, mill sites and disused shops and houses.
Sites within the urban area including those at Roman Road and
Fishmoor and in Feniscowles will be suitable locations and
considered for potential development over the life of the Local Plan
to 2026.
Support for development on Voith and Eclipse Mill sites
ACTION TAKEN:
Voith – refer to Policy 15: Secondary employment areas and Policies Map.
The map confirms that Policy 15 covers the Voith site; the policy provides for flexibility in the combination of activities across any B1, B2 or B8
use.
Policies Map indicates Eclipse Mill site is suitable for appropriate development.
Have any preliminary site investigations been carried out to
determine whether all sites identified are suitable for
development?
ACTION TAKEN:
Site investigations have not to date been carried out; this will be undertaken to inform the preparation of scheme proposals.
The Council has received information from the owners of these sites which advises that there are no significant site issues that would impact on
being able to bring development forward.
Refer to supporting document ‘Land Allocations Methodology’ which outlines the site information considered in the selection of this site as a
potential allocation.
Changes of level across the site would mean that many new
houses would be in an elevated position in relation to existing
homes; overlooking/loss of privacy would become a problem.
Screening. Ensure development incorporates large trees to
protect privacy and enhance countryside location.
Page 41 of 120 APPENDIX 6
ACTION TAKEN:
Refer to Policy 8: Development and people and Policy 11:Design
Policy 8 recognises that development needs to make a positive contribution to the character and amenity of the local area. One of the
considerations of amenity for both established residents and people occupying the new homes relates to privacy, overlooking and the
relationship between buildings. The developer will be expected to demonstrate that these issues have been satisfactorily addressed.
Policy 11 confirms the requirement for all new development to present a good standard of design. It sets out the broad issues and related
components relating to character/townscape/public realm/movement and legibility/sustainability/diversity and materials and colour that should be
considered and will be reviewed to assess scheme proposals.
Adopted Supplementary Planning Documents covering design in general and the design of residential development are already in place and
cover these issues; ‘Blackburn with Darwen Design Guide Supplementary Planning Document (adopted March 2006) and ‘Residential Design
Guide Supplementary Planning Document (adopted September 2009).
HOUSE TYPES
Preference for larger family detached and semi-detached housing

More detailed studies needed to determine types of housing
needed for e.g. for 55+

Affordable 3 bed+ family homes.
Affordable homes for first time buyers.
Low cost housing would help to reduce the number of private
lettings in the area and enable working people to buy their own
home.



Council has made a note of resident’s comments and will use these
to inform site development requirements;
Council is committed to providing an equitable high quality housing
choice across the borough;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including housing mix, house types and specific design standards;
These requirements will be secured via the application of
Development Management policies /guidance to any planning
application;
As part of the planning application process there will be an
opportunity for public consultation on detailed scheme proposals.
Low cost housing is needed closer to town centre;
“Aspirational” to generate the greatest income for the Council.
Uncertainty regarding the types of housing proposed for e.g. 5
bed affordables?
All types will be required if development goes ahead.
Page 42 of 120 APPENDIX 6
Need for low cost housing as there is no work available.
Need to consider mortgage availability and accessible house
prices when determining house type.
Detached 2/3 bed with gardens
One to three bed properties that are affordable and will meet the
needs of an increasing aging population.
ACTION TAKEN:
Refer to Policy 8: Development and people; Policy 11: Design; and Policy 18: Housing mix
Policy 18 acknowledges the need for a wider choice of housing to contribute to the Council’s housing growth agenda in particular the need for
high quality family housing. The proposed housing mix will be particular to each site/development and will be influenced by a number of issues
such as site characteristics, local needs and the dynamics of the local housing market. Detached and semi-detached dwellings should be the
main house type in the mix on all suitable sites. Policy 8 sets out the development considerations that need to be taken into account with regard
to the effect of development on people and neighbourhoods and the need for development to make a positive contribution to the character of the
local area.
Policy 11 identifies the design and layout considerations that need to be taken into account in the preparation and construction of all
development schemes. Adopted Supplementary Planning Documents covering design in general and the design of residential development are
already in place.
AFFORDABLE HOUSING
Not on site. Preference for affordable housing to be located
elsewhere for e.g. clearance areas, closer to town centre and/or
including renovation of empty houses. Other suggestions include
Accrington and Burnley.
AH is needed and should be located within the urban areas close
to established facilities and services for e.g. rail and bus routes.


Council agrees that this form of housing may in some cases be
better located nearer to public transport connections/access to jobs.
Altogether this is more likely to be a sustainable option for those
residents needing affordable housing – both to rent and/or to buy;
It will be essential that the affordable housing mix offers a good
choice and quality of home to all. These requirements will be set
out in the individual schedules of site development requirements.
Main requirement is for social housing. Priority should be
affordable housing including social housing.
Page 43 of 120 APPENDIX 6
ACTION TAKEN:
Refer to Policy 1: The urban boundary; Policy 12: Developer contributions; and Policy 18: Housing mix
Policy 1 confirms that the urban area is the preferred location for development and for many residents this is the most convenient location near to
existing facilities and transport connections.
All development is required to make a contribution to the provision of affordable housing. Policy 18 acknowledges the need for a wider choice of
housing to contribute to the Council’s housing growth agenda in particular the need for high quality family housing. It sets out the Council’s
development considerations relating to house type mix and the options for the provision of affordables – on site or elsewhere via a financial
contribution. Policy 12 sets out the approach to developer contributions, which in the first instance will be secured, via a Section 106 agreement.
SERVICES AND INFRASTRUCTURE
Local facilities need protection including countryside spaces



Council has noted resident’s comments and can appreciate
resident concerns to protect established facilities and their
countryside setting;
These issues will be addressed in Development Management
policies and applied to any planning applications for future
development;
At the planning application stage there will be opportunities for
further consultation on the scheme details.
ACTION TAKEN:
The allocation of this site includes a requirement for a masterplan to be produced prior to any development taking place. It is envisaged that the
masterplan will include requirements to provide facilities, including shops, on site. Whether a new local shop is developed is, however, a
commercial decision.
The Publication edition recognises that facilities such as small shops, post offices, public houses and community halls are an important part of
life in our towns and rural areas. Policy 35 aims to protect these local facilities and includes a requirement that any proposal for the complete
change of use of buildings identified as being important to the sustainability of the community which it serves, will not be permitted except where
it can be demonstrated that the use is no longer economically viable or required by the local community, and that the use is not capable of being
supported by enabling development or a diversified use.
The allocation policy for the site also includes a requirement for development to be designed so as to minimise the impact of development on the
countryside, and to enhance access to the countryside.
Page 44 of 120 APPENDIX 6
HIGHWAYS
Limited site access

Impact of increased traffic volume and congestion from proposed
housing on existing road network Roads already heavily used,
narrow and congested with number of blind corners – particular
areas of concern:-

-
Around local schools. Congestion linked to school parking
(on Livesey Branch Road) already a problem.;
- At entrance/exits from established housing estates on
Livesey Branch Road;
- On narrow country lanes and through Tockholes;
- Gib Lane already heavily used by cars and large vehicles
including wagons, coaches, horse boxes and vans. Used
as a rat run, particularly at peak times. Narrow in parts;
- Gib Lane/Broken Stone Road is a ‘blind’ junction;
- Junction of Gib Lane/Livesey Branch Road already a
traffic bottle neck;
- Congestion at junction of Bog Height Road with Bolton
Road (at the Golden Cup) and Gib Lane/Livesey Branch
Road;
- Broken Stones Road is busy and narrow – used as a cut
through from the M65 to other parts of the borough;
- Congestion will be exacerbated even more together with
Pleasington Lakes Holiday Home development.
Few stretches of Broken Stone Road have footpaths;


Council has noted residents’ comments and can appreciate the
concerns regarding the potential impact of new development;
A number of technical studies are being carried out to support the
development of the Local Plan. These will form the evidence base
for individual site appraisals and to determine individual site
requirements. The studies relating to existing infrastructure include
investigations to determine: Capacity/impact of potential development sites on local highway
network, and
Flooding and surface water drainage issues.
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for highways and access and surface water
drainage. The developer will need to demonstrate how these
requirements will be met as part of the planning application
process/before any development can progress.
Delivery of these requirements will be secured via application of
Development Management policies/guidance to the consideration
of planning applications.
Close Bog Height Road and make access only. Open up a link
with Jack Walker Way;
Top half of Heys Lane should be connected to Jack Walker Way
to provide a more suitable through road. Block off the end of Bog
Height Road or install speed bumps to slow down the traffic;
Any widening of Broken Stones road would destroy its character;
Page 45 of 120 APPENDIX 6
Poor drainage /flooding for e.g.
-
at bottom of field behind Livesey Branch Road
in field behind Gib Lane West
field at back of St Michael’s Close,
bottom half of Bog Height Road and Oakdale estate,
flooding/run-off Bog Height Road down drive at Sprout
House Farm and Barn;
- existing drains which take water away under the Horden
estate are only just adequate. Regular need for drains to
be unblocked.
- understand the land on Bunkers Hill is solid rock
underneath; makes a significant contribution to runoff/flooding.
Bund in place to prevent flooding behind a number of properties
on Livesey Branch Road,. Further along open flag drain has been
constructed to take water away from the rear of properties on
Livesey Branch Road – drains to access opening on Livesey
Branch Road;
Flag drain takes run of from Cockridge Wood and the fields above
– this drain was the subject of a Lands Tribunal hearing in 2009
when local resident took action following many years of persistent
flooding;
Council’s Drainage Team are familiar with history and remedial
works taken to drains behind Old Gates Drive;
Underground springs. Streams and ponds form in the field behind
properties on Livesey Branch Road after heavy rainfall.
Manhole lifts in Livesey Branch Road during heavy rain.
Experience that developers do not put appropriate drainage in
place in spite of local authority requirements. How will this be
managed? Is there capacity in the existing system?
Concerns that road widening (Gib Lane/Broken Stone Road)
Page 46 of 120 APPENDIX 6
would lead to loss of old woodland.
ACTION TAKEN:
The Local Highways Network will identify any improvements required to the local highways to support new housing and employment
development in the borough. The allocation policy for this site includes a requirement that a contribution will be made towards identified local
highways improvements.
Policy 10 (Accessibility and Transport) of the Publication edition requires development to demonstrate that road safety and the safe, efficient and
convenient movement of all highways users is not prejudiced; appropriate provision is made for vehicular access, off-street servicing and parking
in accordance with the Council’s adopted standards. The allocation policy for the site (16/9) states that access to the site is available off Livesey
Branch Road, Broken Stone Road and Gib Lane.
Policy 9 (Development and the Environment) of the Publication edition requires development to demonstrate that it will not be at an unacceptable
risk of flooding. Any development with the potential to create significant amounts of new surface water run-off will be expected to consider, and
wherever possible, implement, options for the management of the surface water at source. The allocation policy for the site (16/9 & 16/10)
recognises there will be a need for development to incorporate SuDS and “soft” measures to control surface water due to the high water table
and sloping ground on the site.
NEW INFRASTRUCTURE REQUIRED
New shops needed.

New churches will be needed.
Requirement for improved local facilities including leisure facilities
and community centres. However the Council cannot afford to run
the established premises.

Need for activity centres for children; without there is a likelihood
of an increase in anti-social behaviour.
Need for community centres – to encourage community
inclusion/cohesion.

Only one pub in the local area?
-
Additional primary/secondary school places needed. Local
schools are already full/over-subscribed.
-
As for the comments above regarding highways. The schedule
setting out all development/scheme requirements will include a
requirement for the provision/integration of additional infrastructure
such as local shops, medical services and facilities and the
integration of open space/green infrastructure as needed;
The developer will need to demonstrate that the proposed scheme
meets all requirements before planning consent is granted/scheme
can progress. In some cases the developer may also to make a
contribution to the provision/enhancement of local facilities and
services;
In order to identify need and determine opportunities for delivery of
additional provision/improved capacity we are working with: Clinical Commissioning Group (CCG) to on the provision of
additional medical facilities including medical centres/GP surgeries;
Education Department to identify the need for and opportunity to
deliver additional primary school provision.
Page 47 of 120 APPENDIX 6
Additional medical centres/GPs would be needed. Doctors’
surgery on Kings Road has recently closed. Doctors’ surgeries are
full.
Hospitals cannot cope at the moment. How will it cope with
increased demands from additional residents?
Connectivity to employment areas will be important.
ACTION TAKEN:
The allocation policy for the site (16/9 & 16/10) includes a requirement for development to be brought forward in line with a masterplan which will
be approved by the Council prior to any development taking place. It is envisaged this masterplan will include opportunities for new community
facilities.
The Council’s Education department has identified a need for a new primary school in this location. Therefore, the allocation policy for the site
requires a contribution to be made towards the provision of additional primary school capacity. In the first instance this requirement is to be met
by reserving a site of at least 1.6 hectares to enable the building of a new primary school.
The Council is working with the Clinical Commissioning Board (CCG) and NHS England to assess the need for additional GPs and medical
centres in the borough.
GREEN BELT/WILDLIFE/ENVIRONMENT
Wildlife/wildlife habitats in the area need to be protected – deer,
variety of birds including owls, tree creepers, great spotted
woodpeckers and pheasants. Bata are present in the local area
and fly over fields in summer months. Also concerns that native
bluebells are protected/not eliminated.
Abundance of wildlife in the field behind Coronation Avenue.
Protection order is in place for greater crested newts whose
habitat is behind the club (bowling club).
Green Wildlife Corridor (Greenspace Corridor) was originally put
in place/included in policy to connect Witton Park/Leeds-Liverpool
Canal and Cockridge and Bunkers Hill woods through a number of
linking green spaces to enable wildlife to migrate to and from




Council agrees that these are important concerns to many
residents and to their enjoyment of their local area and the
countryside generally. The Council would not want any
development to have a damaging impact on wildlife and the
environment;
This information will be used to inform proposed scheme
requirements;
Site assessment and Sustainability Appraisal processes will
consider impact on wildlife/environment and identify any mitigation
measures that will be needed;
Developers will be expected to demonstrate as part of their
planning application how these measures are to be provided as an
integral part of their scheme before any development can progress
Page 48 of 120 APPENDIX 6
West Pennine Moors. The corridor works well and is an essential
feeding area particularly in the winter months.
ACTION TAKEN:
Policy 40 in the Publication edition requires, where circumstances permit, for all development to be designed to make a positive contribution
Blackburn with Darwen’s green infrastructure. One of the requirements of this policy is retain and enhance existing ecological and landscape
features on the site.
Additionally, Policy 9 does not allow any development to occur which is likely to damage or destroy habitats or harm species of international or
national importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or habitats or species
listed in the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other planning
considerations and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to damage or
destroy habitats or species of local importance unless the harm caused is outweighed by other planning considerations and an appropriate
mitigation strategy can be secured.
The policy also requires all new residential development to contribute towards the provision of high quality open space for its residents, either
through financial contributions towards improving the quality and/or accessibility of nearby existing spaces.
Why have some other green areas not been included in site
allocation options for e.g.in the vicinity of Witton Park?

Emerging Green Belt review concludes that the area around Witton
Park should not be released as this land continues to meet the
requirements of the Green Belt.
ACTION TAKEN:
Noted.
Refer to Policy 3: The Green Belt; Policy 4: Land for development beyond the plan period and the Blackburn section of the Policies Map.
Policy 3 acknowledges that Green Belts are a fundamental element of national planning policy; the NPPF lists the purposes of the Green Belt.
The policy refers to the need for special circumstances to support development in the Green Belt. Reference to the Policies Map shows that the
majority of Witton Park continues to be included in the Green Belt. An area alongside Preston New Road, attached to the northern urban
boundary, has been released for development. Policy 4 confirms that the development of this land take place beyond the plan period i.e. after
2026.
Reference to CPRE feedback on review of the Green Belt
capacity for development. Questioning of timing for review.

The programme for the preparation of the Local Plan has
influenced the timing of the Green Belt review. The study and its
recommendations form part of the evidence base for the Plan.
ACTION TAKEN:
Page 49 of 120 APPENDIX 6
Noted. See Council’s comments provided.
No to development/no to development south of Livesey Branch
Road on designated countryside.
Area to south of Livesey Branch Road should be included within
Green Belt.
Availability of greenfield land/countryside is very limited and
should be saved from development.
Building east of Gib Lane would be on the skyline and would spoil
the countryside.
Residents support inclusion of designated ‘Countryside Area’ into
Green Belt.
Core Strategy’s ‘aspiration for growth’ is not an exceptional case
to justify development in the Green Belt.
ACTION TAKEN:
The Green Belt study recommended changes to the boundary of the Green Belt in this area; the outcome is that parcels of land north of Broken
Stone Road have been released for housing development – refer to the Policies Map and Policies 16/9 and 16/10 which confirms the site
allocations. The policies are complementary and each includes a requirement for the sites to be brought forward via a comprehensive
masterplan, which must be approved prior to any development commencing. The policies set out the development considerations that will need
to be taken into account in the masterplan and in scheme detailing. The development is expected to incorporate a landscape scheme including
the protection of important landscape features, such as the areas of established woodland; minimise the impact of development on the
countryside and to enhance access to the countryside. Developer contributions to infrastructure improvements will be required.
The Adopted Policies Map (Publication version) identifies the area south of Broken Stone Road and the land between Gib Lane and Heys Lane
as Countryside Area (Policy 5). This designation was supported by the Green Belt Review, which advised that the Countryside Area policy
provided sufficient protection to this area.
OTHER ISSUES
Nursing home on Shorrock Lane should be renovated to create


The Council agrees this would make a good housing site.
It may not be possible to renovate the existing building
Page 50 of 120 APPENDIX 6
apartments.

The site it is in a suitable location for a range of development over
the life of the Plan.

The Council’s strategic approach is set out in the Core Strategy. It
proposes a co-ordinated approach across 6 interventions including:
1. Business development
2. Housing
3. Local facilities and services including the town centre
4. Environment
5. Quality of Place
6. Jobs and services.
ACTION TAKEN:
Noted. See Council response.
Need for a comprehensive and joined-up strategy for housing
delivery across the borough which includes the inner urban
sites/re-development of existing property to match needs.
Need a joined up strategy that considers all aspects of the
borough/growth agenda including employment, transport, retail
and the town centre. Need for a strategic masterplan to ensure
mixed development is brought forward in a co-ordinated way.
ACTION TAKEN:
Noted. See Council response - the strategic approach is set out in the Core Strategy. Policies 16/9 – Land west of Gib Lane - and 16/10 – Land
east of Heys Lane - in the Publication edition require a comprehensive masterplans are to be created covering the whole of the area between
Broken Stone Road and the built up area together with the area to the south of Broken Stone Road previously granted planning consent for a
holiday lodge complex.
Confusion regarding the future of the Pleasington Lakes scheme.
Site made a dumping ground by the proposed golf course

The planning permission in place for the Pleasington Lakes scheme
requires the development to be implemented by 18th July 2015.
ACTION TAKEN:
Noted. Planning permission remains in place for the Pleasington Lakes scheme.
Two previous attempts to build west of Gib Lane have been
refused by the Council and supported by a Planning Inspector –
what has changed?
ACTION TAKEN:
Planning applications are considered against the Development Plan in place at the time of the application. The more detailed Publication edition
plan and policies set out the planning framework/direction of change that is needed to achieve the Council’s aspirations for economic growth.
Page 51 of 120 APPENDIX 6
ACTION TAKEN:
All comments relating to the following headings have been collated with the representations covering ‘general feedback’; refer to Appendix 5.
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
Page 52 of 120 APPENDIX 6
8. PARSONAGE ROAD, Blackburn
Issues and
options
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
question
SITE ISSUES
Area has a clay base and is very boggy. Field continually
waterlogged. Flash floods. Field between Belvedere Road and
East Lancs Road are very marshy. Run off from the field has
flooded some properties in Belvedere Road and Balmoral
Avenue. Constant seepage in Parsonage Road and approach
to Knotts Brook Bridge. The bridge floods following heavy rain.



A number of properties in the area have installed pumps.
Council has made a note of residents’ comments and will use these
to inform site development requirements;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for surface water drainage;
Developer will need to demonstrate that these issues have been
addressed in scheme proposals/planning application before
planning consent is granted/development can proceed.
ACTION TAKEN:
Policy 9: Development and the Environment, of the Publication edition, requires development to demonstrate that it will not be at an
unacceptable risk of flooding. Any development with the potential to create significant amounts of new surface water run-off will be expected to
consider, and wherever possible, implement, options for the management of the surface water at source.
The allocations policy for this site (16/1) indicates that the Level 2 SFRA has identified the site is within Flood Zone 1 and largely at low risk of
surface water flooding, although some shallow surface water flooding does occur within the site. United Utilities have indicated that surface
water could be directed to either Knotts Brook or Little Harwood Brook. The development will be required to incorporate SuDS.
Resident in Parsonage Road had deed of easement in field at
side of property for septic tank (refer to response 2 and 8 for
contact details).
Resident in Parsonage Road owns part of the lane next to the
field.


Thank you for these comments. They have been noted and will be
passed onto developers who come forward with an interest in
developing out this site;
The developer will need to ensure that all land ownership issues
have been dealt with before any development can proceed.
Page 53 of 120 APPENDIX 6
Issues and
options
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
question
ACTION TAKEN:
Noted. See Council response.
Trees along left hand side of the field are protected.



These comments have been noted and will be taken into account in
assessing any development proposals/planning application;
The Council expects protected trees to be retained and integrated
within a development layout unless there is a good reason for any
to be removed for example if a tree is diseased and/or dying back;
It is also expected that the developer will regard these features as
an attractive and valuable asset to the proposed scheme.
ACTION TAKEN:
Refer to Policy 9: Development and the environment.
Policy 9 sets out the development considerations relating to trees. With regard to protected trees there is an expectation that these should be
saved and properly incorporated into the scheme layout and design. If this is not achievable, the onus is on the developer to put forward a
robust case to demonstrate the over-riding merits of the scheme. Planning conditions attached to a scheme approval will require replacement
trees to be planted on or near the site.
Impact of development on dam at Parsonage Reservoir?


Council appreciates people’s concerns, has noted information and
will pass this on to developers who come forward with an interest in
developing out this site;
Cannot anticipate that the position of dam will prevent scheme
being brought forward. Any consideration of impact will be
discussed at the planning application stage.


Resident ‘s comments and information has been noted;
National Grid/Electricity North West are aware that the Council is
ACTION TAKEN:
Noted. See Council response.
Refer to Policy 9: development and the environment.
Proximity of pylons/electricity lines running from Balmoral
Road/Belvedere Road/Warrenside Close could be an issue.
Page 54 of 120 APPENDIX 6
Issues and
options
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
question
Area has been targeted by compensation companies

preparing its Local Plan, have been included in previous
consultations and will be consulted on the draft Local Plan. Their
comments/feedback will be incorporated in the schedule of site
requirements prepared by the Council for each potential
development site. The schedule will inform developers of all matters
they need to consider/address as part of the detailing of scheme
proposals;
The developer will need to demonstrate to the Council’s satisfaction
that these matters have been taken into consideration as part of the
scheme delivery before planning consent is granted/any work is
able to progress on site.
ACTION TAKEN:
Refer to Policy 16/1: Parsonage Road
Policy 16/1 requires that any scheme layout take regard of the safety-required distances between overhead lines, the ground and housing.
Planning has been refused in the past because of drainage
issues.


Resident concerns have been noted;
Expected that modern methods of construction will be able to
address and improve any drainage issues on site and enable
development to progress.

Information/concerns have been noted and will be taken into
account in assessing suitability of the site for development and
development requirements;
Public Rights of Way will be protected and integrated within
scheme proposals. There may be some requirement for
realignment as part of the scheme proposals/layout and if needed,
the opportunity for improvements.
ACTION TAKEN:
Noted. See Council response.
Retain footpath connections across the field.

ACTION TAKEN:
Refer to Policy 11: Design; Policy 10 Accessibility and transport and Policy 38: Green infrastructure.
Page 55 of 120 APPENDIX 6
Issues and
options
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
question
2 x12” water main pipes cross the field

Houses on Balmoral Drive are subject to extension restrictions
and must remain as bungalows.

Thank you for the information. This has been noted and will be
taken into account in the detailing of any scheme layout;
Conditions on Parsonage Road will be forwarded to the Council’s
Highway Department.
Parsonage Road itself is in a bad state of repair.
ACTION TAKEN:
Noted. See Council response.
HOUSING DEVELOPMENT
4.2
Janet Dixon
Town
Planners
limited for
owners of
55,
Parsonage
Road,
Blackburn.
Relates to 55 Parsonage Road and the land behind (protected
open space along urban boundary). Makes comparison with
proposed development sites at Blackburn Golf Club, also
protected open space within the urban area, and encourages
allocation of land at Parsonage Road site for upper market
housing. Suggests that impact of loss of open space is
minimal/site should be considered for development before urban
extensions or the development of Green Belt land.
Support the ‘urban-led’ delivery option and propose that this site
should be included in the accompanying schedule of sites.
ACTION TAKEN:
Refer to Policy 38.
Land has been retained as ‘Green Infrastructure on the Adopted Policies Map’ owing to its ecological value.
Page 56 of 120 APPENDIX 6
New housing is needed in the borough. Consider that this is an
area of established retired residents and bungalows. The design
of the new properties should be sympathetic to this.

Consider building some ‘real’ eco homes, which would appeal to
people and establish a different local community.

Unacceptable impact on privacy and local views. New
properties on relatively higher ground will overlook existing and
remove all privacy.

HOUSE TYPES

Council has made a note of resident’s comments and will use
these to inform site development requirements;
Council is committed to providing an equitable high quality housing
choice across the borough;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for housing mix including affordables for rent
and for sale, house types and specific design standards;;
These requirements will be secured via the application of
Development Management policies /guidance to any planning
application. The planning application process includes the
opportunity for public consultation on the detail of scheme
proposals.
Affordable low cost houses.
Smaller properties for young people to rent, not buy and afford
to live in.
Essential that new housing has off-street parking and good
sized gardens for families.
ACTION TAKEN:
Refer to Policy 7:Viable development; Policy 8: Development and people; Policy 10 Accessibility and transport; Policy 11:Design; and Policy
18: Housing mix
Policy 8 acknowledges that growth and development across the borough needs to make a positive contribution to people’s lives and their
neighbourhoods and should not have a poor impact on those elements that influenced residents to live in a particular area. The policy
indicates that development must secure a satisfactory level of amenity for both established and residents and consider the privacy/overlooking
and relationships between buildings.
Policy 11 confirms the requirement for all development to present a good standard of design. It sets out the design considerations that
development will need to meet including an acknowledgment and enhancement of the established character of the area; create an attractive
townscape – with integrated car parking that does not dominate the street scene - and public realm; promote sustainable travel choices;
demonstrate sustainable choices in design, construction and use; and be designed to offer flexible and adaptable living spaces. Policy 10
requires development to make provision for off-street parking.
A key priority for the Council’s housing growth agenda is to broaden the choice of housing in the borough and include in particular high quality
Page 57 of 120 APPENDIX 6
family homes. Policy 18 sets out how this is to be achieved for example through the inclusion of detached and semi-detached housing on
suitable sites and the provision of affordable housing in the housing mix. The housing mix will be particular to each scheme and will be based
on a number of considerations including site characteristics, local housing needs and scheme viability (Policy 8).
SERVICES AND INFRASTRUCTURE
PUBLIC TRANSPORT
Improved/regular bus service needed. Bus service recently
resumed but with minimal service.



Council appreciated residents’ need for convenient connections to
surrounding areas and to local facilities and services;
Resident’s comments will be taken into account as part of the
Council’s consideration of the development requirements for each
site;
Scale of development/cumulative demand from other
developments in the area may offer the opportunity for
improvements in public transport provision.
ACTION TAKEN:
The need for existing and future bus services to be financially sustainable results in difficulty in planning for public transport as a form of
infrastructure. New bus services will require a customer base in place first due to their commercial nature. Policy 10 of the Publication edition
states that development for uses that are likely to generate large numbers of trips will only be permitted in locations which are conveniently
accessible by existing or proposed public transport services. If appropriate, the Council will work with the developer to formulate, implement
and monitor a Travel Plan setting out the measures that the developer, either alone or in conjunction with neighbouring uses, shall adopt to
reduce reliance on the use of the private car for journeys to and from the site.
HIGHWAYS
Existing roads e.g. East Lancashire Road is in a very poor state
of repair. How can the Council consider building new when it
can’t look after the existing properly?
Roads off Bank Hey Lane North, Brownhill Avenue, East Lancs
Road, Balmoral Avenue are not designed for high volumes of
traffic – all are cul-de-sacs. Brownhill junction and surrounding
roads – Whalley New Road and Parsonage Road could not cope
with huge increase in volume of traffic.



Council acknowledges that this information needs to be taken into
account as part of the site assessment;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including highways/footpath new/upgraded, access and surface
water drainage. The developer will need to demonstrate how
these requirements will be met before any development can
progress;
These requirements will be secured via the application of
Page 58 of 120 APPENDIX 6
Development Management policies /guidance to any planning
application.
Poor and/or blocked drainage with sewage coming up in places.
No more traffic. Parsonage Lane already a busy and at peak
times a congested country lane. Some blind spots and traffic
movement is already difficult e.g. turning out from Balmoral
Drive. Excessive speeding along the road despite 30 mph speed
restriction. Balmoral Road will become very dangerous with any
increase in traffic. Belvedere Road is a no-through road – quiet
and safe for children.
Access would be difficult off narrow and steep road from the
reservoir. Very icy in winter.
Poor footpath provision is dangerous for pedestrians. Footpath
ends at 102 Parsonage Road and does not start again until
Sunnybower bus turnaround.
Any new development should be accessed off the dual
carriageway via traffic-controlled junctions.
ACTION TAKEN:
The Local Highways Study will assess the current condition and capacity of the local highways network in the Borough and to assess the
impacts of new housing and employment sites in the borough over the Plan period. The allocation policy for the site states that the scale of
development is likely to require a priority T-junction at Parsonage Road.
NEW INFRASTRUCTURE REQUIRED
No/limited facilities for a large number of dwellings with families

Open space to replace space removed
Shops. Development will be a long way from any local shops

Schools. Both local primary and secondary are oversubscribed.
Pub
Petrol filling station

As for the comments above regarding highways. The schedule
setting out all development/scheme requirements will include a
requirement for the provision/integration of additional
infrastructure such as local shops, as needed;
The developer will need to demonstrate that the proposed
scheme meets all requirements before planning consent is
granted/scheme can progress. In some cases the developer may
need also to make a contribution to the provision/enhancement of
local facilities and services;
We are working with the Education Department to identify the
need for additional school provision;
Page 59 of 120 APPENDIX 6
Doctor
Church

We are working with the Clinical Commissioning Group (CCG) to
identify the need for and the opportunity to provide additional
medical facilities/services.
ACTION TAKEN:
Refer to Policy 32: Local and convenience shops; Policy 35: Protection of local facilities; Policy 40: Integrating green infrastructure with new
development; Policy 16/1 Parsonage Road, Blackburn; and Policy 12: Developer contribution.
The Council recognises the importance of local facilities and services to its residents, the sustainability of neighbourhoods and in the
considerations of relocating to an area. Policy 35 in the Publication edition aims to protect local facilities. However, in terms of provision of
new shops, although the Council can encourage their development, it is ultimately a commercial decision. Policy 32 sets out the approach to
proposals for the provision of new local shops and services.
Policy 40 of the Publication edition requires all new residential development to contribute to the provision of high quality open space for its
residents, either through provision of public open space on site or, where more appropriate, through financial contributions towards improving
the quality and/or accessibility of nearby existing spaces.
Policy 16/1 the allocation policy for this site includes a requirement for a contribution towards the delivery of a new single form entry school in
north Blackburn. Policy 12 sets out the Council’s approach to securing a contribution towards the investment needed in local infrastructure
arising from the impacts of the development.
The Council is working with the Clinical Commissioning Board (CCG) and NHS England to identify requirements for new health infrastructure
within the borough.
GREEN BELT/WILDLIFE/ENVIRONMENT
Abundant wildlife in the field should be protected including
ground nesting birds, foxes, pheasants, deer, owls/barn owls,
lapwings, curlews and marshland birds such as warblers.
ACTION TAKEN:
Policy 9 in the Publication edition does not allow any development to occur which is likely to damage or destroy habitats or harm species of
international or national importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or
habitats or species listed in the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by
other planning considerations and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely
Page 60 of 120 APPENDIX 6
to damage or destroy habitats or species of local importance unless the harm caused is outweighed by other planning considerations and an
appropriate mitigation strategy can be secured.
The allocation policy for the site includes a requirement for appropriate surveys and mitigation measures to be carried out to ensure
development does not have an adverse impact on the ecological value of the brook that runs in close proximity to the north eastern boundary
of the site.
OTHER ISSUES
Confusion regarding term ‘safeguarded’ in earlier consultation
material. Interpreted by some as meaning ‘protected’.

Council apologises for the use of planning jargon and any
confusion. Safeguarded in this context means land being
protected to allow for future development to take place. The
Council no longer uses this term in consultation material to avoid
any further misunderstanding.
ACTION TAKEN:
Noted. See Council response.
The Publication edition Policy 4 refers to land for development beyond the plan period.
Alternative/additional site to consider – redevelopment of
Whitebirk Retail Park.

Council is not able to include this site as an option for
development as it is not within the borough.
ACTION TAKEN:
Noted. See Council response.
Regenerate other areas that are run down. Areas/buildings that
are long term eyesores should be dealt with first before taking
any greenfield land and to improve the look of the town for e.g.:
-
Cob Wall Working Men’s Club;
Land opposite Shadsworth swimming pool;
Infirmary Building;
Lark Hill Health Centre;
Land next to Nissan and Peugeot dealership;
Derelict houses next to Alan Price Automobiles/car
repair garage,
Page 61 of 120 APPENDIX 6
-
Empty business units for e.g. Comet;
Disused playing fields behind houses off Whalley Old
Road, Sunnybower;
- Land between Whalley New Road and Pleckgate Road;
- Land on Pleckgate Road between the school and
Rhodes Avenue/Kingfisher Close and Lammack Road,
and
- Derelict mills.
ACTION TAKEN:
The Council wishes to be proactive in supporting developers to bring forward the delivery of new housing and other developments
It acknowledges that it needs to address a wide range of housing related matters to deliver its agenda for growth and regeneration and that
complementary investment and a toolkit of measures will be needed to encourage both new development and improvements including dealing
with empty properties and areas/buildings that are considered to be eyesores.
Refer to the supporting document ‘Housing Implementation Strategy’ which outlines the Council’s housing delivery toolkit for working
creatively and proactively with developers.
ACTION TAKEN:
All comments s relating to the following headings have been collated with the representations covering ‘general feedback’; refer to Appendix 5.
AFFORDABLE HOUSING
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
Page 62 of 120 APPENDIX 6
9. BROWNHILL DRIVE, Blackburn
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
SITE ISSUES
Retain public right of way a at top of Newington Avenue - contains
semi mature trees, is a valued wildlife refuge, can form a
screen/buffer between the proposed new development and prevent
Newington Avenue becoming a through route (rat run) for drivers
trying to avoid Brownhill roundabout.





Information/concerns have been noted and will be taken into
account in assessing suitability of the site for development and in
identifying individual site development requirements;
Public Rights of Way will be protected and integrated within
scheme proposals. There may be some requirement for
realignment as part of the scheme proposals/layout and if needed,
the opportunity for improvements.
Every effort will be made to retain and integrate mature trees.
Council fully acknowledges the contribution/benefits mature trees
make to a scheme. This is addressed in Development Management
policies;
Developer will be required to demonstrate how these issues –
footpaths and trees – have been successfully addressed in any
planning application before the development can proceed;
Highways design will ensure that rat-runs are not created.
ACTION TAKEN:
The site has not been allocated for housing development in the Publication edition. The Green Belt Study revealed that it could be released from
the Green Belt, but the land is not yet available for development and therefore it has been allocated as land for development beyond the plan
period (Policy 4). Any scheme proposals beyond the plan period would consider the potential impact on public rights of way and wildlife as part of
the development management process.
Page 63 of 120 APPENDIX 6
Policy 10 (Accessibility and Transport) includes a requirement that development must not directly affect any public rights of way, unless the right
of way is maintained or the proposal provides for its replacement by an equally attractive, safe and convenient route.
Land is very wet.

Flooding and drains has been troublesome to local residents.
There was a pond in the fields at one time.

Poorly maintained field drains have caused flooding in fields,
natural springs and collapsed underground watercourses – manmade ‘soughs’.

Council has made a note of resident’s comments and will use these
to inform site development requirements;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for surface water drainage;
Developer will need to demonstrate that these requirements/issues
have been addressed in any planning application before planning
consent is granted/development can proceed.
Drainage problems have created a wetland area for wildlife.
Poor drainage makes use of footpaths across the field very difficult.
ACTION TAKEN:
The site has not been allocated for housing development in the Publication edition. The Green Belt Study revealed that it could be released from
the Green Belt, but the land is not yet available for development and therefore it has been allocated as land for development beyond the plan
period (Policy 4). Any scheme proposals beyond the plan period would consider the management of surface water and avoidance of flooding as
part of the development management process.
Evidence of iron ore leaching out of hillside; may indicate
unmapped mine workings.
Previous consideration of residential use of land to southwest of
Belvedere Road abandoned due to drainage issues




The impact of ground conditions will need to be taken into account
in the assessment of site suitability for development;
Council is not aware of anything in this area that would restrict
development.
Onus will be on the developer to undertake a full site investigation
to identify any constraints/impacts on scheme viability. This
information will be required to accompany any planning application;
Expectation that modern methods of drainage and construction will
be able to address issues which may in the past have impacted on
scheme viability/deliverability and enable development to be
brought forward.
ACTION TAKEN:
The site has not been allocated for housing development in the Publication edition. The Green Belt Study revealed that it could be released from
the Green Belt, but the land is not yet available for development and therefore it has been allocated as land for development beyond the plan
Page 64 of 120 APPENDIX 6
period (Policy 4). Any scheme proposals beyond the plan period would consider Policy 8 of the Publication edition which requires potentially
unstable land to be remediated to provide a safe environment for occupants. Site investigations would be necessary as part of the development
management process.
Regarded as a historic area with several listed properties.



Listed Building are protected;
Essential that any scheme in the vicinity of Listed Buildings is
designed to be sympathetic and enhance the setting;
The schedule of site requirements for each development site will
set out all scheme requirements including, design standards.
ACTION TAKEN:
Any development must consider the impact on heritage assets and / or archaeology, as included in the NPPF and in Policy 39 of the Publication
edition, which requires the avoidance of harm to heritage assets and to archaeological remains and their settings, citing preservation in situ as the
preferred solution.
HOUSING DEVELOPMENT
More housing not wanted.
Concerns that development will be poorly designed; developer will
seek to maximise number of units on site and provide dense low
quality homes;
Concerns that development will be poorly designed; developer will
seek to maximise number of units on site and provide dense low
quality homes.
Concerns regarding loss of open views – will result in a reduced
quality of outlook.
ACTION TAKEN:
Refer to Policy 3; The Green Belt; Policy 4: Development beyond the plan period; Policy 8: Development and people; and Policy 11: Design.
The Green Belt Study recommended that this site could be released from the Green Belt without impacting on the integrity of the Green Belt
(Policy 3). Policy 4 and the area shown on the Policies Map indicates that this site and surrounding land is to be protected for development beyond
the plan period. This reflects the uncertainty regarding the availability of land in this area. In the meantime only development that does not impact
Page 65 of 120 APPENDIX 6
on the comprehensive development of the whole site at a later date will be considered.
Policy 8 seeks to ensure that development brings benefit to people and the elements of local areas that make them attractive to people. Its sets
out how the development will need to respond to a range of issues, which can, in some cases, have an adverse influence on people. A developer
will need to demonstrate in scheme proposals that the development has acknowledged the potential impacts identified in Policy 8 and has
successfully dealt with these. This is complemented by Policy 11, which requires all development to present a good standard of design. The policy
sets out the design considerations that need to be taken into account in scheme preparation and construction; it identifies the elements that the
Council will assess that are acknowledged to influence character/townscape/public realm/movement and legibility/sustainability/diversity and
materials and colour. The developer will be expected to demonstrate how all of these requirements have been addressed in scheme proposals.
Adopted Supplementary Planning Documents on design in general and on the design of residential areas are already in place.
HOUSE TYPES
Not detached.

Detached and semi-detached would best match character of the
local area.

Bungalows
House types should be in line with current market values in all
areas.
Smaller 2 bed low cost or sheltered to enable older people to move
out of larger 3 bed homes – this would create a supply of family
homes. 85% of people in Brownhill are elderly.


Council has made a note of resident’s comments and will use these
to inform site development requirements;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for housing mix including house types and
tenure mix and design standards ;
These requirements will be secured via the application of
Development Management policies /guidance to any planning
application;
Council will work with developers to ensure housing mix addresses
local housing need and its aspirations for growth/wider choice of
housing. This will include consideration of affordable housing which
in turn is influenced by the purchaser’s access to borrowing.
Households’ access to mortgage and ability to afford to live in the
home will be a key determining element in types of homes built.
ACTION TAKEN:
Refer to Policy 8: Development and people; Policy 11: Design; and Policy 18: Housing mix
Policy 18 acknowledges the need for a wider choice of housing to contribute to the Council’s housing growth agenda in particular the need for high
quality family housing. The proposed housing mix will be particular to each site/development and will be influenced by a number of issues such as
site characteristics, local needs and the dynamics of the local housing market. The Council will be supportive of proposals, which provide
affordable, older people’s and supported accommodation. Detached and semi-detached dwellings should be the main house type in the mix on all
Page 66 of 120 APPENDIX 6
suitable sites Policy 8 sets out the development considerations that need to be taken into account with regard to the effect of development on
people and neighbourhoods and the need for development to make a positive contribution to the character of the local area.
The above is complemented by Policy 11, which identifies the design and layout considerations that need to be taken into account in the
preparation and construction of all development schemes. Adopted Supplementary Planning Documents covering design in general and the
design of residential development are already in place.
AFFORDABLE HOUSING
Affordable housing is not compatible with local area. Social housing
should not be mixed with higher priced houses. Brownfield and
reclaimed sites should be used such as Matthew Brown brewery
site together with renovation of empties



Thank you for these comments;
Please refer to the information provided with the ‘general/thematic
responses’ which clarifies the definition of affordable and social
housing. This can include homes for sale and for rent;
The Council is committed to providing sustainable housing
solutions i.e. providing homes for lower salary groups in locations
which offer good connections to jobs and potential employment, to
an equitable quality housing mix/housing offer for all and to
balanced and mixed communities/ community cohesion.
ACTION TAKEN:
Refer to Policy 1: The urban boundary; Policy 12: Developer contributions; and Policy 18: Housing mix
Policy 1 confirms that the urban area is the preferred location for development and for many residents this is the most convenient location near to
existing facilities and transport connections.
All development is required to make a contribution to the provision of affordable housing. Policy 18 acknowledges the need for a wider choice of
housing to contribute to the Council’s housing growth and regeneration agenda in particular the need for high quality family housing. It sets out the
Council’s development considerations relating to house type mix and the options for the provision of affordables – on site or elsewhere via a
financial contribution. Policy 12 sets out the approach to developer contributions, which in the first instance will be secured, via a Section 106
agreement.
Rugby Club would be a perfect site for affordable housing/village
like Buckshaw Village, Chorley.
ACTION TAKEN:
Refer to Policy 16/2 – Land north of Ramsgreave Drive, Blackburn and the Policies Map.
Page 67 of 120 APPENDIX 6
Policy 16/2 and map confirm that 2 parcels of land, including the site of the Rugby Club, have been allocated for housing development. The policy
sets out the development considerations that will need to be taken into account in the preparation of scheme proposals.
SERVICES AND INFRASTRUCTURE
PUBLIC TRANSPORT
Better bus service will be needed.


Resident’s comments will be taken into account as part of the
Council’s consideration of the development requirements for each
site;
Scale of development/cumulative demand from other developments
in the area may offer the opportunity for improvements in public
transport provision.
ACTION TAKEN:
The need for existing and future bus services to be financially sustainable results in difficulty in planning for public transport as a form of
infrastructure. New bus services will require a customer base in place first due to its commercial nature. Policy 10 of the Publication edition states
that development for uses that are likely to generate large numbers of trips will only be permitted in locations which are conveniently accessible by
existing or proposed public transport services. The Council will also work with the developer to formulate, implement and monitor a Travel Plan
setting out the measures that the developer, either alone or in conjunction with neighbouring uses, shall adopt to reduce reliance on the use of the
private car for journeys to and from the site.
HIGHWAYS
Access would be problematic. Access may be difficult. Access to
the north via Parsonage Road – this route already overly busy for a
country lane and used an alternative route between Blackburn and
the Ribble Valley. To northwest – narrow estate roads and many
have been closed off to prevent rat runs. To the south via Emerald
Avenue would destroy the wetland and wildlife.

Constant run off flows down Bank Hey Lane North; creates
dangerous icy conditions in winter.

Surface water run-off builds up behind embankment on Brownhill
Drive embankment. May have been caused by building and


Council acknowledges that this information needs to be taken into
account as part of the site assessment;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including highways, access and surface water drainage. The
developer will need to demonstrate how these requirements will be
met before any development can progress;
Developer will need to carry out a full site investigation to determine
any constraints and/or mitigation works needed to enable the
development to progress. This information will be requested as part
of any planning application;
These requirements will be secured via the application of
Page 68 of 120 APPENDIX 6
widening of the bypass.
Development Management policies /guidance to any planning
application.
Drainage problems extend beyond the bypass and cause flooding
in Blackburn Cemetery and on the Pearl Street housing estate.
Brownhill roundabout very congested already at peak times
Increased housing would aggravate traffic congestion particularly at
Parsonage Road/Whalley New Road traffic lights.
ACTION TAKEN:
The Local Highways Study will assess the current condition and capacity of the local highways network in the Borough and to assess the impacts
of new housing and employment sites in the borough over the Plan period. It may be necessary, if development comes forward on the site, for a
contribution to be made towards any identified local highway improvements required.
Policy 10 (Accessibility and Transport) of the Publication edition requires development to demonstrate that road safety and the safe, efficient and
convenient movement of all highways users is not prejudiced; appropriate provision is made for vehicular access, off-street servicing and parking
in accordance with the Council’s adopted standards. As a result, any development proposal that came forward on this site would have to
demonstrate how it complies with these requirements.
Policy 9 (Development and the Environment) of the Publication edition requires development to demonstrate that it will not be at an unacceptable
risk of flooding. Any development with the potential to create significant amounts of new surface water run-off will be expected to consider, and
wherever possible, implement, options for the management of the surface water at source.
EDUCATION
Schools including new primary school. No schools to north of site
and 4 local schools are over-subscribed.


Council appreciates this is a major concern for many families;
We are working with the Education Department to identify the need
for additional primary school provision
ACTION TAKEN:
There will be a requirement for a new single entry Primary school to support new housing planned for in the north of Blackburn. If the site were to
be developed, the Council may require a contribution towards this.
NEW INFRASTRUCTURE REQUIRED
Shops/local shops
Doctor/medical centre

As for the comments above regarding highways. The schedule
setting out all development/scheme requirements will include a
requirement for the provision/integration of additional infrastructure
Page 69 of 120 APPENDIX 6


such as local shops, primary school places and health facilities as
needed;
The developer will need to demonstrate that the proposed scheme
meets all requirements before planning consent is granted/scheme
can progress. In some cases the developer may need also to make
a contribution to the provision/enhancement of local facilities and
services;
We are working with the Clinical Commissioning Group (CCG) to
identify the need for and the opportunity to provide additional
medical facilities.
ACTION TAKEN:
The Publication edition recognises that facilities such as small shops, post offices, public houses and community halls are an important part of life
in our towns and rural areas. Policy 35 within the Publication edition aims to protect these local facilities and includes a requirements that any
proposal for the complete change of use of buildings identified as being important to the sustainability of the community which it serves, will not be
permitted except where it can be demonstrated that the use is no longer economically viable or required by the local community, and that the use
is not capable of being supported by enabling development or a diversified use. If a development proposal comes forward on the site the Council
may look to secure provision of facilities, if appropriate on site, or a contribution towards new facilities.
The Council is working with the Clinical Commissioning Board (CCG) and NHS England to identify requirements for new health infrastructure
within the borough.
GREEN BELT/WILDLIFE/ENVIRONMENT
Protect wetland area and associated wildlife. Site forms part of
wildlife corridor. Abundant wildlife needs to be protected – Roe deer
and wide variety of birds including pheasants and sparrow hawks.
ACTION TAKEN:
Policy 40 in the Publication edition requires, where circumstances permit, for all development to be designed to make a positive contribution
Blackburn with Darwen’s green infrastructure. One of the requirements of this policy is retain and enhance existing ecological and landscape
features on the site. Additionally, Policy 9 does not allow any development to occur which is likely to damage or destroy habitats or harm species
of international or national importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or
habitats or species listed in the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other
planning considerations and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to
damage or destroy habitats or species of local importance unless the harm caused is outweighed by other planning considerations and an
Page 70 of 120 APPENDIX 6
appropriate mitigation strategy can be secured.
Do not give up/sacrifice any Green Belt land. Questioning of
whether development on green field sites is right and moral
approach by the Council especially considering potential impact on
Green Belt. Priority should be given to brownfield sites/town centre
areas where regeneration and investment has already taken place.
Council should stake the opportunity to provide high quality,
spacious, well designed eco-friendly homes.
ACTION TAKEN:
The site has not been allocated for housing development in the Publication edition. The Green Belt Study revealed that it could be released from
the Green Belt, but the land is not yet available for development and therefore it has been allocated as land for development beyond the plan
period (Policy 4).
Preference for agricultural and recreational uses.
ACTION TAKEN:
The site has not been allocated for housing development in the Publication edition. The Green Belt Study revealed that it could be released from
the Green Belt, but the land is not yet available for development and therefore it has been allocated as land for development beyond the plan
period (Policy 4). Any scheme proposals beyond the plan period would be designed to minimise the impact of development on the countryside,
and to enhance access to the countryside.
Proximity to site offers easy access into countryside for local people
and visitors
ACTION TAKEN:
The site has not been allocated for housing development in the Publication edition. The Green Belt Study revealed that it could be released from
the Green Belt, but the land is not yet available for development and therefore it has been allocated as land for development beyond the plan
period (Policy 4). Any scheme proposals beyond the plan period would be designed to minimise the impact of development on the countryside,
and to enhance access to the countryside.
Majority of residents moved here from elsewhere in town for better
quality of life close to countryside and green field outlook.
ACTION TAKEN:
Page 71 of 120 APPENDIX 6
Loss of a view is not a planning consideration. The site has not been allocated for housing development in the Publication edition. The Green Belt
Study revealed that it could be released from the Green Belt, but the land is not yet available for development and therefore it has been allocated
as land for development beyond the plan period (Policy 4). Any scheme proposals beyond the plan period would be designed to minimise the
impact of development on the countryside, and to enhance access to the countryside.
ACTION TAKEN:
All comments relating to the following headings have been collated with the representations covering ‘general feedback’; refer to Appendix 5.
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
OTHER ISSUES
Page 72 of 120 APPENDIX 6
10. BLACKBURN RUFC and LAND NORTH OF RAMSGREAVE DRIVE (including Yew Tree Drive and Preston New Road), Blackburn
Issues and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
SITE ISSUES
Flooding

Drainage of site is poor. Boggy areas include: -

-
-
Slope facing railway between Ramsgreave Drive and the
footpath leading to Whalley New Road to schools at
Wilworth;
Below Campbell Court. Area is rarely passable and a
wetland with abundant wildlife has established, and;
Low lying areas adjacent to Preston New Road are often
under water following heavy rainfalls. Concerns that
flooding would extend to properties on Wyfordby Avenue.
Numerous underground watercourses cross the area and randomly
rise to the surface. At least one major sewer and a water main
cross the land, which have disrupted these watercourses.


Council has made a note of resident’s comments and will use
these to inform site development requirements;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for surface water drainage
With regard to the wetland area. The site assessment process
will consider the contribution of this area to local wildlife and the
impact of development and identify any mitigation measures that
may be needed. These requirements will be incorporated within
the schedule of site development requirements;
Developer will need to demonstrate that these issues have been
addressed in any planning application before planning consent is
granted/development can proceed.
Concerns that flooding would be displaced elsewhere.
ACTION TAKEN:
Part of the site has been allocated for housing within the Publication edition, and part of it will remain in the Green Belt as a result of the Green
Belt Study. The allocation requires the preparation of a Masterplan; provision of Sustainable Drainage Systems and the incorporation of
measures to control surface water runoff, flood risk and the consequences of blockages in the culvert. If a planning application is received,
residents adjoining the site will be consulted, and Policy 9 of the Publication edition requires development to demonstrate that it will not be at an
unacceptable risk of flooding, or increase the level of risk elsewhere. Developers will have to comply with easement requirements in the case
of public sewers.
Page 73 of 120 APPENDIX 6
Mature trees need to be protected. Avenues of protected trees on
Preston New Road site.




These comments have been noted and will be taken into account
in assessing any development proposals/planning application;
Council acknowledges the contribution of mature trees to
enhancing development schemes and resident enjoyment of their
local area;
The Council expects protected trees to be retained and integrated
within development layout proposals unless there is a good
reason for any to be removed for example if a tree is diseased
and/or dying back;
Every effort will be made to protect mature trees during
construction.
ACTION TAKEN:
Policy 9 in the Publication edition expects development to incorporate existing trees into the design and layout, and states that the loss of
protected trees will only be granted where it would be in the interests of good arboricultural practice or the desirability of the development
outweighs the amenity and / or nature conservation value of the trees. The policy also requires replacement trees to be provided if any are lost;
and the consideration of making Tree Preservation Orders to ensure that due consideration is given to the importance of the trees in the
planning process.
Roman Road that runs near to site needs to be protected.


Similar to the approach above regarding mature/protected trees;
All protected features will be retained, protected and where
possible integrated within scheme proposals.
ACTION TAKEN:
The protection of archaeology is included in Policy 39 of the Publication edition, which requires the avoidance of harm to archaeological remains
and their settings, citing preservation in situ as the preferred solution.
Land has been used as common land for at least 30 years. Does
 Thank you for these comments – the information has been noted
this offer any established use/protection?
and the Council acknowledges the value of access to the
countryside;
 The Council does not consider there to be a case for an
established protection of this land. However the Council will
investigate the status of any land before development
progresses.
ACTION TAKEN:
Noted. The Council does not consider there to be a case for an established protection of the land. The public right of way, which runs around
the edge of the site, is to be retained and enhanced (according to the housing allocation Policy 16/2 of the Publication edition).
Page 74 of 120 APPENDIX 6
Several established rights of way cross the site and a network of
established paths.

Preston New Road site is crossed by ancient footpaths that provide
links from Beardwood up to Billinge Wood and the Weaver’s trail.
Public footpath 54 crosses Preston New Road site. Previous
Inspector’s report confirmed there was no justification for re-routing
this public footpath for development; development adjoining
footpath would unacceptable harm the character and appearance
of surroundings and conflict with Local Plan policies.

Information/concerns have been noted and will be taken into
account in assessing suitability of site /constraints to
development and development requirements;
Public Rights of Way will be protected and integrated within
scheme proposals. There may be some requirement for
realignment as part of the scheme proposals/layout and if
needed, the opportunity for improvements.
ACTION TAKEN:
Part of the site (north of Ramsgreave Drive) has been allocated for housing within the Publication edition, and part of it will remain in the Green
Belt as a result of the Green Belt Study. The public right of way, which runs around the edge of the site, is to be retained and enhanced
(according to the housing allocation Policy 16/2 of the Publication edition).
Concerns children would not be able to travel to replacement club.

Whilst this is not an issue for the Local Plan the Council can
understand people’s concerns and will bear this in mind in
discussions with the Rugby Club.

Council agrees with these concerns and can confirm this would
be a key consideration in the review of any scheme proposals;
As with similar issues raised above regarding the need to protect
valuable assets that make a significant contribution to both the
attractiveness and people’s use of an area.
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including features that need to be protected/retained/integrated
within scheme proposals. The developer will need to demonstrate
how these requirements will be met before any development can
progress;
These requirements will be secured via the application of
Development Management policies /guidance to any planning
application.
ACTION TAKEN:
Noted. See Council response.
Development would destroy most important gateway to Blackburn
town centre – this would detract from overall attractiveness of
Blackburn for visitors, commuters and businesses and reduce the
Council’s revenues in the long term.



Page 75 of 120 APPENDIX 6
ACTION TAKEN:
The Preston New Road site has not been allocated for housing development in the Publication edition. The Green Belt Study recommended
that it could be released from the Green Belt and therefore it has been allocated as land for development beyond the plan period (Policy 4).
Any scheme proposals beyond the plan period would consider the potential impact on this gateway site and subsequent implications.
HOUSING DEVELOPMENT
4.2
Blackburn
Rugby
Union
Football
Club
(BRUFC)
and Jones
Lang
LaSalle/Lea
Hough
Landowners support ‘delivery-led’ approach to housing growth and
delivery of executive housing. In agreement/encourage early
release of land north of Ramsgreave Drive/BRUFC land for
residential use/ upper market development early in the plan period.
Intend to promote release of land from the Green Belt to support
land assembly and housing delivery against test identified in the
Core Strategy.
ACTION TAKEN:
Refer to Policy 16/2 – Land north of Ramsgreave Drive, Blackburn.
Policy confirms two parcels of land that have been identified as strategic sites and have been allocated for housing; it sets out the development
considerations that will need to be taken into account in preparing proposals for an acceptable scheme. The Plan anticipates the development
will be delivered within the next 5 years, by March 2018.
Due consideration needs to be given to character and setting of
established homes for e.g. cottage housing on Lammack Road.
Development in the ‘bowl’ would be out of keeping with the local
area and spoil the rural character. Position of established, mature
trees and topography/changes in level likely to be challenging for
development
Challenge that perceived densities would not enhance character of
local area (contrary to saved Local Plan policies).
Page 76 of 120 APPENDIX 6
ACTION TAKEN:
Refer to Policy 9: Development and the environment; Policy 11: Design; and Policy 16/2 – Land north of Ramsgreave Drive
Policy 8 states that all development must make a positive contribution to the character of the local area. This is complemented by Policy 11,
which requires all development to present a good standard of design. The policy sets out the design considerations that need to be taken into
account in scheme preparation and construction identifies the elements that it will assess that are acknowledged to influence
character/townscape/public realm/movement and legibility/sustainability/diversity and materials and colour. The developer will be expected to
demonstrate how all of these have been addressed in scheme proposals.
Policy 16/2 indicates that the development should be based on a housing density of 15.6 dwellings per hectare. This is regarded an appropriate
density for attractive family housing in this location.
The Council acknowledges that local residents do have issues of concern relating to this allocation and will ensure that there are opportunities
for community engagement with the preparation of scheme details.
HOUSE TYPES
Mixed scheme including larger 3 bed homes and smaller homes for
young professionals. Important to establish a mixed community


Affordable housing is needed.

Detached and semi-detached.
New 4 bed detached executive homes are not what is needed.
More beneficial for the town/town centre brownfield sites to be
regenerated via development of low cost family homes within
walking distance of bus/train connections. Enabling people/first time
buyers to purchase property would encourage residents to work in
town/locally. Considered a more sustainable solution.

Council has made a note of resident’s comments and will use
these to inform site development requirements;
Council is committed to providing an equitable high quality
housing choice across the borough;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for housing mix including affordables for rent
and for sale, house types and specific design standards;
These requirements will be secured via the application of
Development Management policies /guidance to any planning
application.
No semi-detached, large 3- bed or small 2 bed houses preferred.
Bungalows are needed.
ACTION TAKEN:
Refer to Policy 16/2 – Land north of Ramsgreave Drive, Blackburn; Policy 12: Developer contributions; and Policy 18: Housing mix.
Page 77 of 120 APPENDIX 6
Policy 16/2 sets out the development considerations that need to be taken into account in scheme delivery; this includes a requirement that the
development across the site should complement the surrounding established residential areas by providing a wider choice of housing to meet
local needs. Policy 18 complements this; it acknowledges the importance of a wider choice of housing to the achievement of the Council’s
housing growth agenda in particular good quality family housing. The policy requires detached and semi-detached homes to be the primary
element on sites where this can be accommodated and where it complements the character of the local area. Policy 18 also deals with
affordable housing and confirms the delivery options – on site as part of a mix of family housing or via a financial contribution. Policy 12 covers
the mechanism for securing the financial contribution.
SERVICES AND INFRASTRUCTURE
Council should be protecting its sports activities.
ACTION TAKEN:
The Council is working with consultants to produce a Playing Pitch Strategy which assess the supply and demand for sports pitches (football,
rugby, hockey, cricket & bowls) over the Plan period. The Council recognises the importance of ensuring there is adequate provision of sports
facilities for residents and as a result, the requirements of this allocated site includes the caveat that the Rugby Club cannot be developed unless
and until the Club has relocated within Blackburn with Darwen.
HIGHWAYS

Surrounding road would become very busy.
Concerns of added congestion for e.g. on Pleckgate and Lammack
Road/on Preston New Road at peak times/at Brownhill roundabout.
Worries of exhaust pollution from stationary traffic to local residents
and pedestrians.
Vehicular access would be difficult. No established vehicular
access to the site: -


Council is grateful for resident’s comments and acknowledges that
this information needs to be taken into account as part of the
assessment of the site’s suitability for development;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including highways and site access. The developer will need to
demonstrate how these requirements will be met before any
development can progress;
These requirements will be secured via the application of
Development Management policies /guidance to any planning
application.
Unmade track from Higher Wilworth would not support
regular traffic;
Railway line (Clitheroe railway line) forms a barrier along
the length of one side.
Access from Roe Lee Mill site may be possible – already
have traffic problems;
Page 78 of 120 APPENDIX 6
-
Additional access point off Ramsgreave Drive would
seriously impact on an already congested road particularly
at peak times.
Increased noise and environmental pollution
ACTION TAKEN:
The Local Highways Network will identify any improvements required to the local highways to support new housing and employment
development in the borough. The allocation policy for this site includes a requirement that a contribution will be made towards identified local
highways improvements.
Policy 10 (Accessibility and Transport) of the Publication edition requires development to demonstrate that road safety and the safe, efficient and
convenient movement of all highways users is not prejudiced; appropriate provision is made for vehicular access, off-street servicing and parking
in accordance with the Council’s adopted standards. The allocation policy for the site (16/2) highlights that in order to reduce the number of
additional junctions required and to minimise the impact of development on the free flow of traffic, the two development parcels (east of Barker
Lane and west of Barker Lane) are each to have only one point of access onto the A6119.
EDUCATION
School provision is over capacity. How will this be addressed in the
north -western areas of Blackburn where significant increase in
family housing is planned?
ACTION TAKEN:
The allocation policy for this site includes a requirement that the developer makes land available for a new primary school, in addition to a
suitable contribution towards its construction.
HEALTH
Concern regarding impact of loss of open space on health
Loss of sporting facility. Protect sporting facilities to safeguard
health and well-being.
Noise. Increased noise would not be welcome.
ACTION TAKEN:
Page 79 of 120 APPENDIX 6
Policy 40 in the Publication edition requires all new residential development to contribute towards the provision of high quality open space for its
residents, either through provision of public open space on site or, where more appropriate, through financial contributions towards improving the
quality and/or accessibility of nearby existing spaces.
The Council is working with consultants to produce a Playing Pitch Strategy which assess the supply and demand for sports pitches (football,
rugby, hockey, cricket & bowls) over the Plan period. The Council recognises the importance of ensuring there is adequate provision of sports
facilities for residents and as a result, the requirements of this allocated site includes the caveat that the Rugby Club cannot be developed unless
and until the Club has relocated within Blackburn with Darwen.
Policy 8 of the Publication edition requires all development to secure a satisfactory level of amenity (which includes noise) and safety for
surrounding uses and for occupants or users of the development itself.
NEW INFRASTRUCTURE REQUIRED



As for the comments above regarding highways. The schedule
setting out all development/scheme requirements will include a
requirement for the provision/integration of additional
infrastructure such as local shops, medical facilities and the
integration of open space as needed;
The developer will need to demonstrate that the proposed scheme
meets all requirements before planning consent is
granted/scheme can progress. In some cases the developer may
need also to make a contribution to the provision/enhancement of
local facilities and services;
In addition, as noted below
ACTION TAKEN:
See previous comments.
New/extended schools. Existing primary schools are full.

We are working with the Education Department to identify the
need for additional primary school places.

We are working with the Clinical Commissioning Group (CCG) to
identify the need for and the opportunity to provide additional
medical facilities/services;
ACTION TAKEN:
See previous comments
GP services/Hospital
ACTION TAKEN:
The Council is working with the Clinical Commissioning Group (CCG) and NHS England to identify the needs for additional GP services.
Page 80 of 120 APPENDIX 6
Open space within the new housing. Open space for children to
play. Space to walk dogs.

The site schedule will set out requirements for additional
infrastructure including open space/green infrastructure;
ACTION TAKEN:
Policy 40 in the Publication edition requires all new residential development to contribute towards the provision of high quality open space for its
residents, either through provision of public open space on site or, where more appropriate, through financial contributions towards improving the
quality and/or accessibility of nearby existing spaces.
Additional bus services. Improved bus service needed. Only 1
bus/hour to town from Ramsgreave Drive at the moment.

Demand from increased numbers of residents may present an
opportunity for an improvement in the local bus service;
ACTION TAKEN:
The need for existing and future bus services to be financially sustainable results in difficulty in planning for public transport as a form of
infrastructure. New bus services will require a customer base in place first due to its commercial nature. Policy 10 of the Publication edition
requires development for uses that are likely to generate large numbers of trips will only be permitted in locations which are conveniently
accessible by existing or proposed public transport services. The Council will also work with the developer to formulate, implement and monitor a
Travel Plan setting out the measures that the developer, either alone or in conjunction with neighbouring uses, shall adopt to reduce reliance on
the use of the private car for journeys to and from the site.
New rugby club

It is expected the Club will relocate elsewhere within the borough;
ACTION TAKEN:
The Council is working with consultants to produce a Playing Pitch Strategy which assess the supply and demand for sports pitches (football,
rugby, hockey, cricket & bowls) over the Plan period. The Council recognises the importance of ensuring there is an adequate provision of sports
facilities for residents and as a result, the requirements of this allocated site includes the caveat that the Rugby Club cannot be developed unless
and until the club has relocated within Blackburn with Darwen.
Easing congestion through Brownhill and means to cross the dual
carriageway is needed. A number of accidents have occurred at top
of Barker Lane.
Connections are needed to provide people living in new houses to
access schools, shops and all services.
Improved road network



Council agrees with the need for good connections. This is a key
theme running through the delivery of a number of the Core
Strategy interventions;
The schedule setting out all development/scheme requirements
will include a requirement for the improvements to the local road
network;
An assessment of capacity/impact of potential development sites
on local highway network is being carried out to inform site
allocations. This will be used as an evidence base to support
Page 81 of 120 APPENDIX 6
individual site appraisals and to inform individual site
requirements.
ACTION TAKEN:
The Local Highways Network study will identify any improvements required to the local highways to support new housing and employment
development in the borough. The allocation policy for this site (Policy 16/2) includes a requirement that a contribution will be made towards
identified local highways improvements.
GREEN BELT/WILDLIFE/ENVIRONMENT
4.1
Lea Hough
Landowner support for urban extension/amendment to Green Belt
boundary to include land north of Ramsgreave Drive within the
urban boundary. Consider the release of this land would have a
limited impact on the function of the Green Belt and would enable
delivery of Core Strategy objectives relating housing growth and
investment.
ACTION TAKEN:
The land north of Ramsgreave Drive has been allocated for new housing development, as shown on the Adopted Policies Map (Publication
edition).
No support for building in the Green Belt/new homes on green
fields. Protect the Green Belt. Land to west of Preston New Road
provides a valuable green gateway – in terms of visual quality and
openness - into the town.
ACTION TAKEN:
Part of the site has been allocated for housing within the Publication edition, and part of it will remain in the Green Belt as a result of the Green
Belt Study. The allocation requires the preparation of a Masterplan which will ensure an attractive scheme is developed that is sympathetic to
the local area and character. It will provide a rural transition zone between the development and the wider rural landscape to the north, including
the establishment of a robust boundary for the Green belt through landscaping and planting. It also requires the development to be supported by
a landscape and green infrastructure framework incorporating perimeter woodland planting and on site open space incorporating formal and
informal play. The development will be required to utilise important key vistas into the adjoining open countryside, providing visual linkages to
Mellor Ridge.
Policy 40 in the Publication edition requires, where circumstances permit, for all development to be designed to make a positive contribution
Blackburn with Darwen’s green infrastructure. One of the requirements of this policy is retain and enhance existing ecological and landscape
Page 82 of 120 APPENDIX 6
features on the site. The policy also requires all new residential development to contribute towards the provision of high quality open space for
its residents, either through financial contributions towards improving the quality and/or accessibility of nearby existing spaces.
The Publication edition includes a policy on the Green Belt (Policy 3) and states that planning permission will not be granted, except in very
special circumstances or where another policy in the Local Plan specifically supports a proposal, for the construction of new buildings, other than
for the purposes of agriculture, forestry, outdoor sport and recreation facilities, cemeteries and for other appropriate uses. Additionally, the policy
states that development in the Green Belt will only be granted planning permission where it is demonstrated that it will preserve the openness of
the Green Belt and will not give rise to a conflict with the purposes of including land in it.
Wildlife in surrounding area should be protected. Abundant wildlife
(both Ramsgreave Drive area and PNR) including a number of
protected and threatened species including bats, lapwings, owls
and kestrels. Roe deer shelter in the scrub above the boggy area
near Campbell Court.
Much needed open space in an increasingly urbanised area.
ACTION TAKEN:
Policy 40 in the Publication edition requires, where circumstances permit, for all development to be designed to make a positive contribution
Blackburn with Darwen’s green infrastructure. One of the requirements of this policy is retain and enhance existing ecological and landscape
features on the site. The policy also requires all new residential development to contribute towards the provision of high quality open space for
its residents, either through financial contributions towards improving the quality and/or accessibility of nearby existing spaces.
Additionally, Policy 9 does not allow any development to occur which is likely to damage or destroy habitats or harm species of international or
national importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or habitats or species
listed in the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other planning
considerations and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to damage or
destroy habitats or species of local importance unless the harm caused is outweighed by other planning considerations and an appropriate
mitigation strategy can be secured.
OTHER ISSUES
Request for residents to be involved in Environmental Impact
Assessment

An assessment of environmental matters/issues and any
potential impact from development will be will be assessed as part
of the Sustainability Appraisal (SA) The SA will be published
alongside the draft Local Plan’ as part of the next round of
consultations.
Page 83 of 120 APPENDIX 6
ACTION TAKEN:
The Sustainability Appraisal is to be published alongside the Publication edition. Environmental Impact Assessment regulations will be followed should a development project
come forward.
Uncertainty regarding replacement facility for rugby club. Where have the Council
allocated a replacement site?
The Rugby Club has previously used Lottery monies to expand the club and
purchase 2 additional pitches for youth sport. RC now proposes to sell these
pitches. Regarded as an obscene waste of public money.




Discussions between the Rugby Club (RC) and the Council are ongoing;
RC is considering its relocation options. Some may include Council owned land;
Residents will be consulted before any development takes place;
The issue regarding potential clawback is not a planning consideration. This is
for the club to resolve within the terms of any funding agreement it may have
secured.
Questioning why Rugby Club is considering selling?
What does the Rugby Club get from this?
ACTION TAKEN:
Noted. See Council response above.
The Rugby Club site has been identified as a strategic site and is allocated for housing development in the Publication edition, under Policy 16/7 which stipulates that the club
site cannot be developed unless and until the club has relocated within Blackburn with Darwen.
ACTION TAKEN:
All comments relating to the following headings have been actioned as part of the general feedback; refer to Appendix 5.
AFFORDABLE HOUSING
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
Page 84 of 120 APPENDIX 6
11. EAST DARWEN (including Bailey’s Field and Ellison Fold), Darwen.
Issues and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
Area has been used by the public for a wide range of recreational
activities for up to 30 years. Established network of footpaths, created
by people using the site, crosses the site.
COUNCIL RESPONSE


Information/concerns have been noted and will be taken into
account in assessing suitability of the site for development and
development requirements;
Public Rights of Way will be protected and integrated within
scheme proposals. There may be some requirement for
realignment as part of the scheme proposals/layout and if
needed, the opportunity for improvements.
ACTION TAKEN:
Part of the site has been allocated for housing in the Publication edition, leaving the southern part unallocated. The allocation includes a
requirement for a Masterplan to be produced prior to any development taking place; and retention and enhancement of the public right of way.
Policy 10 (Accessibility and Transport) of the Publication edition includes a requirement that development must not directly affect any public
rights of way, unless the right of way is maintained or the proposal provides for its replacement by an equally attractive, safe and convenient
route.
Area was previously heavily mined for coal and a significant number
of mine shafts (approx. 25) are scattered across the site. A previous
developer who had an option to build abandoned their proposals as
they considered it too costly to reclaim the site and address the
issues linked to the previous coalmining use.

Evidence of ongoing subsidence.



Council acknowledges that this information needs to be taken
into account as part of the site assessment;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including design standards, environmental needs and any
mitigation works. The developer will need to demonstrate how
these requirements will be met before any development can
progress;
Developer will need to carry out a full site investigation to
determine any constraints and/or mitigation works needed to
enable the development to progress. This information will be
requested as part of any planning application;
Expected that modern methods of construction including
building materials will offer a deliverable solution to enable this
Page 85 of 120 APPENDIX 6
scheme to progress.
ACTION TAKEN:
Part of the site has been allocated for housing in the Publication edition, leaving the southern part unallocated. The allocation includes a
requirement for a Masterplan to be produced prior to any development taking place; and detailed geo-technical studies to show the extent of
the areas affected by historic mining activity and therefore any potential mitigation. Policy 8 of the Publication edition also requires potentially
unstable land to be remediated to provide a safe environment for occupants.
Flooding. Run off flows down Pole Lane.



Council recognises flooding is a serious concern for local
residents. Information provided has been noted and will be
taken into account in assessing suitability of the site for
development and in identifying development requirements;
Council is keen to promote sustainable solutions;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for surface water drainage. The developer
will need to demonstrate how these requirements will be met
before any development can progress.
ACTION TAKEN:
Part of the site has been allocated for housing in the Publication edition, leaving the southern part closest to Pole Lane unallocated. The
allocation includes a requirement for a Masterplan to be produced prior to any development taking place; and Sustainable Drainage Systems to
ensure that runoff is managed and does not contribute to flooding elsewhere. Policy 9 of the Publication edition also requires management of
surface water at source.
Roads are bad in the snowy weather particularly Marsh House and
Pole Lane.

Council understands people’s concerns and will take this
information into account in considering scheme
proposals/discussion with developers.
ACTION TAKEN:
Part of the site has been allocated for housing in the Publication edition, leaving the southern part unallocated. The allocation includes a
requirement for a Masterplan to be produced prior to any development taking place, which will consider the most appropriate design solutions
including cold weather scenarios.
Page 86 of 120 APPENDIX 6
HOUSING DEVELOPMENT
4.2
How
Planning
Site should be allocated for housing. It is a brownfield site which
should be preferred to Green Belt Land. It is capable of delivering
executive housing for which there is a need. Site can provide a link
road through the site to relieve congestion in Darwen.
ACTION TAKEN:
Refer to Policy 4: Land for development beyond the plan period; Policy 16/14 – East Darwen; Policy 45:Major road schemes; and Policies Map
Policy 16/14 confirms that the northern section of the previously safeguarded site has been allocated for housing development within the plan
period to 2026. Delivery of the new housing will be phased: it is expected up to 120 of the total estimated 400 dwellings will be completed within
the next 5 years to 2018.The policy sets out the development considerations that need to be taken into account as scheme proposals are
detailed. The site includes a protected road line for construction of the Darwen East Distributor Road; refer to Policy 45 and the Policies Map.
The southern section of the site is identified as land for development beyond the plan period; refer to Policy 4. In the meantime any
development on this land must not compromise the comprehensive development of the wider site.
Concerns of over-development of the site and high population
density.
Development will cause loss of views and residential amenity.
Distance from existing properties needs to be enough to give people
space. Aspects that first attracted residents to the area – quiet/semirural and peaceful – should be saved as a local leisure resource
similar to Jubilee ‘meadows’ being established by Prince Charles.
ACTION TAKEN:
Refer to Policy 8: Development and people; Policy 11: Design; and Policy 16/14: - East Darwen.
Policy 8 seeks to ensure that development brings benefit to people and the elements of local areas that make them attractive to people. Its sets
out how the development will need to respond to a range of issues – including considerations of privacy/overlooking and the relationship
between buildings -, which can, in some cases, have an adverse influence on people – this includes established residents and the occupants of
the new housing.. A developer will need to demonstrate in scheme proposals that the development has acknowledged the potential impacts
identified in Policy 8 and has successfully dealt with these. This is complemented by Policy 11, which requires all development to present a
good standard of design. The policy sets out the design considerations that need to be taken into account in scheme preparation and
construction; it identifies the elements that the Council will assess that are acknowledged to influence character/townscape/public
realm/movement and legibility/sustainability/diversity and materials and colour. The developer will be expected to demonstrate how all of these
Page 87 of 120 APPENDIX 6
requirements have been addressed in scheme proposals. Adopted Supplementary Planning Documents on design in general and on the
design of residential areas are already in place.
Policy 16/14 identifies that the scheme should be designed with a housing density across the site of 16 dwelling per hectare. This is consistent
with larger dwellings including the house footprint and surrounding private spaces. This density will not lead to overdevelopment of the site;
overdevelopment would detract from the attractiveness and merits of the site’s semi-rural location.
HOUSE TYPES
New house types should vary to encourage a cross section into the
community. Area is not really suitable for households on low
incomes.

See above comments relating to scheme requirements and
housing mix. The discussion with developers on housing mix
will consider the affordability of proposed homes, local housing
needs and the Council’s priority to secure a broader housing
mix/wider choice of homes.
ACTION TAKEN:
Refer to Policy 8: Development and people; Policy 11: Design; and Policy 18: Housing mix
Policy 18 acknowledges the need for a wider choice of housing to contribute to the Council’s housing growth agenda in particular the need for
high quality family housing. The proposed housing mix will be particular to each site/development and will be influenced by a number of issues
such as site characteristics, local needs and the dynamics of the local housing market. Detached and semi-detached dwellings should be the
main house type in the mix on all suitable sites. Policy 8 sets out the development considerations that need to be taken into account with
regard to the effect of development on people and neighbourhoods and the need for development to make a positive contribution to the
character of the local area.
Policy 11 identifies the design and layout considerations that need to be taken into account in the preparation and construction of all
development schemes. Adopted Supplementary Planning Documents covering design in general and the design of residential development are
already in place.
SERVICES AND INFRASTRUCTURE
No local shops


Council has noted resident’s comments and will be take these
into account in determining individual site requirements ;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including new infrastructure such as the need for additional
local shops. The developer will need to demonstrate how
Page 88 of 120 APPENDIX 6

these requirements will be met before any development can
progress;
Developer may be asked to make a contribution and/or
incorporate new facilities within scheme proposals.
ACTION TAKEN:
The allocation includes a requirement for a masterplan to be produced prior to any development taking place which will be approved by the
Council prior to any development taking place. It is envisaged that the masterplan will include requirements to provide facilities on site or make
a contribution towards provision of local facilities. Whether a new local shop is developed will, however, be a commercial decision.
NEW INFRASTRUCTURE REQUIRED
Need for additional nursery/school places; play space for children;
doctor/dentist services including NHS dentist


We are working closely with the Education Department to
identify the need for additional capacity in local schools;
Involvement of Clinical Commissioning Group (CCG) to
identify need for and opportunities to provide
additional/enhanced medical facilities/services.
ACTION TAKEN:
The allocation includes a requirement for land to be made available for a new single entry primary school, which will also allow for expansion, if
required, in future years. In terms of nursery places, the Council’s Early Years team have confirmed there are sufficient places available to
meet the needs of residents in the borough both now and in future years. This will be kept under review.
Policy 40 of the Publication edition requires all new residential development to contribute to the provision of high quality open space for its
residents, either through provision of public open space on site or, where more appropriate, through financial contributions towards improving
the quality and/or accessibility of nearby existing spaces.
The Council is working with the Clinical Commissioning Board (CCG) and NHS England to identify requirements for new health infrastructure
within the borough.
No usable bus service/improved service needed.


Resident’s comments will be taken into account as part of the
Council’s consideration of the development requirements for
each site;
New development/increased number of residents together with
new development on other east Darwen sites may present the
opportunity for improvements in public transport provision.
ACTION TAKEN:
The need for existing and future bus services to be financially sustainable results in difficulty in planning for public transport as a form of
infrastructure. New bus services will require a customer base in place first due to its commercial nature. Policy 10 (Accessibility and Transport)
Page 89 of 120 APPENDIX 6
of the Publication edition states that development for uses that are likely to generate large numbers of trips will only be permitted in locations
which are conveniently accessible by existing or proposed public transport services. If appropriate, the Council will work with the developer to
formulate, implement and monitor a Travel Plan setting out the measures that the developer, either alone or in conjunction with neighbouring
uses, shall adopt to reduce reliance on the use of the private car for journeys to and from the site.
GREEN BELT/WILDLIFE/ENVIRONMENT
Home to an abundance of wildlife including kestrels, skylarks, owls,
newt, bats, rabbits, deer, frogs and foxes.
Consideration needs to be given to impact of wind turbines on wildlife



Council acknowledges the importance of local wildlife and its
contribution to people’s enjoyment of the countryside;
Site assessment and Sustainability Appraisal processes will
consider the impact of development on wildlife and the
environment and identify any mitigation measures that may be
required;
Any required mitigation works will be included in the schedule
of development requirements that will be produced for each
proposed site. . The developer will need to demonstrate how
these requirements will be met before any development can
progress.
ACTION TAKEN:
Policy 9 of the Publication edition states that any development likely to damage or destroy habitats or harm species of international or national
importance will not be permitted. Furthermore, development likely to damage or destroy habitats or species of local importance will not be
permitted unless the harm caused is outweighed by other planning considerations and an appropriate mitigation strategy can be secured.
Additionally, Policy 37 sets out a list of criteria which proposals for wind turbines must comply with. One of these criteria includes a requirement
that any proposal must not have an unacceptable adverse impact on a protected habitat or other feature of ecological importance, unless a) the
benefits of the development clearly outweigh the harm caused, b) the development is designed to minimise the degree of harm, and c) the
residual harm is mitigated or compensated for.
Countryside corridors are needed to link green spaces and provide
easy access into the countryside.
Field in the centre of the community is well used – fear new
development will swallow this up.
Perception that there would be no open space left if land between
Chapels and Pole Lane is developed. Ellison Fold is important for
recreation and should be kept as open space
Page 90 of 120 APPENDIX 6
ACTION TAKEN:
Policy 40 sets out a requirement for integrating green infrastructure within new development. This requires all development, where
circumstances permit, to be designed to make a positive contribution to Blackburn with Darwen’s green infrastructure. It also requires all new
development to contribute to the provision of high quality open space and for functioning ecological networks not to be compromised.
Furthermore, development should contribute to the restoration, enhancement and connection of natural habitats through the provision of
appropriate green infrastructure.
OTHER ISSUES
Suggested alternative site including former Moorland School site
(brownfield land) and Hoddlesden Mill. Priority should be given to
developing this site before releasing greenfield land.


School site is under consideration and will be assessed as an
opportunity for housing development over the Plan period to
2026;
The company that owns the Hoddlesden Mill site is currently in
administration. Issues related to releasing the site are complex
and there is limited scope for the Council to intervene/kick start
the development. Council is exploring its options to support
bringing development forward.
ACTION TAKEN:
The former Moorland School site has also been allocated for housing in the Publication edition. Hoddlesden Mill is in use as an employment
site and is therefore not currently available for redevelopment.
ACTION TAKEN;
All comments relating to the following headings have been collated with the representations covering ‘general feedback’; refer to Appendix 5.
AFFORDABLE HOUSING
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
Page 91 of 120 APPENDIX 6
12. POLE LANE, Darwen
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
SITE ISSUES
Flooding. Rainwater from adjoining fields collects at the rear of
properties in Coniston Avenue and runs off into the site.


Water pressure on Coniston Drive is very poor.
Information/concerns have been noted and will be taken into
account in assessing suitability of the site for development and
development requirements;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for surface water drainage; The developer will
need to demonstrate how these requirements will be met before
any development can progress.
ACTION TAKEN:
Policy 9 (Development and the Environment) of the Publication edition requires development to demonstrate that it will not be at an
unacceptable risk of flooding. Any development with the potential to create significant amounts of new surface water run-off will be expected to
consider, and wherever possible, implement, options for the management of the surface water at source.
The allocation policy within the Publication edition for this site (16/15) includes a requirement for the development to incorporate SuDS and
measures to control surface water run-off.

Existing public right of way behind properties on Coniston Drive.

Information/concerns have been noted and will be taken into
account in assessing suitability of the site for development and
development requirements;
Public Rights of Way will be protected and integrated within
scheme proposals. There may be some requirement for
realignment as part of the scheme proposals/layout and if needed,
the opportunity for improvements.
Page 92 of 120 APPENDIX 6
ACTION TAKEN:
Refer to Policy 10: Accessibility and transport and Policy 16/15 – Pole Lane, Darwen.
Policy 10 advises that should development affect a public right of way provision needs to be made within the scheme for its replacement by an
equally attractive, safe and convenient route.
The allocations policy for this site (16/15) includes a requirement to consider/mitigate impacts on public rights of way that cross the site.

Concerns that there will be subsidence over former mine
workings when work starts.



Council acknowledges that this is an issue of concern for local
residents;
Council is aware of the site history;
Developer will be expected to carry out a full Site Investigation prior
to any development progressing and demonstrate to the Council’s
satisfaction that the works will not impact on neighbouring
properties;
Expected that modern methods of construction including building
materials will offer a deliverable solution to enable this scheme to
progress.
ACTION TAKEN:
Noted – See above Council response. The Coal Authority is a consultee on planning applications and will invited to make comment on any
scheme proposals that cover previously mined land.
Refer to Policy 8: Development and People
Policy 8 requires that in the case of previously developed land and/or unstable land, for example where subsidence is evident, the
development proposal will need to demonstrate that an acceptable land remediation scheme can be implemented which provides a safe
environment for user groups and does not the displace the problem.
HOUSING DEVELOPMENT
4.2
Sedgwick
Support the ‘delivery-led’ housing growth option and proposes
the safeguarded land in saved Local plan policy RA2/4 be
Page 93 of 120 APPENDIX 6
Associates
allocated for residential development. Site is considered to be
attractive for upper market/executive housing and available to be
brought forward in the short term/next 5 years.
ACTION TAKEN:
Refer to Policy 16/15 – Pole Lane, Darwen and Policy 4:Land for Development beyond the Plan Period
Policy 16/15 confirms that the previously safeguarded site RA/2 (land north of Spring Meadows) has been allocated for residential development
and sets out the development considerations that will need to be taken into account in scheme proposals. This land has recently been granted
outline planning consent for 133 dwellings.
Policy 4 applies to land south of Spring Meadow; the Green Study recommended that this land can be released from the Green Belt without
impacting on the purpose and the integrity of the Green Belt. The Publication edition Policies Map indicates that this land has been identified for
development beyond the plan period. The policy confirms that planning consent for development on this site will not granted except for a
proposal that does not compromise the comprehensive development of the whole site.
Proposed scale of housing is regarded as overdevelopment of
the site and out of character. Darwen does not need this scale of
development.


Development should respect character of Darwen.
HOUSE TYPES
Properties need to be sympathetic to existing in type and value.
Larger family detached and some semi-detached.
Definitely not smaller 2 bed low cost homes.
Darwen has very little quality housing developments/very few
detached quality homes.
Houses need to make provision for off street parking as roadside
parking is problematic and causing safety problems.




Council has noted resident’s concerns and will take these into
account in determining requirements for new housing on this site;
Council will be looking to promote a high quality and attractive
scheme that is sympathetic to local area and the character of
Darwen;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including housing mix/type, design standards, off-street parking and
regard for the place/setting.
Development Management policies will also require the scheme
details included within a planning application to give regard to and
respect the character of the local place – Darwen in this case;
The developer will need to demonstrate how the site requirements
and Development Management policies will be met before consent
is given /any development can progress;
As proposals are submitted there will be opportunities for
community involvement as part of the planning application process.
Sheltered accommodation is needed for the aging population.
Page 94 of 120 APPENDIX 6
Small, easily managed bungalows for the elderly similar to the
Bowling Green complex.
Certainly not 3 storeys. Preference for bungalows and lower
level development to safeguard light and views.
ACTION TAKEN:
Refer to Policy 16/15 – Pole Lane; Policy 10: Accessibility and Transport; Policy 11: Design and Policy 18: Housing mix
Policy 16/15 sets out the development considerations that will need to be taken into account as scheme details are prepared relating to the
established public right of way across the site and surface water drainage. Policy 10 provides guidance on
Comprehensive layout is needed to avoid unattractive piecemeal
development.


Council fully agrees;
Developer will be asked to prepare a masterplan for the whole site
to demonstrate how the development will be planned/designed and
brought forward. This will include phasing information and enable
the Council/community to understand the relationship between
individual phases.
ACTION TAKEN:
Outline planning consent has been granted for 133 dwellings on the allocation site. The Council will work closely with the applicant on the
detailing of proposals to ensure an attractive and appropriate scheme is prepared at the next stage of planning application. This will include
opportunities for public consultation.
Consideration will be given too to the implications of this scheme to future development of land to the south of Spring Meadow covered by
Policy 4: Land for development beyond the plan period.
SERVICES AND INFRASTRUCTURE
PUBLIC TRANSPORT
Frequency of the bus service would need to be improved.
Currently no bus service on Sundays. Taxis are too expensive

Council appreciates the importance of a good bus service in
enabling residents to connect with local facilities and services;
Page 95 of 120 APPENDIX 6
for many people.

New development/increased demand for public transport together
with development on other east Darwen sites may present the
opportunity for improvements to the local bus service.
ACTION TAKEN:
The need for existing and future bus services to be financially sustainable results in difficulty in planning for public transport as a form of
infrastructure. New bus services will require a customer base in place first due to their commercial nature. Policy 10 of the Publication edition
requires development for uses that are likely to generate large numbers of trips to be located close to conveniently accessible to existing or
proposed public transport services. The Council will also work with the developer to formulate, implement and monitor a Travel Plan setting out
the measures that the developer, either alone or in conjunction with neighbouring uses, shall adopt to reduce reliance on the use of the private
car for journeys to and from the site.
HIGHWAYS
Additional traffic will impact on highway safety and create more
noise and disturbance.


Traffic calming is needed at top and bottom of Pole Lane.
Pole Lane is already a busy road and is used as a ‘rat run’ from
A666 to motorway junctions avoiding the town centre. This
causes congestion at Pole Lane /Blacksnape Road roundabout
particularly at peak time.

Development will cause added congestion on Roman Road and
adjoining roads.
Council has noted resident’s comments and can appreciate the
concerns regarding the potential impact of new development;
An assessment of capacity/impact of potential development sites
on local highway network is being carried out to inform site
allocations. This will be used as an evidence base to support
individual site appraisals;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for highways and access. The developer will
need to demonstrate how these requirements will be met as part of
the planning application process/before any development can
progress.
ACTION TAKEN:
The Local Highways Network will identify any improvements required to the local highways to support new housing and employment
development in the borough. The allocation states that in the event that the current planning permission lapses and a new planning permission
is granted, development will be required to contribute towards the creation of the Darwen East Distributor Road to ease congestion.
Heavy volumes of traffic causes constant problem of potholes.
High number of accidents at junction of Pole Lane with Sough

Council understands resident’s concerns and will look at the
opportunity to address these within the Council, with partners
and/or in discussion with a developer.
Page 96 of 120 APPENDIX 6
Road.
ACTION TAKEN:
The Local Highways Network will identify any improvements required to the local highways to support new housing and employment
development in the borough.
NEW INFRASTRUCTURE REQUIRED
Open space – essential to health and wellbeing. Parks and
woodland on this side of the valley in Darwen.
Additional/replacement open space is vital. Basis of successful
neighbourhoods and major contribution to quality of life.
Primary and secondary schools




Children’s nurseries
Community centres

Recreation facilities including play area for children too young to
use Blacksnape.

Shops

Health centre
Resident’s comments have been noted and will be taken into
account in determining development requirements;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for new/additional infrastructure;
We are working closely with the Education Department to identify
the need for additional capacity in local schools;
Involvement of Care Commissioning Group (CCG) to identify need
for and opportunities to provide additional/enhanced medical
facilities/services;
The developer will need to demonstrate how these requirements
will be met as part of the planning application process/before any
development can progress;
Developer may be asked to make a contribution and/or incorporate
facilities within scheme proposals/scheme delivery as appropriate;
Police Authority will be consulted on site allocations and have the
opportunity to input into the future planning/provision of policing
services within neighbourhoods.
Police Station
ACTION TAKEN:
Policy 40 of the Publication edition requires all new residential development to contribute to the provision of high quality open space for its
residents, either through provision of public open space on site or, where more appropriate, through financial contributions towards improving
the quality and/or accessibility of nearby existing spaces.
The Council recognises the importance of ensuring sufficient services and facilities are available for its residents and the Publication edition
Page 97 of 120 APPENDIX 6
includes a policy (Policy 35) which aims to protect local facilities. However, although the Council can encourage new shops and community
facilities to support the new development, it is ultimately a commercial decision.
The allocation states that in the event that the current planning permission lapses and a new planning permission is granted, development will
be required to contribute towards a new single form entry primary school for East Darwen. The Council’s education department has confirmed
there is no shortage of secondary school places in the borough.
The Council is working with the Clinical Commissioning Board (CCG) and NHS England to identify requirements for new health infrastructure
within the borough.
GREEN BELT/WILDLIFE/ENVIRONMENT
Abundant wildlife including deer. Needs to be protected. Loss of
biodiversity; needs to be safeguarded.




Council agrees that these are important concerns to many
residents and to their enjoyment of their local area and the
countryside generally. The Council would not want any
development to have a damaging impact on wildlife and the
environment;
This information will be used to inform proposed scheme
requirements;
Site assessment and Sustainability Appraisal processes will
consider impact on wildlife/environment and identify any mitigation
measures that will be needed;
Developers will be expected to demonstrate as part of their
planning application how these measures are to be provided as an
integral part of their scheme before any development can progress.
ACTION TAKEN:
Policy 9 does not allow any development to occur which is likely to damage or destroy habitats or harm species of international or national
importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or habitats or species listed in
the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other planning considerations
and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to damage or destroy habitats
or species of local importance unless the harm caused is outweighed by other planning considerations and an appropriate mitigation strategy
can be secured.
Page 98 of 120 APPENDIX 6
Loss of open space. Retain open space in accordance with
‘Blackburn with Darwen Open Space Strategy (March 2006), in
particular the guidance on landscape character.
Loss of landscape/open aspect/views from urban encroachment.
This would destroy the character of the area.





Resident’s concerns have been noted and will be taken into
account in determining development scheme requirements;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for integration of open space/green
infrastructure;
Development Management policies will require developer to
demonstrate that development has regard to and respects the
character of Darwen;
The developer will need to demonstrate that the proposed scheme
meets all requirements before planning consent is granted/scheme
can progress;
A key consideration of the Green Belt review is to retain the
openness of the countryside and protect this from urban
encroachment.
ACTION TAKEN:
Policy 40 sets out a requirement for integrating green infrastructure within new development. This requires all development, where
circumstances permit, to be designed to make a positive contribution to Blackburn with Darwen’s green infrastructure. It requires all new
development to contribute to the provision of high quality open space and for functioning ecological networks not to be compromised. In
addition, development should contribute to the restoration, enhancement and connection of natural habitats through the provision of
appropriate green infrastructure.
ACTION TAKEN:
All comments relating to the following headings have been collated with the representations covering ‘general feedback’; refer to Appendix 5.
AFFORDABLE HOUSING
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
Page 99 of 120 APPENDIX 6
OTHER ISSUES
Page 100 of 120 APPENDIX 6
13. FORMER MOORLAND HIGH SCHOOL, Darwen
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
SITE ISSUES
Flooding and drainage

Drainage is poor and badly maintained on Pot House/Holden
Fold Lane – drains are blocked.

Council has made a note of resident’s comments and will use
these to inform site development requirements;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements
including provision for surface water drainage.
ACTION TAKEN:
Part of the site has been allocated for housing in the Publication edition (Policy 16/12), leaving Square Meadow unallocated. The allocation
includes a requirement for surface water management and the potential requirement to provide on-site attenuation. Policy 9 of the Publication
edition also requires management of surface water at source.
Local views would be compromised if development took place
on the ‘Square Meadow’.



Council acknowledges resident’s regard for the Square Meadow
and will take account of this in determining the development
requirements for the larger site;
At this stage site boundaries have not yet been established for
development on this site. More information and the opportunity for
further consultation will be available at the draft Plan stage at the
end of this year/early 2014;
Expected the developer will use/integrate all site assets including
the local views to enhance the attractiveness of development
scheme.
ACTION TAKEN:
Square Meadow has not been allocated for housing development in the Publication edition.
Page 101 of 120 APPENDIX 6
HOUSING DEVELOPMENT
4.2
Lea Hough
and Co for
landowner/
land at
Dandy
Lane,
Darwen
Owner of land at Dandy Lane supports the ‘urban-led’ delivery
option for housing delivery and confirms willingness to release site
for development as an integral part of the Moorland High School
allocation; this land would provide direct access to Blacksnape
Road. Landowner willing to commit to delivery in the short term.
ACTION TAKEN:
Refer to Policy 4: Land for development beyond the plan period and Policy 16/12: Former Darwen Moorland High School.
This Publication edition Policies Map indicates this site has been released from the Green Belt and is identified for development beyond the plan
period; refer to policy 4. The policy confirms that any development of this site in the meantime, prior to 2026, must not compromise the
development of the wider site.
Policy 16/12 confirms that the site of the former school building has been allocated for development.
Happy for development to be progressed across the whole site
with Square Meadow incorporated/retained for community
use/football.
Develop on old school building site leaving Square Meadow and
former school playing fields for sport and leisure including football,
cricket, and golf, walking dogs, rounders and kite flying.

-
-
As noted above –
Council acknowledges resident’s regard for the Square Meadow and
its potential for a range of recreational uses/activities and will take
account of this in determining the development requirements for the
larger site;
At this stage site boundaries have not yet been established for
development on this site. More information and the opportunity for
further consultation will be available at the draft Plan stage at the end
of this year/early 2014 and at a future date as part of a planning
application.
ACTION TAKEN:
Refer to Policy 16/12: Former Darwen Moorland High School and Policy 38: Green infrastructure.
Policy 16/12 confirms that the site of the former school building has been allocated for development; the area known locally as ‘ Square Meadow”
remains as protected open space covered by Policy 38.
HOUSE TYPES
Page 102 of 120 APPENDIX 6
Small house suitable for first time buyers – not affordable housing.

Bungalows in keeping with adjacent houses.

Detached and semi-detached bungalows and houses similar to
existing in Pot House.
Resident’s comments have been noted and will be taken into account
in determining site/development requirements:
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements including
house mix and house types.
3-bed family homes
ACTION TAKEN:
Refer to Policy 8: Development and people; Policy 11: Design; and Policy 18: Housing mix
Policy 18 acknowledges the need for a wider choice of housing to contribute to the Council’s housing growth agenda in particular the need for high
quality family housing. The proposed housing mix will be particular to each site/development and will be influenced by a number of issues such as
site characteristics, local needs and the dynamics of the local housing market. Detached and semi-detached dwellings should be the main house
type in the mix on all suitable sites. Policy 8 sets out the development considerations that need to be taken into account with regard to the effect of
development on people and neighbourhoods and the need for development to make a positive contribution to the character of the local area.
Policy 11 identifies the design and layout considerations that need to be taken into account in the preparation and construction of all development
schemes. Adopted Supplementary Planning Documents covering design in general and the design of residential development are already in
place.
AFFORDABLE HOUSING
Should be elsewhere nearer to town


Council agrees that this form of housing may in some cases be better
located nearer to public transport connections/access to jobs.
Altogether this is more likely to be a sustainable option for those
residents needing affordable housing – both to rent and/or to buy;
It will be essential that the affordable housing mix offers a good
choice and quality of home to all. These requirements will be set out
in the individual schedules of site development requirements.
ACTION TAKEN:
Refer to Policy 1: The urban boundary; Policy 12: Developer contributions; and Policy 18: Housing mix
Policy 1 confirms that the urban area is the preferred location for development and for many residents this is the most convenient location near to
Page 103 of 120 APPENDIX 6
existing facilities and transport connections.
Policy 18 acknowledges the need for a wider choice of housing to contribute to the Council’s housing growth agenda in particular the need for high
quality family housing. It sets out the Council’s development considerations relating to house type mix and the options for the provision of
affordables – on site or elsewhere via a financial contribution. Policy 12 sets out the approach to developer contributions, which in the first instance
will be secured, via a Section 106 agreement.
SERVICES AND INFRASTRUCTURE
Football pitch (Square Meadow) should be retained for use by the
local community. Two local football teams have agreed to merge
to share the sports ground and are confident they can self-fund all
costs involved.



Site regarded as only local open space for children to play safely
away from traffic and neighbours.
As noted above with regard to housing development ;
Additional information provided here will be considered as part of
determining the development requirements for the wider site;
It may be possible to organise a joint meeting with all development
partners to enable the options to be fully considered. Council would
be willing to facilitate an initial meeting.
ACTION TAKEN:
Square Meadow has been omitted from the allocation, as shown on the Adopted Policies Map (Publication edition).
Policy 40 of the Publication edition requires all new residential development to contribute towards the provision of high quality open space for its
residents, either through financial contributions towards improving the quality and/or accessibility of nearby existing spaces.
Keep Blacksnape children’s play area well maintained.
Rural facilities need to be protected.

Council agrees and will endeavour to ensure this is taken into
account in its commitment to children’s play and the protection of
local facilities in villages/rural areas.
ACTION TAKEN:
The Publication edition recognises that facilities such as small shops, post offices, public houses and community halls are an important part of life
in our towns and rural areas. Policy 35 within the Publication edition aims to protect these local facilities and includes a requirements that any
proposal for the complete change of use of buildings identified as being important to the sustainability of the community which it serves, will not be
permitted except where it can be demonstrated that the use is no longer economically viable or required by the local community, and that the use
is not capable of being supported by enabling development or a diversified use.
Policy 40 of the Publication edition requires all new residential development to contribute towards the provision of high quality open space for its
Page 104 of 120 APPENDIX 6
residents, either through financial contributions towards improving the quality and/or accessibility of nearby existing spaces.
PUBLIC TRANSPORT
Bus service would need to be improved to cope with increased
numbers of people.


Resident’s comments have been noted and will be taken into account
as part of the Council’s consideration of the development
requirements for this site;
New development/increased number of residents together with new
development on other east Darwen sites may present the opportunity
for improvements in public transport provision.
ACTION TAKEN:
The need for existing and future bus services to be financially sustainable results in difficulty in planning for public transport as a form of
infrastructure. New bus services will require a customer base in place first due to their commercial nature. Policy 10 of the Publication edition
requires development for uses that are likely to generate large numbers of trips will only be permitted in locations which are conveniently
accessible by existing or proposed public transport services. The Council will also work with the developer to formulate, implement and monitor a
Travel Plan setting out the measures that the developer, either alone or in conjunction with neighbouring uses, shall adopt to reduce reliance on
the use of the private car for journeys to and from the site.
HIGHWAYS
Too much traffic already on Holden Fold Lane – uses as a rat run.
Lack of road sweeping and clearing of litter.

Roman Road/Pot House Lane/Holden Fold and Moor Lane are
already heavily used at peak times. Used as rat run to motorway
or industrial sites such as Whitebirk and Shadsworth.

Accessing the site will be an issue


Thank you for your comments. These have been noted and will be
taken into consideration in determining development requirements for
this site;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements including
requirements for highways and access;
Development Management policies will require developer to
demonstrate that development has regard to these requirements;
The developer will need to demonstrate that the proposed scheme
meets all requirements before planning consent is granted/scheme
can progress.
ACTION TAKEN:
The Local Highways Network will identify any improvements required to the local highways to support new housing and employment development
in the borough. Policy 10 (Accessibility and Transport) of the Publication edition requires development to demonstrate that road safety and the
safe, efficient and convenient movement of all highways users is not prejudiced; appropriate provision is made for vehicular access, off-street
Page 105 of 120 APPENDIX 6
servicing and parking in accordance with the Council’s adopted standards.
The allocation policy for this site includes a requirement to provide a contribution towards the Darwen Eastern Distributor Road in addition to
acknowledging there is likely to be a requirement for Moor Lane/Holden Fold to be widened.
NEW INFRASTRUCTURE REQUIRED
Shops

Open space must be a priority on this site.

As for the comments above regarding highways. The schedule
setting out all development/scheme requirements will include a
requirement for the provision/integration of additional infrastructure,
and the integration of open space/green infrastructure, as needed;
The developer will need to demonstrate that the proposed scheme
meets all requirements before planning consent is granted/scheme
can progress.
ACTION TAKEN:
The Council recognises the importance of ensuring sufficient services and facilities are available for its residents and the Publication edition
includes a policy (Policy 35) which aims to protect local facilities. However, although the Council can encourage new shops to be developed on
site, it will ultimately be a commercial decision.
Policy 40 (Integrating green infrastructure with new development) in the Publication edition requires all new residential development to contribute
towards the provision of high quality open space for its residents, either through provision of public open space on site or, where more appropriate,
through financial contributions towards improving the quality and/or accessibility of nearby existing spaces.
Renovate changing rooms on Square Meadow.
School sports hall converted to a climbing centre. These facilities
can be successfully self-funded, the area lacks such a facility and
there are a large number of climbers in Darwen who would
volunteer to help run the centre.

Resident comments have been noted. These are not a Local Plan
consideration. However comments will be forwarded to the Council’s
Leisure Services Department for their information and action, if
appropriate.
ACTION TAKEN:
Noted. See Council response - comments forwarded to Leisure Services Department.
Page 106 of 120 APPENDIX 6
GREEN BELT/WILDLIFE/ENVIRONMENT
Loss of open space will destroy local character of the Darwen
market town.



Important countryside/open space area.
A number of residents have expressed similar concerns in relation to
Darwen;
Council acknowledges the value/contribution of open space and
landscape setting to the character of Darwen;
Retaining the character of Darwen will be referred to in Development
Management policies and will be a key consideration in the review of
any planning application Expected that developers will also regard
this as an asset to be enhanced/form an integral part of any
development;
ACTION TAKEN:
Policy 9 (Development and the Environment) of the Publication edition states that development involving the partial or complete loss of an area of
green infrastructure will not be permitted unless the development can be accommodated without the loss of the function of the open space; the
impact can be mitigated or compensated for through the direct provision of new or improved green infrastructure elsewhere, or through the
provision of a financial contribution to enable this to occur; or the need for or benefits arising from the development demonstrably outweigh the
harm caused, and the harm has been mitigated or compensated for so far as is reasonable. As a result, any new development on the site would
have to meet these requirements.
Policy 40 (Integrating green infrastructure with new development) sets out a requirement for integrating green infrastructure within new
development. This requires all development, where circumstances permit, to be designed to make a positive contribution to Blackburn with
Darwen’s green infrastructure. It requires all new development to contribute to the provision of high quality open space and for functioning
ecological networks not to be compromised. In addition, development should contribute to the restoration, enhancement and connection of natural
habitats through the provision of appropriate green infrastructure.
The policy also includes a requirement for all new residential development to contribute to the provision of high quality open space for its
residents, either through provision of public open space on site or, where more appropriate, through financial contributions towards improving the
quality and/or accessibility of nearby existing spaces.
Policy 11 (Design) relates to the design of new development, and includes a requirement for all new development to enhance and reinforce the
established character of the borough.
Home to wildlife. Needs to be safeguarded.

Council acknowledges the contribution that wildlife/countryside
makes to residents, values this also and accepts it needs to make
every efforts to ensure this is safeguarded;
Page 107 of 120 APPENDIX 6



Individual site assessments and Sustainability Appraisal processes
will identify any impact and the need for mitigation measures;
The schedule of site development requirements will set out all
mitigation measures that developer’s will have to take on board in
any scheme proposals;
Developer will need to demonstrate with any planning application that
these requirements have been addressed before planning consent is
granted/scheme can proceed.
ACTION TAKEN:
Policy 9 of the Publication edition does not allow any development to occur which is likely to damage or destroy habitats or harm species of
international or national importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or
habitats or species listed in the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other
planning considerations and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to
damage or destroy habitats or species of local importance unless the harm caused is outweighed by other planning considerations and an
appropriate mitigation strategy can be secured.
OTHER ISSUES
Could the school be re-opened as a feeder for the Academy?

Retain the school for future use?

These matters will be taken up with the appropriate Council
Department/partner;
Will also require further discussions with central government’s
Department for Education.
ACTION TAKEN:
The former Darwen Moorland High school site has been allocated for housing development (Policy 16/12) in the Publication edition. The policy
specifies that the developer will make a contribution towards a new single form entry primary school for East Darwen.
ACTION TAKEN:
All comments relating to the following headings have been collated with the representations covering ‘general feedback’; refer to Appendix 5.
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
Page 108 of 120 APPENDIX 6
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
Page 109 of 120 APPENDIX 6
14. KIRKHAM’S FARM/CRANBERRY LANE, JACK’S KEY, Darwen
Issues
and
options
question
Respondent
SUMMARY OF REPRESENTATIONS
COUNCIL RESPONSE
SITE ISSUES
Potential for flooding of properties downstream from Jack’s Key –
properties flooded in June 2012. Cranberry Lane site holds a
considerable amount of water. The run off from developed site
will go into River Darwen below the flood protection measures
completed by the Environment Agency at Jack’s Key.
Source of the River Darwen is in the local area. Flooding occurs
on land behind houses on Cranberry Lane and run-off causes
many gardens to be waterlogged for many months ion the year.






Council shares resident’s concerns regarding flooding in Darwen and
would regard any scheme unacceptable that increased the likelihood
of future flooding;
A series of technical studies are being carried out to form the evidence
base for individual site assessments and to inform development
requirements. One of these studies is investigating surface water
issues and flood risk;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements including
surface water drainage, design standards and any mitigation works;
These issues will be addressed in Development Management policies;
As part of any planning application the developer will need to
demonstrate how these requirements will be met as part of scheme
proposals before planning consent is considered/any development can
progress;
Expected that modern methods of construction including building
materials will contribute to deliverable schemes.
ACTION TAKEN:
Policy 9 (Development and the Environment) of the Publication edition requires development to demonstrate that it will not be at an unacceptable
risk of flooding. Any development with the potential to create significant amounts of new surface water run-off will be expected to consider, and
wherever possible, implement, options for the management of the surface water at source.
Page 110 of 120 APPENDIX 6
The allocation policy for this site (16/17) includes a requirement for the development to incorporate SuDS and measures to control surface water
run-off (the site has been identified as being located within the Darwen Critical Drainage Area). It also identifies that at least one culvert runs
through the site, feeding the headwaters of the River Darwen. As a result, there will be a need for ongoing maintenance.
Loss of privacy and local views .Overlooking from new
development.



Council understands that residents have enjoyed open aspects for a
considerable time;
Any new development will be sensitively and sympathetically planned
with regard to established housing;
Design standards, considerations of privacy and overlooking will be
addressed in Development Management policies.
ACTION TAKEN:
Loss of a view is not a planning consideration. Any scheme proposal on the site would be designed to minimise the impact of development on the
countryside, and to enhance access to the countryside.
Policy 8 (Development and People) of the Publication edition requires development to secure a satisfactory level of amenity and safety for
surrounding uses and for occupants or users of the development itself, with reference to noise, vibration, odour, light, dust, other pollution or
nuisance, privacy/overlooking, and the relationship between buildings.
Concerns that wildlife would be displaced.





A number of residents have raised their concerns regarding local
wildlife;
The Council is very aware of its contribution to the countryside and
people’s enjoyment of their local area;
A key part of the individual site assessment and Sustainability
Appraisal processes will be to identify any mitigation measures that
may be needed to protect wildlife and their habitats;
These requirements will be incorporated within the individual site –
specific schedules referred to above;
As noted above any developer will need to demonstrate how these
measures have been provided for as part of any development
proposal.
ACTION TAKEN:
Page 111 of 120 APPENDIX 6
Policy 9 of the Publication edition does not allow any development to occur which is likely to damage or destroy habitats or harm species of
international or national importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or
habitats or species listed in the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other
planning considerations and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to damage
or destroy habitats or species of local importance unless the harm caused is outweighed by other planning considerations and an appropriate
mitigation strategy can be secured.
Established network of footpaths across the site that are used
daily.


Information/concerns have been noted and will be taken into account
in assessing suitability of the site for development and development
requirements;
Public Rights of Way will be protected and integrated within scheme
proposals. There may be some requirement for realignment as part of
the scheme proposals/layout and if needed, the opportunity for
improvements.
ACTION TAKEN:
Refer to Policy 10: Accessibility and transport and Policy 11: Design.
Policy 10 sets out the development considerations for sites which are crossed by public rights of way rights. The policy requires the route to be
maintained or replaced/realigned by an equally attractive, safe and convenient route.
Policy 11 identifies movement and legibility as a key design consideration in scheme detailing and confirms the need for scheme layouts and
design to provide safe and convenient movement about the site and connectivity with the wider neighbourhood and surroundings.
Coal Board website (coal.decc.gov.uk) suggests there are mine
shafts and other previous and probable mine workings in the
area. Creates potential for land instability and problems including
subsidence resulting in reduced house values and possible
litigation.
ACTION TAKEN:
Refer to Policy 8: Development and people.
Policy 8 seeks to ensure that the development brings benefit to people and the elements of local areas that make them attractive to people. The
policy requires an acceptable and deliverable land remediation scheme to be prepared, as necessary, for sites which have been previously
developed and as a result are unstable. The scope of any remediation work will need to be determined by site investigation study/works including
reference to Coal Board information. The site will need to be remediated to a standard that provides a safe environment for residents and ensures
Page 112 of 120 APPENDIX 6
any problems are not displaced.
HOUSING DEVELOPMENT
4.2
Peter Brett
Associates
LLP/Bloor
Homes NW
Harold Heys
Endorse the need for upper market/executive housing and
support the ‘delivery-led’ option for achieving housing growth.
Advocate the allocation of non-Green Belt safeguarded site at
Cranberry Lane (saved Local Plan policy RA2/1) as an
appropriate site to be allocated for development of executive
homes. Site is available to be brought forward in the short
term/early part of the plan and could meet policy requirements for
affordable housing.
An adjacent landowner is willing for family owned site to be
included in development scheme.
Support for development at Cranberry Lane
New housing development is not wanted
ACTION TAKEN:
Refer to Policy 16/17 – Kirkham’s Farm, Darwen.
Policy16/17 confirms the previously safeguarded site has been allocated for development. The policy sets out the development considerations that
need to be taken into account in scheme detailing. This is regarded a strategic growth site and is considered suitable for high quality family housing
as the principal element in the housing mix; it is expected development will be delivered in the next 5 years to 2018.
Alternative sites identified including: -
Land on Goose House Lane (sewage works site)
-
Empty office/industrial premises at bottom of Goose
House Lane
-
Moorlands School site a better option – good location,
open aspects and well served by existing road network.

The Council welcomes further information on alternative sites. All sites
within the urban area are suitable locations for development. Their
suitability will be assessed alongside other proposed sites.
ACTION TAKEN:
Page 113 of 120 APPENDIX 6
Noted. See Council response
Refer to Policy 16/12 – Former Darwen Moorland High School.
Policy 16/12 confirms that the former school site has been allocated for housing development.
Development would destroy the local character and features that
make it attractive.


Council appreciates resident’s concerns regarding the impact of
possible changes/future development in their local area;
These issues will be addressed in Development Management policies
and applied to considerations of all future planning applications.
ACTION TAKEN:
Refer to Policy 8: Development and people and Policy 11: Design
Policy 8 seeks to ensure that the development brings benefit to people and the elements of local areas that make them attractive to people. The
developer will need to demonstrate in scheme proposals that the development will make a positive contribution to the character of the local area.
This is complemented by Policy 11 which sets out the design considerations that new developments are expected to address. The policy sets the
components of design that need to be taken into account to present a good standard of design; this includes a number of aspects relating to
character . New development is expected to enhance and reinforce the established character of the area.
HOUSE TYPES
Cranberry Lane would be suitable for executive housing.


Detached and semi-detached


Resident preferences have been noted and will be taken into account
in drafting site development requirements;
Council is committed to providing an equitable high quality housing
choice across the borough;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements including
provision for housing mix including affordables for rent and for sale,
house types and specific design standards;;
These requirements will be secured via the application of Development
Management policies /guidance to any planning application.
ACTION TAKEN:
Page 114 of 120 APPENDIX 6
Refer to Policy 18: Housing mix.
The Council recognises that a wider choice of housing, in particular high quality family homes is apriority for the successful delivery of its housing
growth and regeneration agenda. Policy 18 confirms that new development will be required to widen the choice of house types available across the
borough and that the principal element of the dwelling mix should be detached and semi-detached dwellings on suitable sites.
SERVICES AND INFRASTRUCTURE
PUBLIC TRANSPORT
Better bus service is needed.


Council appreciates the importance of a good bus service in enabling
residents to connect with local facilities and services;
Demand from increased numbers of residents may present an
opportunity for an improvement in public transport.
ACTION TAKEN:
New bus services will require a customer base in place first due to their commercial nature. Policy 10 of the Publication edition states that
development for uses that are likely to generate large numbers of trips will only be permitted in locations which are conveniently accessible by
existing or proposed public transport services. The Council will also work with the developer to formulate, implement and monitor a Travel Plan
setting out the measures that the developer, either alone or in conjunction with neighbouring uses, shall adopt to reduce reliance on the use of the
private car for journeys to and from the site.
HIGHWAYS
Accessing the site in vicinity of Cranberry Lane/Watery Lane
junction would be problematic. Top end of Cranberry Lane is a
dead end and is used by farmers/livestock/riders and walkers.
Adding to congestion – there is only one exit and entry to
Cranberry Lane – the road is a cul-de-sac/dead end.
Inadequate roads for increased traffic. Concerns that increased
traffic is a danger to residents using the lane. Cranberry Lane is a
busy route and on-street parking outside many homes,
particularly terraced properties creates frequent ‘bottlenecks’.
Concerns regarding cumulative impact of additional traffic on the
east Darwen sites.




Council is grateful for resident’s comments and acknowledges that this
information needs to be taken into account as part of the site
assessment;
An assessment of capacity/impact of potential development sites on
local highway network is being carried out to inform site allocations.
This will be used as an evidence base to support individual site
appraisals;
For each proposed development site the Council will prepare a
schedule setting out all development/scheme requirements including
highways and site access. The developer will need to demonstrate
how these requirements will be met before any development can
progress;
These requirements will be secured via the application of Development
Page 115 of 120 APPENDIX 6
Narrow bridge over the railway on Sough Road has serious ‘blind
spots’. Narrow footpath on one side of the road only creates
makes the road dangerous for pedestrians.
Management policies /guidance to any planning application.
Accessing the site in vicinity of Cranberry Lane/Watery Lane
junction would be problematic.
Adding to congestion – there is only one exit and entry to
Cranberry Lane – the road is a cul-de-sac/dead end.
Loss of local routes to walkers
ACTION TAKEN:
The Local Highways Study will assess the current condition and capacity of the local highways network in the Borough and to assess the impacts of
new housing and employment sites in the borough over the Plan period. The allocation policy requires that the development of site will need to
contribute towards the creation of the Darwen East Distributor Road
Policy 10 (Accessibility and Transport) of the Publication edition requires development to demonstrate that road safety and the safe, efficient and
convenient movement of all highways users is not prejudiced; appropriate provision is made for vehicular access, off-street servicing and parking in
accordance with the Council’s adopted standards. As a result, any development proposal that came forward on this site would have to demonstrate
how it complies with these requirements.
EDUCATION
Limited places at local schools and nurseries
ACTION TAKEN:
The allocation policy requires development to contribute towards increased primary school capacity in Darwen. In terms of nursery places, the
Council’s Early Years team have confirmed there are sufficient places available to meet the needs of residents in the borough both now and in
future years. This will be kept under review.
Already lack of health facilities including GP surgeries and at
hospital
ACTION TAKEN:
The Council is working with the Clinical Commissioning Group (CCG) and NHS England to assess the need for additional health infrastructure in
Page 116 of 120 APPENDIX 6
the borough.
NEW INFRASTRUCTURE REQUIRED
Local shops

Improved bus service


As for the comments above regarding highways. The schedule setting
out all development/scheme requirements will include a requirement
for the provision/integration of additional infrastructure such as local
shops, integration of open space/green infrastructure as needed;
The developer will need to demonstrate that the proposed scheme
meets all requirements before planning consent is granted/scheme can
progress. In some cases the developer may need also to make a
contribution to the provision/enhancement of local facilities and
services;
In order to identify need and determine opportunities for delivery of
additional provision/improved capacity we are working with the
following: -
ACTION TAKEN:
The need for existing and future bus services to be financially sustainable results in difficulty in planning for public transport as a form of
infrastructure. New bus services will require a customer base in place first due to their commercial nature. Policy 10 of the Publication edition states
that development for uses that are likely to generate large numbers of trips will only be permitted in locations which are conveniently accessible by
existing or proposed public transport services. The Council will also work with the developer to formulate, implement and monitor a Travel Plan
setting out the measures that the developer, either alone or in conjunction with neighbouring uses, shall adopt to reduce reliance on the use of the
private car for journeys to and from the site.
The Council recognises the importance of ensuring sufficient services and facilities are available for its residents. Policy 35 aims to protect local
facilities. However, although the Council can encourage new shops to be developed on site, it is ultimately a commercial decision.
Additional capacity needed in local primary schools and
nurseries.
-
Education Department to identify the need for an opportunity to deliver
additional primary school provision;
Additional health provision – GP/medical centre.
-
Clinical Commissioning Group (CCG) to on the provision of additional
medical facilities including medical centres/GP surgeries;
Additional capacity needed in hospital’s A&E Department.
ACTION TAKEN:
The allocation policy for the site (16/17) requires development to contribute towards increased primary school capacity in Darwen. In terms of
Page 117 of 120 APPENDIX 6
nursery places, the Council’s Early Years team has confirmed there are sufficient places available to meet the needs of residents in the borough
both now and in future years. This will be kept under review.
The Council is working with the Clinical Commissioning Group (CCG) and NHS England to assess the need for additional health infrastructure in
the borough. See previous comments regarding primary school and nursery provision.
GREEN BELT/WILDLIFE/ENVIRONMENT
Abundance of wildlife and habitats that need to be protected
including deer, kestrels, peregrine falcons, owls and badgers.
Would need to mitigate impact of light pollution on fauna in the
woodland of the Clough
Countryside should be protected. It is part of the local character
and attractiveness to the area.
. Concerns regarding impact of construction and ‘continuous
occupation’ on ecosystems in particular more fragile habitats
which make up special conservation interest of the site
In addition to wildlife there are significant industrial remains in the
eastern meadow adjacent to the mine spoil mounds





Council also values the contribution of wildlife/countryside to and
accepts it needs to make every efforts to ensure this is safeguarded;
Individual site assessments and Sustainability Appraisal processes will
identify any impacts of development and the need for mitigation
measures;
The schedule of site development requirements will set out all
mitigation measures that developer’s will have to take on board in any
scheme proposals;
These requirements will be secured via the application of Development
Management policies /guidance to any planning application.
Developer will need to demonstrate with any planning application that
these requirements have been addressed before planning consent is
granted/scheme can proceed.
Area would benefit from ‘light touch’ management.
Council needs to honour and respect the existing biodiversity and
habitat on land surrounding Jack’s Key reservoir and its potential
for improvement. An article in the Telegraph in March 2012
outlined the opportunity for the Council to work with the
Environment Agency and a local community group to achieve
this,
. Concerns regarding impact of development on Jack’s Key
reservoir site; rich/diverse plant communities on surrounding
meadowlands. Only portion of site where development would not
severely impact on existing ecosystems is area of open land to
east of St Barnabas School playing fields and bordered on
eastern side by woodland of Jack’s key Clough and extending
Page 118 of 120 APPENDIX 6
from established residential properties to western corner of the
dam. Care would be needed to prevent any surface run-off or
land drainage water carrying pollutant/nutrient rich run-off into the
Clough/River Darwen.
.ACTION TAKEN:
Policy 40 in the Publication edition requires, where circumstances permit, for all development to be designed to make a positive contribution
Blackburn with Darwen’s green infrastructure. One of the requirements of this policy is retain and enhance existing ecological and landscape
features on the site. The policy also requires all new residential development to contribute towards the provision of high quality open space for its
residents, either through financial contributions towards improving the quality and/or accessibility of nearby existing spaces.
Additionally, Policy 9 does not allow any development to occur which is likely to damage or destroy habitats or harm species of international or
national importance. It also provides protection for habitats and species of principal importance, Biological Heritage Sites, or habitats or species
listed in the Lancashire Biodiversity Action Plan unless the harm caused is significantly and demonstrably outweighed by other planning
considerations and an appropriate mitigation strategy can be secured. The policy also does not allow development that is likely to damage or
destroy habitats or species of local importance unless the harm caused is outweighed by other planning considerations and an appropriate
mitigation strategy can be secured.
OTHER ISSUES
Belgrave Heights/Waite Street scheme is an awful eyesore in the
town centre and for those residents who moved into the early
completions.
 Council agrees that this stalled site is not attractive;
 The developer’s circumstances are complex. The council does not
have the ability to intervene to kick start the development;
 It will continue to monitor the situation and explore any available
opportunity to support the re-commencement/completion of the
scheme.
ACTION TAKEN:
The Council is in discussion with a potential developer to explore the options for completing this scheme.
ACTION TAKEN:
Page 119 of 120 APPENDIX 6
All comments relating to the following headings have been collated with the representations covering ‘general feedback’; refer to Appendix 5.
INVESTMENT IN OTHER AREAS AS WELL AS HOUSING
COUNCIL’S ROLE IN BRINGING DEVELOPMENT FORWARD
CONSULTATION PROCESS
Page 120 of 120 APPENDIX 6
APPENDIX 7: Maps to illustrate the target areas for distribution of resident invitations
to consultation events – February-May 2013
Local Plan Part 2: Site Allocations and Development Management Policies
Regulation 18 Consultations: Preparation of a Local Plan
1. Blackburn (North)
2. Blackburn (South)
3. Darwen and Hoddlesden
4. Tockholes
5. Belmont Village and Edgworth/Chapeltown
Page 1 of 6 APPENDIX 7 Map 1
Page 2 of 6 APPENDIX 7 Map 2
Page 3 of 6 APPENDIX 7 Map 3
Page 4 of 6 APPENDIX 7 Map 4
Page 5 of 6 APPENDIX 7 Map 5
Page 6 of 6 APPENDIX 7 APPENDIX 8: List of consultees to site specific land availability update – May-June
2013
Local Plan Part 2: Site Allocations and Development Management Policies
Regulation 18 Consultations: Preparation of a Local Plan
AGENT COMPANY
Madison Commercial
3D.G design
Maze Planning
Acting Chair, Darwen Cricket Club
McAteer Associates Ltd
Ainscough Strategic Land
McDermott Developments Ltd
B&E Boys Ltd
Michael Marsden
Bailey Dyson Ltd
Northern Box & Packaging Ltd
Belmont Holdings Limited
Oriental Developments Ltd
Blackburn Naturalists' Field Club
Paul Butlers Associates
Blackhurst Swainson Goodier
Persimmon Homes
Blackthorn Limited
Pete Marquis Contractors
Boys
Primrose Holdings 1995 Ltd
CA Planning
RFT Project Management Ltd
Campbell Driver partnership
Robert John Jopling Ltd
Capita Symonds
Rural Solutions
Cassidy Ashton
Sanderson Weatherall
Cedar Distributions Ltd
Sedgwick Associates
Charles Topham and Sons Ltd
St Wilfrid's COE High School
City Park
St. Stephen's Conservative Club
De Pol Associates Ltd
Stanton Andrews Architects
DTZ
Steven Abbott Associates
Sunderland Peacock and Associates
Ltd
Dunlop Haywards
Dutton Carpets
Enza property group
Taylor Weaver
First Investments Ltd
The Planning & Development Network
The Wildlife Trust for Lancs,
Manchester & N Merseyside
Fletcher Smith Architects
Timack (N.W.) Ltd
Frank Whittaker
Tommy Ball's of Blackburn
George Edwardian
Trevor Dawson
GHA
Together Housing
GL Consultancy
Urban Psyche
Graham Anthony Associates
Urban Regen Ltd
Grays Inn Estates Group Ltd
Wainhomes NW Ltd
GVA Grimley
Walsh Companies
How Planning
Pamela Beard Smith
Inspired Developments
Mrs Patricia Hancock
Janet Dixon Town Planners Ltd
Haroon Patel
JASP Planning Consultancy ltd
John Sturgess
Jones Lang LaSalle
Wendy Gormley
JWPC Limited
David Hunter
Lambert Smith Hampton
J Taylor
Lea, Hough & Co
Kay Locker
Lidl UK
John Whitehead
Eric Wright Group
Page 1 of 2 APPENDIX 8
Mr Stephen Martin
Harold Spacey
James Fairweather
Andrew Almono
Peter Jepson
John Whitehead
Eileen Johnson
Kevin Pover
David Stratford
Stuart Ramwell
Page 2 of 2 APPENDIX 8
APPENDIX 9: List of consultees on draft Development Management policies
Local Plan Part 2: Site Allocations and Development Management Policies
Regulation 18 Consultations: Preparation of a Local Plan
Organisation
Position
First name
Surname
Blackburn Civic Society
Chair
Richard
Prest
Bolton Council
Planning Department
Burnley Council
Policy and Environment
Manager
Margaret
Whewell
Bury Council
Monitoring and Research
Officer
Philippa
Gibbon
Campbell Driver Partnership
Director
Ciara
Naessens
Canal and River Trust
Area Planner (North West and
North Wales)
Alison
Truman
Capita Symonds
Design and Policy Manager
Richard
Saint
Cassidy and Ashton
Director
Alban
Cassidy
Chorley Council
Policy and Design Team
Leader
Peter
McAnespie
Coal Authority
Chief Planner / Principal
Manager
Rachael
Bust
DLA Architecture
Associate
Jamie
Davenport
English Heritage
Historic Environment Planning
Advisor (North West)
Emily
Hrycan
Environment Agency
Planning Advisor
Philip
Carter
Eric Wright / Maple Grove
Consultant
Andrew
Dewhurst
G Hoerty Associates
Director
Gary
Hoerty
Highways Agency
Assistant Asset Manager
Cathy
Dean
HOW Planning
Consultant
Jon
Suckley
Hyndburn Council
Principal Planning Officer
Paula
FitzGerald
JWPC
Principal Consultant
Stuart
Booth
Lancashire County Council
Archaeological Dept
Specialist Advisory Services
Peter
Iles
Lancashire County Council
Senior Planning Officer
Sarah
Manchester
Page 1 of 2 APPENDIX 9: List of consultees on draft Development Management policies
Ecology Dept
(Ecology)
Lancashire County Council
Planning Policy
Planning Officer
Richard
Sharples
Lancashire Enterprise
Partnership
LEP Co-ordination
Emma
Prideaux
Lancashire Police
Architectural Liaison Officer
Terry
Burke
Lancashire Wildlife Trust
Conservation Officer for Central
and Western Lancashire
Dave
Dunlop
Lancashire Fire and Rescue
Fire Safety Enforcement Team
Leader
Peter
Aspin
Mono Consultants (for Mobile
Operators association)
Town Planner
Dominic
Needham
Lead Adviser, Land Use
Operations Team
Kate
Wheeler
Pendle Council
Planning and Building Control
Manager
Neil
Watson
Preston Council
Planning Officer
Mike
Molyneux
Ribble Valley Council
Senior Planner
Colin
Sharpe
Rossendale Council
Principal Planner (Forward
Planning)
Anne
Storah
Sedgwick Associates
Consultant
Matthew
Symons
South Ribble Council
Planning Officer
Kezia
Taylerson
Sport England
Planning Manager
Fiona
Pudge
Sunderland Peacock
Director
Duncan
Isherwood
Together Housing Group
Head of Project Management
Wendy
Malone
United Utilities
Developer Services and
Planning
Andrew
Leyssens
Natural England
Page 2 of 2 APPENDIX 9: List of consultees on draft Development Management policies
APPENDIX 10: Development Management Policies Consultation – July-August 2013
Local Plan Part 2: Site Allocations and Development Management Policies
SUMMARY SCHEDULE OF REPRESENTATIONS MADE UNDER REGULATION 18: Preparation of a Local Plan
Policy No.
(Consultation
version)
1
Policy No.
(Publication
version)
7
1
7
Stuart Booth
(JWPC Ltd)
1
7
Alison Truman
(Canal & River Trust)
1
7
Emily Hrycan
(English Heritage)
1
1
7
7
Respondent
SUMMARY OF REPRESENTATION
Peter Iles
(LCC Specialist
Advisory Services)
- In point (1), the word contained could be amended to advised, and proactively should be
removed.
- In point (2), add “and validation criteria”.
Action:
In point (1), the word contained is preferred. In point (2), reference to validation criteria
has been added.
There are lots of words in the policies. Suggest the policies should be shorter with more
information in the supporting text. The policy should say what we’re going to do, with the text
saying how we’ll do it.
Action:
Noted and amendments made where appropriate.
- Does this cover developer contributions?
- Is the plan viability assessment being consulted on?
Action:
There is a policy on developer contributions later in the document (Policy 6). Plan viability
will be part of the evidence base which will go through consultation in January 2014
alongside the Site Allocations and Development Management Policies Plan.
The policy should mention that an SPD will be produced.
Neil Watson
(Pendle Borough
Council)
Jamie Davenport
(DLA Architecture)
Action:
Wherever a Supplementary Planning Document exists or is intended, it is mentioned in the
introductory text. It does not form part of the policy.
Will commercially viable be defined?
Action:
A definition has been included within the glossary, but new guidance expected following
the Taylor Report will inform any further criteria.
Does ‘viable development’ cover all sectors?
Action:
Page 1 of 12 APPENDIX 10
Policy No.
(Consultation
version)
2
Policy No.
(Publication
version)
8
Respondent
Emily Hrycan
(English Heritage)
2
8
Terry Burke
(Lancashire Police)
2
8
Stuart Booth
(JWPC Ltd)
2
8
Gary Hoerty
(GH Associates)
2
8
Peter Iles
(LCC Specialist
Advisory Services)
2
8
Stephen Lamb
(Chorley Borough
Council)
3
9
Philip Carter
(Environment Agency)
SUMMARY OF REPRESENTATION
Yes – it tends to be in relation to affordable housing but it could cover anything from
house conversions to major developments.
In the text, replace “respects” with “makes a positive contribution to”.
Action:
Amendment completed.
There is only one mention of security in the whole document, in one word of this policy. There
should be more policy details regarding the prevention of crime and disorder; and community
safety. [TB (Lancashire Police) provided written examples after the meeting]
Action:
An extra bullet point (v) has been added to Policy 2.
Point (i) needs re-wording because some developments, such as potential urban extensions will
not preserve the character of the area. The policy could instead refer to managed change, and
be aligned with the allocations policy.
Action:
Wording of point (i) amended, replacing preserve with contribute positively to.
Point (i) should be more positive, such as enhance / improve rather than preserve.
Action:
Wording of point (i) amended, replacing preserve with contribute positively to.
Point (i) says overall so the most important factor is to find the right balance.
Action:
Noted.
- Should there be explicit mention of overlooking, overshadowing or overbearing?
- Should there be a criteria covering measures to help prevent crime and promote community
safety?
- Should there be a reference to the potential for light pollution?
Action:
Overlooking and the relationship between buildings have been added to point (ii), and
light is also mentioned. An extra bullet point has been added regarding crime and
community safety (v).
- Water quality should be added to Point (1).
- In the Green Infrastructure section, please change or to and.
- In the Habitats and Species section (ii), please change or to and.
Action:
Amendments completed.
Page 2 of 12 APPENDIX 10
Policy No.
(Consultation
version)
3
Policy No.
(Publication
version)
9
3
9
Matthew Symons
(Sedgwick Associates)
3
9
Alison Truman
(Canal & River Trust)
3
9
Paula FitzGerald
(Hyndburn Borough
Council)
3
9
Respondent
SUMMARY OF REPRESENTATION
Neil Watson
(Pendle Borough
Council)
- Does section 1(i) comply with the NPPF, because no exceptions are included? What is an
‘unacceptable contribution’? Exceptional circumstances should be mentioned.
- Part (i) of the Habitats and Species section should be checked against the NPPF because
development affecting national / international sites may not be considered to be sustainable
development.
- Part (ii) of the Habitats and Species section may not be compliant with the NERC Act. Inserting
and would resolve this; or county could be moved into part (i).
Action:
Wording amended.
Part (ii) of the Trees section regarding off-site replacement planting may not meet the tests of
reasonableness. It should be re-worded to ensure that any re-planting is closely related to the
site.
Action:
Near the site is included in the wording.
Part (ii) of the Habitats and Species section should state and instead of or. Local sites should
have the same protection.
Action:
Amendment completed.
The Woodland Trust is very helpful when consulted on tree policies. Hyndburn were asked to
mention Veteran Trees.
Stuart Booth
(JWPC Ltd)
4
10
Gary Hoerty
(GH Associates)
4
10
Richard Saint
Action:
Wording amended to include veteran trees.
Is the first sentence of section (1) needed?
Action:
Efficient and effective use of land is needed but the remainder of the sentence is
superfluous. Wording amended.
What is considered to be large numbers of trips or people? In rural areas, we need to encourage
diversification but many developments could fail under this policy due to the lack of public
transport provision or cycle routes (3(iii) and 3(iv)). There should be exceptions or flexibility for
rural areas.
Action:
In order to avoid being too prescriptive, ‘large numbers of trips’ is to be a judgement
based on the details of the case and its location. The wording of point 3(iv) has been
amended, but point 3(iii) is retained to ensure development is located where public
transport can be used or where convenient access exists to the nearest public facility.
- Please delete non-car means from the text.
Page 3 of 12 APPENDIX 10
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
SUMMARY OF REPRESENTATION
(Capita Symonds)
- In section (2), there could be more positive emphasis on the creation and implementation of
Travel Plans.
- In section (4), need to be clearer about situations when a Transport Assessment is needed.
Action:
Wording amended as suggested.
The Trust supports draft policy 4 in respect of reducing reliance on the use of the private car and
ensuring that sites are accessible by other means including on foot and by bicycle. However, as
stated in our response to the Issues and Options consultation, new development in the vicinity of
the canal can lead to an increased burden on the waterway infrastructure, including by increasing
the use of the towpath by pedestrians and cyclists. The Trust is therefore pleased to note the
requirement in criterion 4 for Transport Assessments to show the effect of proposals on existing
transport systems and for developers to provide or contribute to the necessary enhancements.
Action:
Noted.
How can point (1) be applied when routes frequently change?
4
10
Alison Truman
(Canal & River Trust)
4
10
George Bell
(Capita Symonds)
4
10
Safina Alam
(Capita Symonds)
4
10
Judith Furlonger
(PLACE)
4
10
Stephen Lamb
(Chorley Borough
Council)
5
11
Neil Watson
Action:
The policy refers to existing or proposed public transport services, so the policy will help
to ensure that developments will secure public transport services in locations where
public transport services may currently be lacking.
- Point (2) should include details of Travel Plans being monitored.
- The lack of bus services to some locations is a real concern, such as the Shadsworth
employment areas.
Action:
Point 2 amended as suggested. Concern regarding bus services is noted.
Do we need to change the language, so businesses can see the advantages of locating in
accessible locations; to see if we can help to facilitate business location and growth?
Action:
Wording amended to include ‘the Council will work with the developer’.
Should there be reference to the cumulative impact of highways not being severe?
Action:
Transport assessments, submitted with planning applications, will consider cumulative
impact, in accordance with the NPPF. Individual development management decisions will
consider the potential impact of the proposal against the current baseline and committed /
planned development; i.e. the cumulative impact.
In point (1), instead of requiring a high standard of design the policy should require a good
Page 4 of 12 APPENDIX 10
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
SUMMARY OF REPRESENTATION
(Pendle Borough
Council)
standard in accordance with the NPPF wording.
5
11
Jamie Davenport
(DLA Architecture)
5
11
Emily Hrycan
(English Heritage)
5
11
Matthew Symons
(Sedgwick Associates)
5
5
5
5
11
11
11
11
Philip Carter
(Environment Agency)
Judith Furlonger
(PLACE)
George Bell
(Capita Symonds)
Safina Alam
(Capita Symonds)
Action:
Amendment completed.
- Design is subjective; it is difficult to say what is a high standard.
- The sub-headings make up the overall design.
- Regarding point (6), should there be specific renewable targets? It would avoid the need for
additional planning applications (e.g. for solar panels) which have been required by Building
Control.
Action:
Noted. Specific renewable targets have been avoided because it’s a fast-moving agenda
and could lead to the Plan prematurely becoming out-of-date.
- Could the SPD be mentioned in the policy?
- Under point (2), it is more important to enhance even in areas where character has already
been compromised. Setting should be considered; this needs strengthening.
Action:
It is considered sufficient to refer to the SPD in the text rather than in the policy. Wording
of Point 2 amended.
An appeal decision in Sheffield showed that overall design was key; as per the NPPF.
Action:
Noted.
In section 6(iii), amend to read avoids detrimental impacts.
Action:
Amendment completed.
How can we require skilled designers?
Action:
Whilst we can’t require it by policy, we strongly encourage skilled designers to be
commissioned; especially for major schemes.
Do we still have the Colour Study?
Action:
Yes.
The movement and legibility section is important, but often conflicts with the requirements of
Secured by Design. Are there any circumstances when movement will outweigh security
requirements?
Page 5 of 12 APPENDIX 10
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
5
11
Stephen Lamb
(Chorley Borough
Council)
6
12
Neil Watson
(Pendle Borough
Council)
6
12
Stuart Booth
(JWPC Ltd)
6
12
Emily Hrycan
(English Heritage)
6
12
Matthew Symons
(Sedgwick Associates)
6
12
Alison Truman
(Canal & River Trust)
SUMMARY OF REPRESENTATION
Action:
Each planning application will be considered on its own merits, with appropriate weight
given to each policy and material consideration.
- How will design quality be measured? Sustainable building? Breeam? Code for sustainable
homes? Lifetime homes? Building for Life? Secure by Design? Designing out Crime?
- Should there be reference to linking in with surrounding patterns of movement?
- Should this policy promote public art?
Action:
- Design quality will be measured against the criteria noted in policy 5.
- Linking in with surrounding patterns of movement is covered under point 5(iii).
- Public art is not included due to viability issues.
- There is a conflict between (1) and (2); if a contribution is necessary how can viability be
argued?
- Suggests that a caveat could be added to point (2) after the word developments: “and the
impacts these reductions would have on the scheme” or “while preserving essential aspects of
safety”.
Action:
- ‘Necessary’ has been deleted from point (1).
- Wording of point (2) amended.
Under point 5(i), replace needed with necessary.
Action:
Amendment completed.
Heritage at Risk should be specifically mentioned in point 5.
Action:
The policy has been amended, removing the list which specified the types of project
where developer contributions may be spent; because it was too prescriptive. The revised
policy is non-specific in this regard, and therefore allows Heritage at Risk to be
considered.
There should always be a policy for a financial contribution, or it would be challenged (see point
(1)).
Action:
Wording amended accordingly.
The Trust generally supports draft policy 6 in respect of the requirement for developer
contributions to be secured through Section 106 agreements, and is pleased to note that priority
will be given to securing requirements that are necessary to allow the development to proceed,
followed by improvements to the transport network.
Page 6 of 12 APPENDIX 10
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
7
18
Emily Hrycan
(English Heritage)
7
18
Peter Iles
(LCC Specialist
Advisory Services)
7
18
Neil Watson
(Pendle Borough
Council)
7
18
Stephen Lamb
(Chorley Borough
Council)
8
19
Stuart Booth
SUMMARY OF REPRESENTATION
The Trust accepts that the overall level of contributions required should not result in development
proposals being rendered unviable. However, criterion 3 is contradictory as it states that the
council may negotiate a nil contribution, based on financial information provided by the applicant.
Requirements that relate to a specific proposal, for example the provision of a new bridge
crossing over the canal to provide vehicular access, is by definition essential to allow
development to proceed. The Trust would therefore suggest the removal of the reference to
negotiating a nil contribution.
Action:
Reference to nil contribution removed.
In point (2), instead of using the word compatible, this should be changed to the NPPF wording:
positive contribution.
Action:
Amendment completed.
Do the exceptional circumstances relating to apartment development (point (4)) include the
conversion of historic buildings?
Action:
Yes.
How and why do we wish to resist 100% affordable housing developments?
Action:
100% affordable housing developments can be resisted by granting planning approvals
for a mix of tenure, and the objective is to create mixed communities. Smaller
developments (less than 10 dwellings) can still be 100% affordable because they could
still contribute to a mixed community, whilst larger developments should create a mixed
community within the site.
- How can you refuse a housing application that ‘doesn’t widen choice’?
- Shouldn’t appropriate apartment development be encouraged as it is higher density/sustainable
and efficient use of land? Isn’t there an affordable need for smaller apartments given bedroom
tax?
Action:
The policy aims to be a positive statement about how the Borough needs to develop.
Each proposal would be treated on its own merits, and a proposal could be refused if it
doesn’t provide an appropriate mix. This offers sufficient flexibility at the same time as
deterring poor quality applications. Appropriate apartment development will be allowed,
and is encouraged in the Town Centres.
Is this justifiable when some conversions are permitted development? Do we have evidence to
Page 7 of 12 APPENDIX 10
Policy No.
(Consultation
version)
8
8
Policy No.
(Publication
version)
19
19
Respondent
SUMMARY OF REPRESENTATION
(JWPC Ltd)
justify the policy?
Action:
The policy is part of a range of interventions which the Council is carrying out to manage
the high concentrations of HMO development, which is a cause for concern in the
Borough. An SPD has been produced, an Article 4 direction has been implemented, and a
multi-agency group regularly meets to attempt to tackle the problem.
Amend point (iv) to read: “adequate refuse/recycling collection facilities are provided.”
Stuart Hammond
(BwD Environmental
Services)
Matthew Symons
(Sedgwick Associates)
9
21
Gary Hoerty
(GH Associates)
9
21
Matthew Symons
(Sedgwick Associates)
10
22
Gary Hoerty
(GH Associates)
10
22
Matthew Symons
Action:
Amendment completed.
Why is Bed & Breakfast accommodation being deterred? What about tourism?
Action:
The policy allows for the development of bed and breakfast accommodation ‘only
exceptionally’. Appropriate tourism development is likely to be an exception.
Why is economic development preferred over residential development; how can adequate
marketing be evidenced and how is it justified? Section 55 of the NPPF and Green Belt Policy
supports residential development. Is an economic use more sustainable than a residential use,
considering transport and infrastructure impacts? Recent appeal decisions have considered this
point (GH to provide details).
Action:
The Council’s strategy is to direct new residential development into the most sustainable
urban locations. Economic development is the preferred option for conversions in the
rural areas to help provide jobs and services for people living in the rural areas.
2-storey extensions are not allowed but this seems a harsher test than NPPF green belt policy
which just requires extensions to not be disproportionate. There could be instances where 2storey extensions would be acceptable?
Action:
Policy wording amended as suggested.
Could details of size criteria be included? Suggesting a maximum of 200 square metres which
has been mentioned in appeal decisions (GH to provide details).
Action:
A specific size has not been included in the policy as it would be overly prescriptive, as
buildings to be converted could be very small (and therefore dwarfed by a 200 square
metre extension) or very large. Extensions should not unacceptably impact on the
character and openness of the rural area.
Part 2 removes PD rights but I wouldn’t have thought the removal of all PD rights would be
Page 8 of 12 APPENDIX 10
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
SUMMARY OF REPRESENTATION
(Sedgwick Associates)
necessary all of the time?
Action:
‘In appropriate cases’ has been added to the policy wording.
Section 54 of the NPPF mentions market housing being allowed to facilitate the provision of
affordable housing.
Action:
In accordance with Section 54, the potential for market housing to facilitate the provision
of affordable housing was considered, but not considered appropriate considering
Blackburn with Darwen Borough Council’s targeted growth strategy which directs
residential developments into the urban and village areas. Rural exceptions in the
Borough are considered to only be appropriate to provide affordable housing to meet a
local need.
To be eligible, will individuals already need to live in the locality?
12
24
Matthew Symons
(Sedgwick Associates)
12
24
Neil Watson
(Pendle Borough
Council)
14
16
16 / 20
18
26
30
30 / 33
31
Peter Iles
(LCC Specialist
Advisory Services)
Peter Iles
(LCC Specialist
Advisory Services)
Stephen Lamb
(Chorley Borough
Council)
Stephen Lamb
(Chorley Borough
Action:
The occupancy of the dwellings will be restricted to individuals accepted as requiring
affordable housing in the locality.
Should a quality test be added to point (iii), in terms of the quality of the establishment?
Action:
This is covered under the Core Design Policy.
Should a point (iv) be added, to consider the concentration of uses in the vicinity; to prevent
blocks of a single use developing?
Action:
Policy wording amended.
What locations are inappropriate for hot-food takeaways and why? How has the council
demonstrated that such a policy will not undermine the vitality and viability of centres?
Action:
In order to balance public health impacts, the policy steers hot food takeaways away from
inappropriate locations such as close to schools; and more detail is to be provided in an
SPD. If a proposal could harm viability and vitality, a balanced decision will be made at
planning application stage.
What is the evidence that ‘3 adjoining non-retail uses in a block’ would cause harm/undermine
vitality?
Page 9 of 12 APPENDIX 10
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
SUMMARY OF REPRESENTATION
Council)
19
32
Matthew Symons
(Sedgwick Associates)
19
32
Stephen Lamb
(Chorley Borough
Council)
21
34
Gary Hoerty
(GH Associates)
21
34
Judith Furlonger
(PLACE)
22
35
Matthew Symons
(Sedgwick Associates)
23
36
Neil Watson
(Pendle Borough
Council)
Action:
An assessment of the number of typical units in a block has taken place, and three
adjoining units were considered to be the tipping point at which non-retail uses would
undermine vitality.
Part 1(i) refers to a 100sq m maximum for local shops. We have used the floorspace set by the
Sunday Opening Hours regs as the limit for local shops previously. I don’t recall what the limit for
being able to open all day Sunday is, but I think it is more than 100 sq m and would provide a
justified approach (if you wanted it) towards allowing for example, Tesco Metros – that sort of
shop which really only serves its local community or passers by, but has to be bigger than 100 sq
m.
Action:
Maximum floorspace increased to 250 square metres.
What is the evidence that >100 sq m is not appropriate outside centres. Or that there should be a
limit to 350sqm for conversions?
Action:
The maximum floorspace has been increased to 250 square metres, which links to Sunday
trading regulations for local shops. 350 square metres is considered to be an appropriate
upper limit for conversions because it allows more flexibility for this situation without
harming vitality and viability elsewhere.
Will there be a definition of large numbers of trips?
Action:
No, it will be a case-by-case judgement in order to retain flexibility.
Regarding point (iv), could we require developments to face the canal, to encourage more
tourism along the Blackburn with Darwen section of the canal?
Action:
Covered in Policy 26.
Will there be a definitive list of buildings?
Action:
There will be an ‘Assets of Community Value’ list, and other community buildings will be
considered on a case-by-case basis.
What is point (2) saying?
Action:
Page 10 of 12 APPENDIX 10
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
23
36
Philip Carter
(Environment Agency)
24
37
Emily Hrycan
(English Heritage)
26
40
Alison Truman
(Canal & River Trust)
27
39
Matthew Symons
(Sedgwick Associates)
27
General
comment
General
comment
General
comment
39
General
comment
General
comment
General
comment
Stephen Lamb
(Chorley Borough
Council)
Alison Truman
(Canal & River Trust)
Alison Truman
(Canal & River Trust)
Alison Truman
(Canal & River Trust)
SUMMARY OF REPRESENTATION
It is intended to steer people towards particularly high standards.
Under point (4), could the following be inserted: “all development must be located and designed”?
Action:
Amendment completed.
Please delete the second sentence of the third paragraph.
Action:
Amendment completed.
The Trust is pleased to note that the Leeds & Liverpool Canal is recognised as an important
component of green infrastructure and supports the requirements of draft policy 26 relating to
development proposals in the vicinity of the waterway.
Action:
Noted.
Should conserve or enhance be amended to sustain or enhance as per the NPPF?
Action:
Amendment completed.
Should there be specific mention of the need to protect and enhance heritage assets and identify
and protect locally important areas and buildings?
Action:
All included in the policy.
Why is Blackburn with Darwen Borough Council not progressing with CIL?
Action:
It is considered to be too inflexible given the viability picture of the Borough.
What actions are being taken regarding the Duty to Co-operate?
Action:
Separate meetings have taken place and a Duty to Co-operate report is to be produced for
examination with the Plan.
The Trust is also keen to provide up-to-date information about the condition of the waterway
infrastructure and any programmed improvements, in order to inform any future review of the
council’s Infrastructure and Delivery Plan. You may be aware that Chorley’s IDP identifies the
upgrading of the canal towpath between Botany and Blackburn as a priority project in order to
improve cycle access. It would therefore appear necessary for the short stretch within
Blackburn’s administrative area (from the local authority boundary to Livesey Branch Road) to be
Page 11 of 12 APPENDIX 10
Policy No.
(Consultation
version)
General
comment
Policy No.
(Publication
version)
General
comment
Respondent
Terry Burke
(Lancashire Police)
SUMMARY OF REPRESENTATION
similarly identified, as this stretch would require upgrading in order to facilitate increased use by
cyclists. The council may wish to co-operate with neighbouring local authorities including Chorley
in respect of the canal corridor and the Trust would be keen to be involved in any such cooperative working.
Action:
Noted. The Canal & River Trust will be included in any co-operative working regarding the
canal.
Request a crime and community safety policy, for example “Plan for reduced levels of crime and
improved community safety by: (a) working with the police, community safety partnerships and
other agencies to co-ordinate analysis and action’. (b) Encouraging the inclusion of Secured by
Design principles in new developments. (c) Providing adequate leisure and community facilities
or activities, particularly in high crime areas, and especially for young people. (d) Aiming to
achieve a complementary mix of uses in key service centres with appropriate controls over
entertainment uses, taking account of the local authorities’ Statement of Licensing policies.”
Also suggest that Crime Impact Assessments should be required for all major developments,
some minor developments including changes of use which may increase the risk of crime and
disorder, and sensitive developments which are sited in an area where crime and disorder is a
particular local issue. Crime Impact Assessments should include an assessment of crime and
disorder issues in the vicinity of the development site; an assessment of the development
proposal in terms of its likely impact on crime and disorder; and suggested design solutions that
will reduce the proposal’s vulnerability to crime and disorder.
Action:
Part (v) of Policy 2 has been added to address this issue, and more detail will be provided
in a Supplementary Planning Document. Crime Impact Assessments are required in
appropriate circumstances in accordance with the Validation Checklist.
Page 12 of 12 APPENDIX 10
APPENDIX 11: Summary schedule of representations relating to Development Management Policies – August-September 2013
Local Plan Part 2: Site Allocations and Development Management Policies
REGULATION 18 Consultations: Preparation of a Local Plan
Policy No.
(Consultation
version)
2
Policy No.
(Publication
version)
8
Respondent
SUMMARY OF REPRESENTATION
Mark Harrison
(The Coal Authority)
2
8
Philip Carter
(Environment Agency)
2
8
Andrew Leyssens
The Blackburn with Darwen area has been subject to past coal mining activities which has left a
significant legacy, including approximately 860 recorded mine entries. These mining hazards
pose a potential risk to land stability, which needs to be afforded due consideration as part of
development proposals.
It is therefore considered important that plan users are made aware that unstable land is a locally
distinctive issue that may require consideration as part of development proposals. Whilst The
Coal Authority was pleased to note that the adopted Blackburn with Darwen Core Strategy
included reference to unstable land in Policy CS13, we consider there is an opportunity to make a
minor amendment to this Development Management Core Policy to further highlight the issue.
Whilst The Coal Authority does not wish for the Council to unnecessarily repeat policy, it is a
reality that plan users may not consider all parts of the Development Plan, so a brief cross
reference in the Development Management Core Policies document would be beneficial. The
Coal Authority would therefore recommend the following change to criterion iii):
“…in the case of previously developed or other potentially contaminated and/or unstable land, a
land remediation scheme can be secured…”
Action:
Amendment completed.
NPPF para. 103 refers to ‘giving priority’ to the use of SUDS, but including a reference to the
‘need’ for SUDS in the DM policies will add extra weight and greater certainty about what the
Council expects new development to include. SUDS covers a wide range of techniques so pretty
much any development could include some form of SUDS system, from permeable paving to
large scale balancing ponds. Suggest the following extra wording at the end of section 3 of
Policy 2.
“Development will be expected to incorporate sustainable drainage systems to manage surface
water run-off from new development.”
Action:
An additional criterion added to Policy 3, requiring development with the potential to
create significant amounts of new surface water runoff to consider, and wherever possible
implement, options for the management of the surface water at source. SUDS not
specifically mentioned in order to retain flexibility.
Suggest the following sentence is added at the end of Policy 2 (ii):
Page 1 of 13 APPENDIX 11
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
SUMMARY OF REPRESENTATION
(United Utilities)
‘Sensitive uses should be located an acceptable distance away from existing sources of
pollution.’
Action:
Adequately covered under Policy 2 (ii).
Suggest the following words are inserted after ‘flooding’ in section 3:
‘and that surface water is being dealt with by the most sustainable means possible.’
Action:
An additional criterion added to Policy 3, requiring development with the potential to
create significant amounts of new surface water runoff to consider, and wherever possible
implement, options for the management of the surface water at source.
Part 2: Blackburn with Darwen could consider making explicit reference to the need for new
development to avoid increasing the vulnerability of biodiversity (habitats and species) to climate
change. This also cross-references with the ecological network.
3
9
Andrew Leyssens
(United Utilities)
3
9
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
3
9
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
3
9
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
Action:
Rather than referring to biodiversity within the Climate Change section, alterations have
been made to the Habitats and Species section.
Suggested text amendments in bold:
Green infrastructure
4. Development that results in the fragmentation of or compromises the function of Blackburn with
Darwen’s green infrastructure will not be permitted unless:
i. the harm caused is significantly and demonstrably outweighed by other planning
considerations; and
ii. an appropriate mitigation strategy can be secured.
Habitats and Species
5. Development likely to damage or destroy habitats or harm species of international
or national importance will not be permitted.
6. Development likely to damage or destroy habitats or species of county importance (habitats or
species of principal importance) will not be permitted unless the harm caused is significantly
and demonstrably outweighed by other planning considerations and an appropriate mitigation
strategy can be secured.
Action:
Amendments completed.
Part 13 only requires that opportunities are explored, and not that enhancements are provided.
Consider strengthening this to require development to contribute to net gains for biodiversity (i.e.
sustained increase in abundance, quality and extent of species and habitats that support healthy
ecosystems (TCPA, 2012)).
Action:
Page 2 of 13 APPENDIX 11
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
3
9
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
3
9
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
3
9
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
SUMMARY OF REPRESENTATION
The policy text in section 13 has been amended to include enhancements.
Habitats and Species Section: Draft policies are not proactive in specifying what will be
acceptable development, focusing more on what would be unacceptable. Consider amending to
say that development will be expected to conserve and enhance biodiversity, focussing on
species and habitats appropriate to the local natural area (including national and local priority
species and habitats).
Action:
The starting point is to protect against harm, so the policy reflects this in the most concise
way. Enhancements are also required by section 15 of the policy. Further details will be
provided in the proposed Green Infrastructure Supplementary Planning Document.
Core policies do not appear to promote conservation of species or habitats or the ecological
network.
Core policies do not appear to make distinction between the hierarchy of designated sites and fail
to mention Local Sites (Biological Heritage Sites). Government guidance emphasizes that Local
Sites are of substantive nature conservation value and have a fundamental role to play in helping
meet national biodiversity targets. Point 6 should be re-written to make specific mention of
habitats and species of county importance including BHS and species and habitats listed in the
Lancashire BAP.
Note that point 9 dealing with trees states that development will be expected to incorporate
existing trees into the design and layout of the scheme. It is unclear why development (points 5 –
7) would similarly not be expected to incorporate species and habitats into the design of the
layout of the scheme. I appreciate that this is dealt with under green infrastructure, but should be
more explicitly dealt with under 'biodiversity'.
Action:
The Habitats and Species section amended to be clearer regarding the hierarchy of
designated sites, including Biological Heritage Sites.
Section 5 is slightly confusing, since it does not refer specifically to designated sites, protected or
priority species or habitats (e.g. UK BAP/ Habitats and Species of Principal Importance in
England (section 41 NERC Act 2006)). However, reference to international importance suggests
European designated sites and European protected species and, following on from that, national
importance presumably refers to nationally designated sites (e.g. SSSI) and species protected by
domestic legislation.
Policy should not repeat legislation. The statutory protection enjoyed by international sites means
that protection by policies in the local plan are not necessary, although it is good practice for
explanatory text to cross reference to the relevant legal protection.
Similarly, the local policy should not repeat the NPPF reference to SSSIs but could cross
reference to it to ensure that development management decisions apply government policy.
Similarly, legally protected species do not need policy protection in the Local Plan but, using
information on the status and distribution of protected and priority species collected as part of the
Page 3 of 13 APPENDIX 11
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
3
9
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
3
9
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
3
9
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
3
9
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
SUMMARY OF REPRESENTATION
evidence base for production of the LDF, specific policies could be developed to protect areas
where these species are most likely to occur and for the protection and enhancement of
populations to inform the location and design of development.
Action:
Separate protection legislation is acknowledged, but it is considered necessary to also
include it in planning policy.
Section 6 is similarly confusing, as it refers to habitats or species of county importance (habitats
or species of principal importance). Whilst habitats and species of principal importance will be of
importance at the county level, it should be noted that these are actually of importance in England
(section 41 NERC Act 2006), i.e. those identified as requiring action in the UK Biodiversity Action
Plan (UK BAP). Habitats and species of county importance will also include those listed in the
Lancashire Biodiversity Action Plan. When dealing with species and habitats of importance at the
county level, it would seem appropriate to make specific mention of Local Sites (referred to as
Biological Heritage Sites in Lancashire) under this policy, and to deal positively and in more detail
with their protection and enhancement through the planning system.
Action:
Section 6 amended as advised.
Section 7 appears to differ only the substitution of 'local' for county and the omission of the
phrase 'significantly and demonstrably'. Features of local importance only are not clearly
identified. It may be difficult to apply this policy in a consistent and predictable way.
Action:
Features of local importance will be identified in a Supplementary Planning Document
which will assist in the application of this policy.
Sections 6 and 7 refer only to 'an appropriate mitigation strategy'. Mitigation relates to a reduction
in impact, and does not imply that the impact would need to be fully offset. This form of wording
does not appear to be in accordance with the requirements of the NPPF paragraph 118. I note
that policy 24 (wind turbines) refers to the need for residual harm to be mitigated or
compensated. It is not clear why other forms of development (referred to under other policies)
would not similarly need to compensate for residual impacts on biodiversity.
Action:
The requirement for an appropriate mitigation strategy will ensure that potential impact
can be balanced against proposed mitigation, and only be accepted if the mitigation
strategy is found to be adequate in accordance with the NPPF paragraph 118.
Sections 5 to 7 deal with what will not be acceptable development, but do not deal with what
would constitute acceptable development. Consideration should be given to including stronger
reference to the need for development to incorporate features of existing biodiversity value, and
to enhance them, and the ecological network (including habitat connectivity).
Page 4 of 13 APPENDIX 11
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
3
9
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
3
9
Dave Dunlop
(Lancashire Wildlife
Trust)
3
9
Kezia Taylerson
(South Ribble Borough
Council)
5
11
Andrew Leyssens
(United Utilities)
SUMMARY OF REPRESENTATION
Action:
This consideration is covered in Policy 40 – Integrating Green Infrastructure with New
Development.
Policies could refer to the need to maintain habitat and species connectivity, i.e. development
should maintain and enhance habitat and habitat connectivity for locally appropriate protected
and priority species and habitats and should contribute to the maintenance and enhancement of
the ecological network.
Even where significant impacts on biodiversity are not predicted, and where such measures
would be appropriate, development should deliver beneficial biodiversity such as bat roosts and
bird boxes and landscaping tailored to support the specific species being accommodated.
Consider specifying what biodiversity enhancement should be included, in generic terms, e.g. bat
roost and bird nest, landscaping for local wildlife etc.
Action:
Additional criteria added to the habitats and species section, regarding the ecological
network.
Suggested wording for the Habitats and Species section:
Development that results in further fragmentation of, or compromises the function of, Blackburn
with Darwen’s ecological network will not be permitted unless:
i. the harm caused is significantly and demonstrably outweighed by other planning
considerations; and
ii. an appropriate mitigation strategy can be secured that results in, as a minimum, no net loss of
functionality of that network as it relates to the delivery of targets in the current Local Plan.
Justification - NPPF states that policies should also ‘promote the preservation, restoration and recreation of priority habitats, ecological networks and protection and recovery of priority species
populations’ linked to targets in the plan. (paragraph 117)
Action:
Additional criterion added as advised.
Regarding the section on Habitats and Species – no specific reference to Ecological
Frameworks. We note a brief reference in Policy 26 later in the document. Have you considered
how you will be taking forward the work from the Lancashire Nature Partnership, including
mapping. As we mentioned at the meeting on 22 August we are preparing a Joint Central
Lancashire SPD which will include this information.
Action:
Additional criterion added regarding ecological networks. A Supplementary Planning
Document will also be produced.
- Suggest the following words are added at the end of section 6(iii):
‘including minimising surface water discharge’;
- Suggest the following words are added at the end of section 6(v):
Page 5 of 13 APPENDIX 11
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
7
18
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
20
33
Kezia Taylerson
(South Ribble Borough
Council)
23
36
Andrew Leyssens
(United Utilities)
24
37
Andrew Leyssens
(United Utilities)
SUMMARY OF REPRESENTATION
‘and incorporate water efficiency measures.’
Action:
These requirements are covered under an additional criterion added to Policy 3.
Many species (e.g. bats and birds) are reliant upon the built environment to provide roosting and
nesting opportunities. Clearly, conversion and redevelopment should be required to maintain preexisting opportunities for wildlife (bats and birds). The NPPF does encourage enhancement and
net gain so, even where there may be not specific mitigation or compensation requirement,
consideration should be given to requiring new builds (urban and rural) to build opportunities for
locally characteristic species of bat and bird into the fabric of the build. Associated landscaping
should be developed to complement the bat roost/ bird nest provision.
I appreciate that this issue is introduced under policy 26 green infrastructure, but it would seem
appropriate to explicitly mention it under built development policy since built development is not
actually part of the green infrastructure.
Action:
Policy 3 requires all developments to explore opportunities for enhancements, including
for habitats and species.
Health policy – we acknowledge your policy aiming at dealing with Hot Food Takeaways and
restricting permission in areas where it is likely to lead to an increase in consumption by young
people. We would be interested to hear from you with regards to your evidence base as we are
currently reviewing our Access to Healthy Food SPD.
Action:
Details of evidence base have been provided.
Suggest the following is added as section (6):
‘All development will be expected to incorporate water efficiency measures. New residential
development will be expected to achieve a target water use of no greater than 105 litres per
person per day. This will rise as appropriate with any change in national standards.’
Will you be proposing the delivery of new housing to be in accordance with Code Level 3 of the
sustainable homes? This specifically encourages water efficiency measures which reduce
pressure on our water supply infrastructure whilst also reducing the flows passing through our
wastewater infrastructure.
Action:
Not included due to viability concerns, and because such requirements are controlled via
Building Regulations, with standards subject to regular change.
- Suggest the following is added as criterion (ix):
‘the development does not harm land which is used for water catchment purposes in the borough
and is critical to the delivery of water supply.’
- Suggest the following additional text:
‘New renewable energy infrastructure will not be acceptable on land which is used for water
Page 6 of 13 APPENDIX 11
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
24
37
Mark Harrison
(The Coal Authority)
24
37
Kezia Taylerson
(South Ribble Borough
Council)
SUMMARY OF REPRESENTATION
catchment purposes which is also deep peat. Development on land that has a peat layer greater
than 50cm deep where water is currently used or is planned to be used for drinking water supply
is not acceptable. This is because of the resultant long-term negative impact on water quality
when peat is disturbed. The development of wind farms on peat soils has a number of associated
risks which include:
 major disruption to the hydrology of the area results in long-term degradation of the peat
leading to increase in organic carbon compounds in the water. Decreases in raw water
quality result in an increase in the treatment required at the water treatment works and, in
the long term, the requirement for additional investment for treatment improvements.
Damage to peat soil systems as a result of construction may be impossible to restore;
 generation of sediment (eroded peat) will reduce the capacity of reservoirs over time;
 when peat is disturbed, a habitat which should be sequestering carbon can emit carbon in a
variety of forms, Dissolved Organic Carbon (DOC), Particulate Organic Carbon (POC),
gaseous CO2; and
 alteration of the hydrology of streams associated with peat bodies may negatively influence
the flood hydrograph of river catchments, thereby accentuating flood risks downstream.
In general once a peat system has been disturbed, this tends to precipitate a chain reaction of
events that leads to loss of carbon, degradation of habitat, negative impacts on raw water quality
and alterations to the hydrological functions and services of the upper catchments of river
systems.’
Action:
The avoidance of harm to the quality and yield of water resources is covered under Policy
3(vi).
Wind farms can often cover significant areas of land, which can have a sterilising effect on
mineral resources during their period of operation, generally 25 years. As the Council will be
aware, the Blackburn with Darwen area contains coal resources that are capable of extraction
using surface mining methods.
Given the potentially sterilising effect of wind farms on mineral resources, The Coal Authority
considers that the Development Management Core Policies should require this issue to be
afforded due consideration, and therefore recommends the following minor amendment to
criterion 1.vi) as follows:
“…the development has no unacceptable impact on local hydrology and safeguarded mineral
resources.”
Action:
Amendment completed.
Would be interested to be engaged in the reaction to this policy. What is your definition of ‘no
unacceptable impact’? We are currently preparing a Renewable Energy and Low Carbon SPD
and would be interested to find out more information if possible.
Page 7 of 13 APPENDIX 11
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
26
40
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
26
40
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
26
40
Dr Sarah Manchester
(Lancashire County
Council Ecology
Service)
SUMMARY OF REPRESENTATION
Action:
Noted and communication will continue.
Supporting text lists the function of Blackburn with Darwen's green infrastructure, including
"enhances the ecological framework".
There is no specific mention of 'biodiversity' – consider amending policy to specify green
infrastructure and biodiversity. Greater emphasis should be given to the importance of green
infrastructure to our declining biodiversity resource, i.e. green infrastructure is wildlife habitat.
Text refers to the 'ecological framework', and states that this policy will be supported by a
Supplementary Planning Document on green infrastructure and the ecological framework. Point 5
of the policy refers explicitly to the 'ecological network' (as referred to in the NPPF). If framework
and network are being used interchangeably here, consider using network only. If framework
refers to something else, clarify.
Action:
Reference to biodiversity added to the text, and the term network is used instead of
framework.
Section 1 (ii, iii, v and vi): These are clearly desirable elements and it is assumed that the SPD
will provide a greater level of detail, i.e. definition of key local species and guidance on what
features would be appropriate; the types of connections that will appropriate to connect with
neighbouring sites (e.g. woodland, if the neighbouring site is woodland, etc).
However, it should be noted that 'ecological' is of or relating to ecology, and ecology refers to the
relationship between organisms to one another and to their physical environment. Therefore
reference to 'retention and enhancement of ecological features' may be insufficiently specific to
assess development proposals against. Consideration could be given to replacing with 'features
of biodiversity or nature conservation value'.
Creation of woodland and trees should be encouraged, where appropriate. However, there are
many situations where woodland and trees are not appropriate but the creation of other habitat
types would be. Consideration should be given instead to stating that the creation of locally
appropriate habitats (which may include woodland and trees, grasslands, wetlands and
waterbodies) should be encouraged.
Action:
Further clarity and detail responding to these suggestions will be provided in the
proposed Supplementary Planning Document.
Point 4 does stress that functioning ecological networks are key green infrastructure. However,
consideration should be given to further emphasizing the 'biodiversity' element of green
infrastructure, and making clear that sometimes green infrastructure is just wildlife habitat and no
other uses will be acceptable (i.e. it cannot always be multifunctional).
Action:
Comments were considered, and existing wording is sufficient; to be supported by further
Page 8 of 13 APPENDIX 11
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
27
39
Emily Hrycan
(English Heritage)
27
39
Emily Hrycan
(English Heritage)
27
39
Emily Hrycan
(English Heritage)
SUMMARY OF REPRESENTATION
detail in the proposed Supplementary Planning Document.
Section 1 appears to define the significance of heritage assets by providing a list of specific
features. The significance of heritage assets can only be determined on an individual basis
through a proper and accurate assessment of the asset in question (NPPF Para 129). Only then
can a decision be made on what should be retained and replaced both internally and externally.
Therefore, it would be preferable to remove this reference to individual features to ensure that
any aspects that are not included (on your list) are still taken into account.
Action:
Amendment completed.
It is suggested that the policy be reworked to include the following elements:
- A clear explanation of the considerations and approach to development proposals affecting
each of the different heritage asset types, including locally-important heritage assets.
- A clear statement of the approach and requirements for proposals affecting Scheduled
Monuments, nationally important archaeology, and other archaeological remains.
This would greatly help those determining schemes that affect the historic environment to
understand what considerations should be taken into account in reaching a decision about the
appropriateness of the development proposals.
Action:
Rather than specifying each of the heritage asset types, the policy focuses on
interventions being proportionate to the significance of the asset, which applies to all of
the types of heritage asset.
Suggested textual considerations and structure for the policy (to be amended accordingly) is as
follows:
“Proposals for development should protect and, where appropriate, enhance or better reveal
those elements which contribute to the significance of the Borough’s heritage assets:Conservation Areas
 Proposals affecting a Conservation Area should preserve or enhance those elements that
have been identified in the respective Conservation Area Appraisal as making a positive
contribution to their special character or appearance.
 Demolition or other substantial loss to the significance of a building or feature that contributes
positively to the Conservation Area will be permitted only where this harm is outweighed by the
public benefits of the proposal.
 Development which would result in harm to a public or private open space that contributes
positively to the character of a Conservation Area will be permitted only where this harm is
outweighed by the public benefits of the proposal.
Historic Parks and Gardens
 Proposals affecting a Historic Park and Garden should ensure that development does not
detract from the enjoyment, layout, design, character, appearance or setting of that landscape,
Page 9 of 13 APPENDIX 11
Policy No.
(Consultation
version)
27
Policy No.
(Publication
version)
39
Respondent
Peter Iles
(Lancashire County
Council Specialist
Advisory Services)
SUMMARY OF REPRESENTATION
cause harm to key views from or towards these landscapes or, where appropriate, prejudice
their future restoration;
Scheduled Monuments and other archaeological remains
 Development which would result in harm to the significance of a Scheduled Monument or
other nationally-important archaeological site will not be permitted.
 The preservation of other of archaeological sites will be an important consideration. When
development affecting such sites is acceptable in principle, the Council will seek to ensure
mitigation of damage through preservation of the remains in situ as a preferred solution. When
in situ preservation is not justified, the developer will be required to make adequate provision
for excavation and recording before or during
 Development.
Listed Buildings
 Listed Buildings and their settings will be preserved and, where appropriate, enhanced. Loss
of any significance should be minimised, and will be permitted only where any harm is justified
by the public benefits of the proposal.
 The total or substantial demolition of a listed building will be permitted only in exceptional
circumstances.
Locally-important heritage assets
 Development which would remove, harm or undermine the significance of a locally important
heritage asset, or its contribution to the character of the area will only be permitted where the
public benefits of the development would outweigh the harm. Schemes which will help ensure
a sustainable future for Blackburn and Darwen’s heritage assets, especially those identified as
being at greatest risk of loss or decay, will be supported”.
Action:
Rather than specifying each of the heritage asset types, the policy focuses on
interventions being proportionate to the significance of the asset, which applies to all of
the types of heritage asset.
Suggested amended wording for the introduction to Policy 27:
Blackburn with Darwen has ancient origins, and settlement is known from at least the Bronze Age
(2500BC-700BC). The district is traversed by the major Roman road route from Manchester to
Ribchester although the only military occupation site known is the signal station on Mellor Moor.
The pattern of settlement we see today is likely to have been established during the Early
Medieval period (400AD-1066), a church on the site of the present St Marys Cathedral is said to
have been founded in the 6th century and may be that noted in the Domesday Survey. The towns
grew incrementally through the Medieval period, served by a network of farmsteads and smaller
settlements, developing with them a significant woollen industry and slowly exploiting the natural
sources of stone, coal and water-power. Along with developments in transport, these resources
were the key to development during the Industrial Revolution, when a major phase of growth and
Page 10 of 13 APPENDIX 11
Policy No.
(Consultation
version)
27
Policy No.
(Publication
version)
39
Respondent
Kezia Taylerson
(South Ribble Borough
Council)
32
47
Andrew Leyssens
(United Utilities)
General
comment
General
comment
Philip Carter
(Environment Agency)
General
comment
General
comment
Cathy Dean
(Highways Agency)
General
comment
General
comment
Kate Wheeler
(Natural England)
General
General
Kezia Taylerson
SUMMARY OF REPRESENTATION
building took place...
Action:
Existing introductory text is considered to be suitable.
Policy 27 clause 2 - Impact on Impact? Very long policy.
Action:
Wording corrected to impact on significance. Noted that it’s a long policy.
- Suggest the following should be added to the text:
‘In rural areas, applicants should be aware of investigating availability of infrastructure. This may
be limited or not available and therefore development could be costly.’
- Suggest the following is added as section 3 of the policy:
‘It may be necessary to co-ordinate the delivery of new development with the delivery of new or
improved infrastructure to ensure new development is phased and not occupied until necessary
infrastructure works have been carried out. Applicants should be aware that existing
infrastructure in green belt, rural and countryside locations is more likely to be limited.’
Action:
The availability of infrastructure is one of many constraints which may affect the viability
of a development. The DM policies within the local plan do not aim to advise developers
on the range of potential constraints.
The requirement to co-ordinate the phasing of infrastructure in association with
development is to be controlled via suitably worded planning conditions rather than
through policy.
We have reviewed the amended document which includes the changes suggested by the
Environment Agency. As such, we have no further comments to make on the draft document.
Action:
Noted.
The Highways Agency is satisfied with the content of the document with regard to the Council’s
approach to managing the transport implications of new development schemes and ensuring
compliance with other relevant policies. The proposed precautionary and safety measures fully
meet our objectives.
Action:
Noted.
Natural England doesn’t have any specific comments at this stage but we look forward to future
engagement.
Action:
Noted.
We note there are no policies for employment and accept your explanation that the Core Strategy
Page 11 of 13 APPENDIX 11
Policy No.
(Consultation
version)
comment
General
comment
General
comment
General
comment
General
comment
Policy No.
(Publication
version)
comment
General
comment
General
comment
General
comment
General
comment
Respondent
SUMMARY OF REPRESENTATION
(South Ribble Borough
Council)
sufficiently covers this area.
Kezia Taylerson
(South Ribble Borough
Council)
Kezia Taylerson
(South Ribble Borough
Council)
Kezia Taylerson
(South Ribble Borough
Council)
Andrew Leyssens
(United Utilities)
Action:
Noted.
Policy 3 on Climate Change and Environment and Policy 23 on Climate Change within the
Environment chapter – some similarities/ repetition within each policy for your awareness.
Action:
Noted.
Policy 3 discusses Green Infrastructure, as does Policy 26. Are there some cross overs here?
We note the reference to ecological networks within this policy.
Action:
The Green Infrastructure policy (26) is distinct as it refers to Integrating Green
Infrastructure with New Development. Policy title amended accordingly. Policy 3
(Development and the Environment) focuses on the prevention of harm to green
infrastructure rather than the provision of enhancements required by Policy 26.
General comment – policy wording relates to ‘planning permission will not be granted’ etc. Our
advice was to phrase policies positively ‘planning permission will be granted where …’
Action:
Some policies are positively worded, such as Policy 11 (Design). Where the policy test is
an impact one, the policy has been phrased in the most concise way to reflect the
avoidance of harm.
We recommend the insertion of a new policy on surface water:
‘Surface Water
The treatment and processing of surface water is a not a sustainable solution. Surface water
should be managed at source and not transferred. Every option should be investigated before
discharging surface water into a public sewerage network. Surface water should be discharged in
the following order of priority;
 An adequate soakaway of some other form of infiltration system.
 An attenuated discharge to watercourse.
 An attenuated discharge to public sewer.
Applicants wishing to discharge to public sewer will need to submit clear evidence demonstrating
why alternative options are not available. Approved development proposals will be expected to be
supplemented by appropriate maintenance and management regimes for surface water drainage
schemes. This will be secured by planning condition.
On greenfield sites, applicants will be expected to demonstrate that the current natural discharge
Page 12 of 13 APPENDIX 11
Policy No.
(Consultation
version)
Policy No.
(Publication
version)
Respondent
SUMMARY OF REPRESENTATION
solution from a site is at least mimicked. On previously developed land, applicants should target
a reduction of at least 30% in surface water discharge, rising to a target of 50% in any critical
drainage areas.
A discharge to groundwater or watercourse may require the consent of the Environment Agency.
Landscaping proposals should consider what contribution landscaping of a site can make to
reducing surface water discharge. This can include soft and hard landscaping such as
permeable surfaces.’
Action:
Additional criterion added to Policy 3, relating to the management of surface water at
source wherever possible.
Page 13 of 13 APPENDIX 11