1. Introduction

This submission is based upon the representations of the people of Westhoughton and their reactions to the proposals, and my own personal experiences in my capacity as a BMBC Councillor and a resident of Westhoughton.

1. The area of the proposed development has a great biodiversity with rare and protected wildlife and diverse flora and fauna. The presence of a number of protected wildlife species together with the concentrations of diverse and delicate array of Ornithological Mammalian, Botanical, Insect and Hepidoptera species and their habitats must be protected. Through the area, many animals use the site as a wildlife corridor to and from other locations. On many occasions late at night or early in the morning many of these animals can be observed in the adjoining gardens rummaging for food.
2. Bolton MBC has a policy for Agenda 21 and clearly many of the proposals contained therein have significant implications for the wildlife outlined above.

2.1 The local authority’s UDP has been in existence for a number of years and is currently in a review process this will go out for a public consultation during the second quarter of 2000. Therefore to proceed on the current proposal would be premature and deny the people of Westhoughton the opportunity to shape and influence the future of the surrounding areas of Westhoughton for the next 10 years.

2.2 The developer has suggested that the site is of strategic importance to the borough as a whole. This is extremely difficult to accept given that other sites have had and still have preference over Lee Hall e.g. Middlebrook and Wingates.

2.3 Loss of this open space would be detrimental to the community, because many people utilise it for recreational purposes with its network of footpaths giving opportunities for exercise. Our predecessors in Victorian times adopted sensible measures to provide the community with parks and open spaces as green lungs. Local people would be faced with additional unnecessary journeys up to Rivington, Belmont and beyond for this purpose. All this is at odds with the modern trend of reducing unnecessary travel by car. Many constituents have indicated that increasingly they are able to enjoy the area by being able to stroll through local fields away from the noise and bustle of modern life, it being a safe haven. This is borne out by a survey by the Countryside Agency in 1998 where six out of ten people thought their immediate countryside was of significant and real importance to them.

2.4 The current UDP is very precise and states that the development of the northern part of the site cannot proceed until the final alignment of the proposed Wigan, Hindley and Westhoughton Bypass is known. The southern part of Lee Hall should remain open land until the access constraints can be resolved. Therefore without the Bypass there cannot be a development.

3.1 Traffic Impact Assessment outlined by the developer is poor, lacking in detail and traffic counts are now out of date having been done in 1997.

3.2 As part of the development package it is suggested will include the first part of the A5225 trunk road from M61 to M6. The road as proposed has inadequate provision for link roads to all areas of industrial site, it is clearly a short stretch of dual carriageway which leads from Chequerbent roundabout to Platt lane near to the railway line and will do nothing to alleviate traffic congestion in Westhoughton. It will cause considerable inconvenience to residents of Platt Lane and on to Atherton who may have increased congestion outside their properties and it cannot be described even in the loose terms a trunk road.

3.3 Proposals for a Park and Ride scheme would not be viable because the nearest railway station, Daisy Hill, does not have a direct link to Bolton. Westhoughton station has no carparking facilities and is approximately 1 mile to the West.

3.4 During the morning and evening rush hours there is heavy congestion on Park Road, Leigh Road, Wigan Road and Church Street. At its peak near to commencement of the school day, tailbacks run all the way from Daisy Hill to Chequerbent and through Wigan Road to beyond Wearish Lane and out towards Hindley/Wigan.

3.5 The last 12 months have seen 3 serious road traffic accidents in the Westhoughton area. This resulted in gridlock for several hours whilst the situations were resolved by the emergency services. This application would have a clear and very significant impact on traffic flows and increase congestion in the area.

3.6 There are significant deficiencies in the proposals these are as

follows: -

3.6.1 No definite plans for permanent additional bus services through the site.

3.6.2 Predictions for Park Road are that its capacity will be exceeded by 25% within the next 10 years.

3.6.3 Currently at peak evening rush hour traffic queues form from the beginning of the slip road of Junction 5 down to where it joins the A58 at Snydale Way with traffic from the east and south of the motorway network.

3.6.4 Extra commercial vehicles and cars using the industrial estate on a daily basis leaving and entering would add to congestion on the existing infrastructure.

3.6.5 Westhoughton railway station is not close enough for regular use to and from the site.

3.6.6 No direct links exist to Westhoughton or Daisy Hill stations

3.6.7 There exists a lack of confidence in public transport services.

3.6.8 Existing rail services have an unenviable reputation for unreliability

3.7 No significant major relief road scheme exists to reduce congestion in Westhoughton. There are four main roads in Westhoughton, Park Road, which services through traffic from Daisy Hill to the south of the town, Hindley/Wigan to the west. Bolton Road provides an alternative route to Bolton and a deviation to Chequerbent roundabout. Leigh Road and Wigan Road provide access and egress to the large housing developments to the south and west of Westhoughton. These roads were constructed at the beginning of the last century and were not capable of carrying the traffic flows of today.

3.8 Any additional increase to these routes to and from Chequerbent roundabout would only add to traffic flows and would have a very real impact with increased commercial and commuter traffic at peak times.

3.9 There are already very real, well-documented and identifiable risks to health, caused by the emissions of exhaust fumes from traffic. Lead-free petrol contains benzene, a notorious cancer-causing agent and there are links to skin disorders etc

3.10 Chequerbent Roundabout features regularly on the early-morning breakfast road bulletins on local radio stations, because of the heavy congestion and queuing traffic on Park Road. By adding an additional link road into the proposed site it would have a considerable knock-on effect on congestion. It would add to the accident potential with its nine radial arms.

4.1 As outlined in my introduction it is ridiculous to suggest that an ecological survey can be carried out during a few hours on one day in August 1997. The survey must be carried out over a twelve-month period to cover all four seasons of the year to collate the animals and plant life etc which exists in the area.

4.2 Many animals, birds and invertebrates will undoubtedly use the area on a seasonal or monthly basis. The nocturnal activities of birds such as owls and bats and the many badgers, which inhabit the area, have been overlooked in the developer’s survey.

4.3 In the report it suggests that the area is "species-poor, semi-grassland which in part has grown rank" The timescale, the method of survey and locations used for the survey cannot hope to be taken seriously as a qualitative or quantitative survey.

What may appear to be poor, useless land is the perfect habitat for the great-crested newt protected under the Wildlife and Countryside Act 1981. This animal thrives on a large habitat of rank, marshy, grassland and scrub in order to survive.

Large areas of the site are perfect grasslands for foraging by badgers and track marks are clearly visible on many of the pathways. The decline in the badger population has been caused by the loss of this type of area.

It is well known that bats roost in farm buildings and mature trees. The development would lead to a severe decline in the bat population as they would have lost essential feeding grounds and it is ridiculous to suggest that they would easily relocate elsewhere.

This site provides essential links in the chain of wildlife corridors, which criss-cross the area and allow animals and man to co-exist.

It has been identified as a hot spot on previous wild life surveys for the Local Authority. There can be little doubt wildlife links would be severed. Feeding and breeding habitats lost, species such as the skylark, lapwing. Great-crested newt etc would be adversely affected by the loss of open green space.

The whole area around the site is fed by ancient springs or issues, which link the chain of ponds and watercourses, which meander across this land and finally pass through Pennington Flash and on to the Mersey Basin. Any change to these links may have very serious implications further afield. Any alteration to this delicate balance of the water table may have serious consequences to human, animal and plants life in the area and beyond. There is a real threat of pollution of the Mersey Basin from contaminants entering the surface water and then contaminating the under-lying aquifer, which would transfer over a wider area through ground water, and via Westleigh and Pennington Brooks.

The intrusion into the everyday lives of the residents of Park Road and Chequerbent from dust, noise and light pollution should not be under-estimated when assessing the implications for the local population.

5.1 When the developers made the original planning application, it included a Business Park and Housing Development for something of the order of 1100 houses. It has been suggested that this was withdrawn due to pressure from SWAN and local residents. It is more likely that the Developer has covert motives and wishes to proceed on a piecemeal basis. By nibbling sections of the land with the objective of gaining permission for this, to build with a better chance of success therefore and important objective of the Inquiry must be to search out the "masterplan" of the whole site.

5.2 I believe that the present planning application is severely flawed and is based on the developers’ intention to utilise the whole site to the detriment of the whole community. I am sure that the Appellant and his advisors are acutely aware of the implications of the larger development and consider that there is a better chance of this application having a higher success rate.

6.1 Governmental policy statements have recently clearly set out an important agenda for the effective protection of the environment. Ministers have stated that we must act to limit global environmental threats such as climate change, protection of human health and safety hazards from poor air quality and toxic chemicals. This will encompass those things which people value i.e. wildlife, landscapes and historic buildings. There is therefore a clear need to respect environmental objectives whilst preserving our cultural heritage and natural resources reducing the need to travel significant distances.

6.2 Local residents value all of these objectives and have expressed their horror at the potential of yet more building development in the area. The prospect of increasing poor air quality from the development and the associated increased traffic volumes has grave implications for those at most risk i.e. the young and old.

6.3 Our children are now faced with the prospect of an urban sprawl with few if any open spaces. They are our future. Tomorrow's population and have expressed their concerns at the way scarce resources, open spaces are being utilised because of avarice and greed.

6.4 The DETR document Planning for Sustainable Development Towards Better Practice, states that not all rural areas are the same. Near to major cities the key sustainable development objectives will relate to avoiding urban sprawl, retaining and improving distinctive landscapes and managing recreational pressures.

7.1 The Appellant has suggested that as part of this development he will agree to construct the first phase of the proposed A5225. Therefore the requirements for this will need to be of a much higher standard than is being proposed. The original proposals were for an underpass through the Chequerbent roundabout. It would therefore seem to me appropriate to expect the developer to include this in the overall plan for this section of highway.

7.2 The route of the proposed bypass still has a reserved status and therefore it would be premature and inappropriate to consider the application until a final decision has been made on whether to proceed or cancel the route

8.1 This development cannot nor must not be taken in isolation when considered by the inquiry. There are additional proposals under consideration, which will have a cumulative effect on Westhoughton. These are as follows, Bowlands Hey to the west of Westhoughton (600+ houses) which is the subject of an appeal in the third quarter of this year, Belvedere Farm Hindley Green comprising a similar development of housing and industrial and Metal Box playing fields.

8.2 Should all of these applications become reality the implications for Westhoughton and its environs do not bear thinking about. They will now doubt be detached dwellings with higher than average car ownership, which will undoubtedly add to congestion, noise and dust etc.

9.1 In my opinion the case against the proposed development is overwhelming. There would be unacceptable increases in traffic congestion and it would deny an important area of recreation for local residents. Such a development would fly in the face of government policy to develop brownfield sites of which there are many in the Borough. There is a clear failure by the developer to submit a masterplan of the intentions for the whole site.

9.2 The development is unacceptable. It fails to meet the requirement of the current UDP in relation to the provision of Route A5225, no firm decision has been taken about its future and the need to have it in place before developments can take place. This application is a deliberate attempt by the landowner to carry out development in a piecemeal fashion.

The new Regulations are very clear and precise about the legal requirements in relation to the need for an E.I.A. at specific thresholds. It is extremely difficult to understand the reluctance to pass this matter to a higher authority as is required by this piece of legislation. Therefore such a decision is unlawful and could potentially lead to a legal challenge.

3. The people of Westhoughton await the decision of the Inquiry.

They believe that right is on their side and there is a clear and overwhelming requirement to reject the application. They fear the possibility and prospect of yet another Retail Park with all the associated inconveniences may be the end result if successful.

In my opinion there is only one decision that can be made and that is to reject the application.

Councillor David Chadwick

Representing Westhoughton on Bolton M.B.C.